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Home My WebLink About12-2954I Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suiite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff O MCC <- CitiMortgage, Inc., PLAINTIFF, v. Frank E. Coover 19 Wyrick Avenue Shippensburg, PA t7257, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: /,-2 • 07Q63 CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT - CIVIL ACTION NOTICE TO DEFEND NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim of relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFF LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 5 $1X3.75 PA AT7-? & a 7s-Z? & 7 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la Corte en forma escrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomara medidas y puede continuer la demanda en contra suya sin previo aviso o notificacion. Ademas, la Corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus edades u otros derechos importantes Para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION ACERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOME AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 2 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 PLAINTIFF, CitiMortgage, Inc., V. Frank E. Coover 19 Wyrick Avenue Shippensburg, PA 17257, DEFENDANT Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: CIVIL ACTION MORTGAGE FORECLOSURE COMI'LAINT IN MORTGAGE FORECLOSURE Plaintiff, CitiMortgage, Inc., by and through its undersigned attorney brings this action in mortgage foreclosure upon the following cause of action: 2 3 Plaintiff, CitiMortgage, Inc., is a corporation, limited partnership, limited liability company, federal savings bank, or national banking association under and pursuant to the National Banking Act (13 Stat. 99, 12 U.S.C. 1 et seq.) with its principal place of business at 1000 Technology Drive, O'Fallon, MO 63368-2240. Defendant, Frank E. Coover, is the real owner, mortgagor, and grantee in the last Deed of record to the real property located at 19 Wyrick Avenue, Shippensburg, PA 17257 and, if applicable, riparian nights appertaining thereto (hereinafter referred to as "Premises") . On October 5, 2006, Defendant made, executed, and delivered a Mortgage to Argent Mortgage Co., LLC (hereinafter referred to as "Originating Lender") as security for 3 Defendant's payment and other obligations in consideration of a mortgage loan made to Defendant by the Originating Lender. Said Mortgage was recorded in the Office of the Recorder in and for Cumberland County on October 12, 2006 in Mortgage Book 1969, Page 798 and is incorporated herein by reference by virtue of Pa. R.C.P. 1019(g). 4. The aforesaid Mortgage has not been re-recorded. 5. The aforesaid Mortgage has not been modified. 6. Plaintiff is the Originating Lender, a legal successor thereto, or an assignee of the Originating Lender through Assignment of Mortgage. 7. The address of the Premises is 19 Wyrick Avenue, Shippensburg, PA 17257. 8. The aforesaid Mortgage is in default because the required monthly payments due under the terms of the aforesaid Mortgage have not been made from October 1, 2010 through the present date. By the terms of the aforesaid Mortgage, upon breach and failure to cure said breach after written notice thereof, all sums secured by said Mortgage shall be immediately due and owing. 9. The terms of the aforesaid Mortgage further provide that, in the event of default, Defendant shall be liable for, inter alia, Plaintiffs costs and attorneys' fees. W. The following amounts are due as of April 30, 2011: 4 Principal Accrued Interest through April 30, 2011 B PO Property Inspection Corporate Advances Servicing Fees 56k of Principal for Attorneys' Fees Total $ 138,442.17 $ 3,440.89 $ 84.00 $ 54.00 $ 785.00 $ 50.50 $ 6,922.11 $ 149,778.67 plus additional pre-judgment and post-judgment interest at the per diem rate of $14.2235 or at the adjusted amount if the interest rate is variable, additional late charges. additional corporate advances, additional escrow advances, and any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage. If the Mortgage is reinstated prior to a sheriff's sale, the attorneys' fees set forth in the preceding paragraph may be less than the amount demanded based on work actually performed. The attorneys' fees requested in the preceding paragraph are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect attorneys' fees of up to five percent (5610) of the remaining principal balance in the event the Premises is sold to a third party purchaser at sheriff's sale; or, if the complexity of the action requires additional fees, such :Fees may exceed the amount demanded in the preceding paragraph. 12. Plaintiff is not seeking a judgment on personal liability (or an in personam judgment) against Defendant in this action but reserves the right to bring a. separate action to establish that right, if such right exists. If Defendant received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish the personal liability that was discharged in bankruptcy, but only to foreclose the Mortgage and sell the Premises pursuant to Pennsylvania law. 13. Plaintiff has demanded the total amount due from Defendant, but Defendant has failed and/or refused to pay the same. 14. Notice of Intention to Foreclose pursuant to Act 6 and/or Act 91 was sent in accordance with Pennsylvania law more than 34 days ago. WHEREFORE, Plaintiff respectfully requests that judgment in rem be entered in its favor and against Defendant., Frank E. Coover, for foreclosure and sale of the Premises in the amounts due as set forth in Paragraph 10., namely $149,778.67, plus additional pre-judgment and post-judgment interest at the per diem rate of $14.2235 or at the adjusted amount if the interest rate: is variable, additional late charges, additional corporate advances, additional escrow advances, any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage, and such other relief as this Court deems just and proper. RICHARD M. SQUIRE & ASSOCIATES, LLC B y. _ Richard quire, Esq. (PA LD.# 04267) ?. Troy Freedman, Esq. (PA I.D.# 85165) Christina C. Viola, Esq. (PA I.D.# 308909) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire ), squirelaw.corn tfreedrnan@squirelaw.com cviola@squirelaw.com Attorneys for Plaintiff Date: 7.' UNLESS YOU NOTIFY US WITHIN THIRTY (30) DAYS AFTER RECEIPT OF THIS LETTER/NOTICE/PLEADING THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED. WE WILL ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON YOUR REQUEST WITHIN THIRTY (30) DAYS, WE WILL PROVIDE YOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM THE CURRENT CREDITOR. THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85 165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff CitiMortgage, Inc., V. PLAINTIFF, Frank E. Coover 19 Wyrick. Avenue Shippensburg, PA 17257, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA DOCKET NO: CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION Dan Fitzgerald , hereby states that he/she is Document Control Otfi(erof CitiMortgage, Inc., Plaintiff in this matter and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my knowledge, information or belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to > msworn falsification to authorities. Name: Dan Fitzgerald DATE: h - / - (2 File #: CMI-632F S:2 Name: Frank E. Coover Title: Document Control Officer 8 Exhibit "A" ALL the following described real estate lying and being situate in Shippensburg Township, Cumberland County, Pennsylvania, bounded and limited as follows: TRACT NO. I: Bounded on the South by Lot No.6; on the East by land now or formerly of Gleim, on the North by Lot No.8; and on the West by Shippen Street, BEING KNOWN AS LOT NO.7 in the Plan of Lots known as John A. Wyrick's Developments, HAVING A FRONTAGE on Shippen Street of 75 feet and an even depth M200 feet from the center of Shippen Street. "TRACT NO.2: BEGINNING at the comer of Lot No.7 and Shippen Street; thence in an Eastwardly direction 200 feet to land now or formerly ofGleim and Shindeldecker; thence in a Northwardly direction along the same lands, 50 feet, more or less, to land now or formerly ofR. Reed; thence in a westerly direction 200 feet along same lands and Lot No.9 to a point in Shippen Street; thence in a suthwardly direction along Shippen Street 43 feet to the place of beginning. Being the same real estate which James M. Weibley, widower, by his Attorney-in-Fact, Elmer D Weibley, by Power-of-Attorney by his deed crated August 20, 2002 and recorded in Cumberland County Deed Book 253, Page 1411 conveyed to John B. Dymond, who is being joined by Nancy G. Dymond, his wife. Parcel# 36-35-23-88-029 Premises: 19 Wyrick Avenue, Shippensburg, PA 17257 FORM 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) rc r. i c, vs. Defendant(s) 01 oill/d (ef$4 Civi? NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE;::. DIVERSION PROGRAM ;.' You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have! a lawyer you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717)243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service: upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference s scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE' YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date Signature of Counsel for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMERIPRIMAR Y APPLICATION Borrower name (s): Property Address: City: Is the property for sale? Yes ? No ? Listing date: Realtor Name: Borrower Occupied: Yes ? No O Mailing Address (if different) _ City: Phone Numbers: Home: Cell: Email: # of people in household: How long? CO-BORROWER Mailing Address: _ City: State: _ Z p: Phone Numbers: Home Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number. Date You Closed Your Loan: Second Mortgage Lender: _ Type of Loan: Loan Number Total Mortgage Payments Amount: $ Included Taxes and Insurance _ Date of Last Payment: Primary Reason for Default: State: Zip: _ Price: $ Realtor Phone: State: Zip:__ Office: Other: Is the loan in Bankruptcy? Yes ? No ? If yes, provide names, location of court, case number & attorney: Assets Home: Other Real Estate: Retirement Funds: Investments: Checking: Savings: Other. Automobile #1: Model: Amount Owed: Amount owed: Automobile #2: Model: Amount owed: Other transportation (automobiles, boats, motorcycles) Year: Amount owed: Value: Value: Value: Model: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. 2. Borrower Pay Days: Monthly Gross Monthly Gross Monthly Gross Monthly Amount: Monthly Amount: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other Prop. Payment _ Install. Loan Payment r Child SupportiAlim. L Cable TV Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes ? No If yes, please provide the following information Counseling Agency: Counselor: Phone (Office,: Email: Fax: Year: Year: Morthly Net Morthly Net Monthly Net Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): _ Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed FORM 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PI aint'ff(s) vs. Defendant(s) REQUEST FOR CONCILIATION CONFERENCE Civil Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage 'oreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Signature of Defendant Date Date FORM 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. Defendant(s) Civil CASE MANAGEMENT ORDER AND NOW, this day of ,20 , the defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at . M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. if the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. SHERIFF'S OFFICE OF CUMBERLAND COUNTY "!LED- Ronny RAnderson !'HE'ftTNONCiTAI'} Sheriff 4??tp ta4 ?Cuat,?rh?t Jody S Smith 2012 MAY 22 AM 9: 10 Chief D"uty Richard W Stewart Solicitor CE e= -?,r V-ERIFr PENNSYLVANIA Citimortgage, Inc Case Number vs. 2012-2954 Frank E Coover SHERIFF'S RETURN OF SERVICE 05/14/2012 05:34 PM - Shawn Gutshall, Deputy Sheriff, who being duly swom according to law, states that on May 14 2012 at 1734 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Frank E. Coover, by making known unto himself personally, at 19 Wyrick Avenue, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. UTSHAL , DEPUTY SHERIFF COST: $48.00 May 18, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. s M 4 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff PLAINTIFF, CitiMortgage, Inc. V. Frank E Coover 19 Wyrick Ave Shippensburg, PA 17257, DEFENDANT. Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 12-2954 CIVIL ACTION PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of Plaintiff and against Frank E Coover, Defendant, for his/her/its/their failure to file an Answer to Plaintiff s Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises as described in Plaintiffs Complaint, and assess Plaintiffs damages as follows: Figures Good Through Principal Balance 6/30/2012 $138,442.17 Q?? ?i?.so?d a Ck4 r FAClients\Citi Mortgage\Coover, Frank - 632F\Default Judgment merged 6-12-12.wpdKG Total Interest Amount $9,497.71 Paid Out School Taxes $1,356.69 Paid Out City Taxes $3,419.81 Paid Out Hazard Insurance $1,119.00 Non-Escrow Tax Item(Water/Sewer /Meter Bill) $43.83 FC Attorney Fees $3,063.75 Appraisal/BPO $252.00 Inspections $243.00 TOTAL PAYOFF $157,437.96 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. RICHARD M. SQUIRE & ASSOCIAT , LLC By: Ric . Squir PA I.D.# 04267) Troy Freedman, Esq. (PA I.D.# 85165) raig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsauirea,sauirelaw.com tfreedman(cr?,squirelaw.com cotnvenheimer(&sauirelaw. com Attorneys for Plaintiff k DAMAGES ARE HEREBY ASSESSED AS INDICATED Aft DATE: (A A PROTHONOTARY FAClients\Citi Mortgage\Coover, Frank - 632F\Default Judgment merged 6-12-12.wpdKG Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff CitiMortgage, Inc. PLAINTIFF, V. Frank E Coover 19 Wyrick Ave Shippensburg, PA 17257, DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 12-2954 CIVIL ACTION VERIFICATION OF NON-MILITARY SERVICE The undersigned hereby verifies that he is one of the attorneys 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 Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemember's Civil Relief Act of 2003, as amended. (b) that Defendant(s) is/are over 18 years of age and reside(s) or maintain(s) an address at 19 Wyrick Ave, Shippensburg, PA 17257. Attorneys for Plaintiff FX1ients\Citi Mortgage\Coover, Frank - 632F\Defauh Judgment merged 6-12-12.wpdKG This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. RICHARD M. SQUIRE & ASSOCIATES, LLC By: --- Richard . Squire, Esq. PA I.D.# 04267) Troy Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsouirea,sauirelaw.com tfreedman(a;ss uirelaw.com coppenheimerQ,,souirelaw.com Attorneys for Plaintiff F:\Clients\Citi Mortgage\Coover, Frank - 632F\Default Judgment merge 6-12-12.wpdKG Department of Defense Manpower Data Center Sato Re"n Pursuant to SwAcemembers Civil Relief Act Last Name: COOVER First Name: FRANK Active Duty Status As Of: Jun-12-2012 Results as of : Jun-12-2012 09:30:04 SCRA 2.2.1 Actvs Duty1'Ktert Dab Aotve Duty End Dab Status Service Camparent On Active Duty On Ac" Duty Stahl Date NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Sb&n Dele Active Duty alert Data AW" Duty End Date Stop Service CornponaM NA NA No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HidHer unit was Notffed of a Future Call-Up to Active Duty on Ache N4 Status tie Ordw Notification Start Deb Order Notification End Dab Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. A LA A.IJ_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 at seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: U12KOK711C PACER Case Locator - View PA m Thu May1c0 52 322 012 E012 WCoseLoicato No Records Found User: rs0431 P Client: Search: Bankruptcy Party Search 182627310 All Courts Page: 1 No records found Recelpt 05/10/2012 15:28:33 27507201 User r50431 P Client Description Bankruptcy Party Search 182627310 All Courts Page: 1 Pages 1 ($0.10) Page 1 of 1 https://pcl.uscourts.gov/view?rid=91pynEcohcmHufGouiWjmwB4PMfBO1 SHtTKIgJjU&... 5/10/2012 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff CitiMortgage, Inc., V. PLAINTIFF, Frank E Coover 19 Wyrick Ave Shippensburg, PA 17257 DEFENDANT. TO: Frank E Coover 19 Wyrick Ave Shippensburg PA 17257 DATE OF NOTICE: June 4, 2012 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 12-2954 CIVIL ACTION MORTGAGE FORECLOSURE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. 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 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. FAClients\Citi Mortgage\Coover, Frank - 632F\10 day letter merged 6-4-12.wpd\KG IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 F:\Clients\Citi Mortgage\Coover, Frank - 632F\10 day letter merged 6-4-12.wpd\KG Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 CitiMortgage, Inc. PLAINTIFF, V. Frank E Coover 19 Wyrick Ave Shippensburg, PA 17257 DEFENDANTS. NOTICE TO: Frank E Coover 19 Wyrick Ave Shippensburg, PA 17257 Date a Pursuant to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that one a judgment(decree)(order) was entered against you in this office in the proceeding,ks indicated above. Deputy Prothonotary Date Mailed: FAClients\Citi Mortgage\Coover, Funk - 632F\Default Judgment merge 6-12-12.wpdKG WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) CO[.`NTY OF CUMBERLAND) NO. 2012-2954 Civil CIVIL ACTION LAW TO I'HE SIIERIFF OF CUMBERLAND COUNTY: To satisfy the debt., interest and costs due CITIMORTGAGE, INC. Plaintiff (s) From FRANK E. COOVER, 19 WVRICK AVENUE, SHIPPENSBURG, PA 17257 ( 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 attachment has been issued; (b) the garnishee(s) is enjoined from payling 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, 1 f property of the defendant(s) not levied upon an subject to attachment is found in the possession of anvone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: S1571437.96 L' L.: S.50 Intcrest FROM 7-1-2012 to 12/5/2012 @ $14.2235 PER DIEM - $2,246.76 Altv's Comm: "% Due Prothy: 52.25 Atty Paid: $199.25 Other Costs: Plaintiff Paid: Date: 7/31 /2012 David D. Buell, Prothonot r r" (Seal) -- Deputy I:I-QUES f ING PARTY: Name: CRAIG OPPENHEIMER, ESQUIRE Address: RICHARD M. SQUIRE & ASSOCIATES, LLC ONE JENKINTOWN STATION, SUITE 104 115 WEST AVENUE ,JENKINTOWN, PA 19046 Attorne,, for: PLAINTIFF Telephone: 215-886-8790 Supreme Court ID No. 313264 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Attorneys for Plaintiff felephone:215-886-8790 Fax: 215-886-8791 t1Ti=JEd?T?, 2Pt' 1 J; 1.31 Aid 8:.32 UMBERLAND COUNTY CitiMortgage, Inc. IN THE COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-2954 Frank E Coover 19 Wyrick Ave CIVIL ACTION Shippensburg, PA 17257 DEFENDANT. MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) To the Prothonotary: Kindly issue a Writ of Execution in the above matter. Amount Due $ 157,437.96 Interest From 7/1/2012 to 12/5/2012 @ $14.2235 per diem $ 2,246.76 Total: $ 159,684.72 * plus fees and costs Date: July 26, 2012 By: ?' - -?- Richard M-Kquire, Esq. (PA I.D.# 04267) M. Troy Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) Q 115 West Avenue, Suite 104 Jenkintown, PA 19046 y $, cx7 F 215-886-8790 1 b3.7 S u ++ 215-886-8791 (fax) 1 Sp " +' rsquire(wsquirelaw.com pu tfreedman&squirelaw com p c_..ppenheimerna squirelaw com q a a 5 I Attorneys for Plaintiff ? , S a LL.. CMI-632F S:2/DM 1 5? S(o a -7 a U67 k ? ?( , _? , LEGAL DESCRIPTION ALL the foilowmg desk rest estate lying and being situate in 9h4Vensburg Towns ip? Cumberland County, Peonsylvamias, bounded and limned as follows: TRACT NO. 1: Bounded on the Sow by Lot No. 6; on the East by land now or forme rty Of G leim, on thl North by Lot No. S; and on ft Nest by Shippen Street, BEJM KNOWN AS LOT NO.7 the Plan of Lots known as 7otnc A. Wyri&s DevekTma b, HAVING A FRONTAGE on Shiippen S of 75 few w an even depth of 240 feet Smam the center of Ship m 9ft et. TRACT NO. 2: BEGMINGr at the comer of Lot No. 7 and Shippen Street; theme in an y direction 200 foot to land now or formerly of Glabn and Shiindeldeckar, thence in a North dirrection along the some lands, 50 feet, more or less, to laud now or fbimer ly of R. Reed; thance in westerly direction 200 feet along so= lands and Lot No. 9 to a point in Shippm Stmet; thence in a ?outhwardly direction along Shipp= Stred 43 Beet to the place of beginning. KNOWN as 19 Wyrick Avenue, Shippensburg, PA 17257 PARCEL NO: 36-35-23-88-029 BEING the same premises which John B. Dymond and Nancy G. Dymond granted and conveyed unto Frank E. Coover by Deed dated October 21, 2002 and recorded October 23, 2002 in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania as Deed Book 254, Page 869. F:A('Iienis,Citi Mortgage\Coover, I'rank - 632F\writ package 7-25-2012.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I .D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff in - ,fi'f#ik, ? '? ?' 31 g 71XISERLAND COUNTY PENNSYLVANIA CitiMortgage, Inc. IN THE COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND, PENNSYLVANIA V. NO. 12-2954 Frank E Coover ' CIVIL ACTION 19 Wyrick Ave Shippensburg, PA 17257 MORTGAGE FORECLOSURE DEFENDANT AFFIDAVIT PURSUANT TO RULE 3129.1 Citi Mortgage, Inc., Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the r@ al property located at 19 Wyrick Avenue, Shippensburg, PA 17257 Parcel No: 36-3151-23-88-09. Name and last known address of Owner(s) or Reputed Owner(s): Frank E Coover 19 Wyrick Ave Shippensburg, PA 17257 2. Name and last known address of Defendant(s) in the judgment: Frank E Coover 19 Wyrick Ave Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: CitiMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2240 Cumberland Franklin Joint Municipal Authority 725 Municipal Drive Shippensburg, PA 17257 4. Name and address of last recorded holder of every mortgage of record: P:Whents.Citi Mortgage\Coover. Prank - 632E\writ package 7-25-2012.wpd CitiMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2240 US Bank National Association, as Trustee 10801 6th Street, Ste 130 Rancho Cucamonga, CA 91730 Argent Mortgage Company, LLC 3 Park Plaza-10th FL Irvine, CA 92614 Argent Mortgage Company, LLC c/o Nationwide Title Clearing, Inc. 2100 Alt 19 North Palm Harbor, FL 34683 Pennsylvania Housing Finance Agency 211 N. Front Street Harrisburg, PA 17101 5, Name and address of every other person who has any record lien on the property!: None other. 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: Domestic Relations Family Services Bldg. 13 North Hanover Street PO Box 320 Carlisle, PA 17013 Tax Claim Bureau One Courthouse Square - Room 106 Carlisle, Pa 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of'Public Welfare Attn : Legal Department Health & Welfare Building P. O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare Bureau of Child Support Enforcement Health & Welfare Bldg., Room 432 Harrisburg, PA 17105-2675 F:Thents'Cin Mortgage\Coover, Prank - 6321-\writ package 7-25-2012.wpd ?. 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: Tenant/Occupant 19 Wyrick Avenue Shippensburg, PA 17257 VERIFICATION 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. Richard M. Squire & Associates, LLC By: Richard . quire, Esquire M. 'Troy Freedman, Esquire .?rCraig Oppenheimer, Esquire 115 West Avenue, Suite 104 Jenkintown, PA 19046 (215) 886-8790 Attorneys for Plaintiff Date: Jul) 26, 2012 P:AClients,citi MortgageWoover, Prank - 632E\writ package 7-25-2012.wpd r 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: The sale will be canceled if you pay back to CitiMortgage, Inc., the amount of the, judgment plus costs or the back payments, late charges, costs and reasonable attorneys' feels due. To find out how much you must pay, you may call: Richard M. Squire, Esquire; M. Troy Freedman, Esquire or Craig Oppenheimer, Esquire at (215) 886-8790. 2. Yoi.l may be able to stop the sale by filing a petition asking the Court lo strike or open the judgment, if the judgment was improperly entered. You may also ask: the Court to postpone the sale for good cause. Richard M. Squire &. Associates, LLC 13y: Richard M. Squire, Esquire M. l roy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown. PA 19046 (2151 886-8790 Fax (215) 886-8791 Attorneys t-or Plaintiff Citi\lortgage, Inc. v. PLAINTIFF, Frank E Coover 19 Wyrick Ave Shippensburg, PA 17257 DEFENDANT '40 TA. .' .,Ul"IBERLAND COUNTY" PEMSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. 12-2954 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Frank E Coover 19 Wyrick Avenue Shippensburg, PA 17257 Your house (real estate) at 19 Wyrick Avenue, Shippensburg, PA 17257 is scheduled to, be sold at Cumberland County Sheriff Sale, on Wednesday 12/5/2012 at 10:00 a.m., at the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $157,4437.96 plus interest to the sale date obtained by CitiMortgage, Inc. against you. 1 K'hent, Citi NlortgageAConver, hank - 632F\writ package 7-25-2012.wpd I . You may 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 attornev.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidden. You may find out the price bid by calling the Cumberland Sheriffs Office at 717-240-6100- 2. You may be able to petition the Court to set aside the sale if the hid 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 1n the sale. To find out if this has happened you may call the Cumberland County Courthouse at 717-2,40-6100. 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 no later than 30 days after the Sheriff s Sale. This schedule will state who will be receiving the 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 alter the date of filing of said schedule. 7. You may also have other rights and defenses or ways of getting your house back] if you act immediately after the sale. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 1, ?( hent,Titi Mortgage\k Omer. Frank - 632F\writ package 7-25-2012.wpd