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Home My WebLink About01-3220 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 I HEREBY CERTIFY THAT IS A TRUE AND CORRECT ~~ OF 'mE ORIGINAL ALEO FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor(s)) Term No. JAMES HOOVER AND LINDA HOOVER (ReaIOwner(s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) CIVIL ACTION: MORTGAGE FORECLOSURE .,.1 ()/- 3 2.LtJ (1u~ 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. NOT I C B You ha""e been sued in court. If you wish to defend against the claims set forth in the following pages, you must take actir.'n with1n twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fall to do so the case may proceed without you and a judgment may be E"ntered against you by the COurt. without further notice for any money claimed. in the COmplaint or for any ot.her claim or relief requested by t.he Pla.1ntiff. You may lose money or property or other rights important to you. .tOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, Ga TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, (:umberland County Bar Association 2 Liberty Avenue, Carlisle, PA i8('l01 990-9108 Legal Services Inc. a Irvine Row, Carlisle, PA 17013 (717j 24]-9400 A V ISO LE HA!-I DEMANDAOQ A USTED EN LA CORTE. SI DESBA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON BSTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOOADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, BL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.. RECUERDE: 81 USTED NO REPONDE A ESTA DEMAt~, BE PUEDE PROSBOUIR CON EL PROCESO SIN SU PARTICIPAC10N. ENTONCES, LA CI'JIJTE PUEDE, SIN NOTIFICARI0, DECIDIR A FAVOR DEL DEMAI\lDANTE Y REQUERlRA QUE USTED CUMPLA CON TOOAS LAS PROV1SIONES DE RSTA DEMANDA. POR HAZON DE E'SA DEC"ISION. HS POSSIBLE QUE USTHD PtJ'EDA PSRDBR DINBRO. PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOCAOO IMMEDIATAMENTE. 81 NO CONOCE A UN ABOGADO, LLAME AL .<!15-2l8-630i). Legal Sen.J.ces Inc. a IrVIne Row, Carlisle, PA 17013 1717\ .24]-9400 "LAWYER REFERENCE SERVIC'EII (SERVICIO DE REFERENCIA DE ABOOADOS) , TAlIE COPY FROM R In '...-It Wllentor eCORD and tile ' I here unto set my hand ~~1~~~ '~ ' Cumberland County Bar ABBociatJ.on 2 Liberty Avenue, Carlisle, PA (800i 390-9108 I HEREBY CERTIFY THAT THIS IS A TRUE ~D CORRECT COPy OF THE ORIGINAL FIlED COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is FIRST NATIONWIDE MORTGAGE CORP., PO Box 9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481, 2. The name(s) and address(es) of the Defendant(s) is/are JOHN O. OSGOOD, 329 15th Street, New Cumberland, PA 17070 and SUSAN C. OSGOOD, 329 15th Street, New Cumberland, PA 17070, who is/are the mortgagor(s), and JAMES HOOVER, 329 15th Street, New Cumberland, PA 17070, and LINDA HOOVER, 329 15th Street, New Cumberland, PA 17070, who is/are the record owner (s) of the mortgaged property hereinafter described. 3. On March 27, 1974, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ADVANCE MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 575, Page 1071. By Assignment of Mortgage, the mortgage was assigned to Plaintiff, which Assignment is lodged for recording. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due October 1, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The fOllowing amounts are due on the mortgage: Principal Balance Interest from 9/ 1/00 through 5/31/01 at 8.250% Per diem interest rate at $1.76 Reasonable Attorney's Fee Late Charges 10/ 1/00- 5/31/01 Monthly late charge amount at $17.48 Costs of suit and Title Search $ 7,803.99 478.72 1,000.00 139.84 560.00 $ 9,982.55 429.80 Escrow Balance Deficit Monthly Escrow amount $ $ 10,412.35 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 $10,412.35, together with interest at the rate of $1.76, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises, tJ...^-. Jr., Esq. VERIFICATION I, Dennis Kieft I as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date:, f J:; 3 !o I ... i ./ ./ :1 ., I . I .. -, I , J ., '. - I .; '1 I , , '---. ; " .j , r I , i 'j ; ; I.~LU I.IUIIlI.n::u,....ICII1I.1. ..,.......... ioy ..... "'....,IIUg.&.~clln.l' all.... "",cn.1I:I UI I 1:l11IIQY....VClII.La, . ulld Gt-ulltorS , JAMES C. HOOVER and LINDA L. HOOVER, hia wifa, of Sunburv, PennaVlva!11B, Gnzllu.a : WITNESSETH, tJuzt ill ""llSid.....tioll of F1 ftV Dna Thouaand ------------------------------ -------(151,ooo.00)-------------____DoUUr~ ill Mild f14id, t". r.ceipt """"of ia 1uIr.b2/ "knowledg.d, the .uid /1f'411tor s thJ Iler'b2/ grt1lrlt ulld '01l1"1I to t". /J4id fll'411~"S, their haira and asaigna, All THAT CERTAIN lot or tract of land situata in tha Borough of New Cumbarland, Countv of Cumbarland and Stata of Pennavlvania, more particularlv bounded snd described as follows according to a survev of D.P. Raffensparger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on tha Northern aida of 15th Street aaid point being 870.8 feet west of Bridge Street; thence extending along 15th Straet South 62 dsgress West 50 fsat to a corner of lot number 3D on the hsreinafter mentioned plan of lots; thence along lot number 3D north 28 degrsss West 195 fest to a point s cornsr; thsnce North 62 dsgrees East 50 fest to a point a corner; thencs extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and placs of BEGINNING. BEING a part of lot numbsr 31 Section E Plan of Hillaide as recorded in the Cumberland Countv Recorder's Office in Plan Book 1, Page 75. HAVING thereon srected a two storv frame dwslling ana detached frame garage known as 329 15th Street. BEING ths same premises which Louis N. KsIIV and Ruth K. KeIIV, his wife, bV deed dated March 27, ,1974, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book N, Volume 25, Page 1040, granted and conveyed. unto John, O. Osgood and SUSen C. Osgood, his wife, the Grantors herein. " THE ABOVE DESCRIBED premises are conveyed under and subject to Mortgage to Advance Mortgaga Corporation, tha unpaid balance of which ia '28,006.02 ~ Dollars which the Grantees asaume and agree to pay according to the terms and conditions of said mortgage and accompanying bond. .....,5 .~~-::.{'f 7{/~ ~~ Cumbo Co" PI. School Did. Cumb. Co., P.. ;!S R..I !It... Tr....'.' T.. I ~ Rill E.t.l. Y'......r T.. --C- "--(I D '/ -1..77 ~7SfJI 7-....7l ",~~-Jl- A;;7;;:;;;':"iiil;:'~ D~~mt'Ji.~ CMMIt,. Co. Di.l. C.I. AI........-,. CliMb. Co. Dhl. C.I. Alt. ~ Boor#28 rACE 39 --.... ...--..-. -. .., _n__..._... .... _ _ ."_ "'__n _. -- - -, .. .. r"//0lJI4575 r~q3 O;;2l{O 4'3VJ ~ EXHIBIT A P,O. Box 9481 Gai1hBrsburg. MO 2OB9B-9481 December 22, ~OOO Certified Mail Return Receip Requested James Hoover / 329 15th St New Cumberland PA 17070-1312 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortaaae on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paaes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the proaram works. To see if HEMAP can help. yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the counselina agency. The name. address. and phone number of the Consumer Credit Counselina Aaencies servina your County are listed at the end of this Notice. If you have any auestions. you may call the PennsYlvania Housina Finance Aaency toll-free at 1-800-342-2397. (Persons with impaired hearina can call (717)780-1869.) This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de surna importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al nurnero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF350-002/COY 5280 CorJx>ralB a..... Fralleri.... MO 217i13 . 1ST II~E 'l J Ol.o LI) TS" 1 d. Cj J \.')a'l c 'f:J P.O, Bo. 94Bl Gaithorsblfg. MD 21l119B-94Bl Linda Hoover 329 15th St New Cumberland PA 17070-1312 / December 22, 2000~ Certified MailV" Return Receipt Requested RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortaaae on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paaes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the prOGram works. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the counselinG aaencv. The name. address. and phone number of the Consumer Credit Counselina Aaencies servina your County are listed at the end of this Notice. If yOU have any Questions, YOU may call the PennsYlvania Housina Finance Aaencv toll-free at 1-800-342-2397. (Persons with impaired hearina can call (717)780-1869.) This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF356-001/COY ,,?an r"r.....~hIII n.i.... J:,..,.,i"" un ?17n1 .ME '1 ~ D<P L1) 1-) \) ~ J O~yo \/1." PO, Box 9481 Gaitl1ersburg. MO 20898-9481 December 22. 2000 ~ Certified Mail ../' Return Receipt Requested Susan C. Osgood ~ 329 15th St ,,(,.. New Cumberland. PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offHQIWfcF,tQrneEQ.tG~lp~yr~ is in default, and the lender intends to foreclose. specific information about the nature of the default is provided in the attached paaes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the proaram works. To see if HEMAP can help, YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OP THE DATE OP THIS NOTICE. Take this notice with YOU when YOU meet with the counselinq aqency. The name. address. and phone number of the Consumer Credit Counseling Aaencies servina your County are listed at the end of this Notice. If you have any auestions. you may call the PennsYlvania Housing Pinance Aqency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia. pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (pennsylvania Housing Pinance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DP352-001/COY II_DE 'j \ O~ ~ '5)S" I~q~ Od\{4) ~3"'3 p.o. Box 9481 Gailhersburg. MO 208!III-Q481 December 22. 200~ Certified Mail...... Return Receipt Requested John 0 Osgood ~ 329 15th ST ~ . New Cumerland. PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offHQ~cfJQWeEQr'~lP~y~~ is in default, and the lender intends to foreclose. Specific info~ation about the nature of the default is provided in the attached paaes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the counseling agency. The name. address. and phone number of the Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any auestions, YOU may call the PennsYlvania Housing Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (7171780-1869.1 This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia. pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance AgencYI sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo per el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY ............. n. .... "'.:. ~ r._"A..~I. IJll'I",'Ht':l December 22, 2000 Loan No. 6838320381 Page 2 PA Act 91 Homeowner's Name: James Hoover Property Address: 329 15th St New Cumberland PA 17070 Loan Account No.: 6838320381 Original Lender: Advance Mortgage Corporation Current LenderlServicer: First Nationwide Mortgage HOMBOWNBR'S BMBRGIDlCY MORTcu.GB ASSISTANCB PROOIWI YOU MAY BB BLIGIBLB POR PINAHCIAL ASSISTANCB WHICH CAR SAW YOUR HOMB PROM PORBCLOSORB ARD HBLP YOU MAD: PUTORB MORTCJACJB PAYMBNTS IP YOU COMPLY WITH THE PROVISIONS OP THB HOMBOWRBRS' BMBRGDCY MORTCJACJB ASSISTANCB ACT OP 1983 ITHE -ACT-). YOU MAY BB BLIGIBLB POR EMBRGBHCY ASSISTANCB: * IP YOUR DBPAULT HAS BBBN CAOSBD BY CIRCUMSTANCES BBYOIm YOUR COIITROL. * IP YOU HAVE A RBASONABLB PROSPBCT OP BBINO ABLB TO PAY YOUR MORTGAOB PAYMBNTS. AND * IP YOU MBET OTHBR BLIGIBILITY REQUIRBMBHTS BSTABLISHED BY THB PBRNSYLVAHIA HOUSING PINANCE ACJIDlCY. TEMPORARY STAY OP PORBCLOSURB - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MBBTINO MUST OCCUR WITHIN THB NEXT (30) DAYS. IP YOU DO NOT APPLY POR BMBRGBNCY MORTOAGB ASSISTANCB. YOU MUST BRINO YOUR MORTOACJB TO DATB. THB PART OP THIS NOTICB CALLBD -HOW TO CURB YOUR MORTOACJB DBPAULT.- BXPLAINS HOW TO BRINO YOUR MORTOACJI UP TO DATI. DF353-001/COY December 22. 2000 Loan No. 6838320381 Page 3 CONSUMBR CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice. the lender may HOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of the desianated consumer credit counseling agencies for county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATIONS FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this prOblem with the lender. you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so. you must fill out. sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLXCATXON PROMPTLY. J:P YOU FAU TO DO SO OR J:P YOU DO NOT FOLLOW THB OTHER TIME PERIODS SET FORTH IN THIS LET'l'ER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME XMllEDIATELY AND YOUR APPLICATXON FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION: Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligi- bility criteria established by the Act. The Pennsylvania Housing DF353-001/COY December 22. 2000 Loan No. 6838320381 Page 4 PA Act 91 Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. ROTB: IP YOU ARB CURRDI'l'LY PRO'1'ECTED BY THE PILIRG 01" A PETITION IR BANKRUPTCY, THB 1"OLLOWIRG PART 01" THIS IS FOR INFORMATION PURPOSl!:S ONLY ARD SHOULD ROT BE CONSIDBRED AS AN A'l"l'BMPT TO COLLBCT THB DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURB YOUR MORTGAGB DE1"AULT (Bring it Ull to date) RATURB 01" THB DB1"AULT - The MORTGAGE debt held by the above lender on your property located at: 329 15th St New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT because: YOU HAVE ROT MADB YOUR MORTHLY MORTGAGB PAYMBlIITS for the following months and the following amounts are now past due: 1 Months at $349.79 = 349. 79 ~, 1 Months at $442.04 = 442.04 ./ ./ 1 Months at $356.37 = 356.37 ./ Late Charges 87.89 Bad Check Fees .00 Foreclosure Fees .00 Bankruptcy Fees .00 Other Fees / 7.00 Less Suspense Balance __ .00 TOTAL AMOmrl' DUB V' 1,243.09 AS OF THIS DATE I HOW TO CURB THB DBFAULT - y~u may cure the default within THIRTY (30) DAYS of the date of this not ce BY PAYIRG THB TOTAL AMOUJI'l' PAST DUB TO THB LENDBR WHICH IS $ 1, 43.09 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavrnents must be made either by cash, cashier's check. certified check. or money order made DaYable and sent to: First Rationwide Mortgage Corporation Dept. 0107 Palatine, IL 60055-0107 DF354-001/COY December 22, 2000 Loan No. 6838320381 Page 5 PA Act 91 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lend.r int.nd. to exerci.e it. right. to acc.l.rate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attor- neys to start legal action to for.clo.. upon your mortgag.d prODerty. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If YOU cur. the d.fault within the THIRTY (30) DAY p.riod. YOU will not be required to pay attorn.y'. f.... OTHER LBHDER RIMBDIBS - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. DF354-00l/COY . December 22, 2000 Loan No. 6838320381 Page 6 PA Act 9' RIGHT TO CURB THE DEPAULT PRIOR THE SHIRIPP'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU still have the riaht to cure the default and prevent the sale at any time UP to one hour before the Sheriff's Sale. You may do so by payina the total amount then past due, plus any late or other charaes then due, reasonable attorney's fees and cost connected with the foreclosure sale and other cost connected with the Sheriff's Sale as specified in writina bY the lender and by performina any other reauirements under the mortaaae. CUring- your d.efault in the manner set forth in this notice will restore your mortgage to the same position as if you had. never d.efaulted.. BARLIEST POSSIBLE SHERIPP'S BALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDIR: pirst Nationwide Mortgage COrPOration 5280 COrDorate Drive Prederick. NO 21703 Department 252 1-800-888-1333 EPPECT OP THE SHERIPP'S SALE - You should realize that the Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furniShings and other belongings could be started by the lender at any time. ASSUMPTION OP MORTGAGI - You, UPON OUR CONSENT may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAW THB RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR. * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. DF355-001/COY @fil \fUll ~ ,~~ ;fii'U ~~i?~ 11.): [,:::1 0 '_ .~ ul ~1~ ClL!:. v ~ ~: \' 1,-: ". "'~', ~ 1 ~~] d '.::Y;:' " \(' r:i E'J Iii GI l~~ ).ll\r."',l ,,';-, ,,"I~ jjl\l:;H~ ," . .,' :;,,;:1.10 .. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - MeUon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Defendallt(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACfION OF MORTGAGE FORECWSURE No.01-3220-CNIL CERTIFICATION OF SERVICE Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiffs Petition to Amend Judgment with RULE RETURNABLE date of twenty (20)days was mailed by first class mail, postage p HOOVER and LINDA HOOVER at 329 15th Street, e December 19, 2003 ~---. - Gary E. fendant(s) JAMES nd, PA 17070 on .. \ n "" r; <= 0 c.:.. , " ....., -r~ 0 --< 1-'"; :r: ." '-, n,p ~, -om N ..f"'._-' eJ2:; -.., -':-r, .~ ~::J .- -:.~ ::ri c...., =< '" ...... :....:.! f,-, - GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - MeUon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff o~ ~ lIlII v FmSTNAT~~EMORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, PAl 7070 No. 0I-3220-CNIL Defendant( s) R!lI.E AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested in Plaintiffs Motion to Amend Judgment should not be granted. Rule returnable tlie €lay sf ,. _/I::.. J'crlI.?.... . ~o dlMJl' 7- Date: '7.l-h.h- It. Zt;6J A J. ,0) \'): \U '-;;" :'~: -:1,!')'.~i..J:j....i II'''''' ,'. .....-."n'" .' \ IJ'... .:.. : :.;. ~', : i:' ~'1 ..., I ~ :Z!H 91 330 moz :Y"''''''C,H'QU'::iHl '0 ..,,-,J.Vi\ .L 00..1 :J 'l~)U"('KJ31U ..I.W_.'-' l:J GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - MeUon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN TIlE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant(s) ORDER No.01-3220-CIVIL AND NOW, this day of ,2003, upon consideration of the Petition of FIRST NATIONWIDE MORTGAGE CORPORATION to Amend its Judgment, it is, ORDERED: That the petition is granted and Plain tift's judgment is hereby amended to $21,056.51, plus interest and costs. BY THE COURT: J. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS Plaintiff of Cwnberland County vs. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cwnberland, P A 17070 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No.01-3220-CIVIL THIS IS LAW FIRM IS A DEBT COLLECTOR AND WE ARE A TTEMPfING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. PLAINTIFF'S PETITION TO AMEND JUDGMENT AND NOW, this Plaintiff, FIRST NATIONWIDE MORTQAGE CORPORATION, petitions the Court to Amend Judgment for the following reasons: I. Plaintiff's Complaint in Mortgage Foreclosure was filed on May 25,2001 . 2. On September 18, 2001, jUdgment in mortgage foreclOsure was entered in favor of Plaintiff and against Defendants in the amount of $10,655.31, based Upon the demand in Plaintiff's Complaint. (Copies of the Complaint and Judgment are attached hereto collectively as Appendix III) 3. On December 03, 2001 Defendants filed a petition in bankruptcy in the United States Bankruptcy Court for the Middle District of Pennsylvania (No. 01-06400) which stayed further prosecution of Plaintiff's action in mortgage foreclosure. 4. By order of United States Bankruptcy Court dated October 22, 2003 Plaintiff was granted relief from the automatic stay imposed by the Bankruptcy Code. 5. Since the filing of the Complaint, interest has been accruing as have the escrow balance deficit and late charges under the terms of the mortgage contract involved. 6. Due to the stay of proceedings, Plaintiff's judgment is now insufficient to satisfY the amounts due and owing on the mortgage and the mortgage lien on the property in question. 7. Upon disposition of this petition and the scheduling of a Sheriff's Sale on March 03, 2004, the amounts due and owing on the mortgage will be as follows: Principal Balance $7,635.80 Interest from 10/01/00 thru 03/05/04 at 8.250% Per diem interest rate at $2,159.40 $1,250.00 Attorney's Fee at 5.0000% of principal balance Late Charges per Complaint $568.24 Costs of Suit and Title Search $750.00 Escrow Balance Deficit TOTAL $8,693.07 S21,OS6.51 WHEREFORE, Plaintiff prays that the Petition be granted and Plaintiff's Judgment be amended to $21,056.51, plus interest and costs. Gary E. ,Mc , Esq. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - MeUon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS Plaintiff VS. ofCwnberland County CNIL ACfION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACfION OF MORTGAGE FORECLOSURE Defendant( s) No.OI-3220-CNIL VERIFICATION Gary E. McCafferty, Esq., hereby states that he is the attorney for Petitioner within named and that all of the facts set forth within the attached Petition to Amend its Judgment are true and correct to the best of his knowledge, infonna' n and b lief. The undersigned Gary E. s 18 P.S. Section 4904. understands that the foregoing statements are made subject t t GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - MeUon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FmSTNATIO~EMORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS ofCwnberland County Plaintiff vs. CNIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cwnberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE No.OI-3220-CNIL Defendant(s) MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S PETITION TO AMEND JUDGMENT Plaintiff is entitled to the amounts due and owing on the mortgage contract at the time of the Sheriff's Sale of property involved. For reasons stated in the within motion, Plaintiff's judgment in mortgage foreclosure is insufficient to compensate Plaintiff for the amount due and owing under the mortgage. Specifically, interest charges, the escrow balance deficit and late charges have all been accruing while Plaintiff's action in mortgage foreclosure was stayed by Defendant(s) bankruptcy petition. CONCLUSION For the reasons stated above and in the within petition, Plaintiff respectfully requests that the petition be granted and Plaintiff's judgment be amended to $21,056.51, plus interest and costs. . cC'tfferty, Esquire GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - MeDon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS ofCwnberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER mill LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No.01-3220-CIVIL CERTIFICATION OF SERVICE Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiff's Petition to Amend Judgment was mailed by first class mail, postage prepaid to Defendant(s) JAMES HOOVER and LINDA HOOVER at 329 15th Street, New Cumberland, PA 17070 on December 9,2003 , JOSEPH A. GOLDBECK, JR. GARy E. McCAFFERTY' MICIfAEL T. McKEEVER. KRISTINA G. MURTHA. GOLDBECK McCAFFERTY & McKEEVER A Professional Corporation Attorney's at Law SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106-1532 (215) 627-1322 fax (215) 627.n34 I ~ /O? /2003 JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs. JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed please find a copy of Plaintiff's Petition to Amend JUdgment, the original of which has been duly filed of record with the Court. Very truly yours, "'-'--7--~ ~ GEM/mrw Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVEB ~.. ....., A :l o ... " ::l ;;: m ;;: o = .. 51 '" .. .. ... ~ ~ ... I,j.J o .. .. ..... I,j.J Ir' o ...:I I,j.J ~ o ... .. ...:I o ... ... o o o ... ~ .. 0ll10f.4.J.'30 ! ~ m .. in II C :II .. m Ii m ... R o c z ... . 2 S" '" . 1:1 a. ~ ... o o . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. "ll i II" .. 1:1 ; ~ .. ... r'.l II EI f i 1:1 a. ~ II 1:1 ~ 0" ~~ m... "'0 0... ":1: m G) o en~ b s"llm "'21 m mO l'l."O " am;ll; ;!;Cj;!:m!!l: !;_pl_O ~~~~~ :I:"z~'" ?!!I~ r- ill "~,, 0 21 >JJ~O:;! ...me .. comm" iil"'z"II to f;lO!!l: 021 0 !l1~;Il; "'-m !llOm z< m 21 o o ,- ): '" en 't':!l "':II ~; F;lc l!l~ e. -,i,- ri'l,;' ;<->. Z', {,., . -.:.: ~~..: J~ - ~.~~'., ~'L: z ~ iI> . . \CI i ... N ~ 6 .... <Xl <Xl .... Co) o Securily Fealur_Inc;luded. ED Delslle on De[.~ - -.- ... --.-.-.----- Cl W 'J . " n ~ .-\ or, :n "'"1.;1 , ' ....., : ":(:) .p ...: ") ~"tl , 3~ -. ::0; "-2 ",- 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 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. Term No. 01-3220 CIVIL JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor(s)) JAMES HOOVER AND LINDA HOOVER (Record Owner(s)) 329 15th Street New Cumberland, PA 17070 CBRTIFICATE OF SBRVICE PURSUANT TO Pa.R.C.p. 404 Joseph A. Goldbeck, Jr., Esquire, hereby certifies that a true and correct copy of the above-captioned Complaint in Mortgage Foreclosure was served upon Defendant(s) John & Susan Osgood by certified mail . , JR, Susan C. Osgood 52 Catoctin Court Silver Spring, MD 20906 ~ .,-------------.............--.--.---------------.........--------.-.---------- 2. ArtIcle Number 111111 II ?Ja. 11575 ~ IIWB ?3'U. 3. Sorvlc:o ~ CER'IlFlI!D MAIL 4. 110_ DeIIVIIry? (EIdnI FN) D """ 1.__"'-10: RE:f1VD~~l)./"sa-'1- ~ SE.NQER: PS Form 3811, June 2000 Domeslle Aelum AeceIpC r.'2:.Mk;j;,.jj;;,;;;.........-.................h..m................. II'II~IIII'II'" John O. Osgood 52 Catoctin Court Silver Spring, MD 20906 Gry 7J& "575 ~ "WB ?II..5 3. Serva ~ CEIlTIFIED MAIL 4. ~ Ile/Ivory? (EIdnI FN) D """ 1. Ar1k:IeAddlu IlIlo: I RE'Ftvo:i.3':J.. Irh~JII.-r ", .~~R: I 'i PS FOrm 3811, June 2000 IlcInNk Return ~ ~. - (') r~: -u (;.~ ~~.~: (;1 r~:\ ).-;,( ~:~~ ~..-: ~ .... .., .'.': I. ~..-, ......') (i\ :.'.! 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 FIRST NATIONWIDE MORTGAGE CORP. IN THE COURT OF COMMON PLEAS PO Box 9481 Mail Code: 22-528-1011 OF CUMBERLAND COUNTY Gaithersburg, MD 20898-9481 Plaintiff CIVIL ACTION - LAW VS. :ACTION OF MORTGAGE FORECLOSURE JOHN O. OSGOOD AND SUSAN C. Term OSGOOD (Mortgagor{s)) No. 01-3220 CIVIL JAMES HOOVER AND LINDA HOOVER (Record Owner{s)) 329 15th Street New Cumberland, PA 17070 Defendant{s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. BY: Jr. FN-0232 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 (21 <;) 627-1322 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. Plaintiff CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) JIUll8S Hoover (Real Owner only) Linda Boover (Real Owner only) Defendants : NO.01-3220-Civil NOTTCF. OF !':HF.RTFF ,!,: !,:AT,F. OF RF.AT, E!':TATF. TO: John o. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY, Your house (real estate) at 329 15th StrAAt. New ~.mhQrlAnd. PA 17070. is scheduled to be sold at the Sheriff's Sale on DA~amhAr 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2~ Floor, Carlisle, PA 17013 to enforce the court judgment of $10.665.31 obtained by Firat NationwidA MortgagA co~. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVlmT THIS SHERIFF'S Rlt.T,!!: To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: 12151 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ;~~H'I'~y STrLL BI!: ABLI!: TO SAW y~: ~:~P:=;; :: ion HAVl! OTHRR RZGHTS RVRN ZF TRR SRRRZFF'S SA Dc. 1. If the Sheriff's Sale sold to the highest bidder. calling 121S) 627-1~22 is not stopped, your property will be You may find out the price bid by 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at 17]7) 240-6~90 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house, A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution, 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAICB TRIS PAPER TO YOUR LAWYER AT ONCE. II' YOU DO NOT RAVE A LAWYER OR CANNOT AFFORD ONE, 00 TO OR TELEPHONE THB OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GBT LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 , a c:' ;.j c- o ~ 'j) "Vi;;"; ;""1 ."f: -OJ Z:', -~[' m.~.. l~ -<.." RL. .'t.J ~~~ :J.) :":.-1 -;.." ~ .,.. ':.:-; ,::> -c PRAECIPB POR WRIT 01' EXECUTION - (MORTGAGB PORBCLOSURB) P.R.C.P. 3180-3183 Pirst Nationwide Mortgage Corp. Plaintiff COURT 01' COMMON PLEAS : cmmBRLAND COUNTY, PA Vs. : NO: 01-3220-Civil John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) JlUIIes Hoover (Real OWner only) Linda Hoover (Real OWner only) Defendants : PRAECIPE FOR WRIT 01' BXECUTION (MORTGAGE PORBCLOSURE) TO THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from at $1.75 per Total $10.665.31 9/12/01 to sale date $ diem and Costs $ eck, Jr. Sui 500- Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Attorney for Plaintiff Note: Please attach description of property. \ , \0 0 G\ 0 N Ilo.c - ~ ....i . - >.-- a! eo >-.-1 >->- ....... "0 .-Ia.-l.-l H ~ IDI"- III 0 8 0 8 8 B'i =' . alO t u o III ~I"- ..:I~ ~ uS' .....-1 III ! ~ & ~ ~ B ~ fIl.c UJ .-I Poi & IDID a.... .... ~!Ag .... ~ ....Po III ~ 0 ....p. ID .Q I~ .... Ilo.-l UfIl ~ . u ~ .... ~ o U .s ~ ~.... ), I i ~i.-l.-l ID :2 t m 0 i 1111 E-o ~ II ID N . ~IDID H 0 U > sf N ~I .:J III ~ 11I11I I'"' .-I UJ '" :> 'G~~ N ..4 H I ..4 '8~~~ ID IIlfll III .-l B 2! g. 0 ~ 0 WIIISS . ..4 .... P, ~ .... O~ii IllI ~ 0 III ~I Bl eli .j.J H ciUIII~ u~ "0 ~ ~ .... m III III ~ g I.~ ~ .-I ..4 .M Ilo ~g~..:I Ilo 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 First Hationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, NO 20898-9481 Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, NO 20906 : CtlMBBRLAND COtlNTY : COURT OF COMMOH PLEAS : CrvIL DIVISION : NO 01-3220-Civil James Hoover (Real Owner only) Linda Hoover (Real Owner only) 329 15th Street Hew Cumberland, PA 17070 ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot number 31 Section E plan of Hillside as recorded in the Cumberland County Recorder's Office in Plan Book I, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street, Tax Parcel #26-23-0541-133 (') C.J n '" -t .... -.) .... ... ....eu ~ c ~i ., ,.'> :fq~ Cfl "'" ..o~ f ...;) f" " (I ..0 ""l "'t::o.: :" (!'" .. '"0 ~ . . .,'."," , C . . . . ~ () 0, l\J 0 0 0":>8 ;2\"-":: ~ 8 ..0 C C (J:' ." (';:: -~ C -c C C C () ~.' ..c:: ri~.~' ."':' ;, - I I I ':tJ .. - .. ~~ , \ I J I , 2:'-, .' .-L' ,.. ~ :;r.'c ~.-: ". ~ ~f L:. """ ~i~ ( 3. eXl -~ ... ... , ::!> , ... , ... ~ .. r ... , ... , .. , .. ~ -~~ - .. .. ... .. .. .. .. ... -=- .. ... - v.{t- (Rule of Civil Procedure No. 236) - Revised IN THB COURT 01' COMMON PLEAS 01' CUMBBRLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW First Nationwide Mortgage Corp. . Plaintiff Vs. NO. 01-3220-Civil John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) , Defendants Notice is given that a Judgment in the above captioned matter has been entered against you on september~. 2001, &y: 4-- P.~~y If you have any questions concerning this matter please contact: **THIS FIRM IS A DBBT COLLBCTOR ATTBMPTING TO COLLBCT A DBBT AND ANY INFORMATION OBTAINBD WILL BB USE FOR THAT PURPOSB. IF YOU HAVE PRBVIOUSLY RBCBIVIm A DISCHARGB IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BB CONSTRUBD TO BB AN ATTBMPT TO COLLBCT A DEBT, BUT ONLY BNFORCllMBNT OF A LIEN AGAINST PROPBRTY. ** GOLDBECK, MCCAFFERTY & MCKEEVER By: Joseph A, Goldbeck, Jr. Attorney I.D. #16132 Suite SOO-The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 (21 <;1 fi27-] ~22 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp, COURT OF COMMON PLEAS CIVIL DIVISION Vs. John O. Osgood (Mortgagor only) Susan C, Osgood (Mortgagor only) No, 01-3220-Civil CUMBERLAND COUNTY VERTFTCATTOIlT OF lmllT-MTr.TTAJ;tY SRRVTC'R JOSEPH A, GOLDBECK, JR., ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant John O. Osgood (Mortgagor only), is over 18 years of age, and resides at 52 Catoctin Court, Silver Springs, NO 20906. (c) that defendant Susan C. Osgood (MOrtgagor only), is over 18 years of age, and resides at 423 Market Street, Newport, PA 17074. (d) that defendant James Roover (Real Owner only), is over 18 years of age, and resides at 329 15~ Street, New Cumberland, PA 17070. (e) that defendant Linda Roover (Real Owner only), is over 18 years of age, and resides at 329 15th Street, New Cumberland, PA 17070. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. September 12, 2001 (") c:' , '. c: , ;":. ,f) -t."C ;..,., f11Cf -0 Z~' ZC" C-; ~.'~ ::(".0. ~L ....,~ ~i~, "-;'? ;pO;:; ? .", ".. . .. ~ ,,0 .....~ -<. ~" \ 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 (2151 627-1322 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, Me 20898-9481 Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, Me 20906 James Hoover (Real Owner only) Linda Hoover (Real Owner only) 329 15th Street New Cumberland, PA 17070 CCMBBRLAND cotlNTY COURT 01' COMHON PLEAS CIVIL DIVISION : NO 01-3220-Civil PRAECIPB FOR JtlDGMBNT POR FAILURE TO AlIISWRR AND ASSESSMInI1'I' OF naual21rS TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against ,Tnhn o. OSlJOod lMortg"'lJOr only}. Susan c. OSlJOod lMort;lV'lJnr only}. .TAmAR HotrvAr IRf!!IAl OwnRr only} and Lin"'. ~Q'VAr IR..l OwnAr only}, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days (or 60 days if defendant is the United States of America) from the date of service of the complain and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest - 6/1/01 - 9/12/01 Late Charges TOTAL $10,412.35 $ 183.04 $ 69.92 $10,665.31 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above, and (2) that notice has been given in accordance with Rule 237,1, copy attached. DATE: DAMAGES ARE HEREBY ASSESSED AS INDI I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is P.O. Box 9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481 and that the names and last known addresses of the Defendants are: John O. Osgood (Mortgagor only), 52 Catoctin Court, Silver Springs, MD 20906 Susan C. Osgood (Mortgagor only), 423 Market Street, Newport, PA 17074 James Hoover (Real Owner only), 329 15th Street, New Cumberland, PA 17070 Linda Hoover (Real Owner only), 329 15th Street, New Cumberland, PA 17070 1dbeck, Jr. r Plaintiff TO: JOHN O. OSGOOD 423 Market Street Newport, PA 17074 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW FIRM IS A DBBT COLLBCTOR AND WB ARB ATTIlIIPTIIlG TO COLLBCT A DBBT OWBD TO OUR CLIIlJ!lT. ANY INFORMATION OBTAIIIlBD FROII YOU WILL BB USBD FOR THE PURPOSB OF COLLBCTIIlG THE DBBT. TO: JOHN O. OSGOOD 423 Market Street Newport, PA 17074 DATE OF THIS NOTICE: August 20, 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 /s/ JO:Jeph --4. qolJteck. J,.. OOLDBBClt McCAl!'FBRTY r. McltBBVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: SUSAN C. OSGOOD 423 Market Street Newport, PA 17074 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s)) JAMES HOOVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW PIRM IS A DEBT COLLECTOR AND n ARB ATTBllPTIIlG TO COLLBCT A DEBT OnD TO OUR CLIENT. ANY INPORKATI01II' OBTAINED PROM YOU WILL BE USED POR THE PURPOSE 01' COLLECTIIlG TBB DEBT. TO: SUSAN C. OSGOOD 423 Market Street Newport, PA 17074 DATE OF THIS NOTICE: August 20, 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 /s/ JOde,oh -A. (JoIJtect. J,.. GOLDBBCX KcCAPPBRTY & KcKEBVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: JAMES HOOVER 423 Market Street Newport, PA 17074 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOlIN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s)) JAMES HOOVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERIJ\ND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW FIRM IS A DBBT COLLBCTOR AND WI!: ARB ATTIDIPTING TO COLLBCT A DBBT OWI!:D TO OUR CLIBIlT. ANY IIlPORMATIOR OBTUNBD FROM YOU WJ:LL BB l1SBD FOR THB PURPOSB OF COLLBCTING THB DBBT. TO: JAMES HOOVER 423 Market Street Newport, PA 17074 DATE OF THIS NOTICE: August 20, 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 /s/ JO:iepk -A. golJteck. Jr. OOLDBBCIt XcCAPFBRTY " XcB:BIIVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: LINDA HOOVER 423 Market Street Newport, PA 17074 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOlIN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOCVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW FIRM IS A DEB'1' COLLEC'l'OR A!lD WE ARE A'1''1'BIIP'1'ING '1'0 COLLBC'1' A DEB'1' OWED '1'0 OUR CLIBNT. ANY IJIFORIIA'1'ION OB'1'AINBD FROH YOU WJ:LL B8 l1SBD FOR THE PURPOSE OF COLLEC'1'ING '1'HB DEB'1'. TO: LINDA HOOVER 423 Market Street Newport, PA 17074 DATE OF THIS NOTICE: August 20, 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 /s/ Jo~eph --4. qotJteck. J,.. GOLOBEClt McCAFFBRTY " McB:EBVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: JOHN O. OSGOOD 52 Catoctin Court Silver Springs, MD 20906 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (8)) JAMES HOOVER AND LINDA HOOVER (Record Owner(s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW FIRK IS A DEBT COLLECTOR AND WB ARB A'1"l'BIIPTI!IG TO COLLECT A DBBT OWED TO OUR CLIBIl'1'. ANY IIlI!'ORKATION OBTAII!lBI) FROJI YOU WILL BE USED FOR THE PURPOSB OF COLLBCTI!IG THE DEBT. TO: JOHN O. OSGOOD 52 Catoctin Court Silver Springs, MD 20906 DATE OF THIS NOTICE: August 20, 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 /s/ JO:lqpk -.-4. (jOIJtBCk. J,.. GOLDBECB: McCAll'FIlJ!.TY r. McB:EBVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: SUSAN C. OSGOOD 52 Catoctin Court Silver Springs, MD 20906 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (9) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW FIRM IS A DEBT COLLBCTOR AHD WE ARB A'1'TI!:MPTING TO COLLBCT A DEBT OWED TO OUR CLIIlI!IT. ANY INPORMATIOH OBTAIlmD PROH YOU WILL BE USED FOR THE PURPOSE OP COLLBCTING TO DBBT. TO: SUSAN C. OSGOOD 52 Catoctin Court Silver Springs, MD 20906 DATE OF THIS NOTICE: August 20, 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 /s/ Jo~epk --4. (joIJteck. J,.. OOLDBECIt KcCAJ'PBRTY .. KcKBI!:VBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: JAMES HOOVER 52 Catoctin Court Silver Springs, Me 20906 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW PIRM: IS A DBBT COLLBCTOR AND WE ARB ATTBllPTING TO COLLBCT A DBBT OWED TO OUR CLIBNT. ANY INFORJlATION OBTAJ:!lBD PROM YO'll' W7LL BB USBD POR THB PURPOSB 01' COLLBCTING THB DBBT. TO: JAMES HOOVER 52 Catoctin Court Silver Springs, MD 20906 DATE OF THIS NOTICE: August 20, 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 /s/ JO:Je,oh ...A. qotJteck. Jr. GOLDBBCB: McCAPPBRTY to McJ:BBVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: LINDA HOOVER 52 Catoctin Court Silver Springs, MD 20906 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner(s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THJ:S LAW FIRM: IS A DBBT COLLBCTOR AND WB ARB A'I."1'BllPTJ:1lO TO COLLBCT A DBBT OWED TO OUR CLIIDIT. ANY J:lIIJ!I'ORMATJ:ON OBTAIJIBD FROM YOlI' WJ:LL BB USBD FOR TO PURPOSB OF COLLBCTJ:1lO TIIJl DBBT. TO: LINDA HOOVER 52 Catoctin Court Silver Springs, MD 20906 DATE OF THIS NOTICE: August 20, 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 /s/ JOdlifh _...4. qotJteck. J,.. GOLDBBCIt KcCAll'J'BRTY Ii KcItBBVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: LINDA HOOVER 329 15th Street New Cumberland, PA 17070 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW PIRM IS A DEBT COLLECTOR AHIl WE ARB ATTBIIPTIRG TO COLLECT A DEBT OWED TO OtIR CLIBIlT. ANY IHPORMATIOlf OBTAIIlBIl FROX YOU WILL BB USBD FOR THE PtlRPOSE OF COLLECTIRG TRB DEBT. TO: LINDA HOOVER 329 15th Street New Cumberland, PA 17070 DATE OF THIS NOTICE: August 20, 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 /s/ }o:Jeph --4. qolJteck. Jr. GOLDBBCK KcCAPFBRTY & KcDBVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: JAMES HOOVER 329 15th Street New Cumberland, PA 17070 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW FIRM: IS A DEBT COLLECTOR AJlD WB ARE ATTIDIPTING TO COLLECT A DBBT OWED TO OUR CLIIDlT. ANY INJ'ORKll.TION OBTAIIlBD PROJI YOU WJ:LL BE USBD FOR TBB PURPOSE 01' COLLBCTING TBB DBBT. TO: JAMES HOOVER 329 15th Street New Cumberland, PA 17070 DATE OF THIS NOTICE: August 20, 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 Isl JO:le,oh ---4. (JolJteck. J,.. OOLDBBCK KcCAJ'I'ERTY " KcKBBVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: SUSAN C. OSGOOD 329 15th Street New Cumberland, PA 17070 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW FIRM: IS A DEBT COLLECTOR AIlD WB ARE ATTBllPTIlIIG TO COLLIICT A DEBT OWED TO OUR CLIIDlT. ANY IIlFORKATIOII' OBTAINED FROM YOU WILL BE t1llED FOR THE PURPOSE OF COLLECTING TBB DUT. TO: SUSAN C. OSGOOD 329 15th Street New Cumberland, PA 17070 DATE OF THIS NOTICE: August 20, 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 /s/ }o:leph -A. (jotJbect. Jr. OOLDBECJI: KcCAJ'I'ERTY " KcItEBVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia. PA 19106 215-627-1322 TO: JOlIN O. OSGOOD 329 15th Street New Cumberland, PA 17070 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. JOlIN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor(s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner(s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL THIS LAW FIRM IS A DBBT COLLBCTOR AJID WE ARB ATTBIIPTING TO COLLECT A DEBT OWED TO 0tllI CLIBIIT. ANY INFORMATION OBTAJ:HBD PROM YOU WILL BB USBD POR THE PURPOSE OF COLLECTING TB:B DBlT. TO: JOHN O. OSGOOD 329 15th Street New Cumberland, PA 17070 DATE OF THIS NOTICE: August 20, 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 /s/ JO:le,ok -A. (}oIJteck. J,.. GOLDBBCK IIcCAPPBRTY " IIcKBBVBR BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 t~ ~ ~ p __ ~ 8 ~ {:: ;} ~ ~ 'C' ~ r t~Ll () c-' c: ... -W:1 i-~":. rn,: ~: :~ ~: ' r.n}' I:D .......:.... !;= t..' )'> ~:D ;~ t'~~ ~ '.'" ,"., ."oJ " 'Il .. . -", :1.: s';-' " .. """ IP ',- .:.~ -<. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 . Joseph A. Goldbeck, Jr. Alt~'mey 1.0.#16132 Su.le 5000 - Mellon Independence Center 701 Market Street Philadelphia. PA 19106-1532 215-627-1322 AltOnley for Plaintitf FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-10 11 Gaithersburg, MD 20898-9481 Plaintiff vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) 329 15th Street New Cumberland. P A 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 01-J220-CIVIL TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above malter: Amount Due Interest from to 09/12/2001 at 0.0100% (Costs to be added) $10,655.3 I (:~::. 0' f"': c:-: .' 1:..-: ':; .~"-~~ - ; .' :"",. .. .. .. :~2 , , " 0" ., i"n -' - - ~ ,.' 1 ~- C.j , cU (l... , ..:- ....: , ~.~ ',~.J ".., , ~~ Cl ~~:>::>:::: ~ :d]~:-::::::::::;:~::~ -::; (-l:~ I I I, I I '/ I I , ~ C 8281Y~~()J\)~ r/ .('- .... ~,:)()O t"- V, 0-: .j " J ~ ..9 c-:. ~ 0-: ~ L; .....: .;;:. ~~---'--.::l~..... t I \9 8 c-.( t:'-.~ ryf'. ~t t1t CJ .. . . 1 fI -:t: j ul ~ -...J ~ (- . CI.l -< ~ ..l ll. Ol: ....10 -:E ~:E ~O e~ u llrd', ~~O -I- ~lll 0;;' Zo 1.1 ~ = I- is ~ ~ o ~ o 1.1 L<l ~ ~ o ~ ~ ~ o i= < Z i- tIl co: i:i: .; > - ~ '" 'C' " 0 "C ~ }; ;=0 ~ co:~-etl< ~ ~ 8 ~ ll.. oo~tIl1! 0:1: .s.. :I:<l~"5 tIl~ "'.<> ~ ";'(".1 Ei ~ ~ l~ 8 ... .. ~ ~ z" o ~ ~ Ol: o - I- ;;. 1.1 ~ ~ ~ .. ,,-,2 Oil I- .. ~~ .. III ~ ~ !:l 1.1 ~ ll. ..: ... ... .'" ".5 " .. .<> - "Cl>. o~ " .>, -< E tg "'-< .Q . .. " t c > " tU '" ::IIll8 M "Ii ~ :E-a-..b ~lit:::N ~ Il'tIl 2: ~ .."'CI _ - ~.5~<~ ... ..l>.N II S CCI .. \0 1.1 = ~;a"';' "" - :E~O..e-N .:.111:'---8 Jg ] "Cl", l>. ~.~ :I tIl GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, Me 20898-9481 Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, Me 20906 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO 01-3220-Civi1 James Hoover (Real Owner only) Linda Hoover (Real Owner only) 329 15th Street New Cumberland, PA 17070 ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot numb~r 31 Section E plan of Hillside as recorded in the Cumberland County Recorder's Office in Plan Book 1, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3210 CIvil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff(s) From JAMES HOOVER AND LINDA HOOVER (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 anachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account ofthe defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due 510,655.31 Interest FROM 9/12/01 AT 0.0100% L.L. Any's Comm % Ally Paid 5897.72 Plaintiff Paid Due Prothy 51.00 Other Costs Date: NOVEMBER 19, 2003 (Seal) CURTIS R. LONG Prothono~ n ~__ ~. &~. C ~l'cJ Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Anorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney [D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NA TJONWIDE MORTGAGE CORPORA nON PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff \'5. CIVIL ACTION - LAW JAMES HOOVER LINDA HOOVER (Mortgagor(s) and Record Owner(s)) 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No.01-3220-CIV1L AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff in the above action. by its attorney, Joseph A. Goldbeck. Jr.. Esquire, sets forth as of the date the praecipe lor the writ of eKecUlion was filed the following information concerning the real propeny located at: 329 15th Street New Cumberland, P A 17070 I.Name and address ofOwner(s) or Reputed Owner(s): JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland. PA 17070 2. Name and address ofDefendant(s) in the judgment: JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Suppon Enlbrcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 GREENWOOD TRUST CO. P.O. BOX I t848 HARRISBURG, PA 17108 BELCO COMM. CREDIT UNION 403 N. 2ND STREET HARRISBURG. PA 17101-1322 4. Name and address of the last recorded holder of every l1longage of record: FIRST FEDERAL SAVINGS & LOAN 234 N. SECOND STREET HARRISBURG. PA 1710\ 5. Name and address of every other person who has any record interest in or record lien on the propeny and whose interest may be allected by the sale: 6. Name and address of every other person of whom the plaintilT has knowledge who has any record interest in the propeny which may be anected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the propeny which may be affected by the sale. TENANTS/OCCUPANTS 329 15th Street New Cumberland, P A 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infonnation and belief. 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. TY & McKEEVER k, r.. Esq. DATED: November 18. 2003 "- .. C'> ....... ,.- '-' C (..:.,' ~q ~~.. :"..-:, ..,.,rl ~~ nl' :;~-'I. -~. --. ~~ .;:, ~L. ; ~C: :.-... ., ....g -YC ....\ :;(', -:.~ .~,) '.>:1 -< ,0 - o J-3220-CIVIL GObDBECK McCAFFERTY & McKEEVER BY: ll,seph A. Goldbeck. Jr. ....Iomey 1.0.#16132 Suite 5000- Mellon Independence Center 70 t Market Street Philadelphia. P A 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-10 II Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, PA 17070 Tenn No.01-3220-CIVIL Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE A TTEI\1PTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU 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 PROPERTY TO: HOOVER. JAMES JAMES HOOYIIR 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cun,berland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2004, at ]0:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$IO,655.31 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORA nON, the back payments, late charges. costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 o 1-3220-CIVIL ). You may be able to SlOP the sale by filing a petition asking lhe Court to strike or open judgment. if the judgment was improperly entered. You may also ask the Court to postpone tlie sale for good cause. .1. You may also be able to stop dIe sale tlirough other legal proceedings. You may need an allorney to assert your rights. The sooner you contact one, the more chance you will ha\'e of stopping lhe sale. (See nOlice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If tlie Slierilrs Sale is not stopped, your property will be sold to the highest bidder. You may find outtlie price bid price by calling the Sheriff of717-240-6390. 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 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 Sheriffof717-240-6390. 4. If lhe amount due from tlie 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 10 remain in the property until the full amount due is paid to the SherilT 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 liIed by the Sheriff thirty (30) days from the date of the Sherif1's Sale. Tins schedule will state who will be receiving that money. The money will be paid out in accordance wilh this schedule unles.. exceptions <reasons why the proposed distribution is wrong) are filed with lhe Sheriff within ten < 1 0) days alter the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of gelling your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA 17013 , 0 CJ .~ C ..-: -. ;::~ .,- "'T':'- .' (l"i 'f' .- -. , . ~-:: ;.~ .r;, U' 0< r;:L ~'.'" 'Z'"I- . ':. L. -- . :p'. ,~? --, L ...,X ....' :~ -<: ,,, .-, OI-3220-CIVIL G~LDBECK McCAFFERTY & McKEEVER . BY: Joseph A. Goldbeck. Jr. ~ Attorney I.D.#16t32 Suite 5000- Mellon Independence Center 701 Markel Street Phi ladelphia. P A 19106 215-627-1322 Attorney for PlaintitT FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-10 II Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, PA 17070 Ternl No.01-3220-CIVIL 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 COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HOOVER. LINDA LINDA HOOVIlR 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cumberland, P A 17070 is scheduled to be sold at Sherill's Sale on Wednesday, March 03.2004. at 10:00 AM. in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $1 0,655.31 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sherill's Sale you must take immediate action: I. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 OI-3220-CIVIL " . 2. You may be able to stop the sale by tiling a petition asking the Court to strike or open judement, if : the judgment w.s improperly entered. You may also ask the Court to postpone the sale for good ca~se. 3. You may .Iso be able to stop the s.le 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 SA VE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. 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 SheritT 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 property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the .ale. To find out if this has happened, you may call the Sheriff of717-240-6390. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed 10 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 thirty (30) days from the date of the Sheriffs Sale. This schedule will slate 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 tiled. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (l '-;.. ~;.: -cO. n".. fit ~(.-. '7~~ "'=. ... c~ v- --c .:..) :~: - .~ -;:: .., -i"' ,. ~ , . -I") .. :::\ .~Jl -~ ,0 USBC PAM - LIVE - V2.2 - Docket Report Page I of7 CREDS, 2002, CLAIMS, 341Held, PlnCnfrmd, DISMISSED U.S. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:Ol-bk-06400-MDF Assigned to: Mary D France Chapter 13 Voluntary Asset Date Filed: 12/03/200 I Date Terminated: 10/22/2003 Date Dismissed: 10/22/2003 James C Hoover 329 15TH STREET NEW CUMBERLAND, PA 17070 SSN: 205-36-4306 Debtor represented by Keith 8 Dearmond DeArmond Law Finn 1770 E Market St Ste 20 I York, PA 17402 717-846-8916 Fax: 717-846-8916 Linda L Hoover 329 15TH STREET NEW CUMBERLAND, PA 17070 SSN: 180-40-4701 Joint Debtor Charles J. Dehart, III P.O. BOX 410 HUMMELSTOWN, PA 17036 717 566-6097 Trustee United States Trustee PO Box 969 Harrisburg, PA 17108 717-221-4515 Asst. U.S. Trustee represented by Keith 8 Dearmond (See above for address) Filing Date # Docket Text 12/03/2001 I VOLUNTARY PETITION under chapter 13 , [AG], ORIGINAL NIBS DOCKET ENTRY #1 (Entered: 12/03/2001) 12/03/2001 2 NOTICE of intent to dismiss case unless missing documents are filed: due by 12/18/01 Re: Item # 1 [Rescheduled], [AG], ORIGINAL NIBS DOCKET ENTRY #2 (Entered: 12/03/2001) USBC PAM - LIVE - V2.2 - Docket Report Page 2 of7 0]/16/2002 3 CORRESPONDENCE to Attorney allowing until January 23, 2002 to file missing documents. Re: Item # 2, [CA], ORIGINAL NIBS DOCKET ENTRY #3 (Entered: 01/16/2002) 01/22/2002 4 MOTION for extension of time to file Schedules Re: Item # 2, [AG], ORIGINAL NIBS DOCKET ENTRY #4 (Entered: 01/23/2002) 01/23/2002 5 ORDER extending time for filing Schedules: due by 02/08/02 Re: Item # 4 [Cornplied] [Entered: 01123/02], [AG] This entry cancels the previous due date. Re: Itern # 2, [AG], ORIGINAL NIBS DOCKET ENTRY #5 (Entered: 01/23/2002) 02/08/2002 Q Schedules, Statements, Plan & Summary and all missing docurnents Re: Item # 5, [DP], ORIGINAL NIBS DOCKET ENTRY #6 (Entered: 02/11/2002) 02/19/2002 7 CERTIFICATE of Mailing of Notice of 341 Meeting. Objections to the plan are due 15 days after meeting held. , [CA], ORIGINAL NIBS DOCKET ENTRY #7 (Entered: 02/19/2002) 03/21/2002 8 341 meeting not held-to be rescheduled., [CA], ORIGINAL NIBS DOCKET ENTRY #8 (Entered: 03/22/2002) 03/29/2002 9 MOTION for relief frorn stay filed by FIRST NATIONWIDE MORTGAGE CORPORATION as Servicer for the Mortgagee of Record. [fee paid rec#580684 $75.00] [Disposed] [Entered: 03/29/02], [OS] CERTIFICATE OF NON-CONCURRENCE, [DS], ORIGINAL NIBS DOCKET ENTRY #9 (Entered: 03/29/2002) 03/29/2002 10 ORDER that answers are due on 04/19/02 Re: Item # 9, [DS], ORIGINAL NIBS DOCKET ENTRY #10 (Entered: 03/29/2002) 04/05/2002 II ANSWER by Debtors Re: Item # 9, [BW], ORIGINAL NIBS DOCKET ENTRY # 11 (Entered: 04/08/2002) 04/05/2002 14 CERTIFICATE of service of notice of rescheduled 341 Meeting, [CA], ORIGINAL NIBS DOCKET ENTRY #14 (Entered: 04/16/2002) 04/08/2002 12 CERTIFICATE of service Re: Item # 10, [BW], ORIGINAL NIBS DOCKET ENTRY #12 (Entered: 04/08/2002) 04/09/2002 13 CORRESPONDENCE SETTING PRELIMINARY PHONE CONFERENCE on 04/25/02 at 03:00 P.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 9, [BW], ORIGINAL NIBS USBC PAM - LIVE - V2.2 - Docket Report Page 3 of7 DOCKET ENTRY #13 (Entered: 04/09/2002) 04/25/2002 15 PROCEEDING MEMO: phone conference held - stip. with trustee concurrence to be filed within 30 days [6 months were given to cure arrearages] Re: Itern # 9, [CL], ORIGINAL NIBS DOCKET ENTRY #15 (Entered: 04/25/2002) 05/10/2002 16 341 rneeting held., [CA], ORIGINAL NIBS DOCKET ENTRY #16 (Entered: 05/10/2002) 05/16/2002 11 OBJECTION to Plan by Trustee. Re: Item # 6 [Disposed], [JR], ORIGINAL NIBS DOCKET ENTRY #17 (Entered: 05/16/2002) 06/04/2002 18 STIPULATION by Parties setting terms and conditions Re: Item # 9, [BW], ORIGINAL NIBS DOCKET ENTRY #18 (Entered: 06/04/2002) 06/04/2002 19 ORDER approving stipulation Re: Item # 9, [BW], ORIGINAL NIBS DOCKET ENTRY # 19 (Entered: 06/04/2002) 08/08/2002 20 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SEITING HEARING on 09/12/02 at 02:00 P.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101, [BW], ORIGINAL NIBS DOCKET ENTRY #20 (Entered: 08/08/2002) 09/27/2002 21 NOTICE to parties in interest of Objection to Plan by Trustee. Hearing on 11114/02 at 02:00 P.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101, [CG], ORIGINAL NIBS DOCKET ENTRY #21 (Entered: 09127/2002) 11118/2002 22 STIPULATION by Parties Re: Item # 17, [BW], ORIGINAL NIBS DOCKET ENTRY #22 (Entered: 11/18/2002) 11119/2002 23 APPROVED by the court. Re: Item # 22, [BW], ORIGINAL NIBS DOCKET ENTRY #23 (Entered: 11/19/2002) 12/03/2002 24 PRAECIPElWITHDRA W AL Re: Item # 17, [BW], ORIGINAL NIBS DOCKET ENTRY #24 (Entered: 12/03/2002) 12/12/2002 25 ORDER Confirming Plan, [BW], ORIGINAL NIBS DOCKET ENTRY #25 (Entered: 12112/2002) 01117/2003 26 MOTION for relief from stay filed by Waypoint Bank [fee paid rec#590859 $75.00] [Entered: 01/17/03], [DS] CERTIFICATE OF NON-CONCURRENCE, [OS], ORIGINAL USBC PAM - LIVE - V2.2 - Docket Report Page 4 of7 NIBS DOCKET ENTRY #26 (Entered: 01/17/2003) 01/17/2003 27 ORDER that answers are due on 02/06/03 Re: Item # 26 [Rescheduled], [OS], ORIGINAL NIBS DOCKET ENTRY #27 (Entered: 01/17/2003) 01127/2003 28 CERTIFICATE of service Re: Item # 27, [OS], ORIGINAL NIBS DOCKET ENTRY #28 (Entered: 01/27/2003) 02/19/2003 29 CORRESPONDENCE frorn Movant requesting new standing order Re: Item # 27, [BW], ORIGINAL NIBS DOCKET ENTRY #29 (Entered: 02120/2003) 02/20/2003 30 ORDER that answers are due on 03/12/03 Re: Item # 26 [Rescheduled] [Entered: 02/20/03], [BW] This entry cancels the previous due date. Re: Item # 27, [BW], ORIGINAL NIBS DOCKET ENTRY #30 (Entered: 02/20/2003) 03/12/2003 31 CORRESPONDENCE from Movant requesting new order for service Re: Item # 30, [BW), ORIGINAL NIBS DOCKET ENTRY #3 I (Entered: 03/12/2003) 03/12/2003 32 ORDER that answers are due on 04/01/03 Re: Item # 26 [Entered: 03/12/03], [BW] This entry cancels the previous due date. Re: Itern # 30, [BW], ORIGINAL NIBS DOCKET ENTRY #32 (Entered: 03/12/2003) 03/14/2003 33 CERTIFICATE of service Re: Item # 32, [DS], ORIGINAL NIBS DOCKET ENTRY #33 (Entered: 03/14/2003) 04/09/2003 34 MOTION for default judgment Re: Item # 26, [BW]. ORIGINAL NIBS DOCKET ENTRY #34 (Entered: 04/09/2003) 04/17/2003 35 ANSWER by Debtors Re: Item # 26, [BW], ORIGINAL NIBS DOCKET ENTRY #35 (Entered: 04/18/2003) 04/22/2003 36 MOTION for relief frorn stay filed by AMERlCREDlT FINANCIAL SERVICES, INC. [fee pd. $75.00, rec. #594514-AG], [BW], ORIGINAL NIBS DOCKET ENTRY #36 (Entered: 04/22/2003) 04/22/2003 37 CERTIFICATE OF NON-CONCURRENCE Re: Item # 36, [BW), ORIGINAL NIBS DOCKET ENTRY #37 (Entered: 04/22/2003) 04/22/2003 38 ENTRY OF APPEARANCE of Richard C. Maider, Esq., on behalf of AMericredit Financial Services, Inc., [BW), ORIGINAL NIBS DOCKET ENTRY #38 (Entered: 04/22/2003) USBC PAM - LIVE - V2.2 - Docket Report Page 5 of7 04123/2003 39 CORRESPONDENCE SETTING HEARING on 05121/03 at 09:00 A.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 35, [SP], ORIGINAL NIBS DOCKET ENTRY #39 (Entered: 04/23/2003) 04/28/2003 40 ORDER fixing hearing date on OS/21/03 at 09:00 A.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 36, [BW], ORIGINAL NIBS DOCKET ENTRY #40 (Entered: 04/28/2003) 05/05/2003 41 Certificate of Service Filed by Richard C Maider of Deily Mooney Glastetter LLP on behalf of ArneriCredit Financial Services, Inc. (RE: related docurnent(s)[36], [40] ). (Wagner, Belinda) (Entered: 05/05/2003) 05/16/2003 42 Answer Filed by Keith B Dearrnond of Burke and Hess on behalf of James C Hoover, Linda L Hoover (RE: related document(s)[36] ). (Wagner, Belinda) (Entered: 05/16/2003) OS/21/2003 43 Proceeding Memo (RE: related document(s)[39], [26] ). Stipulation due 6/20/2003. (Weigel, Erma) (Entered: OS/21/2003) OS/21/2003 Proceeding Memo: Hearing held. Settled - Stipulation within 30 days. Otherwise, proceeding to be dismissed without prejudice. (RE: related document(s)[26]). (Weigel, Erma) (Entered: OS/21/2003) OS/21/2003 44 Proceeding Memo: Hearing held and continued re: Americredit Fiancial's Motion for relieffrom stay. (RE: related document(s)[42], [36], [40] ). Hearing scheduled for 6/11/2003 at 01 :00 PM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floo r), Federal Building, Harrisburg, PA. Attorney Keith DeArmond to notice parties. (Weigel, Erma) (Entered: OS/21/2003) 06/0212003 45 Certificate of Service of notice rescheduling hearing Filed by Keith B Dearmond of Burke and Hess on behalf of James C Hoover, Linda L Hoover (RE: related document(s)[44], [36], [40] ). Hearing scheduled for 6/11/2003 at 01 :00 PM at 3rd & Walnu t Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (Wagner, Belinda) (Entered: 06/0212003) 06/11/2003 46 Proceeding Memo: Hearing held. Order granting relief from stay to be submitted by Attorney Maider's office.(RE: related document(s) [45], [36] ). (JG) (Entered: 06113/2003) 06/11/2003 Corrective Entry to change Filed date from 6/13/03 to 6/11103. (RE: related document(s)[46] ). (Leon, Kathi) (Entered: 06/16/2003) USBC PAM - LIVE - V2.2 - Docket Report Page 6 of7 06/18/2003 47 Order Granting Motion for Relief from Stay (RE: related document(s) [36] ). (Wagner, Belinda) (Entered: 06118/2003) 06/20/2003 48 Certificate of Default Filed by Judith Rornano ofFedennan & Phelan on behalf of First Nationwide Mortgage Corporation (RE: related document(s)[18]). (Wagner, Belinda) (Entered: 06/20/2003) 06/30/2003 49 Certificate of Service Filed by Richard C Maider of Deily Mooney Glastetter LLP on behalf of AmeriCredit Financial Services, Inc. (RE: related document(s)[47] ). (Morrow, Sue) (Entered: 06/30/2003) 06/30/2003 50 Praecipe/Withdrawal Filed by Keith B Dearrnond of DeAnnond Law Finn on behalf of James C Hoover, Linda L Hoover (RE: related document(s)[35]). (Rirnrney, Jennifer) (Entered: 06/30/2003) 07/02/2003 ~I Order Granting Motion for Relieffrorn Stay (RE: related document(s) [39], [26] ). (Wagner, Belinda) Additional attachment(s) added on 7/17/2003 to replace incorrect image with correct image for this entry. (TH). (Entered: 07/02/2003) 07/09/2003 52 Order granting relief from stay upon certificate of default. (RE: related document(s)[48], [9]). (BW) (Entered: 07/09/2003) 09/12/2003 53 Motion to Dismiss Case for rnaterial default and hearing notice to parties. Filed by Charles 1. Dehart III (RE: related document(s)[1] ). Hearing scheduled for 10/9/2003 at 02:00 PM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (BW) (Entered: 09/12/2003) 10/20/2003 54 Correspondence from Trustee re hearing. No appearance for debtor. Case to be dismissed Filed by Charles J. Dehart III (RE: related document(s)[53]). (BW) (Entered: 10/20/2003) 10/22/2003 55 Order Granting Motion to Dismiss Case for material default (RE: related document(s)[53] ). (BW) (Entered: 10/2212003) 10/24/2003 56 BNC Certificate of Mailing. Service Date 10/24/2003. (Related Doc # 55) (Admin.) (Entered: 10/25/2003) 10/28/2003 57 Report of Trustee in Dismissed Case Filed by Charles J. Dehart III. (BW) (Entered: 10/29/2003) II PACER Service Center II USBC PAM - LIVE - V2.2 - Docket Report Page 7 of7 Transaction Receipt 1111112003 11 :25:26 'a0060 Client Code: Docket Re or! Case Number: 11:01-bk-06400-MDF I Billable Pa es: 3 Cost: 10.21 I \ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT . to wit: OSGOOD JOHN 0 but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of PERRY serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On August 22nd , 2001 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing Out of County Surcharge Dep Perry County 18.00 9.00 10.00 40.24 .00 77.24 08/22/2001 GOLDBECK MCCAFFERTY SO~E~~ R. homas Klin Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me c;;.. (),~ this oJ. f - day of .......,........r .;1".-./ A.D. 0Y'L- 0. ~'~..1? Prot 0 a SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: OSGOOD SUSAN C but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of PERRY serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On August 22nd , 2001 , this office was in receipt of the attached return from PERRY 6.00 .00 10.00 .00 .00 16.00 08/22/2001 GOLDBECK MCCAFFERTY - ~~ -~.. - -- -~. ~~-~ R. homas Kline Sheriff of Cumberland County Sheriff's Costs: Docketing Out of County Surcharge So answer MCKEEVER Sworn and subscribed to before me this .1 ~ ~ d f G...... · ay 0 ----r ....r- :4-01 A.D. C\''f'L c n.,II.~ ~ l' Prothonotary . , First Nationwide Mort. Corp. . IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH Versus , Susan Osgood No. 01-3220 I / SHERIFF'S RETURN And now August 17 ,2001: Served the within name Susan Osgood the defendant(s) named herin, personally at her place of residence in Newport Borough Perry County, PA, on August 17,2001 at 12:00 o'clock PM by handing to Susan Osgood , an adult member of family, 1 true and attested copy(ies) of the within Complaint in Mortgage Foreclosure and made known to her the contents thereof Sheriff of Perry County SHERIFF'S RETURN In tbe Court of Common Pleas Of tbe 41" Judicial District of Pennsylvania-Perry County Brancb First Nationwide Mortgage Corp. vs Jobn O. Osgood 423 Market St. Newport, Pa. 17074 NO. 01-3220 George W. Frownfelter, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Oefendant(s) to wit Jobn O. Osgood, but was unable to locate bim/ber in his bailiwick. He therefore returns Cornplaint in Mortgage Forclosure NOT FOUND ", as to the within nanled Jobn O. Osgood at 423 Market St. Newport, Pa. Defendant lives at 52 Catoctin Court, Silver Springs, MD. Sworn and subscribed to before me this day of , 2001. George W. Frownfelter Sheriff of Perry County GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16l32 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff A it 0 f:;~ ~\12-l' ('a 0 .~V :It..1I J, ___l \. i! ..: --_....~---....__.. _..J I HEREBY CERTIFY THAT TfoNS IS A TRUE AND CORRECT copy OFlHE ORIGINAL FH.EO FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-10l1 Gaithersburg, MD 20898-9481 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor(s)) Term No. ~ JAMES HOOVER AND LINDA HOOVER (ReaIOwner(s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) CIVIL ACTION; M()RTGAG~' FORECLOSURE . J;t 01 - 3 :l2-o ~~., 1."0 . .., ~ .'~ 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. I..: -... NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20j days after the Complaint and notice are served. by entering a written appearance personally or by attorney and filing 1n writing with the court your defenses or objections to the claims set forth agalnst }-"Oll. You are wal-ned that if you fail to do so the case may proceed without you and a judg~ent may be entered against you by the Court withcut further nvti~e fu~ any n~lI~y cldimed in the Complaint or for an.... cthel. clalm or relief requested hy the Plah..t'tff' Vn'I!JIo"" 1....... "lOnpy 0:-- ~!"ClrArr~. r!, "":~"r -igt:t.. ...u:...ol":".1n:.. t.... y....u. YOU SHOULD TAG THIS PAPER TO YOUR Ut.WYER AT ONCE. IF 'll.OU DO NOT HAVE A LAwYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR'lii BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ~umberlanti County Bar Association 2 Liberty Avenue. Carlisle. PA (800) 990-9108 Legal Services Inc. a Irvine Row. Carli81e. PA 17013 i717"1 24)-9400 A V ISO LE MAN DEMANDADO A USTED EN LA CORTE. SI DEBEll. DEFENDERSE CON'TRA LAS QUEJAS PERBSENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DB 20 DlAS DESPUES DE SER SERV100 CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO OUE USTED. 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA BSCRITA, EL PUN'TO DE VISTA DE USTED Y CUALOUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, 5E PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACICH. ENTaNCES. LA COUTE PUBDE. sn: NOTIF1CAR10. DEClDIR A FAVOR DEL DEMAl~DANTE Y REQUERIRA QUE USTED CUMPLA CON TOOAS LAS PROVlSIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION. ES POSSIBLE QUE USTED Pl1EDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGIlDO IMMEDIATAMENTE. SI NO CONQCE A UN ABOGAOO. LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADQS), :;!15-~38-.s300. Cumberland County Bar ASsccia~ion 2 Liberty Avenue. Carlisle. PA (&OOi 9r,j0-910B TRUE COPY FROM RECORD ... T-'~""' .., ".l=~ i .18:", "'il;';.M.1 rr....I\Io.. ... ';JIIIIIIII't.......,~. IIQII.... = . "*' tM ~:;/ ;.~;.j i..:'.M,I"t iIt I';a;:l~. F'a. <l'.g~;J~~~ fll1ll!lll"l Legal Services Inc. a IrVlne Row. Carlisle. PA 17013 (7171 243-9100 r-.--.-_....-:.~---:.. .' .~.:. \AT1~p~t' : COMPLAINT IN MORTGAGE FOREC1~Y CERTIFY THAT THIS IS A TRUE AND CORRECT COPY 1. Plaintiff is FIRST NATIONWIDE MORT~E&fiItpt~AL~ox 9481, Mail Code: 22-528-101l, Gaithersburg, MD 20898-9481. 2. The name(s) and addressees) of the Defendant(s) is/are JOHN O. OSGOOD, 329 l5th Street, New Cumberland, PA 17070 and SUSAN C. OSGOOD, 329 15th Street, New Cumberland, PA 17070, who is/are the mortgagor(s), and JAMES HOOVER, 329 15th Street, New Cumberland, PA 17070, and LINDA HOOVER, 329 15th Street, New Cumberland, PA 17070, who is/are the record owner(s) of the mortgaged property hereinafter described. 3. On March 27,1974, mortgagor(s) made, executed and delivered a mortgage upon the premisefl hereinafter described to ADVANCE MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mort.g...ge Book 57!;, Page 1071. By Assignment of Mortgage, the mortgage was assigned to Plaintiff, which Assignment is lodged for recording. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due October 1, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Pr~ncipal Bdldnce Interest from 9/ 1/00 through 5/31/01 at 8.250% Per diem interest rate at $1.76 Reasonable Attorney's Fee Late Charges 10/ 1/00- 5/31/01 Monthly late charge amount at $17.48 Costs of suit and Title Search $ 7,803.99 478.72 1,000.00 139.84 560.00 Escrow Balance Deficit Monthly Escrow amount $ $ 9,982.55 429.80 $ 10,412.35 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 $10,412.35, together with interest at the rate of $l.76, per day and other expem'es inr11rn'd hy the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. ~cV--. By: GOLDB CK Mc FFERTY & McKEEVER BY: oseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff VERIFICATION I, Dennis Kieft , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date:. r J~3 ~, '1 ./ '1 '., , . ! .; '1 , ! I . I .' I I , I '-. , ., , " 'I "lid ncw uullll.n::I....Lcllu. L'UUIlPoIY 1.11 '"'Ullll.'I:....LOIIU. allY w,,"aloC 1.11 I cllll~y.&.\lall...CII, . . . Gr"lItorB , JAMES C. HOOVER and LINDA L. HOOVER, hia wifa, of Sunbury, Pannaylva!,ia, Gnmtee a : WITNESSETH, that ill OIlnside...tll". 0' Fifty Ona Thouaand ------------------------------ -------(S51,OOO.00)----------_______Dol~r~ ill Mild p"id, the re.eipt whereo' is 1l.ereb\l "./mow/edlled, u... ."id Q1'fIlItors do herebll gl"l1Alt "lid .011""11 to t~. IJ/Iid gra..!.. s, their hairs and aasigns, ALL THAT CERTAIN lot. or tract of land aituate in the 8orough of New Cumberland, County of Cumbarland and State of Pennaylvania, mora particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern aide of 15th Street aaid point being 870.8 feet weat of 8ridge Street; thence extending along 15th Street South 62 degreae West 50 faet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 dagrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. BEING a pert of lot number 31 Section E Plan of Hilleide as recorded in the Cumberland County Recorder's Office in Plan Book 1, Page 75. HAVING thereon eracted e two story frame dwelling and detached frame garage known as 329 15th Street. BEING the aame premises which Louis N. Kelly and Ruth K. Kally, his wife, by deed dated March 27, .1974, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book N, Volume 25, Page 1040, granted and conveyed. unto John O. Osgood and Susan C. Osgood, his wife, the Grantors herein. " THE A30VE DESCRIBED premises a~e conveyed un~er and Subject to Mortgage to Advance Mortgage Corporation, the unpaid balanca of which ia $28.006.02 ~ Dollars which the Grantees assume and agree to pey according to the terms and conditions of said mortgage and accompanying bond. .....,5 ,'~":::~-::.r-I Va.J ,1/2~ Cumbo Co., P.. Sohool Di,l. Cumbo Co., P.. ~ R.., ht.t. T'"Rd.. T.. ~ R..I EII.'e T,I..II" Tn ? -;>....71. ~-S.~ r....7!. i}..'!;'-$"'Sl!? A;;)~~:"ii.t?~ D~;;2t:::::::.tt......~ c...~ C" D"'. C.I. ....1. ~ C...~. Co. 0',1. C.I. ..."'.~ BOoW28 PACE 39 -- "on. _..". _..._..._u.".n _ _. _._ _n _ _ .-- ---.-..'!':"'_- --. --.-. '--~'._-~ ---p-- .. fJ/oul.J51S /;)CJ3 O;J.l{o ~3(g ~ EXHIBIT A P.O. Box 94Bl Gailhorsburg. MD 2OB9B-94Bl December 22, 2~00 Certified Mail Return Receip Requested James Hoover / 329 15th St New Cumberland PA 17070-1312 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the counseling agency. The name. address, and phone number of the Consumer Credit CounselinQ Aqencies serving vour County are listed at the end of this Notice. If you have any auestions. you may call the PennsYlvania Housing Finance AGency toll-free at 1-800-342-2397. (Persons with impaired hearinq can call (717)780-1869.) This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente 1lamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF350-002/COY S2BO Corporate Drive. frederick. MD 21703 I.E "l J O~ LJ),...S" 1 C). ~:J \Ja'l C I..fJ PD. Box!J.l81 Gaithersburg. MD 20898-9481 Linda Hoover 329 15th St New Cumberland PA 17070-1312 / December 22, 2000~ Certified Mail(./"" Return Receipt Requested RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortqage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the proqram works. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the counselinq agency. The name. address. and phone number of the Consumer Credit CounSel1nq Agencies servinq your County are listed at the end of this Notice. If you have any questions. you may call the PennsYlvania Housing Finance Aqency toll-free at 1-800-342-2397. (Persons with iMDaired hearinq can call (7171780-1869.) This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia. pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF356-001/COY !;;'Jan 1"............"'" n.;.... !:.IIII'IDr.r" un ?17n1 MUE I)D~ w)l-rl)~) O~YO\i1.~ PO Bo.94B1 G"'hersbtlrg. MO 20898-9481 December 22. 2000 ~ Certified Mail -" Return Receipt Requested Susan C. Osgood ~ 329 15th St "",,,. New Cumberland, PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offBgm~cFXQI1tJ~'oQtG~lP~W'me is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with yOU when you meet with the counselina aaency. ~name, address, and phone number of the Consumer Credit Counseling Agencies serving your County are iisted at the end of this Noti~e. If you have any QUestions, YOU may call the PennsYlvania Housing Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearina can call (7171780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (Pennsylvania HOusing Finance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY .. .) \ OCp ~ '5 '5 1:;>'1:3 Oa\{i) ~3\13 P.O. Box 9481 Ga;lhersburg. MD 2OIl!I8.9481 December 22. 200~ Certified Mail........ Return Receipt Requested John 0 Osgood ~ 329 15th ST ~ . New Cumerland. PA 17070 Dear Mortgagor: RE: Loan No. 6838320381 Act 91 Notice Take Action to Save Your This is an offHQ~cFJ.RWe EQr,~lP~Y~~e is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPl may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help. yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with YOU when yOU meet with the counseling agency. The name. address. and phone number of the Consumer Credit Counseling Agencies serv~n~ ycur County are listpd a~ t.he ~nd of this Noti~L If you have any QUestions. YOU may call the PennsYlvania Housing Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir SU hipoteca. DF352-001/COY p~...." ... nO. n.:. ~ rn"~..p" .In ?I.,m December 22. 2000 Loan No. 6838320381 Page 2 PA Act 91 Homeowner's Name: James Hoover Property Address: 329 15th St New Cumberland PA 17070 Loan Account No.: 6838320381 Original Lender: Advance Mortgage Corporation Current Lender/Servicer: First Nationwide Mortgage HOMBONNBR'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BB ELIGIBLE POR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOMB FROM FORECLOSURE AND HELP YOU MAXB FUTURB MORTGAGE PAYMBN'I'S IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' BMBRGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY ASSISTANCE: * IF YOUR DBFAULT HAS BEEN CAUSBD BY CIRCUMSTANCES BEYOND YOUR CONTROL, * II' YOU HAVE A REASONABLB PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMBHTS, AND * II' YOU MBBT OTHBR ELIGIBILITY REQUIREMENTS ESTABLISHBD BY THE PENNSYLVANIA HOUSING FINANCB AGENCY. TEMPORARY STAY 01' PORECLOSURE - Under the Act. you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MBETING MUST OCCUR WITHIN THl: NEXT (30) DAYS. II' YOU DO NOT APPLY FOR BMBRGBRCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE TO DATE. THE PART 01' THIS NOTICE CALLED "HOW TO CURB YOUR MORTGAGE DEPAULT," EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. DF353-001/COY December 22. 2000 Loan No. 6838320381 Page 3 CONSUMER CRBDIT COUNSBLING AGENCIBS - If you meet with one of the consumer credit counseling agencies listed at the end of this notice. the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of the designated consumer credit counselinq aqencies for county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATIONS pOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out. sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IP YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGB ASSISTANCE WILL BE DENIED. AGENCY ACTION: Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligi- bility criteria established by the Act. The Pennsylvania Housing DF3S3-001/COY December 22, 2000 Loan No. 6838320381 Page 4 PA Act 91 Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRD'l'LY PROTECTED BY THI FILING OF A PETITION IN BANltRUPTCY, THI FOLLOWING PART 01" THIS IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BI CONSIDIRBD AS AN ATTEMPT TO COLLICT THI DEBT. (If you have filed bankruptcy you can still apply for Bmergency Mortgage Assistance.) HOW TO CURB YOUR MORTGAGB DIFAtJLT (Bring it UD to date) NATURE 01" THB DBFAULT - The MORTGAGE debt held by the above lender on your property located at: 329 15th St New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADB YOUR MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 1 Months at $349.79 = 349. 79 ~ 1 Months at $442.04 = 442.04'/./ 1 Months at $356.37 = 356.37 ~ Late Charges 87.89 Bad Check Fees .00 Foreclosure Fees .00 Bankruptcy Fees .00 Other Fees / 7.00 Less Suspense Balance __ .00 TOTAL AMOUNT DUB L' 1,243.09 AS OF THIS DATE HOW TO CURB THB DIFAULT - Y~u may cure the default within THIRTY (30) DAYS of the date of this not ce BY PAYING THB TOTAL AMOUNT PAST DUB TO THE LINDER WHICH IS $ 1, 43.09 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bY cash, cashier's check. certified check. or money order made payable and sent to: First Nationwide Mortgage Corporation Dept. 0107 Palatine, IL 60055-0107 DF354-001/COY . . December 22. 2000 Loan No. 6838320381 Page 5 PA Act 91 IF YOU DO HOT CURB THE DB FAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice. the lender intends to exercise its riahts to accelerate the mortaaae debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attor- neys to start legal action to foreclose upon your mortaaaed prooerty. IF THE MORTGAGB IS FORBCLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys. but you cure the delinquency before the lender begins legal proceedings against you. you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you. you will have to pay all reasonable attorney's fees incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender. which may also include other reasonable costs. If yOU cure the default within the THIRTY 130) DAY period. YOU will not be required to pay attorneY's fees. OTHBR LENDBR RBMBDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. DF354-001/COY ~ . . December 22, 2000 Loan No. 6838320381 Page 6 PA Act 9" RIGHT TO CURB THE DIFAULT PRIOR THI SHBRIFF'S SALI - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the riqht to cure the default and prevent the sale at anv time UP to one hour before the Sheriff's Sale. You mav do so bv paving the total amount then past due, plus anv late or other charges then due. reasonable attornev's fees and cost connected with the foreclosure sale and other cost connected with the Sheriff's Sale as specified in writinq bv the lender and bv performing anv other reauirements under the mortqage. CUring your default in the manner let forth in thil notice will reltore your mortgage to the lame pOlition al if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course. the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THB LENDER: First Nationwide Mortgage Corporation 5280 Corporate Drive Frederick. MD 21703 Department 252 1-800-888-40333 EFFECT OF THI SHERIFF'S SALE - You should realize that the Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale. a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION 0.., MORTOAGI - You, UPON OUR CONSENT may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAr OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR. * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. DF355-001/COY RECEIPT FOR PAYMENT ------------------- ------------------- Cumberland County Prothonotary's Office Carlisle, Pa l70l3 Rece~pt Date Rece+pt Time Recel.pt No. 5/25/200l 16:13:36 112088 FIRST NATIONWIDE MORTGAGE CORP (VS) OSGOOD JOHN 0 ET AL Case Number 2001-03220 Received of PD ATTY JOSEPH A GOLDBECK JR JHS Total Check... + Total Cash.... + Change........ - Receipt total. = 45.50 .00 .00 45.50 Check No. 140630 ----------------.-------- Distribution Of Payment ----------------------______ Transaction Description Payment Amount COMPLAINT TAX ON CMPLT SETTLEMENT JCP FEE 35.00 .50 5.00 5.00 CUMBERLAND CO GENERAL FUND BUREAU OF RECEIPTS AND CONTROL CUMBERLAND CO GENERAL FUND BUREAU OF RECEIPTS AND CONTROL 45.50 - P:: eo t..... ~ 5..!.~_ :r- .f..... f-... a: ~..; =:..~ 0'1 I c.... ~J """ ,~~~~:~_~' L5E:.~' o V;~. ~'!!J'f .' : I~ 7.' r- oO . .:11. ." tt..J.:J~ _,- .. d . - It, /I!,. '.0 of l' Aj"- " 44l""-; IIJIj-.. -- ... ",. 9llf ',,- .... J ~ '. .ia J';:~40 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-l0ll Gaithersburg, MD 20898-9481 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW VS. :ACTION OF MORTGAGE FORECLOSURE JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor(s)) Term No. JAMES HOOVER AND LINDA HOOVER (ReaIOwner(s)) 329 15th Street New Cumberland, PA l7070 Defendant(s) CIVIL ACTION: iviURTGAGE FORECLOSURE Jf tll - 3)2..0 e-u.~ 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. NOT I C .E You ha~e been sued In court. If you wish to defend against the claims set forth in the following pages, }~U must take dCtlon within twenty (20; days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing In writing with the court your defenses or objections to the claIms set forth against you. You are warned that if you fail to do Se 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 right. ~mp~rtant to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 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 Bar Association 2 Liberty Avenue, Carlisle, PA t800' 990-9108 Legal Services Inc. 8 IrvIn~ Row, Carlisle, P~ 17013 (717) 24)-9400 A V ISO LE HAN DEMANDADO A USTED EN LA CORTE. 51 DESEA DEFENDERSE CONTRA lAS QUEJAS PERESENTADA5, ES AB50LlITAMENTE NECESSARIa QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDQ CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIQ QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTa DE VISTA DE USTED Y CUALQUIER OBJECCIQN CONTRA LAS QUEJAS EN ESTA DEMANDA.. RECUERDE, 51 US'I'ED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. EN'I'ONCE5, LA CaUTE PUEDE. SIN NOTIFlCARIO, DECIDIR A FAVOR DEL DEMANDANT..! Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA. DEMANDA. POR RAZON DE &:SA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO. PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGAOO IMMEDIATAMENTE. SI NO CONOeE A UN ABOGAOO. LLAME AL "LAWYER REFERENCE SERVICE- (SERVICIO DE REFERENCIA DE A8OGADOS). 215 238-630Q. Cumberland County Bar ASSoclat~on 2 Liberty Avenue. Carlisle, PA (800; 990-~108 Legal ServIcee Inc. 8 IrVIne Row, CarlIsle, PA 17013 1717, 2,;)-9400 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is FIRST NATIONWIDE MORTGAGE CORP., PO Box 948l, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481. 2. The name(s) and addressees) of the Defendant(s) is/are JOHN O. OSGOOD, 329 l5th Street, New Cumberland, PA 17070 and SUSAN C. OSGOOD, 329 15th Street, New Cumberland, PA l7070, who is/are the mortgagor(s), and JAMES HOOVER, 329 l5th Street, New Cumberland, PA 17070, and LINDA HOOVER, 329 15th Street, New Cumberland, PA 17070, who is/are the record owner (s) of the mortgaged property hereinafter described. 3. On March 27, 1974, mortgagor (s) made, executed and delivered a mortgage upon the premises hereinafter described to ADVANCE MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 575, Page 1071. By Assignment of Mortgage, the mortgage was assigned to Plaintiff, which Assignment is lodged for recording. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due October 1, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 9/ l/OO through 5/31/01 at 8.250% Per diem interest rate at $1.76 Reasonable Attorney's Fee Late Charges 10/ 1/00- 5/31/01 Monthly late charge amount at $17.48 Costs of suit and Title Search $ 7,803.99 478.72 1,000.00 139.84 560.00 $ 9,982.55 429.80 Escrow Balance Deficit Monthly Escrow amount $ $ 10,412.35 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 $10,412.35, together with interest at the rate of $1.76, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: VERIFICATION I, Dennis Kieft , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: ,r J:; 3 !o I 'j j J ./ :1 ..1 , .1 .1 i J .; ". ; I .1 I I , i '-. . .j ; ., ., r ./ ! 1 ; ; I\ltlllll L.lUIIIUt:l.l:~ttIIU. L'UUllbY UI L"UIIIUtU".LtIllU. tlllU i:JbtJlot:l UI r-t:1II U:::IiY.LVtllIJ.tI. . "lid GnzlltorB , JAMES C. HOOVER and LINDA L. HOOVER, hia wifa, Df Sunbury, Pennaylva!11B, Gf'Imtee a : WITNESSETH, Ulat ill DmIBiIUmUoIl of Fifty Dna ThDuaand ------------------------------ -------(151,OOO.00)-----____________~I~r~ ill Mild JHl.itI. the receipt whereof.. 1ulrebll Ge1mDwIsd"ed, tM Hid I/f'IIlItora do hereby t/f'tIAIt "lid CllIIV"II to the Hid I/f'IIlItee s, their heirs and aasigna, ALL THAT CERTAIN IDt Dr tract Df land aituata in the BDrDugh Df New Cumberland, CDunty Df Cumbarland and Stata Df Pannaylvania, mDra particularly boundad and deacribed as follows eccording to a survey of D.P. Raffenaparger (49-29) dated March 4, 1974, to wit: BEGINNING at a pDint on the Northern aide of 15th Straet Bald point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degreea West 50 feat to e corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degreas West 195 feet to a point e corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plen South 28 degrees East 195 feet to the point and place of BEGINNING. BEING a part of lot number 31 Section E Plan of Hillaide aa recorded in the Cumberland County Recorder's Office in Plan Book 1, Page 75. HAVING thereon erected a two story freme dwelling and detached frame garage known as 329 15th Street. BEING the same premises which Louis N. Kelly and Ruth K. Kelly, hia wife, by deed dated March 27, 1974, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book N, Volume 25, Page 1040, granted and conveyed. unto John o. Osgood and Susen C. Degood, hia wife, the Grantors herein. THE ABOVE DESCRIBED premisea are conveyed under and subject to Mortgage to Advance Mortgege Corporation, the unpaid balance of which ie 128,006.02 ~ Dollars which the Grentees aseume end agree to pey according to the terma end conditions of said mortgege end accompanying bond. .....I~ o'~~~f 71M .IIl.~ Cum&. Co.. Po. S.h..1 Disl. Cumbo Co.. P.. ;tS R..I Elt.f. T,enl'.r To. ~ Rul EII.t. Tr.n.r., T.. ? -:>....77 ~.fJ6 7-....7l ;;..~-$".rd A:;J'~:..Ji.~;;. D'~~""~.~ CUIft" e" Di... C.I. At.. ~ CUM". Co. Di... Col. A",~ BooW28 PACE 39 . --.~ -. ... ".. -....---. ."_n_ '.. ..._n.. _._.... "'__'.__ h'.'__n__..._._u__.. _ .__.~.._ _ ..__ ~ .-.-.----- .- -'--..- _. II.DE fJ/ou.1.j575 /;;)q3 O;;ll.{o ~ 3(g ~ EXHIBIT A po. 1IoJl9481 Gaithorsbu'll. MO 2OII9Il-9481 December 22, 2~00 Certified Mail Return Receip Requested James Hoover / 329 15th St New Cumberland PA 17070-1312 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. S~ecific information about the nature of the default is ~rovided in the attached ~ages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMP) may be able to hel~ to save your home. This notice ex~lains how the ~rogram works. To see if HEMAP can hel~. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when yOU meet with the counselina aaency. The name, address. and ~hone number of the Consumer Credit Counseling Aaencies serving your County are listed at the end of this Notice. If you have any auestions, you may call the PennsYlvania Housing Finance ADencv toll-free at 1-800-342-2397. (Persons with im~aired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF350-002/COY 5280 Cclrpn18 Drive. F.....'id<. MO 21703 II' 1ST ~ 'l J 0<.0 LI) 1-5" 1 d- t):J \.)a'l C 'fJ P.O. BIlJ<!I481 GaIthersburg. MO 211B9B-948l Linda Hoover 329 15th St New Cumberland PA 17070-1312 / December 22, 2000~ Certified Mail(/""" Return Receipt Requested RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortaaae on your home is in default, and the lender intends to foreclose. Soecific information about the nature of the default is provided in the attached paqes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to help to save your home. This notice explains how the proaram works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the counselina aaency. The name, address, and phone number of the Consumer Credit Counselinq Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the PennsYlvania Housina Finance Agency toll-free at 1-800-342-2397. (Persons with imPaired hearinq can call (7171780-1869.1 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el conten1do de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency 1 sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo per el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF356-001/COY C"HJI'I ('.............. n.illa ~.......i,." un 7I7n1 _. ~'D<P L1S"1-rj"d<tJ O~YO\i"2.~ PO Box 9481 Gaithersburg. MO 2IJl!I8.94Bl December 22. 2000 ~ Certified Mail ...,., Return Receipt Requested Susan C. Osgood ~ 329 15th St -"'..., New Cumberland. PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offllQ~cFxQrnetoQt,~lp~yr&me is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paaes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM IHEMAP) may be able to help to save your home. This notice explains how the proaram works. To see if HEMAP can help. YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with yOU when YOU meet with the counselina aaency. The name. address. and phone number of the Consumer Credit Counseling Aaencies servina your County are listed at the end of this Notice. If YOU have any auestions. yOU may call the PennsYlvania Housing Finance AGency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia. pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta ageneia (Pennsylvania Housing Finance Agency) sin cargos a1 numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su cas a de la perdida del derecho a redimir su hipoteca. DF352-001/COY .. " \ O~ l..J)")5' Idl"{:l Od"W ~3\13 P.D.Ilox9481 Gailhersburg. MD 21l1198-9481 December 22, 200~ Certified Mail........ Return Receipt Requested John 0 Osgood ~ 329 15th ST ~ . New Cumerland. PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an Offl;W~cfJQtnEQr'.plP~~~ is in default. and the lender intends to foreclose. SDecific information about the nature of the default is crovided in the attached caaes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to helD to save your home. This notice eXDlains how the croaram works. To see if HEMAP can helc. YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with YOU when YOU meet with the counselina agency. The name. address. and Dhone number of the Consumer Credit Counselina Agencies serving your County are listed at the end of this Notice. If you have any auestions. yOU may call the PennsYlvania Housina Finance Agency toll-free at 1-800-342-2397. (Persons with imcaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestame por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY ........... ......n.'._ r__..I_.:.L iln'llt"JM December 22. 2000 Loan No. 6838320381 Page 2 PA Act 91 Homeowner's Name: James Hoover Property Address: 329 15th St New Cumberland PA 17070 Loan Account No.: 6838320381 Original Lender: Advance Mortgage Corporation Current Lender/Servicer: First Nationwide Mortgage HOMBOWIII:R'S BMBRCJDCY MORTCJACIB ASSISTANCB PROCIRAM YOU MAY BB BLICJIBLB POR PIRANCIAL ASSISTANCB WHICH CAR SAVB YOUR 80MB PROM PORBCLOSURI AIm HILP YOU MAD: PUTURB MORTCJACII PAYMIR'l'S IP YOU COMPLY WI'1'H THI PROVISIOII'S OP THB HOMIONIIBRS' BMBRCJIDICY MORTCJACIB ASSISTANCI ACT OP 1983 I'1'HB -ACT-), YOU MAY BB BLICJIBLB FOR BMBRCJIDICY ASSISTANCI: · IP YOUR DIPAULT HAS BID CAUSBD BY CIRCUllSTANCBS BBYOIID YOUR COII"1'ROL, · IP YOU HAVB A RBASONABLB PROSPICT OP BBIIIO ABLB TO PAY YOUR MORTCJACIB PAYMIR'l'S, AIm · IP YOU MBBT OTHBR BLICJIBILITY RBQUIRIMBRTS BSTABLISHBD BY '1'HB PBRNSYLVANIA HOUSIIIO PIRANCI ACJDCY. TBMPORARY STAY OP PORBCLOSURB - Under the Act. you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. '1'HIS MBBTIIIO MUST OCCUR WITHIN THB NIX'1' (30) DAYS. IP YOU DO MOT APPLY POR BMBRGIDICY MORTCJACJI ASSISTANCB. YOU MUST BRIIIG YOUR MORTGAClI TO DATI. '1'HB PART OP '1'HIS IIOTICI CALLBD -HOW TO CURB YOUR MORTCJACII DBPAULT.- IXPLAINS HOW TO BRIIfCJ YOUR MORTGACD UP TO DATI. DF353-001/COY December 22. 2000 Loan No. 6838320381 Page 3 CONSUMER CREDIT COUNSBLIIfO AGDCIBS - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may ROT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of the desianated consumer credit counselina aaencies for county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATIONS FOR MORTGACD: ASSISTAllCB - Your mortgage is in default for the reasons set forth later in this Notice (see fOllowing pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out. sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in Submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILB YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO ROT FOLLOW 'l'HB OTHBR TIMB PBRIODS Sft FORTH 1M 'l'HIS LB'l"l'BR, FORBCLOSURB MAY PROCBBD AGAINST YOUR KOMB IMMBDIATBLY AIm YOUR APPLICATION FOR MORTGAGB ASSISTAllCB WILL BB DDIBD. AGBNCY ACTION: Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligi- bility criteria established by the Act. The Pennsylvania Housing DF353-001/COY December 22, 2000 Loan No. 6838320381 Page 4 PA Act 91 Finance Agency has sixty (60) days to make a decision after it receives your application. During that time. no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARB CURRD'l'LY PROTBCTBD BY THJ: PILIIIO OP A PITITICDl IR BANKRUPTCY, THI POLLONIRG PART OP THIS IS POR IIIPORMATICDl PURPOSBS ONLY AlII) SHOULD NOT BE CCDlSIDERBD AS AN A'l"l'BMPT TO COLLECT THI DEBT. (If you have filed bankruptcy you can Iti11 apply for Emergency Mortaaae Alliltance.) HOW TO CURB YOUR MORTCJACJB DEPAULT IBrina it UD to date) IlATlJRB OP THE DEPAULT - The MORTGAGE debt held by the above lender on your property located at: 329 15th St New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT because: YOU HAVB NOT MADB YOUR MONTHLY MORTCJAOB PAYMBRTS for the following months and the fOllowing amounts are now past due: 1 Months at $349.79 = 349.79// 1 Months at $442.04 = 442.04'/ /' 1 Months at $356.37 = 356.37 ./ Late Charges 87.89 Bad Check Fees .00 Foreclosure Fees .00 Bankruptcy Fees .00 Other Fees / 7.00 Less Suspense Balance __ .00 TOTAL AMOUII'l' DUB Vi, 243 . 09 AS OF THIS DATE , HOW TO CURB THB DEPAULT - y~u may cure the default within THIRTY (30) DAYS of the date of this not ce BY PAYINQ THE TOTAL AMOUII'l' PAST DUB TO THB LDDBR WHICH IS $ 1, 43.09 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaYments must be made either bY cash. cashier's cheek, certified check. or money order made paYable and sent to: Pirlt Nationwide Mortgage Corporation Dept. 0107 Palatine, IL 60055-0107 DF354-001/COY December 22. 2000 Loan No. 6838320381 Page 5 PA Act 91 IP YOU DO HOT CURB THE DBPAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice. the lender intend. to exerci.e it. riaht. to accelerate the mertaaa. debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS. the lender also intends to instruct its attor- neys to start legal action to for.c1o.e upon YOUr mortaaa.d property. IP THB MORTGAGB IS FORECLOSBD UPOR - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys. but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However. if legal proceedings are started against you, you will have to pay all reasonable attorney's fees incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If YOU cur. the default within the THIRTY (30) DAY period, YOU will not be r.auir.d to pay attorn.y'. f.... OTHBR LENDBR RBMBDIBS - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. DF354-001/COY . December 22, 2000 Loan No. 6838320381 Page 6 PA Act 9 RIGHT TO CURB THB DBFAULT PRIOR THB SHBRIFF' S SALB - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the riaht to cure the default and prevent the sale at anv time UP to one hour before the Sheriff's Sale. You mav do so bv paving the total amount then past due, Dlus anv late or other charaes then due. reasonable attornev's fees and cost connected with the foreclosure sale and other cost connected with the Sheriff's Sale as specified in writing bv the lender and bv performina any other reauirements under the mortgage. CUring your default ill the manner aet forth ill thia notice will reatore your mortgage to the aame poaitioll aa if you had never defaulted. EARLIBST POSSIBLE SHBRIFF'S SALB DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately 6 montha from the date of thia .otice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO COJITACT THB LElmBR I Firat .ationwide Mortaaae COrDOratioll 5280 COrDorate Drive Frederick. MD 21703 DeDartment 252 1-800-888-&333 BPPECT OP THE SHERIPP'S SALB - You should realize that the Sheriff's Sale will end your ownerShip of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OP MORTGAGB - You, UPON OUR CONSBRT may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THB RICJH'1': * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR. * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. DF355-001/COY ~ ~ ~ ~ ~ r..... - - - ~.:. - ~ - -- - . ~ ~ - ~ r Q. ~ (T'" , -- -- ~ u.. c...f --, "-' s:: <: , ~ .. .- . .) ~} ..t:::- ... =. .~) , I. "," YI ~\~ :_') . - .; -, ,;; :;'"J <:::: ~ -<. . : : GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff I HEREBY CERTIFY Tt-IA T TfoNS IS A TRUe Mo CORRE'CT COPy OF THE ORiGINAL FlLEo FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 GaitherSburg, MD 20898-9481 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor(s)) Term No. JAMES HOOVER AND LINDA HOOVER (Real Owner(s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) CIVIL ACT!ON: MORTGAGE FORECLOSURE tI 01- ~ l.L tJ (I-<--<L:"'L/ THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If }~U wish to defend against the claims set forth in the following pages, you must take aetlon within twenty (20i days after the Complaint and notice are served. by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or obJections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you Bnd a judgment may be entered against you by the Court without further notice tor any money claimed in the Complaint or for any other clalm 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. IP YOU DO NOT HAVE A LAWYER OR CANNOT APFORD ONE. GO TO OR TELEPHONE TKE OFPICE SET roRTH BEWW Ta FIND OUT WHERE YOU :AN GET LEGAL HELP. , CUmberland County Bar ASSOCiation 2 Liberty Avenue. Carlisle. ~A ;8QOI 990-9108 Legal Services Inc. B IrvIne Row. Carlisle. PA 17013 (il7J 24.3-9400 A V I sa LE HAN DEMANDADo A USTED EN LA CORTE. 51 DESD DEPENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES A8S0LUTAMEN1'E NECESSARIa QUE liSTED RESPONDA DENTRO DE 20 DIAS DE'SPUES DE SER SERVIOO CON ESTA DEMANDA Y AVISO. PARA DE'FENDERSE ES NECESSARIa QUE USTED, 0 SU ABOGADO. REGISTRE CON LA CORTE EN F'ORMA BSCRITA. BL PUN'I'O DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE; 51 USTED NO REPONDE A ESTA DE'MANDA. BE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUSOE, SIN NOTIPICARIO. DECIDIR A FAVOR DEL DEMAlIDANTE Y REOUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DE:MANDA. POR RAZON DE ESA DECISION. ES POSSIBLE QUE USTED PUEDA PERDER DIN'ERO, PROPIEDAD U OTROS DERECRQS IMPORTANTES. LLEVE ESTA DEM1\NDA A UN ABOOADQ IMMEDIATAME:NTE. S I NO CONOCE A UN ABOGAOO, LLAME AL 215-238-6300. ~umberland County Bar ASSOCiation 2 Liberty Avenue. Carlisle, PA CSOO; 990-9108 ~LAWYER REFERENCE SERVICEn (SERVICIO DE REFERENCIA DE ABOGADOS) , 1ft r:~ COpy FROM RecoRD and the .:~. I here unto set my hand fhl ,,- 5a/(/ Caul! at earliSIe. Pa . ~. d Y O~l...dZJ!..... '-x~rh Legal Services Inc. 8 Irv1ne Row, Carlisle. PA 17013 (71'7) 243-9400 --... I HEREBY CERTIFY TIlA T THlG IS A. TRUE AND CORRECT COPy OF THE ORIGINAL FIlED COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is FIRST NATIONWIDE MORTGAGE CORP., PO Box 9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481. 2. The name(s) and addressees) of the Defendant(s) is/are JOHN O. OSGOOD, 329 15th Street, New Cumberland, PA 17070 and SUSAN C. OSGOOD, 329 15th Street, New Cumberland, PA 17070, who is/are the mortgagor(s), and JAMES HOOVER, 329 15th Street, New Cumberland, PA 17070, and LINDA HOOVER, 329 15th Street, New Cumberland, PA 17070, who is/are the record owner (s) of the mortgaged property hereinafter described. 3. On March 27, 1974, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ADVANCE MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 575, Page 1071. By Assignment of Mortgage, the mortgage was assigned to Plaintiff, which Assignment is lodged for recording. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due October 1, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 9/ 1/00 through 5/31/01 at 8.250% Per diem interest rate at $1.76 Reasonable Attorney's Fee Late Charges 10/ 1/00- 5/31/01 Monthly late charge amount at $17.48 Costs of suit and Title Search $ 7,803.99 478.72 1,000.00 139.84 560.00 $ 9,982.55 429.80 Escrow Balance Deficit Monthly Escrow amount $ $ 10,412.35 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 $10,412.35, together with interest at the rate of $1.76, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. Jr., Esq. VERIFICATION I. Dennis Kieft , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date:. 5" J:J3 k I .j .1 :\ 1 .-. .1 I I , I I"~I.U ..."'IIIUQ......C1II..... ""UUIIUY "'I .......IIIUD......OI''-I. ClI''''' oJllaul:; U' I C1II1IQy..."gll.La, . and Gnlntora JAMES C. HOOVER and LINDA L. HOOVER, hia wifa, of Sunbury, Pannay1va[11B, Grantee a : WITNESSETH, that in consideration of F1 fty Dna Thouaand ______________________________ _______(S51,000.00)_________________~Uar~ in MM paid, tho roooipt tuhoroof is herobl/ czolmDwl8c!ged, th.e .aid gr4ntot'B rlo horebtf gram.t aM 0011.01/ to t~o .a.id grantoo s, their heira and assigna, ALL THAT CERTAIN lot or tract nf land aituata 1n the Borough of New Cumberland, CDunty Df Cumbar1and. and State of Pennsylvania, mDre particularly bounded and described as fD11Dws accDrding tD a survey of D.P. Raffensperger (49-29) dated March 4, 1974, tD wit: BEGINNING at a point on the Northern aide of 15th Straet aaid point being 870.8 feet west Df Bridge Street; thence extending along 15th Street SDuth 62 degrees West 50 feet to a CDrner of lot number 30 on the hereinafter mentiDned plan Df 1Dts; thence along 1Dt number 30 north 28 degrees West 195 feet to a pDint a CDrner; thence North 62 degrees East 50 feat tD a pDint a cDrner; thence extending through 1Dt number 31 Dn said plan South 28 degrees East 195 feet to the point and place of BEGINNING. BEING a part of lot number 31 SectiDn E Plan Df Hi11aide aa recorded in the Cumberland CDunty RecDrder's Office in Plan BDDk 1, Page 75. HAVING thereon erected e tWD stDry frame dwelling end detached frame gerage knDwn as 329 15th Street. BEING the same premises which LDuie N. Kelly and Ruth K. Kelly, his wife, by deed dated Merch 27, .1974, and recDrded in the Office Df tha Recorder Df Deeds in and fDr Cumberland County in Deed BDDk N, VD1ume 25, Page 1040. grantad and cDnveyed.untD John O. OsgDDd and Susan C. OsgDDd, his wife, the Grantors herein. ., THE ABOVE DESCRIBED premises are cDnveyed under and eubject tD MDrtgage tD Advance MDrtgage CDrpDratiDn, the unpaid balance nf which ie 128,006.02 ~ DD11ars which the Grantees assume and agree tD pay accDrding tD the terms and cDnditiDns of said mDrtgage and accDmpanying bDnd. . _.,5 .~~~ 71/J fi2~ Cumbo Co., Pe. Sohoot Dis!. Cumbo Co.. P.. ;!'I. R..I htd. "1111'.' T.. -f::!- aul Ellete 1r.".I.r ,.. . .., <- - (J D "7 -~.77 ~-S.~ r...-7[ '^....::,.!l.- aI. "2":';''':0 Ami. ........ D.~.~..t.; '0:' "",I. .... /L Atf /lA.-t'......"'-/l.<<<-c, V/4?~.... -;(f'~ Cum.... C.. Dhl. e.l. Alt. ~ CUlllb. Co. Dhl. C.I. A,t. REGISTE RED BY THE HOF EWCUMBERLAND ~ ~&.. BooiVV28 rACE 39 -. -.-.-.-..----..--- -.. .... ------. -'" - _UE rJ/ouJ.l515 r;)t13 O;;LlfO ~ 3(g ~ EXHIBIT A pc. Box 9481 G,i1hBrsbul1l. Mc 211898.9481 December 22. 2000 Certified Mail Return Receip James Hoover / 329 15th St New Cumberland PA 17070-1312 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. SpecifiC information about the nature of the default is provided in the attached paaes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM IHEMAPI may be able to help to save your home. This notice explains how the proaram works. To see if HEMAP can help, yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with yOU when YOU meet with the counselina aaency. The name, address, and phone number of the Consumer Credit counseling Aaencies serVing~OUr count~ are listed at the end of this Notice. If yOU have any ~estions, .ou may call the pennsYlvania Housing Finance Aaency toll-free at 1-800-342-2397. (Persons with impaired hearina can call (7171780-1869.1 This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia. pues afecta su derecho a continuar viviendo en su casa. 8i no comprende e1 contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF350-002/COY 5200 Corporate crive. F""'erick. Mc 217113 .. 'JST ~ 'l I 0'0 l.J '5" TS" \ (j. ~:J \)a'-l a 'fJ P.O. Box 9481 Gaithersburg. MO 211898-94B1 Linda Hoover 329 15th St New Cumberland PA 17070-1312 / December 22, 2000~ Certified MailV Return Receipt Requested RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgaae on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paaes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the proaram works. To see if HEMAP can help. yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with yOU when yOU meet with the counselina aaency. The name, address. and phone number of the Consumer Credit counselina Aaencies servina your count~ are listed at the end of this Notice. If YOU have any questions. _ou may call the Pennsylvania Housing Finance AaenCy toll-free at 1-800-342-2397. (Persons with imPaired hearina can call (717l780-1869.) This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agencyl sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF356-001/COY C'JGn f'.........ID n.i.... I=.DIiD,irlt l"" ?17m .tsr . ~ ~,()~ L1S'1") \ )<!) o~yo \4~~ PO. Box 9481 Gaithersbu'g. MO 21l898-9481 December 22, 2000 ~ certified Mail --' Return Receipt Requested susan C. Osgood ~ 329 15th St --'.. New Cumberland. PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offllQ.llU!cFtQrneto ~lp oW;me is in default and the lender intends to foreclose. S ecific information about the nature of the default is rovided in the attached a es, The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM hel to save our home. This notice ex lains ma be able to ro ram works. This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit counseling AgenCY may be able to help explain it, You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (pennsylvania Housing Finance AgenCY) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage AssistanCe program" el cual puede salvar su casa de la perdida del derecho a redimir su hipeteca. DF352-001/COY . 1ST ~DE .) \ OCp Lr) 'IS' \dqj Oal.(4) ~3'-13 p.o. Box 9481 Gaitller1burg. MO 208!11l-9491 December 22, 200~ certified Mail........- Return Receipt Requested John 0 Osgood ~ 329 15th ST ./ _: New cumerland. PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offHQ~cfJQWeEQ a ~LP ~~ is in default. and the lender intends to foreclose. specifiC information about the nature of the default is provided in the attached paaes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when yOU meet with the counseling agency. The name address and hone number of the Consumer credit counselin Agencies serVing~OUr count~ are listed at the end of this Notice. If yOU have any _ estions. ou may call the pennsylvania Housing Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearina can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY .._ "'... _nO. n.:. _ r~~..~":_" .In 'U"JM December 22. 2000 Loan No. 6838320381 Page 2 PA Act 91 Homeowner's Name: James Hoover Property Address: 329 15th St New Cumberland PA 17070 Loan Account No.: 6838320381 Original Lender: Advance Mortgage Corporation current Lender/Servicer: First Nationwide Mortgage HOMBOWNBR'S BMBRGBNCY MORTGAGE ASSISTANCE PROGlWI YOU MAY BE ELIGIBLB FOR FINANCIAL ASSISTANCE WHICH CAR SAVE YOUR HOMB FROM FORBCLOSURB AND HBLp YOU MAD FU'l'URB MORTGAGB PAYMD'1'S IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNBRS' BMBRGBNCY MORTGAGB ASSISTANCB ACT OF 1983 (THB WACTW) , YOU MAY BB ELIGIBLB FOR EMERGENCY ASSISTANCE: * IF YOUR DBFAULT HAS BBEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A RBASONABLB PROSPECT OF BUNG ABLB TO PAY YOUR MORTGAGB PAYMD'1'S, AND * IF YOU MEET OTHBR ELIGIBILITY RBQUIREMENTS ESTABLISHED BY THB PENNSYLVANIA HOUSING FINANCB AGENCY. TEMPORARY STAY OF FORBCLOSURB - Under the ACt. you are entit~ed to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THB NBX'l' (30) DAYS. IF YOU DO NOT APPLY FOR BMBRGBNCY MORTGAGE ASSISTANCB, YOU MUST BRING YOUR MORTGAGE TO DATB. THE PART OF THIS NOTICB CALLBD wHOW TO CURB YOUR MORTGAGB DBFAULT, W EXPLAINS HOW TO BRING YOUR MORTGAGB UP TO DATB. DF353-001/COY December 22. 2000 Loan No. 6838320381 Page 3 CONSUMER CREDIT COUNSELING AGBRCIBS - If you meet with one of the consumer credit counseling agencies listed at the end of this notice. the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and teleghone numbers of the desi nated consumer credit counselin a encies for count in which the gropertv is located are set forth at the end of this Notice. It is onlY necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATIONS POR MORTGAGB ASSISTANCB - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specifiC information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so. you must fill out. sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in SUbmitting a complete application to the pennsylvania HOusing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST PILE YOUR APPLICATION PROMPTLY. IP YOU PAIL TO DO SO OR IF YOU DO NOT POLLOW THE OTHER TIME PERIODS SET PORTH IN THIS LB'l'TER, FORECLOSURE MAY PROCEED AGAINST YOUR HOMB IMMEDIATELY AND YOUR APPLICATION POR MORTGAGB ASSISTANCE WILL BE DENIED. AGENCY ACTION: Available funds for emergency mortgage assistance are very limited. They will be disbursed by the AgenCY under the eligi- bility criteria established by the Act. The Pennsylvania HOusing DF353-001/COY ." December 22. 2000 Loan No. 6838320381 Page 4 PA Act 91 Finance Agency has sixty (60) days to make a decision after it receives your application. During that time. no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above, You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTBCTED BY THB FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS IS FOR IHFORMATIOR PURPOSES ONLY AND SHOULD NOT BB CONSIDBUD AS AN ATTEMPT TO COLLECT THB DBBT. (If you have filed bankruptcy you can still apply for Emergency Mortaaae AS8istance.) HOW TO ctJRB YOUR MORTGAGE DBFAULT (Brina it UP to date) NATURE OF THB DBFAULT - The MORTGAGE debt held by the above lender on your property located at: 329 15th St New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADB YOUR MOR'l'HLY MORTGAGB PAYMENTS for the following months and the following amounts are now past due: 1 Months at $349.79 = 349. 79 /~ 1 Months at $442.04 = 442.04 ./ ./ 1 Months at $356.37 = 356.37 ~ Late Charges 87.89 Bad Check Fees .00 Foreclosure Fees .00 Bankruptcy Fees .00 Other Fees / 7.00 Less Suspense Balance .00 TOTAL AMOUNT DUB Lr 1,243.09 AS OF THIS DATE , HOW TO CURB THE DEFAULT - y~u may cure the default within THIRTY (30) DAYS of the date of this not ce BY PAYING THB TOTAL AMOUN'l' PAST DUE TO THB LENDBR WHICH IS $ 1, 43.09 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cash, cashier's check. certified check. or money order made payable and sent to: First Nationwide Mortgage Corporation Dept. 0107 palatine, IL 60055-0107 DF354-001/COY December 22. 2000 Loan No. 6838320381 Page 5 PA Act 91 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice. the lender intend. to exercise its riaht. to accelerate the mortaaae debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS. the lender also intends to instruct its attor- neys to start legal action to foreclose upon your mortaaaed prODerty. IF THB MORTOABE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you. you will still be required to pay the reasonable attorney's fees that were actually incurred. up to $50.00. However. if legal proceedings are started against you. you will have to pay all reasonable attorney's fees incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If YOU cure the default within the THIRTY (30) DAY period. YOU will not be required to pay attorney'. fee.. OTHER LENDBR REMEDIBS - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. DF354-001/COY . December 22, 2000 Loan No. 6838320381 Page 6 PA Act g" RIGHT TO CURE THE DEFAULT PRIOR THE SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU still have the riaht to cure the default and prevent the sale at any time UP to one hour before the Sheriff's Sale. You ma. do so b a in the total amount then ast due, plus an late or other charges then due, reasonable attorney's fees and cost connected with the foreclosure sale and other cost connected with the Sheriff's Sale as s ecified in writin b the lender and b performin any other reauirements under the mortaage. CUring your default in the manner Bet forth in thiB notice will reBtore your mortgage to the Bam8 pOBition aB if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately 6 monthB from the date of thiB Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale, Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: FirBt Nationwide Mortaaae COrPoration 5280 COrPorate Drive Frederick, MD 21703 Department 252 1-800-888-1333 EFFECT OF THE SHERIFF'S SALE - You should realize that the Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You, UPON OUR CONSENT may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR. * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. DF355-001!COY , ~ ~ ~~tjti1~~ -1/)7 'Ie -' ~- . ,~ ~ N:3 d "L!\ff\ 1L,... \'1 r. " ',', _'W', '. 6Z uw 10. Hv IS 1\ "~I:l ' ..r>:l0 u"r;t~, ,,: ,,:. 3~1~. 441113115 ." . GOLDBECK McCAFFERTY & McKEEVER BY: Jo~eph.A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JAMES HOOVER AND LINDA HOOVER (Mortgagor(s) and Record Owner(s)) (Record Owner(s)) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term 329 15th Street No. 01-3220 CIVIL New Cumberland, PA 17070 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2(0) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriff's Office/competent adult (copy of ~ return attached) . ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriff's Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment attached) . Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached). Certified Mail & ordinary mail by Sheriff's Office (copy of return attached) . Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully /" , ,.. ..row ~<:"~"="~"'J,"'~II :':"! ..en :<:>.... ~ - \,~~'II:d .i6V.I~MI::> iJ:)\.II:Un!'oul Qf-J .' ! 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SENDER: OOlDBECK McCAFfERty t 4"I'EEVER . september t" PS Farm 3811. June 2000 o.n- Re\Ul"n ~ipt UNITED STATES PDST~~-~~~~~'"'''''''' -.... !11~" " . -" - -. '~i~l~;a~~'~a;i~"i '. Peslage & Fees Paid , ' "J I " .' ..~.:- . ""m1~IIIO.G.10 I · PRINT YOUR NAME, ADDRESS AND ZIP COD~ELOW. ! " "" "', '"'" 1/1/,""""" "", "'" 1/1./11.1/11' GOLDBECK McCAFFERTY & McKEEVER SUITE 500 - THE BOURSE BUILDING 111 SOUTH INDEPENDENCE MALL EAST. PHILADELPHIA PA 19106-2519 .. .____a____a.........___...._. .~_~~.~.........______........ .~___________..... 2. Article Number ~ 1IIII1 III 3_ Servlco1YPe CERTIFIED IIAIL 4. Res.rIcI8d 0eI1very? (&1rB FesJ 1. MicIo.Addnts8odIa: 0.... LINDA HOOVER 32.9 1Sth street New Cumberland, PA 17070 . ::::::_~~~~:~~.,. D. II .......,~ 1-3 tre . Ullellll'l '.o'n ilem 11 liVES, w,loI~ :t8b-lOr/&lllt,"'i 108IOW: -:::1_ U- I.:.:.... CNo .....------- n...._____ RE: HOOVIR,JAMIS / FNo02S2 12/ "01 . SENDER:"" .GoLDBECK McCAFFERTY & McKEEVER - september, PS Form 3811, JW18 2000 Domeollc IleIum "*>>;0,-- "- ~~~~~ .s;~~~" ~~;~~ "s~~~.~'..'..'....." - - "II 'I"'"}I'" no. --.. ~. ~~:~i:~~~~~.: Permtt No. G-l0 , , I . PRINT YOUR NAME, ADDRESS AND ZIP CODE BELOW. ! , 1",111,1"",1111.,.,11",,1,1,1,1,.,,111,1,.,11,,1 GOLDBECK McCAFFERTY & McKEEVER SUITE 500 - THE BOURSE BUilDING 111 SOUTH INDEPENDENCE MAll EAST PHilADELPHIA PA 19106-2519 . u r-< ~ ~ (J> ." " iiii U1 .... '" N 0 n- oZ 3 ., c .. '" "'0 . . "" , . -, ~g, .......... . ~ ,. .. n .~ . . iD .. .. "'11 ~ L ~ \ 0 , {\J ~ V" 1-1 S- G n 0 :I ... t ~ ~ . 'l! :>. ll" =' f. ~sli' I, ~;z8 !.ili '1~ "'a-'!I'" en 9 ~j~i ~ I.=> ... ,- S~ -'" . 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S' . ::c:-a::c=:, 2- ~.~Ui i _fa.~r I lp ""'&.(")0 z .,,~oI!!!:.""" AI >Ul:=-.;p ! -Ec:r . ~ !f ~ r "m=- !. ~. iI ~ :"'I~ i ~ . '" : ......;,~. ....... " ~7- ,. ~ ~ n .~- ,.. -;?:~;.:. ..~ , ..--,""."..t . ...... --~;: :,:1 ; ~ jlll ~ :: :~II anal ~-IN.:' N :... ... N'" "... ~ N ;;; ::= Cl Cl ... .... 0\ .... UI .... .... "!!" - ,~.. . . . -. r . " 5l):o~ rno.3 . "". :J~. ""." !:-a. . g ~"'(I)~ [:::itrl .s-!JlCl1~ ::r;'O::s: a~1 =tsz:t oCllOj! ::rniil Ji"" a::s:OlIlO l>> !!.c ~ill ~!: ~~: ~ . "3 00009. i 11 oil!:,ll- 8c'!1!f i.e.. ~.o. 0. - 3 ~ ~ . . 000 ~~f{: 0:1: ~ii!~ :7 ~ if. i'::J . g. ~ fJ Do. ~ .~ ~ ~ ~ ~ -a" o - r..::J 7ii -.!! ti .;, ::;:E: '1 Q " . a ~ . . 0. ii' . 00 z - 0. ~ - c ii o . 0. !fom> :a.;R' ",;a.~ "''''3 g:fl-a "tt o~::r 0." . Q !!!.o a ~. 8 --. .. 3- :"'I 'tJ _. ~ -1lI "" . -.11I II ~ =c il 2.~& T 1 3 . i:! n- ".- .'" ll-.'!l .,.It U ~ '" GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE vs. JAMES HOOVER AND LINDA HOOVER (Mortgagor(s) and Record Owner (s) ) Term No. 01-3220 CIVIL 329 l5th Street New Cumberland, PA 17070 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORP., 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 at: 329 15th Street, New Cumberland, PA 17070 1. Name and address of Owner(s) or Reputed Owner(s) : JAMES HOOVER 329 15th Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPT OF PUBLIC WELFARE, BUREAU OF CHILD SUPPORT ENFORCEMENT, HEALTH & WELFARE BLDG., ROOM 432 P.O. BOX 2675 HARRISBURG, PA 17105 CUMBERLAND CO. DEPT. OF DOMESTIC RELATIONS P.O. BOX 320 CARLISLE, PA l7013 GREENWOOD TRUST CO. P.O. B9X 11848. HARRISBURG, PA 17108 BELCO COMM. CREDIT UNION 403 N. 2ND STREET HARRISBURG, PA 17101-1322 4. Name and address of the last recorded holder of every mortgage of record: FIRST FEDERAL SAVINGS & LOAN 234 N. 2ND STREET HARRISBURG, PA 17101 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 whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GOLOB BY: Joseph Attorn & McKEEVER , Jr., Esq. tiff DATED: November 27, 2001 n C' '.f~ f: - ~J -- ~~n , ::~ .., --- ,- I'.> r (:: , , ''':' -, ( -- '- ::':; ~T ;~: -. ') ,. - , :;~ , r, , -.~ --, 35 :.< :.) (J"l -<" First Nationwide Mortgage Corp. VS John O. Osgood (Mortgagor Only) Susan C. Osgood (Mortgagor Only) James Hoover (Rea! Owner Only) Linda Hoover (Real Owner Only) In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3220 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions frorn Attorney Joseph A. Goldbeck. Sheriff's Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30.00 50.00 15.00 .50. 1.00 25.66 22.10 15.00 15.00 5.64 12.30 237.50 197.58 $627.28 paid by attorney Sworn and subscribed to before me ?-~t?~ This /:J~ day of !o.J.h_ J... ~ 2001,A.D. C)'F' - 0. ~,tJf"i, Prothonotary R. Thomas Kline. Sheriff BY~~~ R a! E ate Deputy \.,"0 . (ft.?>'"I" \'1 ~. 1/9,n First Nationwide Mortgage Corp. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) Defendants NO. 01-3220-Civil AFFID1VIT PURSUANT TO RnT.R 3129.1 Firs~ NA~ionwide Mor~gAge co~., Plaintiff in the above action, by its attorney, Joseph Goldbeck, Jr., Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 329 15~h S~reet. N~ n.mner1and. PA 17070. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) ~.mAR RnOVAr (RAAl OwnAr only) 329 15'" S~ree~ New n.mner1and. PA 17070 Linda Hoover CReal Owner onlyl 329 15'" S~ree~ NIRW' rn",hArlAntl. PA 17070 2. Name and address of defendant (s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) John o. osliJOod CMor~Sl'''lJOr onlyl 52 Ca~o~~in Cour~ Silver Spri~s. NO 20906 Susan C. Osgood CMor~gAgnr onlyl 423 MArke~ S~ree~ N~or~. PA 17074 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably' ascertained, please so indicate) Greanwnnd TnIS~ Cn. P.O. Box 11848 Harrisburg. PA 17108 Be1~n ~nmm. Credi~ Union 403 N. 2M S~ree~ HarriAml~. PA 17101-]322 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) First Fsdsra1 Savings & Loan 234 N. 2m Strsst RArrishu'qJ. PA 17101 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) Hml.a 6 . Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) C~l1ft1hArl.n'" Cnun~ D"I)t: _ of nnmAR~i~ RAlat:ionR P.O. Box 320 Carlis1s. PA 17013 Pa n.pt. of Pub1i~ Ws1fars H,trAAU of Child S~r~ Rnfor~amAnt: Hsa1th lUld WA1fars B1qg. Room 432 P.o. Box 2675 Rarrisbur~. P1 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Hml.a I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. #4904 relating to unsworn falsification to authorities. September 12, 2001 ldbeck, Jr. r Plaintiff , GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney 1.0. #l6132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 (?15l 6?7-n?? ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. Plaintiff : CUMBERLAND COUNTY COURT OP COMMON PLEAS : CIVIL DIVISION Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real OWner only) Defendants NO.01-3220-Civil NO'l'TC'F. OF .'lHF.IUFF '.'l .'lAT.F. OF RF.l\T. F..'l'l'A'I'F. TO: James Hoover (Real Owner only) 329 15'" Street New Cumberland, PA 17070 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 329 15th Street. New ~.mherland. PA 17070. is scheduled to be sold at the Sheriff's Sale on De~Amher 5. 2001 at 10:00 a.m., in CUmberland County, CUmberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013 to enforce the court judgment of S10.665.31 obtained by First Nationwide Mort~a~e co~. (the mortgagee) against you. NOTIC~ OF OWRRR'S RIGHTS YOU MaV BE ABLE TO PRRVRNT THIS SHERIFF'S SALR To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (2]51 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on.how to obtain an attorney.) YOU MA.Y STILL BR ABLR TO SAVR YOUR PROPRRTY AND YOU HAVR OTBRR RIGHTS EVJeN IF THE SHRRIFF' S SAr.E DORS TAXE PLACE_ 1. If the Sheriff's Sale sold to the highest bidder. calling (?1~1 6?7-1~?? is not stopped, your property will be You may find out the price bid by 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (717) ?4D-6,QO 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAltB THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT APFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. a Irvine Row Carlisle, PA 17103 (717) 243-9400 GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 (215) 627-1,22 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) Defendants NO.01-3220-Civil IITOTTC'F. OF 1=lHF.RTFF '!'l !':IIT.F. OF RF.AT, F.!'lTIITF. TO: Linda Hoover (Real Owner only) 329 15t!> Street New cumberland, PA 17070 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 329 15th Street. New ~.mhQr1and. P1 17070. is scheduled to be sold at the Sheriff's Sale on Dec~her 5. 2001 at 10:00 a.m., in CUmberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2M Floor, Carlisle, PA 17013 to enforce the court judgment of ~10.665_31 obtained by Fir.t Nationwide Mort~age co~. (the mortgagee) against you. NOTrCB OF OWNER'S RrGHTS YOU MAY BR ABLE TO PREVli:NT THrs SHERrFF'S SALI!: To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (215) 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance ~'ou will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU M1Y STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale sold to the highest bidder. calling (21~1 627-1.22 is not stopped, your property will be You may find out the price bid by 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (7]7) 240-6~gO 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (lO) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAD THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAmlOT AFPORD ONE, GO TO OR TELEPHONE THE OPFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 121 <; 1 627-1322 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. Plaintiff CUMBBRLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real OWner only) Linda Hoover (Real OWner only) Defendants NO.01-3220-Civi1 NOTICE OF SHERIFF'S SALE OF RF.l\T. F.STlI.TF. TO: Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, Me 20906 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 329 15th Street. Hew ~.mn.rla"~. P1 17070. is scheduled to be sold at the Sheriff's Sale on D.~amn.r 5. 2001 at 10:00 a.m., in Cumberland County, CUmberland County Courthouse, Commissioners Hearing Room, 200 Floor, Carlisle, PA 17013 to enforce the court judgment of ~10.665_31 obtained by Pirst HationwidA Mortgag. co~_ (the mortgagee) against you. NOTiCB OF OWNER'S RiGHTS YOU MAY BB ABLB TO PRlrVlmT THiS SHBRiPP'S J:lu.1i: To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: 12151 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on now to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVR YOUR PROPERTY ANn YOU HAVIll OTHER RIGHTS EVRN IF THE SHERIFI"S l:tAT.'Il: DOES TAXE PLACE_ 1. If the Sheriff's Sale sold to the highest bidder. calling (215) 627-1.22 is not stopped, your property will be You may find out the price bid by 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (717) 240-6.90 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAlCE THIS PAPBR TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BBLOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue CarliSle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 GOLDBECK McCAFFERTY & McKEEVER .. By: Joseph A. Goldbeck, Jr. Attorney I.D. #l6132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 (21 C;l 6?7-n2? ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. Plaintiff : CUMBBRLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) Defendants NO.01-3220-Civil NOTTeF. OF SHF.RTFF I S .C:IH,F. OF RF.ll.T. F.STll.TF. TO: John O. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, Me 20906 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 BANI<RUPTCY, 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 329 15th Street. New ~'mher1and. PA 17070. is scheduled to be sold at the Sheriff's Sale on De~Amher 5. 2001 at 10:00 a.m., in CUmberland County, CUmberland County Courthouse, Commissioners Hearing Room, 2~ Floor, Carlisle, PA 17013 to enforce the court judgment of S10.665.31 obtained by Firat Nationwide Mor~~age co~. (the mortgagee) against you. NOTICE OF ONNRR'S RIGHTS YOU MAY B2 ABLR TO PR2VRlIl'I' THIS SImR'[PF'S SALR To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (215) 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The Sooner y~u contact one, the more chance you will have of stopping the sale. (See notice on page two. on now to obtain an attorney.) ;~~ :V STiLL BE AI'ILE TO SAVR i~~ ~:~P:=: :~ ion RAVR OTll'RR RiGHTS EVMl iJ' THR SHRRiJ'J" S S D C _ 1. If the Sheriff's Sale sold to the highest bidder. calling (215) h27-1,22 is not stopped, your property will be You may find out the price bid by 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (717) 240-h,QO 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAXB THIS PAPBR TO YOUR LAWYER AT ONCB. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELBPHONE THE OFPICB LISTED BELOW TO FIND OOT WHERB YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 . GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, Me 20898-9481 Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, Me 20906 : COMBBRLAND COUNTY : COURT OF CODON PLEAS : CIVIL DIVISION : NO 01-3220-Civil James Hoover (Real Owner only) Linda Hoover (Real Owner only) 329 15th Street New Cumberland, PA 17070 ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot number 31 Section E plan of Hillside as recorded in the Cumberland County Recorder's Office in Plan Book 1, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 WRIT OF EXECUTlq~ snit/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-3220 CIVIL1SlOC TERM CIVIL ACTION -LAW TO THE SHERIFF OF CUmberland COUNTY: To satisfy the debt, interest and costs due First Nationwide Mortqaqe Corp. PLAINTIFF(S) from John O. Osgood (Mortgag= only) 52 Catoctin Court, Silver Springs, MD 20906, Susan C. Osgood (Mortgagor only), 423 Market Street, Newport, PA 17074, Jcmes Hoover and Linda Hoover (Real Owners only) 329 15th St.. New Cunberland, PA 17070 DEFENDANT(S) (1) You are directed to levy upon the propeny 01 the defendant(s) and to sell ~ T ~..l Des=iDtion (2) You are also directed to anach Ihe propeny 01 the detendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to not.y Ihe garnishee(s) that: (a) an aUachment has been issued; (b) the garnishee(s) is/are enjoined lrom paying any debt to or lor the account 01 the defendant(s) and from delivering any propeny of the defendant(s) or otherwise disposing thereol; (3) If propeny of the delendant(s) not levied upon an subject to anachment is lound in the posseSSion of anyone other than a named garnishee, you are directed to not.y him/her that he/she has been added as a garnishee and is enjoined as above staled. Amount Due $10,665.31 from Y/ll/Ul to sale date at Interest $1 7" p"T rli"", Any's Comm % Any Paid $252.94 Plaint.1 Paid $.50 l.l. Due Prothy Other Cosls SI_OO Dale: September 18, 2001 Curtis R. Long Prothonotary, Civil Division _by: ~"'?' P. ~A"'.AJ_I REQUESTING PARTY: Name Joseph A. Goldbeck, Jr. Suite 500 - The Bourse Bldg. 111 O. Independence tiall East Philadelphia, PA 19106 Anorney lor: Plaintiff Deputy Address: Telephone: 215-627-1322 Supreme Coun 10 No. 16132 REAL ESTATE SALE No. 53 On September 19,2001, the sheriff levied upon the defendant's interest in the real property situated in Borough of New Cumberland, Cumberland County, PA, known and numbered as 329 15th St., New Cumberland, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 19,2001 By: Cjod-L( ~ Real Estate Deputy ... ....~ .... - __J ~- - -o- n -- '"" ~ <' , -- - ,- en -~ ~_d "- ..... .~ '-' u.J ~ 0 V'> (-1 CViI CViI c::::J ~ &vii . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. 1.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgentbal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Curnberland 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 Curnberland Law Joumal on the following dates, VIZ: October 12, 19,26,2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject rnatter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. :/~YWl--- Roge M. Morgenthal, Editor IlEAL ESTATE 8AlZ NO. 113 Writ No. 2001-3220 Civil FIrst NaUonWlde Mortgage Corp. vs. John O. Osgood (Mortgagor Only) Susan C. Osgood (Mortgagor Only) James Hoover (Real Owner Only) LInda Hoover (Real Owner Only) Atty.: Joseph Goldbeck ALL TIiAT CERTAIN lot or tract of land sJtuate 1n the Borough of New Cumberland. County of Cum- berland and State of Pennsylvania. more particularly bounded and de- scrtbed as follows according to a survey of D.P. Raffensperger (49.29) dated March 4. 1974. to Wit: SEGlNNING at a pOint on the Northern side of 15th Street said pOInt being 870.8 feet west of Bridge Street: thence extending a10ng 15th Street l!Iouth 82 cIcI"CC8 West 50 feet to a Comer of lot nUm- ber 30 on the hereinafter menUoned Plan of Int!llI" th...n...... ..1__ _. . SWORN TO AND SUBSCRIBED before rne this 26 day of OCTOBER. 2001 NOTARIAl SEAl LOIS E. SNYDER, Nlllaly Public Mr:..~=t::m~~ ...................... Crame garage 1m"";;' -;;~- 329 15th Street. 33 Tax Parcel #26-23-054t-1 . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of PUblication Under Act No. 587. AIlPmved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Th~ .. · .. ....... __ -.., ~ Th. """" N... Co., . ~...... '...... ~, -. ~..,.. Ioh ~.. C_~_", ~ -.",...,..." ,"..., _~'...~ ~ ...~u ~ "'" '" ..... S_ · .. C" ~ "'-., C_ ~ eo_., s.. ~ """........ ....~ "" _..., ~ Iho "''''''-N... "" Th. S_, P."",-- ~-- ~..... "_, ,,,"".... ,......, ~ '" <0 '" ..... S_, i. .. Ci" Co..", .... S.... "'....... ... Tho Po........ ".. Tho ..... P'M~-_ _. -" .."" .., "'< ~, _m.,., ''"', '...., __., ~, .. h~ ..~ ...,..."'" "'...., ever since; "'" .. ""'" .... .. -.. - · -- ~.".. h_ . ...., .. ""''''' "" _.., . .." ....., .... .- S_~ ..", -. .,,"" __ 00 .. "" "" "'" "W., ~ -. .... .. '"' "W., ~ N__ ",... Tho. .",_ h. _ ... eo_, .. _ . .. __ ""'"' ~ ... ....""" .... .. -. .... .~ " ~ .. _... ~ '" .Io_. .. " .. "'", - "" _, ~ PUblication are trua; and "'" .. ... ...._, "'- ~ .. .... ........ .... . ... ......... .... - <0 ~'" ... - ~ ...... ~ Tho P.""'-.... eo. ........ by _ .... -... <0. _ __ ...... "" .- ......, by .. -... ~, ...~ ~ - ~ .. ... "",-, .... ''''''''- ..., ....., . .. ..~ '" .. "-"'''' ~ """" · .... <0, ... Co.." ~ eo..... __ .... ...., :::::o:',m'tL"" Copy S. _ .. .. ''"' ~"'" "'" """.0. SA L E #53 TonyLIl~I::ry . IIEAi. ElTAlE lIAUi No. 511 ,.,.~ ~ ""'..;:_ WlttMo.___ I.ty~e""'""'",;;;;s,or- CIoIIlWm II __ FIlII ......,.,.......l:aIp. tmIler. Penn~", "'1IIoete/lan 01 5.\lPI ~~ar...orlond_ m~~:'~ ~::~or CIuDIJorIud IIId or """'''_ _ ...x.1orty boIInded IIIlf deo:ribid . 1ilI.... -.... 10....., or D.P. Rda...... 149- 29) dIrol MonlJ 4, 11174, 01 wit III!GINNING .. . poial ... die NordIem Iide or .15IJJ Sbaollicl poIol boia, ms __or IIddoo SIrao:IlIence..~..... 15rlI5IIal Saudi 62....... WeIr 50 r", b'_Ii"" -30lII~hooeiuftor...........pIoaor l01I: I!IaIco "- "" nu_ 30 IIllIIh 21 doJncs PUblisher's Receipt for Advertising Cost Tho ..... N... C" ""oh" ~ Th. P._ ."" "" s_ __ ~_ ~ ,,~'" -, h_ - -.. ~.. -u. ,- ."" _ ~. ."" ""'" ... .. _. ho~ 1 duly paId. James L. Clark being duly sWorn according to law. deposes and says: CUMIlERLAND COUNTY SHERiFFs OFFICE CUM8ERt.ANo COlJNTy COURTHouSE CARLISLE. PA. 17013 Statement of Advert/sing Costs To THE PATRIOT-NEWS CO., Dr. For PUblishing the notice or PUblication altached hereto on the abOve stated dates Probating sama Notary Fee(s) Total $ $ $ 196.08 1.50 197.58 By.................................................................... .. e. ~ 'S 8 i u l;l. Ii ~ ~ a \ ~~ i ." o 0 z'" ~ .. 1 ~ i ....__ I . '<<1- u"'C""'"""8 -:::-. >.'::': _ U 0 e !! ~ ~ .c -::: 0 C u '-'"2. ..... >-" ... ... 0"" .... ,.. - "2 0 C C .=3 ~8 ~ '9 .... cD c: in -g "& o 0 0 .!:I. ... :s '- - ca ~:!:..... 0 u ~ II ~ ...~... uoeo~ -"'i-~~~N ~~ut~oo~S"C~~ E~~u~ ~Qee"Q_CD"""".:!Ot:;"Oot1lU - 1:: 1:: 0 6 0 1'!i u g ~ " II ~ -: "'5 ~ ~ s 00 ~~.co_:Sn1c~n1~~~~ ~~~~.c~-UoB~~~--ci~~ ~~~~~i~~]i~~i:~~~~i ~f~U8~~n1'" ~S~.c~"'C~u~ ~o~ ..~a~iu.ci~z~E~~ . .:c:ci-~iii~..E"~iil~E~Ul15 OUWn1< "Q5"'Ca"'Co2ou u~ ~ ~ ~'g ~gh~ g~l;l~~~l ~ ~ "") :J '0 ~ .H e ;; ell ~ 2: a.CC -a eie~~:~agg~~~~ ~~~ . =g=-~-~~~~"'Cll=.!:I. -u~ ~ c~c_.c_c"'C~ZUn1og <<ISm - oc-C-~~~ ~De Um "'C...~ ~ _ ~ .E ~ .. 0,;;., ~ Vi ~ " ~ 'C u"C CO') "It' ~:~~~g~g:~e~Bj ~~= ~ jou.......u ell _=...~...n:i ~ 8 ~~e~eMn1'o.E~~c u~~ N 8 UU ~.c...~u--E- cc~ m u ~"Cn1 _~w~o03u oao N ..~u~~~~=~~t:=u~ ~~~ ~ o.c-SC"tcQjuSil:i caal 1:: ~"'Ou - ~5~€i~~:~1::5~ ~u: ~ !c~gn1C"tugoo-~ St~E~~ ~ oo~ o~..,"'EE="C"C~>~ ~~ ~ 0 ........ ugu~ n1 uu~ ~~\i~_€Ee~&~u~8~:c~e~~ ~~c.~.!1~ 8..s~.s ~ e~ 8. ~~US GOLDBECK, McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. Term No. 01-3220 CIVIL JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor(s)) JAMES HOOVER AND LINDA HOOVER (Record Owner(s)) 329 15th Street New Cumberland, PA 17070 PRAECIPE TO SATISFY JUDGMENT as to Defendants John and Susan Osgood TO THE PROTHONOTARY: As to the defendants John Osgood and Susan Osgood, kindly satisfy the judgment in the above captioned matter upon payment of your costs only. , JR., ESQUIRE ," 1- ~.. p .. c, ,- ":0&:; ...... ,~, .F ~ lI\. .~ -, ~u; ~1 g C;;:j .' :;::: _I., '<;:' Cl5f:: ..... ;::s ;:.: ...... . . .--~ ::::. ..c: (r, ," :fiC, ..' ~..- J ~ .., f ...~} "" .... .:5f: I~" ~ ;<) - II> ::SC): ~ " r; . .-....;... ..... ..(\ \0 . .~}.:~i ~ ". ("j::'-i' - ....~ r\) :s ..... ~ i::J ~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL 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 OSGOOD JOHN 0 but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , OSGOOD JOHN 0 OSGOODS MOVED OVER 20 YEARS AGO. NO KNOWN ADDRESS. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 11.70 .00 10.00 .00 39.70 S~ ./~~ R. Thomas Kline-- Sheriff of Cumberland County .~----~ GOLDBECK MCCAFFERTY & MCKEEVER 07/11/2001 Sworn and subscribed to before me day of ~ ... SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL 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 OSGOOD SUSAN C but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , OSGOOD SUSAN C OSGOODS MOVED OVER 20 YEARS AGO. NO KNOWN ADDRESS. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So answers. ........ _~____ . <~-- ..:.~~~-- R. homas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY & MCKEEVER 07/11/2001 Sworn and subscribed to before me --- this I ~ -Ik day of J Ll kt 'OM SHERIFF'S RETURN - REGULAR CA9E NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL GERALD I'ORIHINGIal , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, was served upon says, the within COMPLAINT - MORT FORE HOOVER JAMES the DEFENDANT , 2001 , at 1945:00 HOURS, on the 30th day of May at 329 15TH STREET NEW CUMBERLAND, PA 17070 LINDA HOOVER, WIFE by handing to 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 10.00 .00 16.00 Sworn and Subscribed to before me this {g-Il.. day of .---- A.D. So Answers: ~~-~t:~ R. Thomas Kline 07/11/2001 GOLDBECK MCCAFFERTY & MCKEEVER By. .~..u W4~ Deputy S iff SHERIFF'S RETURN - REGULAR CASE NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HOOVER LINDA the DEFENDANT , at 1945:00 HOURS, on the 30th day of May , 2001 at 329 15TH STREET NEW CUMBERLAND, PA 17070 LINDA HOOVER by handing to 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 10.00 .00 16.00 So Answers: .' ," , /, "'7 ~_."J'. ...~~.. ..... ..r or ;;t"....<..,..,....~.1"--~~~ R. Thomas Kline 07/11/2001 GOLDBECK MCCAFFERTY & MCKEEVER Sworn and Subscribed to before me this day of BY:~1. ~_ ~ M ~.:; . Deputy Sh ff A.D. ry~ GOLDBECK, MCCAFFERTY & MCKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite SOO-The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (21 <; I 627-] ~22 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS First Nationwide Mortgage Corp. Vs. CUMBERLAND COUNTY CIVIL DIVISION NO. 01-3220-Civil John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) CF.RTTFTCATT01\T JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby states that he is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA Mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. ldbeck, Jr. r Plaintiff First Nationwide MOrtgage Corp. Plaintiff : CtJMB'SRLAND couNTY : coURT OF coNMON PLEAS : CIVIL DIVISION Vs. Jolin O. osgood (MOrtgagor only) Susan c. OSgood (MOrtgagor only) J8IIl8s BoOVer (Real owner only) Linda HoOVer (Real owner only) Defendants : NO. Ol_3220-CiVil a,tiOS, by itS attorneY' Jos..h Goldbe,k, Jr., Esquire, setS forth sa of the date the Prsa,ipe for the writ of EXSCUtiOS was filed the follosing informatiOS cooteruing the real property lotated at 1~~A~ N.tionw~~A Mo~~g.gA ~n~~. Plaintiff in the above }1!'1!''tnllvTT 1>TT1iAtlIl>NT '1'0 'Am... ~L2q.1. 32q L'i~_h A~_~"A~. w- ....,...b..~L..ft<\. PIl 1'70'70.. 1. Name and addresS of owner (s) or reputed owner (s): Name AddresS (if addresS cannot be reasonablY ascertained. please so indicate) J.""AII 'A~nvAr ('RAa1 nM'nAr "ftLV) ~~ ~:.::~::~. 'P'" L '70'70. :L","~A 'R'nnvA'r ('RARL twnlll!!llr nftLY) :,: ~~::~::~. PIl 1'70'70. 2. Name and address of defendant(s) in the judgment: Name Address (if addresS cannot be reasonably ascertained. please so indicate) J"h... O. oAW'n<\ (1In~~q.W'~ nft'l,y) o;~ ~~n~~~ ~n"rt B 1 _ ___ftgll. MIl 20906. BUll.'" C. 0111100<\ '1Inr~.q.gn~ nft'l,y) ~:;:1rAt St~Allt _~___' PIl 1'70'74. 3. Name and addresS of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonablY ascertained, please so indicate) or..nwnnd T""u,~ ~o. ~~~~ ~:. "l1 84& t or;,_ va. 1.?1-08 'SA1t'!O Cn'IIIIIl- ~"r.d"-t t1n.1oD i~ ~- 2= ~t~""t or am,rg ;~ i?1-01--~~2~ Name of --g~ Of the last recorded hOlde~ -.".e recOrd, . of eVery -... 'if -.. c"'>not b. "''"<>nably ascerta~ned, Please So indicate) ~ ~ 2Dd R";:~ B.U'''4 ~ho;'"V. 171 QJ. n,.",t. ll'~dA""l R...,,4 !1g.. &, r"^~ 5. Na...""" addr... of every other Person who ba. any "'cord lien on the property: Name 6. Name """ addre.. of eve" oth'r Pe"'on .... ba. any r'Cord int.r..t in tbe P~rt,""" ""0.. int.r..t "y be aU,cted by the sale: ....... 'if addre.. c"'>not be rea.Onably ascertained, Please So indicate) lioD.a Name Addro. 'if addr... c"'>not be rea.<>nably asceZained, Please So indicate) 2.0. Rn... ~~ .ca"H 011.... 170J.1 Cnmnsr1and C011rl~ D~t.. nf DamAg~i~ RRlatio g Puh1i... W..11'8... Poll Dltpt.. O~i1d s~~;; lhIf'ort'!'-t Bur_All t1~ _ 7. ress of every. <her person of whom. the Na~ aed ":' knOWI""", "" haa any intere.t 'n the pla~ntlff h a~ may be affetd by the sale: property t a ~~ ~..~ ~l1'A"'" Rl~. 2.0. Rn"'~~I; Ba""i..h,,~_ 'A 171Q.5 Rnnm 4]..2 Name Addre fif address cannot be reasOnably asce~ned, please So indicate) If.ona h t the statemelmade in this affidavit are true ' verify t a be.t of my ...., knowledge or information """ correct to t~r.tand that,. .tat....t. herein ar..... and beli.f. 'uncalti.. of 18 C.s. '4904 relating to uns"rn subject to.thet~eauthorities. falsificatlon September 12, 2001 ldOeck, Jr. r Plaintiff ~ C) C ~._: ;: " :n rRCr.: ,.,., 1'- -:;J Z:J. zc; 1:0 Ul.,. -<..; ~C 0'" ~("J 3..: .. --CI =-:} )::"C ;:::. ~ r. ~ 0:) -< GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS ofCwnberland County Plaintiff vs. CIVIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland. P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No.01-3220-CIVIL ORDER AND NOW, this ..,,. day of f'"~ ,2004, upon consideration of the petition of FIRST NATIONWIDE MORTGAGE CORPORATION to Amend Judgment and Motion to Make Rule Absolute, it is, ORDERED: That the Rule is hereby made absolute and the petition is granted and Plaintiff's judgment is hereby reassessed to $21,056.51, plus interest and costs. BY THE COURT: .1- (, - 6+ r~.) i'l/-lLLC.t ,(...115 . ~>CtV~ f. 1vk-~~-fk"~'1. [1 jCL~t L~ ~lJlJ"r.r 1\Is- Vl,j,.::.j\,:1/..3~,li .3r.1 I ,..,."..:; ~... ,." :" '"",Aln" ~"I'.... _, ' .......iIV SZ;f: !!d S- a3~ ~OOZ AkUlO:'JOH.!.OCd 341 :l0 3JI:I:IO-{]31I:J GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - MeUon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attornll)' for Ph.intiff FIRST NA TIONWlDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland Cowlty Plaintiff vs. CNIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE No.01-3220-CNIL Defendant(s) MOTION TO MAKE RULE ABSOLUTE AND NOW, this Plaintiff, FIRST NATIONWIDE MORTGAGE CORPORATION, moves to make a rule absolute for the foIlowing reasons: I. Plaintiff filed a Petition to Amend Judgment on DECEMBER 11.2003 (True and correct copy attached hereto). 2. A Rule was issued by the Court with a return date of 20 DAYS after service. 3. Plaintiff's Affidavit of Service is attached hereto. 4. No response to the Petition has been made. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg. MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CNIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cwnberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No.01-3220-CNIL AFFIDAVIT Gary E. McCafferty, Esquire.. subject to the penalties of 18 P.S. Section4904, deposes and says that he is the attorney for the within named PlaintilT and that all the facts set fort within the attached a Motion to Make Rule Absolute are true and correct to the best of his ~Wledg~/ nfonnation and belief. V i -~ Before me this ,r:'-~ day: Of J'illA.... .2004 .:qf~' Notary Public NOTARIAL SEAL Kathlern M. Lion. Notary Public Ci'Y of "hiiadclpb'k. Pbila. County My CddllniMidn BKpirt. M&t 14. 2004 I / Gary E. McCa SWORN TO AND SUBSCRIBED: GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 No.01-3220-CIVIL Defendant(s) AFFICA VIT OF SERVICE Gary E. McCafferty, Esquire., attorney for Plaintiff, being duly sworn according to law, hereby certifies that he did serve Defendants JAMES HOOVER and LINDA HOOVER, a copy of Plaintiffs Motion to Make Rule Absolute by first class mail on J NUARY 23, 2004 at 329 15th Street, New Cumberland, PA 1707 SWORN TO AND SUBSCRIBED: Before me this ,2 ') day: Of )7.. 1'- ,2004 cJ/ft I l-<.-rzjh r Notary Public NOTARlAL SEAL 11':..,;.f,lpcn "'1. ~Iorl' ~o~ry Public .. . .w....I"..:.adt:.t"L...1 tu1a.County .~ "mmiMian &.pires May 14.2004 GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Menon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JAl'vlES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COl\.fMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No.OI-3220-CIVIL CERTIFICATION OF SERVICE Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiffs Petition to Amend Judgment with RULE RETURNABLE date of twenty (20)days was mailed by first class mail, postage p HOOVER and LINDA"HOOVER at 329 1Sih Street, e fendant(s) JAMES nd, PA 17070 on December 19,2003 -fit... - , I GOLDBECK McCAFFERTY & McKEEVER A Professional Corporation Attornay's st Law SUITE SOOO MELLON INDEPENDENCE CENTER 701 Msrkat Straat PHILADELPHIA, PA 19106-1532 (215) 627-1322 fex (215) 627-7734 JOSEPH A GOLDBECK, JR. GARY E. McCAFFER1Y" MICHAEL T. McKEEVER' KRISTINA G. MURTHA' . 12 /19 /2003 JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs. JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed please find a copy of Plaintiffs Petition to Amend Judgment, the original of which has been duly filed of record with the Court. j AFFERTY GEM/mrw Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVER GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. A Professional Corporation Suite 5000 - Menon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 (215) 627-1322 FAJ{(215) 627-7734 JOSEPH A. GOLDBECK, JR. GARY E. McCAFFERTY MICHAEL T. McKEEVER December 19, 2003 PROTHONOTARY OF CUMBERLAND COUNTY Prothonotary of Cumberland County I Courthouse Square Carlisle, P A 17013 RE: JAMES HOOVER and LINDA HOOVER No: 01-3220-CIVIL To The Prothonotary: Enclosed herewith please find an original and a copy of Plain tift's CERTIFICATION OF SERVICE with regard to the above-referenced matter. Kindly file the same of record with the Court and return a time-stamped copy in the self-addressed stamped envelope enclosed herewith. Very truly yours, <:<::'J::TY GEM/mrw Enclosure GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 115-617-1312 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACfION - LAW P1aintitI ACfION OF MORTGAGE FORECLOSURE vs. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 No.0I-3220-CIVIL Defendant(s) RULE AND NOW. a rule is entered upon Defendant(s) to show cause why the relief requested in Plaintiff's Motion to Amend Judgment should not be granted. Rule returnable Kl~ liar ef ;..0 ~ Date:.oJ I' DJYYI L I\J ~j.{)()3 ~. J. ...-..... ~ GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - MeUon Independence Center 701 Market Street Philadelphia, PA 19106-1532 21~27-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cwnberland COWlty Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 No.01-3220-CIVIL Defendant(s) ORDER AND NOW, this day of , 2003, upon consideration of the Petition of FIRST NATIONWIDE MORTGAGE CORPORATION to Amend its Judgment, it is, ORDERED: That the petition is granted and Plaintiffs judgment is hereby amended to $21,056.51, plus interest and costs. BY THE COURT: J. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#41386 Suite 5000 - Menon Independence Center 701 Market Street Philadelphia, PA 19106-1531 115-617-1311 Attorney for Plaintiff 0 C) ~ c fA) ~ 0 ..-i "tlC'; rTl 'r miJ~ r'" f'ip z.,-" :;~::.q ZC. ~::; .'t ".. ) ,C -u :".-!-;-, :- ..~2pj ~., ~ . . - ;;h .~- 'n :a ~)I c.:. ~ 3 .&.- .... FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No.01-3220-CIVIL THIS IS 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. PLAINTIFF'S PETITION TO AMEND JUDGMENf AND NOW, this Plaintiff, FIRST NATIONWIDE MORTQAGE' CORPORATION, petitions the Court to Amend Judgment for the following reasons: 1. Plaintiffs Complaint in Mortgage Foreclosure was filed on May 25, 2001 . 2. On September 18, 2001, judgment in mortgage foreclosure was entered in favor of Plaintiff and against Defendants in the amount of$10,655.31, based upon the demand in Plaintiffs Complaint. (Copies of the Complaint and Judgment are attached hereto collectively as Appendix III) 3. On December 03, 2001 Defendants filed a petition in bankruptcy in the United States Bankruptcy Court for the Middle District of Pennsylvania (No. 01-06400) which stayed further prosecution of Plaintiff's action in mortgage foreclosure. 4. By order of United States Bankruptcy Court dated October 22, 2003 Plaintiff was granted relief from the automatic stay imposed by the Bankruptcy Code. 5. Since the filing of the Complaint, interest has been accruing as have the escrow balance deficit and late charges under the terms of the mortgage contract involved. 6. Due to the stay of proceedings, Plaintiff's judgment is now insufficient to satisfy the amounts due and owing on the mortgage and the mortgage lien on the property in question. 7. Upon disposition of this petition and the scheduling of a Sheriff's Sale on March 03, 2004, the amounts due and owing 011 the mortgage will be as follows: Principal Balance $7,635.80 Interest from 10/01/00 thru 03/o!/04 at 8.250% Per diem interest rate at Late Charges per Complaint $2, I 59.40 $1,250.00 $568.24 Attorney's Fee at 5.0000% of principal balance Costs of Suit and Title Search $750.00 Escrow Balance Deficit $8,693.07 TOTAL 521.056.51 WHEREFORE, Plaintiff prays that the Petition be granted and Plaintiff's Judgment be amended to $21,056.51, plus interest and costs. , Resp y,Esq. . . GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff \'s. CIVIL ACfION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACfl0N OF MORTGAGE FORECLOSURE Defendant(s) No.01-3220-CIVIL VERIFICATION Gary E. McCafferty, Esq., hereby states that he is the attorney for Petitioner within named and that all of the facts set forth within the attached Petition to Amend its Judgment are true and correct to the best of his knowledge, informa' n and b lief. The undersigned understands that the foregoing statements are made subject t , Esq. GOLD~CKM~A~RTI&McnEWR BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street PhIladelpbla, PA 19106-1532 1lS-6Z7-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN TIlE COURT OF COMMON PLEAS of Cumberland County CIVIL ACDON - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 No.0I-3220-CIVIL Defelldanl(s) MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S PETITION TO AMEND JUDGMENT Plaintiff is entitled to the amounts due and owing on the mortgage contract at the time of the Sheriff's Sale of property involved. For reasons stated in the within motion, Plaintiff's judgment in mortgage foreclosure is insufficient to compensate Plaintiff for the amount due and owing under the mortgage. Specifically, interest charges, the escrow balance deficit and late charges have all been accruing while Plaintiff's action in mortgage foreclosure was stayed by Defendant(s) bankruptcy petition. CONCLUSION For the reasons stated above and in the within petition, Plaintiff respectfully requests that the petition be granted and Plaintiffs judgment be amended to $21,056.51, plus interest and costs. I cctfferty, Esquire GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Snite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaindff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN TIlE COURT OF COMMON PLEAS of Cwnberland County Plaintiff CIVll. ACfION - LAW vs. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE No.OI-3220-CIVIL Defendant(s) CERTIFICATION OF SERVICE Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiffs Petition to Amend Judgment was mailed by first class mail, postage prepaid to Defendant(s) JAMES HOOVER and LINDA HOOVER at 329 15th Street, New Cumberland, PA 17070 on December 9,2003 GOLDBECK McCAFFERTY & McKEEVER A Professlonsl Corporation Attorney's st Law SUITE 5000 MELLON INDEPENDENCE CENTER 701 Markat Slreat PHILADELPHIA, PA 19108-1532 (215) 827-1322 fax (215) 627-7734 JOSEPH A. GOLDBECK, JR. GARY E. McCAFFER1Y* MICHAEL T. McKEEVER. KRISTINA G. MURnlA. I'J,. /01/2003 JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs. JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed please find a copy of Plaintiff's Petition to Amend Judgment, the original of which has been duly filed of record with the Court. Very truly yours, !:::::1~ -- GEM/mrw Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVER GOLDBECK McCAFFERTY & McKEEVER A Protelllonl' Corporltlon Attorney'1 It LIW SUITE 5000 MELLON INDEPENDENCE CENTER 701 Mlrket Street PHILADELPHIA, PA 19106-1532 (215) 627-1322 fax (215) 627-n34 JOSEPH A GOLDBECK, JR. GARY E. McCAFFERTY" MICHAEL T. McKEEVER" KRISTINA G. MURTHA. )J.. 1 0 9 12003 JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs. JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed please find a copy of Plaintiffs Petition to Amend Judgment, the original of which has been duly filed of record with the Court. ~ GARY E. McCAFFERTY GEM/mrw Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVER GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - MeHon Independence Center 701 Market Street PhJIadelphia, PA 19106-1532 115-617-1322 Attorney for PlaindfJ DEe 1 22003 ATTO"~1EY (~ ~ ~ :IJ.. ,.... '-:r'll COpy AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested in Plaintiff's Motion to Amend Judgment should not be granted. Rule returnable II,~ .b., llf l. O.~ FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Defe:l1dant(s) Date: ~'" ~ II. 1003 . IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No.01-3220-CIVIL RULE ~ J. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street PhUadelpbia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVH. ACTION - LAW VS. ACfION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cunlberland, P A 17070 No.0I-3220-CIVIL Defendant(s) ORDER AND NOW, this day of ,2003, upon consideration of the Petition of FIRST NATIONWIDE MORTGAGE CORPORATION to Amend its Judgment, it is, ORDERED: That the petition is granted and Plaintiff's judgment is hereby amended to $21,056.51, plus interest and costs. BY THE COURT: J. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - MeUon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff 0 Co ~ ~ W :'>- ,:;:, .__-1 -00' : ., n ifF .;") ",. : ...::~ S Z. " t 2~; . ~~ '<:\..} -"\..1 -'--"1 ~(~: ;!': .:~~ s>LI :f! :::'0 c: ~ - ~ s;- FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN TIlE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. CIVIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No.01-3220-CIVIL THIS IS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATIEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. PLAINTIFF'S PETITION TO AMEND JUDGMENT AND NOW. this Plaintiff, FIRST NATIONWIDE MORTQAGE. CORPORATION, petitions the Court to Amend Judgment for the following reasons: I. Plaintiffs Complaint in Mortgage Foreclosure was filed on May 25,2001 . 2. On September 18, 2001, judgment in mortgage foreclosure was entered in favor of Plaintiff and against Defendants in the amount of $1 0,655.31, based upon the demand in Plaintiffs Complaint. (Copies of the Complaint and Judgment are attached hereto collectively as Appendix III) 3. On December 03, 2001 Defendants filed a petition in bankruptcy in the United States Bankruptcy Court for the Middle District of Pennsylvania (No. 01-06400) which stayed further prosecution of Plaintiffs action in mortgage foreclosure. 4. By order of United States Bankruptcy Court dated October 22, 2003 Plaintiff was granted relief from the automatic stay imposed by the Bankruptcy Code. 5. Since the filing of the Complaint, interest has been accruing as have the escrow balance deficit and late charges under the tenns of the mortgage contract involved. 6. Due to the stay of proceedings, Plaintiffs judgment is now insufficient to satisfy the amowlts due and owing on the mortgage and the mortgage lien on the property in question. 7. Upon disposition of this petition and the scheduling of a Sheriffs Sale on March 03, 2004. the amounts due and owing on the mortgage will be as follows: Principal Balance $7,635.80 Interest from I 0/01/00 thru 03/o!/04 at 8.250% Per diem interest rate at Late Charges per Complaint $2,159.40 $1,250.00 $568.24 Attorney's Fee at 5.0000% of principal balance Costs of Suit and Title Search $750:00 Escrow Balance Deficit $8,693.07 TOTAL 521.056.51 WHEREFORE, Plaintiff prays that the Petition be granted and Plaintiffs Judgment be amended to $21,056.51, plus interest and costs. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - MeUon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, PA 17070 Defendant(s) VERIFICATION IN THE COURT OF COMMON PLEAS of Cumberland COIUlty CNIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No.01-3220-CNIL Gary E. McCafferty, Esq., hereby states that he is the attorney for Petitioner within named and that all of the facts set forth within the attached Petition to Amend its Judgment are true and correct to the best of his knowledge, inform a . nand b lief. The undersigned understands that the foregoing statements are made subject t Gary E. s 18 P.S. Section 4904. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 115-617-1322 Attorney for Plaintiff FmSTNATIO~EMORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-101\ Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cwnberland, P A 17070 No.01-3220-CIVIL Defendant(s) MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S PETITION TO AMEND JUDGMENT Plaintiff is entitled to the amounts due and owing on the mortgage contract at the time of the Sheriff's Sale of property involved. For reasons stated in the within motion, Plaintiff's judgment in mortgage foreclosure is insufficient to compensate Plaintiff for the amount due and owing under the mortgage. Specifically, interest charges, the escrow balance deficit and late charges have all been accruing while Plaintiff's action in mortgage foreclosure was stayed by Defendant(s) bankruptcy petition. CONCLUSION For the reasons stated above and in the within petition, Plaintiff respectfully requests that the petition be granted and Plaintiffs judgment be amended to $21,056.51, plus interest and costs. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney 1.0.#42386 Suite 5000 - Mellon Independence Center 701 Market Street PhDadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County PlaintitI CIVIL ACTION - LAW vs. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cwnberland, PA 17070 ArnON OF MORTGAGE FORECLOSURE No.01-3220-CIVIL Defendant(s) CERTIFICATION OF SERVICE Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiffs Petition to Amend Judgment was mailed by first class mail, postage prepaid to Defendant(s) JAMES HOOVER and LINDA HOOVER at 329 15th Street, New Cumberland, PA 17070. on December 9,2003 GOLDBECK McCAFFERTY & McKEEVER A Professional Corporation Attorney's at Law SUITE 5000 MELLON INDEPENDENCE CENTER 701 Markat Street PHILADELPHIA, PA 19106.1532 (215) 627-1322 fax (215) 627-7734 JOSEPH A. GOLDBECK, JR. GI<<f E. McCAFFERTY" MICHAEL T. McKEEVER. KRlsnNA G. MURTHA. I {)... lof 12003 JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs. JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed please find a copy of Plaintiffs Petition to Amend Judgment, the original of which has been duly filed of record with the Court. Very truly yours, 0..~- GEM/mrw Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVER . Goldbeck McCalreny & McKeeVfll' A PROFOSSIONALCORPORATlON JOSI!PH A. GowBl!CK.lR. GARy E. MCCAm!RTY. MICHABL T. McKEEvER. R8NEB M. PozzuoU-BUECKER. KiumNA G. MURlHA. lJ!suE E. PumA. I.JsA A. 0' ANOEU. AlTORNEY'S AT LAw SI!Nl1lY omca Pl.<zA SlJII'I!420 216 HADDON AVENUB WBSTMONr, NJ 08108 (856) 858-3242 FAX (856) 858-2997 .PA&NJBAR SlJII'I! SOOO MEl.LON INDEPI!NIlENCl! CEr<rER 701 MARKET S'l1U!IIT PHIlADWHIA, PENNsYLVANIA 19]06- 1532 (215) 627-1322 FAX (215) 627-7734 PI.tiAsI! KEPI. Y TO TIlE PHIlADEI.PIIIA OFFICE WW.GOLOBECKLAW.COM January 12, 2004 Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs. JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear Sirs: Enclosed herewith please find an original and a copy of Plaintiff's Motion to .m~ke Rule Absolute with regard to the above-referenced matter. Kindly file the same of record with the Court and return.!" time-stamped copy in the self-addressed stamped envelope enclosed herewith. Very truly yours, ~~~ GEM/mrw Enclosures Goldbeck McCatrlllty & McKeever A PRoFESSIONAL CORPORA'I1OIl lOOEPH A. Om.oBECK, lR. GARy E. MCCAmlaTY. MICHABL T. McKI!I!vER. Ri!NIm M. PozzUOu-BUI!CKEl!.. KRlmNAG. MURl1IA. lJ!sLD! E. PUlDA. lJsA A. D' ANGBU. ATrOJlNI!Y's AT lAw SllNI1!.y ClmcI! Pl.'.ZA Sum; 420 2]611ADDON AYI!N\JI! WBnMoNT, Nl 08108 (856) 858-3242 FAX (856) 858-2997 .PA & Nl BAR SUITe 5000 MBu.oN INDBPENDI!NCB Cl!Nn!R 701 MARRE'rS11lI!IIT PHD.ADI!I.I'HIA, Pl!NNsYLVANIA ]9106- 1532 (215) 627-1322 FAX(215) 627-7734 PLEASB RBPL y TO TIlE PHILADELPHIA OFFICE WW.GOLDBECKLAW.COM January 12, 2004 Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs. JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear Sirs: Enclosed herewith please find an original and a copy of Plaintiff's Motion to make Rule Absolute with regard to the above-referenced matter. Kindly file the same of record with the Court and return a time-.stamped copy in e self-addressed stamped envelope enclosed herewith. .. GEM/mrw Enclosures Cc: JAMES HOOVER & LINDA HOOVER 329 15th Street New Cumberland, PA 17070 . First Nationwide Mortgage Corporation VS James Hoover and Linda Hoover In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3220 Civil Tenn R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Joseph Goldbeck. Sheriffs Costs: Docketing Poundage Advertising Posting Handbills Levy Surcharge Service Law Journal Patriot News Law Library Prothonotary Share of Bills 30.00 11.25 15.00 15.00 15.00 30.00 23.46 209.60 194.05 1.00 29.32 $ 573.68 paid by attorney 03/01/04 Sworn and subscribed to before me So Answers: This ol....-<.dayof~ .?"""""'~1l-l'~ ( ..--) . R. Thomas Kline, Sheriff 2004, A.D. '--1'-,_. 0 huU-,v. #' BY \/~ _ ~ Prothonotary Real ~eputy ,,,-v . ~<f<i'"Jr e.v. l'tflf'f Goldbeck McCafferty & McKeever . BY: Joseph A. Goldbeck. Jr. Attorney 1.0. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Anomey for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintill" vs. CIVIL ACTION - LAW JAl'vIES HOOVER LINDA HOOVER (Mortgagor(s) and Record Owner(s)) 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 01-3220-CIVIL AFFIDAVIT PURSUANT TO RULE 31Z9 FIRST NATIONWIDE MORTGAGE CORPORATION. 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 propeny located at: 329 15th Street New Cumberland, P A 17070 I.Name and address ofOwner(s) or Reputed Owner(s): JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cwnberland, P A 17070 2. Name and address of Defendant(s) in the judgment: JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 ~ OI-3220-C'IVIL 2. You may be able 10 stop Ihe sale by tiling a pelition asking lhe CoUrlto strike or open judgment. if the judgment was improperly entered. You may also ask lhe Court tll postpone the sale for good cause. 3. You lIIay also be able 10 Slop Ihe sale through olher legal proceedings. You may need an attorney [0 assert your rights. The Sooner you COlllact one. the mure chance you will have of slopping Ihe sale. (See notice below on how 10 oblain an attorney). YOU MAY STILL BE ABLE TO SA '.E YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. Iflhe Sherill's Sale is nol slopped. your property will be sold to the highest bidder. You lIIay find oUlthe price bid price by calling lhe Sheriff of 717-240-6390. 2. You may be able to pelilion the Court lu sel aside the sale if the bid price was grossly inadequate compared 10 lhe value of your property. 3. The sale will go through only if the buyer pays the Sherifflhe full amount due in the sale. To find oul iflhis has happened. you maycalllhe Sheriffof717-240-6390. 4. If lhe Wllounl due from the Buyer is not paid 10 Ihe Sherilf, you will remain the o"'ner of the property as if lhe sale never happened. 5. You have a right 10 remain in the property until the full amount due is paid 10 the Sheriff and the Sheriff gives a deed to the buyer. At that time. lhe 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 thirty (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 ofdislribution is filed. 7. You may also have olher righlS and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND our WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES lNC 8 Irvine Row Carlisle. P A ] 70 13 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 01 _3220-ClV1L GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A.. Goldbeck. Jr. A.\lomev \.D.#16 132 Suite 5lioo- Mellon Independence Center 701 Market Street Philadelphia. P'" \ q \ 06 2 \ 5-h27- \ 322 Atlomey for Plainti!" FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-101 I Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record owner(s) Term No.01-3220-ClVIL 329 15th Street New Cumberland, PAl 7070 Defendant(s THIS LAW FlRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE llSED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HOOVER. LINDA LINDA HOOVI!R 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street. New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03,2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$10,655.31 obtained by FJRST NATIONWIDE MORTGAGE CORPORATION against you. N~E ~F OWNER'S RIGHTS YOU MAY BE T p~VENT TIllS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to FIRST NA TIONWlDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 OI-3220-C'IVIL 2. You may he able to stop the sale by filing a petition asking the Cuun to slrike or open judgment, if the judgment was improperly emered. You may also ask the Court 10 postpone the sale tl>r good calise. 3. You may also be able 10 ",01' the sale Ihrough other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one. the more chance YllU will have of slopping the sale. (See notice below on how to oblain an altomey). YOU MAY STILL BE ABLE TO SA VE YOUR PROPERTY AND YOU HA \"E OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped. your propeny will be sold to Ihe highest bidder. You may lind out the price bid price by calling the SherilT of 717-240-6390. 2. You may be able to pelilion the Coun to sel aside the sale if the bid price was grossly inadequale compared to Ihe value of your propeMy. 3. The sale ",ill go Ihrough only iflhe buyer pays the Sheriff the full amount due in the sale. To find out iflhis has happened, you may call the Sheriffof717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the propeny as if the sale never happened. 5. You ha\", a right to remain in the propeny until the full amount due is paid to the Sheriff and the SherilT 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 thiny (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 with the Sheriff within ten (10) days after the schedule of distribulion is filed. 7. You may also have other rights and defenses, or ways ofgeUing your house back, if you act immediately after the sale. YOU SHOULD TAKE TIllS PAPER TO YOUR LA WYER 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PAl 70 13 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Libeny Avenue Carlisle, PAl 70 13 GO~DBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF Pirst Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, Me 20898-9481 Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, Me 20906 CUMBERLAND COUN'l'Y : COURT OP COMMoN PLEAS CIVIL DIVISION : NO 01-3220-Civil James Hoover (Real Owner only) Linda Hoover (Real Owner only) 329 15th Street New Cumberland, PA 17070 ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot number 31 Section E plan of Hillside as recorded in the Cumberland County Recorder'S Office in Plan Book 1, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3220 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORPORA nON, Plaintiff (s) From JAMES HOOVER AND LINDA HOOVER (I) 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 tbe garnishee(s) that: (a) an attachment bas 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) [fproperty 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 himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due 510,655.31 Interest FROM 9/12/01 AT 0.0100% L.L. Atty's Corom % Any Paid 5897.72 Plaintiff Paid Date: NOVEMBER 19, 2003 Due Prothy 51.00 Other Costs (Seal) CURTIS R. LONG Protho7J ~ ~: n.,D P 'P4J9'_/ Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 -MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme CourtlD No. 16132 Real Estate Sale # 45 On December 01,2003 the sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, P A Known and numbered as 329 15th Street, New Cumberland, more fully described on Exhibit "A" filed Date: December 01, 2003 By: JtJ.du SnU. t~ Real E~t~t'Deputy r--l CV\I CV\I ==- <:W &tiN with this writ and by this reference incorporated herein. ..J I'': '1 I."' ~"~.' ~ ~ "; 1 . I' . '. I' -. ~~, \I~ 1Z II 6\ AON lJl~.1 ~ . ,.1",,; :JJn:~3!1~: . .i.' ;:JJG THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ad No. 587, AppllMld May 16, 1929 Commonwealth of Pennsylvenia, County of Dauphin} sa Michael Morrow, being duly sworn according to law, deposes and says: That he is the 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 The Patriot-News and...Ibi Sundav Patriot-News newspapers of general circulation, printed and publiShed at 812 to 818 Market Street, In the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto Is exactly as printed and publiShed In their regular daily and/or Sundayl Metro editions which appeared on the 20th and 27th day(s) of January and the 3rd day(s} of February 2004. 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 u hin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy SALE #45 ........................... NOTARY PUBLIC Sworn to and subscribed be RIAL ISTATI! BALI No. 41 WrIt No. ZCIO'I4220 CIvIl...... F1... .....Dnwlde M<lo t>"v." Corp. ...... H__ LIncIIIlcIcMr Ally: .......", GDIcIboc:k DISCRIPIlON Notarial Seal Tony L Russell, ~~... 0Iy 01 Hanisburg. Dal4Jhin -'r lIP( Q.mrIIsoion elCjll'. June e. 2OlI8 "" _~CI__ My commission sxpires June 6, 2006 MImbIr. ,..,. CUMBERlAND OOUNTY SHERIFFS OFRCE CUMBERLAND OOUNTY OOUR11-fOUSE CARLISLE, PA. 17013 AU. 11/AT CERrAIN I... II" DIet of IIIId ...... in !be IIanJuah or New CUmberImI, CaunIJ ofCUmblrtllldllld SIIIe or _ylvonl~ ....pIIlil:ulllllybouadodllld_.. rull... _I\I! lD I 11IM)' or D.P. RaJr_(4'J-l9)_M""'4.I!I74.lD wit: . B~.lpainllII!be1lcinlBn1ide ~,'t'!C~""'~r::.-:.-:: 'ublisher's ReceIpt for AdvertisIng Cost "'C"'WIir.".'_r;: ~ublisher of The Patriot-News and The Sundav Patriot-News. newspapers of general CI '- ~:: = JO~ ,. ireceipt of the aforesaid notice and publication costs and certifies that the same have bl WlirI15feetlDlpoiDIl"""",_ f2 ...... .. 1O feet lD I poiDI I """'" tIIia ........ rhmll"" InI number 31 on aid pllIl Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 194.05 By.................................................................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.I784 STATEOFPENNSYLVANIA : COUNTY OF CUMBERLAND : ss. 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 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: JANUARY 16,23,30,2004 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 BSTATB 8ALI!: NO. 45 (', ' C"i.J .~/y , ~'- fiA- ~ (}sa Marie Coyn . Editor SWORN TO AND SUBSCRIBED before me this 30 day of JANUARY 2004 Writ No. 2001-3220 eMI Ffrst NationWide- Mortgage Corp. vs. James Hoover and Linda HoO\'er Atty.: Joseph Goldbeck ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland. County of Cum- berland and State oC PennsylvanJa. more particularly bounded and de- scribed as follows according to a survey oC D.P. Raffensperger 149-29) dated March 4. 1974. to Wit: B~GINNING at a point on the Northern side of 15th Street saJd pOint being 870.8 feet west of Bridge Street: thence extending along 15th St=t South 62 degrees West 50 feet to a corner of lot num- ber 30 on the he-refnafte-r nlf'ntloneod plan of lots: thence along lot num- ~r. 30 north.2B degrees West 195 -~ - - -----. ~'"'~-~... SEAL LOIS E. SNYDER, Notary Public CarlIsle Boro. Cumberland County My Commission Expires Man:h 5, 2005 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) 329 15th Street New Cumberland, P A 17070 Defendant( s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 01-3220-CIVIL TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount Due Interest from to 09/12/2001 at 0.0100% (Costs to be added) $21.056.51 5 ~ ~ 0 Ij ~ ~ 8 ~ I'l ~'$ ~ ;;>'$ 0 ti 0 \-" ,;, 'u p4 " B~ 0 QiA~ ;<. 'i-"'(,.""t ~ oo~ 8 ~o ~ u 0 ~ ;:: \-" :i ~ \-" ~ ..... I'-> cn tr 0 :a': \5 'd-a cr: :(., ~6o 0'6: ~1 'B ~ '7;; t 0 '" S .0 b t,:. ~r;;.-o~4. P4'- "... <l> p..; 1'l~%IJ,~ ;;>oO!.-6~ ~;r.-om'i3 tc.4.~;~ rJlQ'd;.M~ 1J..l'~~~u '5...J ~ 3 ~ " Q ~ ~ h o b 9 ~ ;;;;x:. <P I -..-: ~ 'is ~ O~ ;~) -:t" . ) ,-?' ,..~~ -;,.( .~:~, . ;'~:~:~ i~ ,co'> o ~ 9 \-" ;;; u.., ~'a \oil~ \><'<l o " 'Q ~: ~~ \><'$ \oil \ ~ v~ ~~ ~ c- () {) C ~ . 0- \.t1 r<'l - 'i::>,. '::. .:::: ':; . . - . :. ::: :: '" :: :: -:: :: ~ ~ ~ 'is ~ u c-' " '" .~ g if) >:.--~ ---; uO:....-..o """9.QOM ~""'<U'-;N Q6 g.~~~ ~~'O<<:~ ~.-.~p..;-.o ~gi~.;., ~~-$rC; "",<.OQ ~\r-~ ~o 1. "0 p.. ~~ <2Q \,;l"" OJ, :. .. - :: :)'J~.c ^ 'Q" ~ ~ % <) 0 ~. ) ^ ^ ~ ::rrl 0 rl ..!. vi \i- v:. \,) ~ c... -J-J () . ~ <"'i:r - ::t' q C" j t ~ ('( ~ _ ..J ....., - ...!l - 1 J -1 I' a u rl~ G- 0-- Q '.::l- 0-- -..! (\ - .(J Cl - ~ "1\ t -;;.t.( ':J 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 First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO 01-3220-Civil James Hoover (Real OWner only) Linda Hoover (Real OWner only) 329 15th Street New Cumberland, PA 17070 ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot number 31 Section E plan of Hillside as recorded in the CUmberland County Recorder's Office in Plan Book 1, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3220 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff(s) From JAMES HOOVER AND LINDA HOOVER (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 gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $21, 056.51 Interest FROM 9/12/01 AT 0.0100% L.L. Atty's Comm % Due Prothy $1.00 Other Costs Ally Paid $1486.40 Plaintiff Paid Date: JUNE 8, 2005 (Seal) CURTIS R. LONG Prothonotary p ~ ~: 4~ . 'i?/kL~ Deputy REQUESTING PARTY; Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ill No. 16132 USBC PAM - LIVE - V2.6 - Docket Report Page 1 of8 CREDS, CLAIMS, 2002, 34lHeld U.S. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:04-bk-00933-MDF Assigned to: Mary D France Chapter 7 Previous chapter 13 Voluntary No asset Date Filed: 02/1812004 Date Converted: 01113/2005 Date Discharged: 05/04/2005 James C Hoover 329 15th Street New Cumberland, P A 17070 SSN: xxx-xx-4306 Debtor represented by James M Bach 352 South Sporting Hill Road Mechanicsburg, P A 17050 717737-2033 Fax: 717 737-4220 Email: jamesbach@comcast.net Linda L Hoover 329 15th Street New Cumberland, PA 17070 SSN: xxx-xx-4701 Joint Debtor Leon P. Haller (Trustee) Purcell, Krug and Haller 1719 North Front Street Harrisburg, P A 17102 717234-4178 Trustee represented by James M Bach (See above for address) represented by Leon P Haller Purcell Krug and Haller 1719 North Front Street Harrisburg, PA 17102-2392 717234-4178 Fax: 717 233-1149 Email: Ihaller@pkh.com Charles J. DeHart, III (Trustee) POBox 410 Hummelstown, PA 17036 717 566-6097 TERMINATED: OI/I4/2005 Former Trustee United States Trustee PO Box 969 Harrisburg, PAl 71 08 (717) 221-4515 Asst ns. Trustee I Filing Date # Docket Text httDs://ecf.pamb.uscourts.gov/cgi-binfDktRpt.pl?791 020500472871-L _ 82_0-1 6/6/2005 USBC PAM - LIVE - V2.6 - Docket Report Page 2 of8 02/18/2004 t Chapter 13 Voluntary Petition. Filing fee due in the amount of$ 194.00 Filed by James M Bach on behalf of James C Hoover, Linda L Hoover. (DD) (Entered: 02/18/2004) 02/18/2004 2 Matrix filed/Creditor List Uploaded Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)I ). (DD) (Entered: 02/18/2004) 02/1812004 3 Chapter 13 Plan Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)l ). (DD) (Entered: 02/18/2004) 02/18/2004 4 Motion for Wage Attachment Order Filed by James M Bach on behalf of James C Hoover, Linda L Hoover. (DD) (Entered: 02/18/2004) 02/18/2004 5 Order Granting Motion for Wage Attachment Order (RE: related document(s)[4] ). (DD) (Entered: 02/18/2004) 02/1812004 Receipt of Voluntary Petition Filing Fee. Receipt Number 605387 Fee Amount $ 194.00 (RE: related document(s)I ). (DD) (Entered: 02/1912004) 02/18/2004 Tentative Date for Meeting of Creditors. THIS IS SUBJECT TO CHANGE. 4/8/2004 at 09:00 AM. (DD) (Entered: 02/19/2004) 03/02/2004 6 Request for Notice under 2002 Filed by Alice Whitten on behalf of AmeriCredit. (RCP) (Entered: 03/02/2004) 03/03/2004 Z Request to BNC - Meeting of Creditors. 341(a) meeting to be held on 4/8/2004 at 10:00 AM Federal B1dg, Trustee Hearing Rm, Rm 1160, II th F1, 228 Walnut St, Harrisburg, P A Proofs of Claims due by 7/7/2004 Last day to Object to Plan Confirmation 8/6/2004 (DP) (Entered: 03/0312004) 03/05/2004 8 BNC Certificate of Mailing. Service Date 03/05/2004. (Related Doc # 7) (Admin.) (Entered: 03/06/2004) 03/0512004 9 BNC Certificate of Mailing. Service Date 03/05/2004. (Related Doc # 7) (Admin.) (Entered: 03/06/2004) 04/15/2004 10 Certification that 341 Meeting of Creditors Held (Ch. 13) on 04/08/04. (There is no image or paper document associated with this entry.). (dehart, IlI(ds), Charles) (Entered: 04/15/2004) 07/19/2004 1J Objection to Confirmation of Plan (Plall is ullderfimded) Filed by Trustee (RE: related document(s)3 ). (dehart, III(jr), Charles) httns://ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl?791 020500472871-L_ 82 _ 0-1 6/6/2005 USBC PAM - LIVE - V2.6 - Docket Report Page 3 of 8 (Entered: 07/19/2004) 08/20/2004 12 Objection to Confirmation of Plan Filed by Leslie Puida of Goldbeck McCafferty and McKeever on behalf of First Nationwide Mortgage Corporation (RE: related document(s)JJ). (CR) (Entered: 08/20/2004) 08/20/2004 13 Notice to Parties: (RE: related document(s)[12] ). Hearing scheduled for 9/28/2004 at 09:00 AM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (Attachments: # 1 Certificate of Service) (CR) (Entered: 08/20/2004) 09/23/2004 14 Amended Chapter 13 Plan and notice to all creditors of objection date Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)l, 3 ). Last day to Object to Plan Confirmation 10/22/2004. (NP) (Entered: 09/24/2004) 09/23/2004 IS Motion for Amended Wage Attachment Order Filed by James M Bach on behalf of Linda L Hoover (RE: related document(s)[ 4], [5]). (DP) (Entered: 09/24/2004) 09/26/2004 16 BNC Certificate of Mailing. (RE: related document(s)14 ). Service Date 09/26/2004. (Admin.) (Entered: 09/27/2004) 09/26/2004 11 BNC Certificate of Mailing. (RE: related document(s)H). Service Date 09/26/2004. (Admin.) (Entered: 09/27/2004) 09/27/2004 18 Amended Order Granting Motion for Amended Wage Attachment Order (RE: related document(s)[15]). (Attachments: # 1 Certificate of Service) (DP) (Entered: 09/27/2004) 09/28/2004 19 Proceeding Memo: Hearing not held. Creditor appeared to inform the Court that Debtor's most recent Amended Plan filed 9/23/04 does not address their objection. (RE: related document(s)[12], 13 ). (JG) (Entered: 09/28/2004) 09/29/2004 20 Praecipe/Withdrawal of Trustee's Objection to Confirmation of Plan Filed by Trustee (RE: related document(s)JJ ). (dehart, llIUr), Charles) (Entered: 09/29/2004) 10/06/2004 21 Objection to Confirmation of Plan Filed by Leslie E Puida of Goldbeck McCafferty and McKeever on behalf of First Nationwide Mortgage Corporation (RE: related document(s)11). (CR) (Entered: 10/06/2004) 10/06/2004 22 Notice to Parties: (RE: related document(s)2l). Hearing scheduled for 11/9/2004 at 09:00 AM at 3rd & Walnut Streets, Bankruptcy https://ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl?791 0205004 72871-L. 82 _0-1 6/6/2005 USBC PAM - LIVE - V2.6 - Docket Report Page 4 of8 Courtroom (3rd Floor), Federal Building, Harrisburg, P A. (Attachments: # 1 Certificate of Service) (CR) (Entered: 10/06/2004) 11/08/2004 23 Amended Objection to Confirmation of Plan Filed by Leslie E Puida of Goldbeck McCafferty and McKeever on behalf of First Nationwide Mortgage Corporation (RE: related document(s)21, 14). (Attachments: # 1 Amended Plan# :1. Proof of Claim# :2 Certificate of Service)(Puida, Leslie) (Entered: 11/0812004) 11109/2004 24 Proceeding Memo: Hearing held. Objection sustained. Plan does not provide for adequate funding. Court to prepare Order giving Attorney Bach 30 days to file legal memorandum as to why language in paragraph 13 of proposed plan should be stricken. (RE: related document(s)22, 2J). (JG) (Entered: 11/09/2004) 11/15/2004 28 Order Sustaining Objection to Confirmation of Amended Chapter 13 Plan and Ordering Debtors' Counsel to file Legal Memorandum (RE: related document(s)24, 21 ). (Attachments: # 1 Certificate of Service) (CR) (Entered: 11118/2004) 11/17/2004 25 Second Amended Chapter 13 Plan Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)14 ). (Bach, James) (Entered: 11/17/2004) 11/17/2004 26 Motion for Wage Attachment Order (Amended-2nd) Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)lS ). (Attachments: # I Proposed Order) (Bach, James) (Entered: 11/17/2004) 11/18/2004 27 Request to BNC - Notice re: Amended Ch. 13 Plan (RE: related document(s)l4, 25 ). Last day to Object to Plan Confirmation 12/16/2004. (CR) (Entered: 11/18/2004) 11/20/2004 29 BNC Certificate of Mailing. (RE: related document(s)27 ). Service Date 11/2012004. (Admin.) (Entered: 11/21/2004) 11/20/2004 30 BNC Certificate of Mailing. (RE: related document(s)27). Service Date 11/20/2004. (Admin.) (Entered: 11/21/2004) 11/2212004 31 Order Granting Motion for Second Amended Wage Attachment Order (RE: related document(s)26). (Attachments: # 1 Certificate of Service) (DP) (Entered: 11/22/2004) 11/30/2004 32 Memorandum Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)28). (Bach, James) Additional attachment(s) added on 12/1/2004 (NP). (Entered: 11/30/2004) https://ecf.pamb.uscourts.gov/cgi-binlDktRpt.pl?791 0205004 72871-L _ 82 0-1 6/6/2005 USBC PAM - LIVE - V2.6 - Docket Report Page 5 of8 11/30/2004 33 Corrective Entry: previous attachment omitted/incorrect/incomplete Omitted Exhibit A Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)32). (Bach, James) (Entered: 11/30/2004) 11/30/2004 34 Motion for Relief from Stay. Filing fee due in the amount of $ 150.00 Filed by Jay B Jones of Federman and Phelan LLP on behalf of Waypoint Bank as Servicer for the Mortgagee of Record. (Attachments: # 1 Proposed Order) (Jones, Jay) (Entered: 11/30/2004) 11/30/2004 35 Entry of Appearance Filed by Jay B Jones of Federman and Phelan LLP on behalf of Waypoint Bank as Servicer for the Mortgagee of Record. (Jones, Jay) (Entered: 11/30/2004) 11/30/2004 36 Certificate of Service for the Entry of Appearance Filed by Jay B Jones of Federman and Phelan LLP on behalf ofWaypoint Bank as Servicer for the Mortgagee of Record (RE: related document(s)35). (Jones, Jay) (Entered: 11/30/2004) 12/01/2004 Receipt of Motion for Relief From Stay(1 :04-bk-00933-MDF) [motion,mrlfsty] ( 150.00) filing fee. Receipt number 774913, amount $ 150.00. (U.S. Treasury) (Entered: 12/01/2004) 12/01/2004 37 Order (RE: related document(s}34 ). Answers are due on: 12/16/2004. Hearing scheduled for 12/22/2004 at 09:00 AM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (CR) (Entered: 12/01/2004) 12/02/2004 38 Certificate of Service for the Motionfor Relieffrom Stay and the Order Setting Hearing on the Motion Filed by Jay B Jones of Federman and Phelan LLP on behalfofWaypoint Bank as Servicer for the Mortgagee of Record (RE: related document(s)37, 34). (Jones, Jay) (Entered: 12/02/2004) 12/06/2004 39 Returned mail for Creditor (The Associates), Undeliverable as addressed (RE: related document(s)25 ). (CR) (Entered: 12/06/2004) 12/06/2004 40 Answer Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)3A ). (Bach, James) Additional attachment(s) added on 12/8/2004 (BW). (Entered: 12/06/2004) 12/07/2004 41 Notice to Filing Party: **The document attached was not signed or dated. Please docket a Corrective Entry (missing/incorrect/incomplete attachment) and upload the correct document (Answer to Motionfor Relieffrom Automatic Stay not signed) **. (RE: related document(s) 40). (NP) (Entered: 12/07/2004) https:/ /ecfpamb.uscourts.gov/cgi-bin/DktRpt.pl?791 020500472871-L _ 82 0-1 6/6/2005 USBC PAM - LIVE - V2.6 - Docket Report Page 6 of8 12/07/2004 42 Corrective Entry: previous attachment omitted/incorrect/incomplete Omitted Attorney Signatures Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)40 ). (Bach, James) (Entered: 12/07/2004) 12/22/2004 43 Proceeding Memo hearing cancelled. Stipulation to be filed. Order to be entered. (There is no image or paper document associated with this entry.) (RE: related document(s}37, 34 ). Stipulation due 1/22/2005. (JG) (Entered: 12/27/2004) 12/27/2004 44 Order that Stipulation be filed on or before January 22, 2005 or Motion is denied. (RE: related document(s)34). Stipulation due 1/22/2005. (Attachments: # 1 Certificate of Service) (CG) (Entered: 12/29/2004) 01/10/2005 45 Motion to terminate wage attachment Filed by James M Bach on behalf of Linda L Hoover (RE: related document(s)31 ). (Attachments: # 1 Proposed Order) (Bach, James) (Entered: 01/10/2005) 01/12/2005 46 Order Granting Motion to terminate wage attachment (RE: related document(s)45). (Attachments: # 1 Certificate of Service) (OP) (Entered: 01/12/2005) 01/13/2005 47 Praecipe to Convert (Absolute Right) from Chapter 13 to Chapter 7. Filing fee due in the amount of$ 15.00 Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s) 1 ). (Attachments: # I Statement oflntention, Amended J, Verification Statement) (Bach, James) (Entered: 01/13/2005) 01/13/2005 Receipt of Praecipe to Convert from Ch. 13 to Ch. 7 (Absolute Right) (1:04-bk-00933-MDF) [misc,abscnv7] ( 15.00) filing fee. Receipt number 835636, amount $ 15.00. (U.S. Treasury) (Entered: 01/13/2005) 01/14/2005 48 Notice to Filing Party: ** Please docket the Statement of Intention and Amendment to Schedule J (which were filed as part of the conversion) as separate events **. (RE: related document(s)42 ). (OP) (Entered: 01/14/2005) 01/14/2005 49 Statement oflntentions Filed by James M Bach on behalf of James C Hoover, Linda L Hoover. (Bach, James) (Entered: 01/14/2005) 01/14/2005 50 Amendment to Schedule J Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)L). (Bach, James) (Entered: 01/14/2005) https:!/ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl?791 02050047287] -L 82_0-1 6/6/2005 USBC PAM - LIVE - V2.6 - Docket Report Page 7 of8 01118/2005 Trustee Leon P. Haller (Trustee) added to case.. (There is no image or paper document associated with this entry.) Filed by United States Trustee. (united states trustee(wp),) (Entered: 01/18/2005) 01118/2005 Tentative Date for Meeting of Creditors. THIS IS SUBJECT TO CHANGE. 2/28/2005 at 08:30 AM. (AG) (Entered: 01119/2005) 01/26/2005 51 Stipulation in Settlement of the Motion for Relieffrom Stay Filed by Jay B Jones of Phelan Hallinan & Schmieg, LLP on behalf of Waypoint Bank as Servicer for the Mortgagee of Record (RE: related document(s)34). (Attachments: # 1 Proposed Order) (Jones, Jay) (Entered: 01/26/2005) 01/27/2005 52 Order approving Stipulation (RE: related document(s)[43], 34, 51). (CR) (Entered: 01/28/2005) 01/31/2005 53 Request to BNC - Meeting of Creditors . 341(a) meeting to be held on 2/28/2005 at 09:30 AM Federal Bldg, Trustee Hearing Rm, Rm 1160, 11th Fl, 228 Walnut St, Harrisburg, PA Last day to oppose discharge or dischargeability is 4/29/2005 (AG) (Entered: 0113112005) 02/02/2005 54 BNC Certificate of Mailing. (RE: related document(s)53 ), Service Date 02/02/2005, (Admin.) (Entered: 02/03/2005) 02/0912005 5~ Request for Notice under 2002 Filed by Alice Whitten on behalf of AmeriCredit (DP) (Entered: 02/09/2005) 03/0112005 56 Certification that 341 Meeting of Creditors Held (Ch, 7) on 2/28/2005. (There is no image or paper document associated with this entry.). (haller(bp), Leon) (Entered: 03/01/2005) 03/16/2005 57 Final Report Filed by Trustee. (dehart, III(ck), Charles) (Entered: 03/16/2005) 04/04/2005 5& Application to appoint himselflherself or their law firm as Attorney Filed by Trustee. (Attachments: # I Exhibit # 2 Declaration of Attorney# 3 Proposed Order # 4. Certificate of Service )(haller(bp), Leon) (Entered: 04/04/2005) 04/18/2005 59 Application to Employ Realty Services Group, Inc. as Realtor Filed by Trustee, (Attachments: # 1 Verification# ~ Declaration of Real Estate Agent# 3 Proposed Order # 4 Certificate of Service) (hailer (bp), Leon) (Entered: 04/18/2005) 04/19/2005 60 Order Granting Application of Trustee to appoint self as Attorney (RE: related document(s)58.). (CK) (Entered: 04/19/2005) https://ecf.pamb.uscourts.gov/cgi-bin/DktRptpl?791 020500472871-L _82 _0-1 6/6/2005 USBC PAM - LIVE - V2.6 - Docket Report Page 8 of8 04/28/2005 61 Order Granting Application to Employ Realty Services Group (RE: related document(s)59 ). (CK) (Entered: 04/28/2005) 05/04/2005 62 Request to BNC - Discharge ofDebtor(s) (Admin.) (Entered: 05/04/2005) 05/06/2005 63 BNC Certificate of Mailing of Discharge (Chapter 7) (RE: related document(s)62 ). Service Date 05/06/2005. (Admin.) (Entered: 05/07/2005) 05/1 1/2005 64 Request to BNC - Final Decree VACATED by Order dated 5/20/05. (CK) Modified on 5/20/2005 (DP). (Entered: 05/11/2005) 051\3/2005 65 BNC Certificate of Mailing of Final Decree (RE: related document(s) (4). Service Date 05/13/2005. (Admin.) (Entered: 05/14/2005) OS/20/2005 66 Order Vacating Final Decree (RE: related document(s)64 ). (CK) (Entered: OS/20/2005) I PACER Service Center I I Transaction Receipt I I 06/06/2005 14:27:04 I PACER ~a0060 I Client Login: Code: I :04-bk-00933-MDF Fil or Ent: Description: Docket Search Fil Doc From: 0 Doc To: Report Criteria: 99999999 Tenn: y Links: n Fonnat: HTMLfmt Billable D81032 I Pages: https://ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl?791 020500472871-L _ 82 _0-1 6/6/2005 4 ~oldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney 1.D. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORA T10N PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW JAMES HOOVER LINDA HOOVER (Mortgagor(s) and Record Owner(s)) 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORPORATION, 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 at: 329 15th Street New Cumberland, P A 17070 I.N ame and address of Owner( s) or Reputed Owner( s): JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 2. Name and address ofDefendant(s) in the judgment: JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 3> Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 ~ , Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 GREENWOOD TRUST CO. P.O. BOX 11848 HARRISBURG, PA 17108 BELCO COMM. CREDIT UNION 403 N. 2ND STREET HARRISBURG, PA 17101-1322 SOVEREIGN BANK c/o HEATHER A. SOLLEY 601 Penn Street Reading, P A 19601 WAYPOINTBANK 23 5 North 2nd Street P.O. Box 1711 Harrisburg, P A 170 II 4. Name and address of the last recorded holder of every mortgage of record: FIRST FEDERAL SAVINGS & LOAN 234 N. SECOND STREET HARRISBURG, PA 17101 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 whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 329 15th Street New Cumberland, P A 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: June 6.2005 (") <::: riJ{;"; ,,::: f} ~ c .-' ~:(::j ~c --j. ~:~ -( , '- .... = = OJ"> L. c:: ::.r. I ct) :Do ::!: '9 o UI ~ ~:n :88 OL cc::lU 6::rl zO 6rn ;:--", ;\5 -< 01-3220-CIVIL ~ f GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PAl 91 06 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, PAl 7070 Term No. 0l-3220-CIVIL 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 COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HOOVER. JAMES .lAMES HOOVER 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$2I,056.51 obtained by FIRST NATIONWIDE MORTGAGE CORPORA nON against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay call: 215-627-1322 . OI-3220-CIVIL . 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. 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 of7 I 7-240-6390. 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 property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 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 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 Sheriff within thirty (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 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 of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Ol-3220-CIVIL ~ . GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttomeyI.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 948 I Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, PAl 7070 Term No.01-3220-CIVIL 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 COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HOOVER, LINDA LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cwnberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FI. Courthouse to enforce the court judgment of$21.056.51 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 . OI-3220-CIVIL . 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. 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 property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 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 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 Sheriff within thirty (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 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 of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 0 ,..., f;; c-c> ~ = ~."" CJ1 1~_,;l:JJ <- ~:n . ,; c:: .....' J.'.' Z ,." ./ -(,Jr,:; C. I ,,) ~ Cl:l ~?6 <...J -l ~~:? > :I::P :::!:: 0-..1 s' Z?~ :z': C) ..4 ......; <=> ;..... -< :0 VI .< GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 FN-0232 CF: OS/25/2001 SD: 09/07/2005 $21,056.51 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) Term No. 01-3220-CIVIL 329 15th Street New Cumberland, PA 17070 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plainti.ff, hereby certjfies.that se.rVice on the De~dantso~theNoticCf:S~:iff alewasrnadeb~Jlfl\nl'\' dl~) Co j.9ajoS, 1>1 ~e;t~~rvlce)(y tWe enffs ~/~ I " 'J ( j' Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided Section 4904. '" lr o-'l D :T ..D l'- ru o-'l D D D D ..D o-'l o-'l sps com postage E ~~ ~ 1-. \'l. _ ~~ H all< OJusf> Certified Fee Return Receipt Fee E ~ ::!orsetnent Required) II:!strictedDeliveryFee l flciorsernsnt Required) 4. l~ta' Postage & Fees $ 32 917 U1 D ""reaVER, JAMES D l'- ';';;;'CAjiCNo~;---S-Z-9---"1-':;-ttr---g-tn,et--- _n___n___n____________ : "."."_~x_N~;_____1II.eJol.n_Cllm.bBr._lan.cl.~--J?.A.n-U-OJ-O---- (;.ty, State, ZIP+4 !~ averse/or InstructIOns Forl113800 June 2002 See Certified Mail Provides: . A mailing receipt (aSJeIl8I;J) GOOl' aunr 'aoef: lWO;;l Sd · A unique identifier for your mailpiece . A record of delivery kept by the Postal Service for two years Im/?ortant Reminders: . Certified Mail may ONLY be combined with First-Class Mai~ or Priority Mail@. . Certified Mail is not available for any class of International mail. . NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, please consider Insured or Registered Mall. . For an additional fee, a Return Receipt may be requested to provide proof of delivery. To obtain Return Receipt service, pfease complete and attach a Return Receipt (PS Fann 3811) to the article and add applicable postage to cover the fee. Endorse mailplece "Return Receipt Requested". To receive a me waiver for a duplicate return receipt, a USP~ postmark on your Certified Mail receipt is required. . For an additional fee, delive'Y may be restricted to the addressee or addressee's authorized agent. Advise the clerk or mark the mailpiece with the endorsement ~RestrictedDeliveryN. . If a postmark on the Certified Mail receipt is desired, please present the arti- cle at the post office for postmarking. If a postmark on the Certified Mail receipt is not needed, detach and affix label with postage and mail. IMPORTANT: Save this receipt and present iI when making an inquiry. Internet access to delivery information is not available on mall addressed 10 APOs and FPOs. I u.s. Postal Service,,, CERTIFIED MIAIL", RECEIP (Domestic Mail Only; No Insurance Coverage ProvIded) .-'I .-'I ru ~ r~~("';..'~:"'I' ~1:~'j,'.A~~""'" 'U"s"'e ru PnSlagE $ .-'I o o Return Receipt Fe(, o (Endorsement Requiredi o Restricted Delivery Feu ...D (Endor9om1entRequlrad) .-'I .-'I Yes -V _, CertlfiudFet Total Postage & Fees $ Lt1 D BentTo o HOOVE R. LI NDA r'- ~...CAPCNo.;-":ri9-.--i"5ffimsfre-e"t-------._---_..---n---.n.- or PO Box No. ' CitY.'SiBiB;ZI;;;;;'N-ew"-etrm-b~r-It;rrd-;---'i>'A---.H'8:t{J---- PS Form 3800 June 2002 See Re Certified Mail Provides: . A mailing receipt . A unique identifier for your mallpiece · A record of delivery kept by the Postal Service for two years Important Reminders: · Certified Mall may ONLY be combined with First~Class Mai/$ or Priority Mail$. · Certified Maills not available for any class of international mail. · NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, please consider Insured or Registered Mail. . For an additional fee, a Return Receipt may be requested to provide proof of delivery. To obtain Return Receipt servIce, prease complete and attach a Return Receipt (PS Fonn 3811) to the article and add applicable postage to cover the fee. Endorse mailpiece "Return Receipt Requested". To receive a fee waiver for a duplicate return receipt. a USP&& postmark on your Certified Mall receipt is required. . For an additional fee, delivery may be restricted to the ad.dressee or addressee's authorized agent. Advise the clerk or mark the maiiplece with the endorsement .Restricted7Jelivery~. · If a postmark on the Certified Mail receipt is desired. please present the arti- cle at the post office for postmarking. If a postmark on the Certlfled Mall receipt is not needed, detach and affix label with postage and mail. IMPORTANT: Save this receipt and present it when making an inquiry. Internet access to delivery information is not available on mail addressed to APOs and FPOs. 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ID ~ -< gr" f 5" !} ~ ~ ID li'; :; m . ~ I"''' )> to.):y; ~ :::u,J:>........ ~ ::O;Z ~ ~ en .,., I m Coo 0 :::OOm Q);fS.ghl~ .GlZ;o ~ iii~ "<l'a~~ )> m o:::l (/I.....::!l~)( " 0 r -" g il:@ · (f) )>(lJro $l~..:::::;:;.ffi"a.lit .......--1....... _()tu BS.513 -....J;;U - CD:::I =:I ~ ^, ~~< ('):J: -.0. ~fii ","'0 C! Z..~ - 8'" OJ: _ ."" C. "O~ (!) (f) ~~ ijf" al r :::;;:t> o ~~ )> -. ~ Z ~~, il.i6 iir~ -" ffi~ o :::;;ffi "en o~ o~ ~ iig if~ i~ if~ ~'" ffi'" GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, JI. AttorneyI.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW Ys. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) Term No. 01-3220-CIVIL 329 15th Street New Cumberland, PAl 7070 Defendant( s) AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORPORATION, 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 at: 329 15th Street NewCumberland,PA 17070 l.Narne and address ofOwner(s) or Reputed Owner(s): JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 2. Name and address ofDefendant(s) in the judgment: JAMES HOOVER 329 15th Street NewCumberland,PA 17070 LINDA HOOVER 329 15th Street NewCumberland,PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 GREENWOOD TRUST CO. P.O. BOX 11848 HARRISBURG,PA 17108 BELCO COMM. CREDIT UNION 403 N. 2ND STREET HARRISBURG, PA 17101-1322 SOVEREIGN BANK c/o HEATHER A. SOLLEY 60 I Penn Street Reading, P A 19601 W A YPOINT BANK 235 North 2nd Street P.O. Box 1711 Harrisburg, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: FIRST FEDERAL SAVINGS & LOAN 234 N. SECOND STREET HARRISBURG, PA 17101 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 whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS / OCCUPANTS 329 15th Street New Cumberland, P A 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: August 5, 2005 o c ;:-;'. ""T",!': !~!.'l \ 2:~ {,-~ 02,. r::-:t; *~(~! PC;" ~ .~ ._, r-> ''''' = <->' po c:: G') ~ :r.-n rn.~ :g (:) ~~ OB Zrn ~ N ~ \.0 -0 :J: ~