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Home My WebLink About04-6096 GOLDBECK McCAFFERTY & McKEEVER By: JbSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER. 701 MARKET STREET PHILADELPHIA, P A 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF MANUF ACTURERS & TRADERS TRUST COMPANY S/B/M KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CNIL ACTION - LAW VS. Defendant(s) ACTION OF MORTGAGE FORECLOSURE c:- 'v . r I Term No. .0 '1- (po9~ CIVIl.. ACTION: MORTGAGE FO~@CL08URF DONALD J. VALOIS JANELLE M. VALOIS Mortgagor(s) and Real Owner(s) 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO 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 you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice 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 claim in the Complaint of fot any other claim or relief requested by the Plaintiff. Yon may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PAl 7013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 A VISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRlTA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A EST A DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTlFICARlO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE EST A DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQuI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVlCIOS LEGAL A PERSONAS ELIGIDLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INe 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PAl 7013 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is MANUFACTURERS & TRADERS TRUST COMPANY SlBfM KEYSTONE FINANCIAL BANK NA, PO Box 840, Buffalo, NY 14240-0840. 2. The name(s) and address(es) of the Defendant(s) is/are DONALD J. VALOIS, 11 Ashburg Drive Lot 59, Mechanicsburg, PA 17055 and JANELLE M. VALOIS, 11 Ashburg Drive Lot 59, Mechanicsburg, P A 17055, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. 3. On April 28, 2000 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MANUFACTURERS & TRADERS TRUST COMPANY SlBfM KEYSTONE FINANCIAL BANK NA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1609 Page 482. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 10 19(9). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due April 01, 2004, 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 03/01/2004 through 12/31/2004 at 10.7500% Per Diem interest rate at $29.85 Attorney's Fee at 5.0% of Principal Balance Late Charges from 04/01/2004 to 12/31/2004 Monthly late charge amount at $55.59 Costs of suit and Title Search $101,342.83 $9,134.10 $5,067.14 $500.31 Escrow Monthly Escrow amount $145.12 $900.00 $116,944.38 +$211.83 $117,156.21 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 Sheriffs Sale. Ifthe 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 date ofthe postmark on the Notice was the same as the date ofthe Notice. The Defendant(s) had the required face to face meeting within the required time and Plaintiff has been advised that the Defendant(s) filed an application for mortgage assistance with the Peru'isylvania Housing Finance Agency, the Plaintiff has been advised by the Pennsylvania Housing , Finance Agency that the Defendant(s)' application has been rejected. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure in the sum of $117,156.21, together with interest at the rate of$29.85, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms ofthe mortgage, and for the foreclosure and sale ofthe mortgaged premises. By: Il (jJ}!;{~ K McCAFFERTY & McKEEvER B JOSE A. GOLDBECK, JR., ESQUIRE A ORNEY FOR PLAINTIFF VERIFICATION I, Diana M. Robinson, 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: ,2..- -~ -- rJ '1 ~ (i Diana~. ~ in;on M&T MORTGAGE COMPANY Liens And Things 717 284 3304 08/27 '04 16:56 NO:481 02/03 '2,c,. \~~( ,.,.... "'j .:' !," 'I.~I\ . v... '., ':IDS ,,(CO,,!;' ,. J.' "... :.uwlltkl..h;lA CQU141't. 'A .. -"".- '00 MY 2 ft1'l ! 06 Q:~r. )I"h....... ~ ~ ~p 1).-11-134~ ~II .,~ ~\ . :1000 -"Itn. ClIIAQIl A. t1D1LlUt. f~dl' known .. GIUloCIi: A. J'ZSGJI aftd ~ K. DDlLIIII. vU. MId ~.I>fllld ....,.. ~.,... a., ..,.,." ... I:lOJIND J. VALOI' Ad "~M, vaJAlt, "-band 4I1J' ",!fa a..... "'_"1IIf f1M _III .a...a\, n... ~-1.'-cA"_" ORa NUWOl~ HZ" ~ ~ 10/100-....4---.......... ($10',OC .00) II ..... III "".-11, ,.....--.,....,..."... ",' ..~ ,....,II........IoI.{..o) _1W",IQf__~ .._ .-N .....m. ~I THAT ~Z. IluUdill!l lot ~l"'.tlllll a. Lot No. "', l_.~wd In 'Uv.a' ....,~ 'ftIfttldlip, ~1._ QlUat)'. .e1tII.yloqnl., al .howr . on . 1'1..1 r.eM '\Ibclivl.:f,Clft PI.,. o' ~.. I of! ..tUfDrtl .....". .UIptI~ b" It. "_211 lU.eJ1 .net YlIOVi.'.. UId ncorct.d l.l\ \!Ie orl!i_ .. t.JHo llecDEd.-r: of Dw." ., a-bn'land l:eW\1:J', "'1IIUtr1~;l. in hItC",,'.i,1iIft '111ft Book n, ~ '74. and "in, 1IIP:n fully 1loImd1!' I .nd IiHm!J.N. .. '..11_, .-o~ at . point. ..ad pOint beta. loc.~ed along tbe ~."n' X'ight Dr 'NY li". ot! ~~ Dr.l~, tJ.1\CO oonUtN.lnt 'lOhIl_ the _ullbem ~t.'" .r -" Un. of Mhbu, ga:.i.YII. ~ . eltllY. to ~ l.'~, ..I,d 0___ lIIIv1ng . ..adlu of sO.GO tee~. . 1:..._' 1~" or "1.00 f_t.~ and ut an l.ll4Ila e! u.n f_e no . POinll~." POi_ l_t_ alonsll tIw -.a1:h.Z'ft d,b\ vJj ~ Une elf .. Dl'1_, t~ _1O....Iaw .1~ ._. ~ .. "ul.~ .~ lIDa-t:b , ~n.. os MlINt;.. .. ~ "'t, a ...e.... rd :13.1' 1'..~ to .. PVr.~1 ~ CClftllllutng along l~ _ f'1&' f~ly of ....'...fol'. ~...., "'t .,. w. t..dB9 of Irwth 'I' ~. J' iid.1N'" .:1 ..allltdll ...t. ~ '1__.. .II! 1.~1.1I .e.. I: to a poJ.nllt, '.14 ~.tnll be1.. :L_.... 11I0" ~...s. _ ... rUlllll"ly of Vate;noz.t IIquIInI; '~1DCe eaatinulD1 along ..... bv a be.r~n, ot .guah .0 Ii...... 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Box 1288 Buffalo,NY 14240-1288 PI M<<MmtgageCcxporatioo A.....,d..BIr* 07/2612004 Certified No.: 71826389306004197813 Janelle M Valois 11 Ashburg Dr Lot 59 Mechanicsburg, PA 17050 "':',0'1 '0" f"t ,,,;\ 4 H. '"".",," <H_ t. . "./:j ,:: ',' N .., . '" r~ ....,;:1". ;,: ,ii ~ ~ ~ !-'~~ L1 ..... -::all" ~, ~...,.. Ii: HOMEOWNERS NANE(S): ~.~11. M V.lol. Donald ~ Valots A PROPERTY ADDRESS: 1 1 Astu.lrg Or Lot 511 MechanlcsbUrg, PA 17055 LOAN N::Cr NO: 0001754858 QJRRENT LENIlER/SERVICER: 116T Mortsall" CorporatIon HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PA YMl!:NTS IF YOU COMPLY WITH mE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "Acr'~ YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - 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-fac"meeting with one of the consumer credit counseling agencies listed at the end of this Notice.l:llm MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the conswner credit counseling agency listed at the end of this notice. the lender may NOT take action against you for thirty (30) days after the dale of this meeting. The names. addresses and teleohone numbers of desil!:nated consumer credil counselinl! sl!:encies for the countv in which the Drooertv islocsted are set fotth at the end of this Notic~. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. 18007241633 C<>mIspondence - P.O. 8Qx 840. Buffalo. NY 14240-0840 Payments - P.O. 8Qx 1364. Buffalo, NY 14240-1364 Mottgall'J account Information. just a click away. www.mandtmcflll..ge.com M&T Mortgage Corp. P.O. Box 1288 Buffalo, NY 14240-1288 rlMS'Mmtgage~ 07/26/2004 Certified No.: 71826389306004197806 Donald J Valois II Ashburg Dr Lot 59 Mechanicsburg, PA 17050 HOMEOWNERS HAME(S): Donald ~ Valois ~anaIl. M V.lols PROPERTY ADDRESS: 11 AshbUrg Dr Lot 511 Meehanl csbUr-g, PA 17055 LOAN ACCT NO: OOO1l7S4155l1 CURRENT LENOER/SERV1CER: M6T Mortgage COl'pOratton HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND Ht:LP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE" ACT"). YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGmILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORlj;<;:LOSURE - Under the Act, you are entitled to a temporary stay offoreclosure on your mortgage for Ihirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-fac"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF TIDS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one ofthe consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) day. aftcr the date oflhis meeting. The names. addresses and telellhone numbers of desillnated consumer credit counselinll aJlencies for the c01jlltv in which the proDertv is located are set forth at the end of this Notice. It is only necessary to schedule on~ face-to-face meeting. Advise your lender immediately of your intentions. 1800 724 1633 Correspond<Jnca - P.O.1lox 840, Buffalo, NY 14240-0840 Payments - P.O. Box 1364, Buffalo. NY 14240-1364 Mortgage account Information, just a click away. www.mandlmortgage.com APPLICA nON 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 fmancial assistance from the Homeowner'sEmergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner'sEmergency 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 ~ FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION 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 eligibility cnteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You wi\1 be notified directly by the Pennsylvania Housmg Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECfED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have f1led bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brin!! it up to date). NATURE OF THE DEFAULT -.The MORTGAGE debt held by the above lender on your property located at: 11 Ashburg Dr Lot 5ll MM:hantcsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MORTGAGE PAYMENTS for the following months and the following amounts are now past due: ~lar pa"..nts of $1111.74 for the IllOnths of 04/01/2004 throUgh tOday's date: Other charges: Accrued Lat. Charges: Accrued Other Charges TOTAL AMllUHT PAST DUE: $ $ $ $ 4448.ll8 388.84 24.00 48&7 . eo HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WInCH IS $4857.60, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Paymenta must be made either bv cash. cashier'scheck. certified check or monev order made pavable and ~ M&T Mortgage Corporatlon One Fountain Plaza 17th Floor Attn: Payment Processing Buffalo, NY 14203 You can cure anv other default bv takin~ the following action within THIRTY DO) DAYS of the date of this letter: IF YOU DO NOT CURE THE DEF AUL T-Ifyou do not cure the default within THIRTY (30) DAYS of the datc of this Notice, the lender Intend. to exorcise Its rights to accelerate 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 ofthe total amount past due is not made within THIRTY (30) DAYS, the lender also intends to inslntct its attorneys to start legal action to foreclose upon your mortgaged property. 1800 7241833 Correspon<1ence - P.O. Box 840. Buffalo. NY 14240-0840 Payments - P.O. Box 1384, Buffalo, NY 1424()'1364 Mortgage account Infotmation,just a dick away. www.mandlmortgagll.com IF THE MORTGAGE IS FORECLOSED Ul'ON -- The mortgaged property will be sold by the Shcriffto 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 attorncy'sfees actually incurred by tbe lender even ifthcy 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 tile default witbin the THIRTY (30) DAY perIod, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. JUGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff'sSale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attomcy'sfees and costs cOMccted with the foreclosure sale and any other costs connected with the Sherifi's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default In tbe manner set fortb In this notice will restore yonT mortgage to tbe same position as If you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sherifi' s Sale of the mortgaged property could be held would be approximately 10 months from tbe date of tbls Notice. A notice of the actual date ofthe Sherifi'sSale 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: Name of Lender: M&T Mortgllge Corporation Address: P.O, Box 840 Buffalo, NY 14240 Pbone Number: (800) 724-1633 t:FFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff'sSale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ mayor 1!; lDay not sell or transfer your hOlDe 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 ofthe mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF TIDS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HA VB 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, Sincerely, ~~~CJ1. Russell M. Alessi Jr. Collections Manager Enc: Act 91 Notice Consumer Credit ColDtseling Agencies Serving Your County 18007241633 Correspondence - P.O. Box 840. Buffalo. NY 14240-0840 Payments - P,O. Box 1364, Buffalo, NY 14240-1364 Morlgage eccount informeUon, just e click away. www.mandtmortgage.com ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the mortu!!e on your home IslD default. and the lender Intends to foredose. Soeelfte Information about Ihe natul} of the default (s orovlded In the attached Dal!e& The HOMEOWNER'S MORTGAGE ,4SSIST ANCE PROGRAM (REMAP) may be able to helo to save your home. This Notice ellolalns how the IIrOl!l'am 1I'0rks. To set If REMAP can helll. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with VOIl when you meet with the Counsellnll AlienC\'. The name. address and ohone number of Consumer Credit COllnsellnl! Aeencles servin!! your County are listed at tbe end of tllb Notice. If vou have any Questions. YOU may eall the Pennsvlvanla Bouslnl! Finance Al!enev loll free at 1-800-342.2397.(Persons with Imnalred hearlnl! ~,n call (7111780-1869). This Notice contains Important legal Information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help eJlplaln It. You may also want to contact an attorney In your area. The local bar association may be able to help you find a lawyer. LA NOTlFlCACION EN ADJUNTO ES DE SUMA lMPORTANCIA, PUES AFECT A SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIT AMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRmA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECBO A REDlMlR SU ffiPOTECA. 1600 7241633 CorresponClence - P.O. Box 840, Buffalo, NY 14240-08"10 Payments. P.O. Box 1364. B~ffalo, NY 14240-138"1 Mortgall8 account jnfonnaUon.Juat a click away. www.mand1mortgage.com Homeowners' Emergency Assistance Program CUMBERLAND COUNTY CCCS of Western Permsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, P A 17101 (717) 234-5925 FAX (7] 7) 234.9459 Connnunity Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 ACll"P41MCrM-t!' Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717)762-3285 YWCA ofCarlis]e 30] G Street Carlisle, PA ]7013 (717) 243-3818 FAX (717)731-9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 ~\\ --. ~ - cJ" -L. \ ~ ~ ~ ~ ~ r " ~ ~ ~ <.s~ v' \ ~ G C) "'-, C~ c:.:; 0 c::> ::~,.. .;..- -'0'] :~- ' c:, :'::-1 r' , c-> rl1 ! I -(11',.'1 .., 0- -:JC' ~ ~:-: -. fL " ,.l I :J'"'I" -or 1 ,,,-.:', ~; -'- :::J ;;:.. \.~) ~~! : , 4') ,. . ' .. '.\ !,:., -< :-:0 0\ --< ~ GDLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jf. Attorney 1.0. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MANUF ACTURERS & TRADERS TRUST COMP ANY S/B/M KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION LAW DONALD J. VALOIS JANELLE M. VALOIS (Mortgagor(s) and Record owner(s)) 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 04-6096 ORDER FOR JUDGMENT Please enter Judgment in favor of MANUFACTURERS & TRADERS TRUST COMPANY S/B/M KEYSTONE FINANCIAL BANK NA, and against DONALD J. VALOIS and JANELLE M. VALOIS for failure to file an Answer in the above action within (20) days (or sixty (60) da s if defendant is the United States of America) from the date of service of the Complaint, in the sum of $117 ,74 .97. I hCfc;by (;crtlfy that the abovt; naillc::; afc cOffed and that the pf s ence address o[t11e juJgnlt:nt creditor is MANUFACTURERS & TRADERS TRUST COMPANY S/ KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 and that the name(s) and last known addressees) of the Defendant(s) is/are DONALD J. VALOIS, II Ashburg Drive Lot 59 Mechanicsburg, P A 17055 and JANELLE M. VALOIS, II Ashburg Drive Lot 59 Mechanicsburg, P A 17055; GOLDBECK BY: Joseph A. Attorney for PI FERTY & McKEEVER eck,Jf. TO THE PROTHONOTARY: ASSESSMENT OF DAMAGES Kindly assess the damages in this case to be as follows: Principal Balance Interest from 03/01/2004 through 01/13/2005 Attorney's Fee at 5.0000% of principal balance Late Charges Costs of Suit and Title Search Escrow ANDNOW.this /~daYOf J.d0 $101,342.83 $9,522.15 $5,067.14 $555.90 $900.00 $356.95 ($0.00) $117,744.97 GOLDBECK Me BY: Joseph A. Go d Attorney for Plain' Y & McKEEVER , 2005 damages are assessed as above. VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, DONALD J. VALOIS, is last known about unknown years of age, that Defendant's residence is 11 Ashburg Drive Lot 59, Mechanicsburg, and is engaged in the unknown business located address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. PA 17055, at unknown Date: VERIFICATION OF NON-MILITARY SERVICE . The undersigned, as the representative for the Plaintiff corporation wi thin named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Mili tary Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defend"mt, JANELLE M. about unknown years of age, that Defendant's residence is 11 Ashburg Drive Lot 59, Mechanicsburg, PA and is engaged in the unknown business located at unknown VALOIS, is last known 17055, address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise wi thin the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: / In the Court of Common Pleas of Cumberland County MANUFACTURERS & TRADERS TRUST COMPANY S/BIM KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo. NY 14240-0840 Plaintiff vs. DONALD J. VALOIS JANELLE M. VALOIS (Mortgagor(s) and Record Owner(s)) 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 No. 04-6096 Defendant( s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against DONALD J. VALOIS and JANELLE M. VALOIS by default for want of an Answer. Assess damages as follows: Debt $117,744.97 Interest - 03/0 l/2004 to 0 l/13/2005 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least t'IP days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Ii AND NOW..... Jd.o... ') 19 ' ;;L 06....(( Judgment is entered in favor of MANUFACTURERS & lRADERS TRUST COMP ANY S/B/M KEYSTONE FINANCIAL BANK NA and against DONALD J. VALOIS and JANELLE M. VALOIS by default for want of an Answer and damages assessed in the urn of $117.744.97 as per the above certification. Prothonotary MT-0405 , THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: December 29, 2004 TO: JANELLE M. VALOIS 11 Ashburg Drive Lot 59 Mecbanicsburg, P A 17055 MANUFACTURERS & TRADERS TRUST COMPANY SfBlM KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 ill the Court of Conunon Pleas of Cumberland County Plaintiff CIVlL ACTION - LAW vs. DONALD J. V AL018 JANELLE M. VALOIS (Mortgagor( s) and Record Owner( s)) 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 Action of Mortgage Foreclosure Term No. 04-6096 Defendant(s) TO: JANELLEM. VALOIS 11 Ashburg Drive Lot 59 Mechanicsburg. PA 17055 IMPORTANT NOTICI?, YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY A TIORNEY AND FILE IN WRITING WITIi THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTIl AGAINST YOu. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITIlOUT A HEARING AND YOU MAY WSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TillS OFFICE CAN PROVIDE YOU WITIl INFORMATION ABOUr HTRING A LAWYER. IF YOU CANNOT AFFORD TO H1RE 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. LEGAL SERVICES lNC 8 Irvine Row Carlisle, PA n013 7I 7-243-9400 CUMBERlAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 GOLDBECK McCAFFERTY & McKEEVER BV: Joseph A. Gold""'k. Jr.. Esq. Attorney for Plaintiff Suite 5000 - Menon Independence Center. 701 Market Street Philadelph'ia,PA 19106 215--627~1322 MT-040S -;. THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF TIllS NOTICE: December 29, 2004 TO: DONALD J. V ALOlS 11 Ashburg Drive Lot 59 Meclumicsburg. PA 17055 MANUFACTURERS & lRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 In the Court of Common Pleas of Cumberland County Plaintiff CIVIL ACTION - LAW vs. DONALDJ. VALOIS JANELLE M. VALOIS (Mortgagor(s) and Record Owner(s)) 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 Action of Mortgage Foreclosure Term No. 04-6096 Defendant(s) TO: DONALDJ. VALOIS 11 A,hburg Drive Lot 59 Mechanic,burg. P A 17055 TMPORTANTNonCR YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITIEN APPEARANCE PERSONALLY OR BY ATIORNEY AND FILE IN WRITING WITH TIlE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTIl AGAINST YOU. UNLESS YOU ACT WlTIllN TEN (10) DAYS FROM TIlE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIlER lMPORTANf RIGlITS. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW. TIllS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIR1NG A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS 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. LEGAL SERVlCES INC 8IIvineRow Carlisle, PA 17013 717-243-9400 CUMBERlAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, 1r., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 101 Market Street Philadelphia, PA 19106 215-627-1322 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY. PENNSYLVANIA CIVIL ACTION - LAW MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 Plaintiff No. 04-6096 vs. DONALD J. VALOIS JANELLE M. VALOIS (Mortgagors and Record Owner(s)) I I Ashburg Drive Lot 59 Mechanicsburg, P A 17055 Defendant( s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long proth::l '-- Hr' f2... p ,2.7f~ Deputy If you have any questions concerning the above, please contact Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PAl 91 06 215-627-1322 ~ t;jd~0 \L ~ \) F ~ ~ ~ ~ "'v ~ t, t-l ~ , ' ~. ~:?} y, :i~ :?-;\ L.- ',;1-,.--:::' ~,~: .- -nl.'~J ~J\ \..Cl l._.:;, (??, ~:. ", 'I ~: ~-) -', ~ !"II , , .-- '::'-1 :~ '.~~2. -..l - PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jf. Attorney 1.0.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST COMPANY S/BIM KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 Plaintiff vs. DONALDJ. VALOIS JANELLE M. VALOIS Mortgagor(s) and Record Owner(s) 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 Defendant( s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 04-6096 TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount Due Interest from 03/01/2004 to 01113/2005 at 10.7500% (Costs to be added) $117.744.97 s -p, + ~ ~t ?-.J ~ t ~ l t' ~ V'\ l ~~ V1. C> \:: \::.. r- ti' f w \n-"-.J~ YJ :I-J....c ~ ~ .c f(\ \-'~~B~~~ \ _ _ _ r:J;) - - - ~ ~r :::..:.:..--* , --A " -- -- i.P ??:~ - -- .- co) co ~ -- , ~ l;; 6 ...." ~<t '" '" ~ tu o~ ;:::: ~ ~8 Ij ~~ ~ G ~ ~~ ,,<> 0 ... ~~~.- ~ " ""' ~e. </J(ll l</J~"'''"' <>"'" 6 %~ ,.. ""'0 \oil" Q .$ ~og'-'~ oo~r- 'S " '" ~ %(/1 4. ~ ~~ 5::?:~5~ ~~ ~p: ~ ~""' . ~u o " -o~ ~~1i~~ oj, 0",,", l~ ~o I'<~ >" ~,~ .- "..... ~ ~ ;;'.a..o '?'$~A~ 4. ,.. u~~,g..~ @"Iu %e J; a i~'Oi~ ,,""~ ? ,...;';:!; ~ ~"% ~ ,...00 ~ 0 ,...I'.l ~,...l",,~a ~t:. ~ "",Ir-$ ~~ <<15 ~ -- ~ '" 0 "0 ""' o4..e 1"''' ~ ,"0 .- ~\J, 5 ~- CJ \oil ~o ~ ,..""' ~~ ...-. 01)"--' ~ e:: ~.~ A ;: ~ % \ " </J ,... ':i~ -- ,... ~ <>-e '::Jif> ~ ~ .~ ALL THAT CERTAIN BUILDING LOT DESlGNA TED AS LOT NO. 59, LOCATED IN SILVER SPRING TOWNSHIP, CUMERBLAND COUNTY, PENNSYL V ANlA, AS SHOWN ON A FINAL LAND SUBDIVISIO PLAN OF PHASE I OF WATERFORD SQUARE, PREPARED BY H. EDWARD BLACK AND ASSOCIATES AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN SUBDIVISION PLAN BOOK 67, PAGE 74 AND BEING MORE FULLY BOUNDED AND DESCRIBED AS FOLLOWSI: BEGINNING AT A POINT, SIAD POINT BEING LOCATED ALONG THE SOUTHERN RIGHT OF WAY LINE OF ASHBURG DRIVE; THENCE CONTINUING ALONG THE SOUTHERN RIGHT OF WAY LINE OF ASHBURG DRIVE, BY A CURVE TO THE LEFT, SAID CURVE HAVING A RADIUS OF 660.00 FEET, A TANGENT LENGTH OF 7.00 FEET, AND AN ARC LENGTH OF 13.99 FEET TO A POINT, SAID POINT LOCATED ALONG THE SOUTHERN RIGHT OF WAY LINE OF ASHBURG DRIVE; THENCE CONTINUING ALONG SAME, BY A BEARING OF NORTH 53 DEGREES 5 MINUTES 42 SECONDS EAST, A DISTANCE OF 23.16 FEET TO A POINT: THENCE CONTINUING ALONG LANDS NOW OR FORMERLY OF W ATERFORM SQUARE, LOT 58, BY A BEARING OF SOUTH 29 DEGREES 36 MINUTES 43 SECONDS EAST, A DISTANCE OF J 38.28 FEET TO A POINT, SAID BEING LOCATED ALONG LANDS NOW OR FORMERLY PF W ATERFORD SQUARE LOT 60 BY A BEARING OF NORTH 29 DEGREES 36 MINUTES 43 SECONDS WEST, A DISTANCE OF J 35.00 FEET TO A POINT, SAID POINT BEING THE PLACE OF BEGINNING. Goldbeck McCafferty & McKeever BY: Josenh A. Goldbeck, Jr. ,. Attorney I.D. #16132 Suiie 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CNIL ACTION - LAW DONALD J. VALOIS JANELLE M. VALOIS (Mortgagor(s) and Record Owner(s)) II Ashburg Drive Lot 59 Mechanicsburg, P A 17055 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 04-6096 AFFIDAVIT PURSUANT TO RULE 3129 MANDY ACTURERS & TRADERS TRUST COMPANY S/BIM KEYSTONE FINANCIAl BANK NA, 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: 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 I.Name and address ofOwner(s) or Reputed Owner(s): DONALD J. VALOIS II Ashburg Drive Lot 59 Nlcl;hanicsburg, P A 17055 JANELLE M. VALOIS II Ashburg Drive Lot 59 Mechanicsburg, P A 17055 2. Name and address ofDefendant(s) in the judgment: DONAlD J. VALOIS II Ashburg Drive Lot 59 Mechanicsburg. P A 17055 JANELLE M. VALOIS 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 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 '" P A DEP ARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg. P A 17105-2675 W A TERFORD SQUARE VILLAGE HOMEOWNERS ASSOC 2961 SPANGLER ROAD MANHEIM,PA 17545 4. Name and address of the last recorded holder of every mortgage of record: GMAC MORTGAGE CORP 3200 PARK CENTER DRIVE SUITE 150 COSTA MESA. CA 92626 PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street PO BOX 15057 Harrisburg, P A 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 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 (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. GOLDBECK McC BY: Joseph A. Gol Attorney for Plaint! Y & McKEEVER , Esq. DATED: January 13,2005 ----- . ~~ ~ eft (-- :::::.,.. ,--T o.D ::-;,~ 04-6096 , GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttomeyI.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST COMPANY S/BIM KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW VS. DONALD J. VALOIS JANELLE M. VALOIS Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE II Ashburg Drive Lot 59 Mechanicsburg, P A 17055 Term No. 04-6096 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: VALDIS, DONALD J. DONALD .I. VALOIS 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 Your house at II Ashburg Drive Lot 59, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday. June 08, 2005, at 10:00 AM. in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $117 ,744.97 obtained by MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA 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: 1. The sale will be cancelled if you pay to MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA, the back payments, late charges. costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 04-6096 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. Yau 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 ifthis has happened, you may call the Sheriff of717-240-6390. 4. Hthe 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 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. PA 17013 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, P A 17013 f-~, C:..) r"") C;:;::J :'11 c..n ,- ~ ;'?'~ (,) CD 04-6096 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorneyl.D.#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST COMPANY S/B/M KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW VS. DONALD J. VALOIS JANELLE M. VALOIS Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 11 Ashburg Drive Lot 59 Mechanicsburg, PA 17055 Term No. 04-6096 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: v AWlS. JANELLE M. .JANELLE M. VALOIS II Ashburg Drive Lot 59 Mechanicsburg, P A 17055 Your house at 11 Ashburg Drive Lot 59, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 08, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$117 ,744.97 obtained by MANUFACTURERS & TRADERS TRUST COMPANY S/B/M KEYSTONE FINANCIAL BANK NA 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: 1. The sale will be cancelled if you pay to MANUFACTURERS & TRADERS TRUST COMPANY SIB/M KEYSTONE FINANCIAL BANK NA, the back payments. late charges. costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 04-6096 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. Yau 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 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 fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have 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 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, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 ------- . .. ~ ()l ~ -I <:...1'\ ,- -"~,-~ :,;:,,- - \.-::,) - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-6096 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA Plaintiff (s) From DONALD J. V ALOlS AND JANELLE M. V ALOlS (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 the garnishee(s) that: (a) an attaclunent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attaclunent 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. AmountDue $117,744.97 Interest FROM 3/1/04 TO 1113/05 AT 10.7500% L.L. $.50 Atty's Comm % Atty Paid $132.66 Plaintiff Paid Date: JANUARY 19, 2005 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) . pr~tho"Z ~. /)4-0 P 7fr/?/?AJ r--- Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 .. ...... SHERIFF'S RETURN - REGULAR CASE NO: 2004-06096 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS VALOIS DONALD J ET AL CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon VALOIS DONALD J the DEFENDANT at 2016:00 HOURS, on the 8th day of December, 2004 at 11 ASHBURG DRIVE LOT 59 MECHANICSBURG, PA 17055 by handing to DONALD J. VALOIS a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 6.66 .00 10.00 .00 34.66 ...-".:f:;;:f;./'" 'r~ R. Thomas ./;-;? .,:~.iJ~~,~~2:~..~~ Sworn and Subscribed to before 12/09/2004 GOLDBECK MCCAFFERTY MCKEEVER By: J--- -. 1/,7 tf:t-.. . . .. .A~.4/ Depyty Sheri f . .... me thls 10 - day of (l~UJ~ "1 dl (,V,{ A.D. I) ~ U.I L.- Q f}AAPP.h-> --. 'j Prothonotary ; ~ SHERIFF'S RETURN - REGULAR CASE NO: 2004-06096 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS VALOIS DONALD J ET AL CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon VALOIS JANELLE M the DEFENDANT J at 2016:00 HOURS, on the 8th day of December, 2004 at 11 ASHBURG DRIVE LOT 59 MECHANICSBURG, PA 17055 by handing to DONALD J VALOIS, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 e(';!P"" R. Thomas Kline <~"'-~. ...t:~ p' 12/09/2004 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscribed to before By: l:~2P;? J De ty SheriM x:., me this Jt) ~ day of q'-:'AIU'-7 ~ :/ A. D. ~ Q 1vuJ~_ ~ Prothonotary / .\ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney \.0. #16132 Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST COMPANY S/B/M KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. DONALD J. VALOIS JANELLE M. VALOIS (Mortgagor(s) and Record owner(s)) 11 Ashburg Drive Lot 59 i Mechanicsburg, PA 17055 No. 04-6096 PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Settled, Discontinued and Ended upon payment of your costs only. fJI~ ... JOSEPH A. GOLDBECK, JR., ESQUIRE C-., () t;;:::) C~::) ~d ';;"1'1 --.\ -'"]-" ::r'" ~ - -< C-\ " .. .' C:? (..rJ -. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST COMPANY S/B/M KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland Counly Plaintiff VS. No. 04-e096 DONALD J. VALOIS JANELLE M. VALOIS (Mortgagor(s) and Record owner(s)) 11 Ashburg Drive Lot 59 !Mechanicsburg, PA 17055 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs only. fJloat)- JOSEPH A. GOLDBECK, JR., ESQUIRE S c:.:'.) c..r1 <-t -" I'll Cf\ ~--? (...,.) . 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 AttQl11e for Plaintiff CITIFINANCIAL SERVICES INC. 14415 South 50th Street Suite 100 Phoenix, AZ 85044 CIMD-0488 06/08/2005 $64,370.68 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LA W vs. ACTION OF MORTGAGE FORECLOSURE SONYA R. CRULL Mo~tgagor(s) and Recbrd Owner(s) Term No. 04-6291 14 Pickes Road Newville, PA 17241 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (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: )IlL ( ) ( ) ( ) Personal Service by the Sheriffs Office/"",..."__ . (copy of return attached). 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). I ~) The undersigned understands that the statements herein are subject to the penalties provided by I";. .S, ". if SectIOn 4904. .' . .")' . . L I '.",.' /..t'.'" ! I /Re p I 7s!, ~ .' d,! I I, / . <{ ; I L.- ,\.I <- B:A oldbe ,Jr ttorney for Ylaintiff lj L-/ oJ ,..- Q ~ s.'~ o .~ b ". '" <:P ~ <:P :" ~ ro 9; ~ '" o \3 "ii '" <P <1> ~ 9.- ~ ) ) Xl ~ ,... .>: \ c""' "'SC roO'. ~" S[c ~~ " ~ ~~ ~10 ~ \! w ,,""' ,,^SC 1l\" <\" ~~ 10~ %-9.. ~10 " -Ii \!w n o 3 -g. \!. " !.a ~ 'i ~ S- F 0.. '" ~ ." o 3' ~ ." " " ~, -0 \ ~ ~\ -0 '" ~ ~ SC ~' z\ 3' i\ ~\ <J> ~ ." :I. " ~ "1\ ... ~ ~ i ~ o :> 7? " " ~ " --.l \ \ '\ \ " \ /~J~-\'-' , . ~------. --- G> "" , \ \ \ \ /\ '" N\ \or-.,..~'-- ,,,,~=-I'\'-'ro \~O'p",to~ \"'1'\?J01'\0. \~~~g~6'. '\ ~~ ~ 1" -I '" ~. _ -oWt ;; \" ' l> \'T\ ~ ~ \ ~ 0- 3 '" '1: ". 9 \',\\\CiC ~ ~~og2 ~ \c ~~, oa 9.- U2, ~ 3 is ~ =-'~ Q. % 5 " ,---------~~-_._- :1:",,:1:"':2 0",,00 (l>' ",~F 0>000 ;9~roo ~OJc.s. (Jl 'CP~p.1 rn ~o 3.~ tro c:-u ~ )'t-<.v-?;, ~~~9...'J:> "'O~ ::J ~\ tDN'D.()?:l "]?'o () '~j,l~~\ ~ ~ ~ ~ ~ ~ ~~ cP ~ ~ ~ (1)-0 - q, ~"5 <;?, ~ ~ N tO~-o (1)'" ~ \ ~c 0 g (]\ ::O.-ol'l~ --n\'{/) 00..-0 o,li- a C) C \- 3'" Z ", \>0 t,~ ';!! ~. %~\i\ \ N~~ :Xl q "--~ ~~" , 0 '" ~ ~ i']':JUU (fl-;;o7J7J "U'8 C 3 'Wa ;; " 'R'R o~ 0 ~,; ~, 39: ~ g~ 3' ~g. % ~ ~- 0. 0 % ~ -.---------- (j) {j)N () -0 )>cjSO ~ c.:::i'-"t, ~ ,...[11[11[11 ~TjO ~OoO o 1'" :::i o~ -< "Z,7' :c z..- -1.:...8 ~ 0 ~ '" \~ "J> -"$' ~ ~ :=;;". "I! '$"- !~< ",,,- \',.10 z~-I ",,,,,[11 ~'T1Z _.6~ ::::-?,k a:.~--~ -(]'I (j) "';0- ,)> 00 \-'" ~ () ",,0.0 t-' C ,,,,, '" ,~.-~ ~ ~ '~i~~ ~~ ;T_9:g,,&)( -n '3 v> ~~~(f) It 9.,t.) %o:fto-~ ;or---a-Q.,~3 ro Ol :J ~ jll"'O ~? '>>-.iSi :I IOX:;'O- g %' <] \,,&~ ,%lp ct ....,~ <I> :1'3 --~.. ~----- ~- -,~------ ~~ ~ ~i .~ o ~IO ou> g\ .. !/\\l~:\ \\\/fl~\ ------~--- _.--~-- c-~\ /~. r\ .=\ ~,-"" Citifinancial Services, Inc. VS Sonya R. Crull In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-6291 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on April 21, 2005 at 4:36 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Sonya R. Crull, by making known unto Sonya Crull, at 14 Fickes Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 08, 2005 at 7:23 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Sonya R. Crull located at 14 Fickes Road, Newville, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Sonya R. Crull, by regular mail to her last known address of 14 Fickes Road, Newville, PA 17241. This letter was mailed under the date of April 25, 2005 and never returned to the Sheriffs Office. Sworn and subscribed to before me This _ day of ~~~~ R. Thomas Kline, ~eriff" 2005, A.D. Prothonotary B\\ iH~J vvu1:h Real E tate Deputy j I GOLDBECK McCAFFERTY & McKEEVER - BY: Joseph A. Goldbeck, Jt. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 70 J Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 14415 South 50th Street Suite 100 Phoenix, AZ 85044 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. SqNY A R. CRULL M~rtgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 14 fickes Road Nelvville, PA 17241 Term No. 04-6291 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL SERVICES INC., PJaintiffin 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 loc~ted at: 14 Fickes Road Newville, PA 17241 I.N~me and address ofOwner(s) or Reputed Owner(s): SONYA R. CRULL 14 Fickes Road Ne,wille,PA 17241 2. Nf'me and address of Defendant(s) in the judgment: SONYA R. CRULL 14 Fickes Road Newville,PA 17241 3. N~me 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 ofCbild Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 . 4. Name and address of the last recorded holder of every mortgage of record: CONSECO BANK 2825 E. COTTONWOOD P ARKW A Y SUITE 230 SALT LAKE CITY, UT 84121 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. ljIame 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 14 Fickes Road Newville, PA 17241 (attach separate sheet ifmore 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 relaling to unsworn falsification to authorities. DATED: May 3, 2005 r' .:<,~ ..'.', ".>'l 0" -'() c,'I " .'. .r:;-' ...._._.._,-~--"'~-~..__.._----------- Certified Mail Provides: . A mailing receipt ,,;J.~'.la,1.)lii (;oa(~ ounr 'oom; \JJJQ::I Sd . A unique identifier lor vour rnailpiece . A record 01 delivery kept by the Postal Service tor two years Important Reminders: . Certified Mail may ONL'( t,le comblnud with h;~ji-Class M<'lIlfr~ or Plio ,ritv Mail<[,. . Certified Mail is nnl ava'llable for any class 01 intornational mail . NO INSURANCE COVERAGE IS PROVIDED with Cer1itiod Mai, For valuables, please consider Insured or Registered Mail . For an additional fee, a Refurn Recelpl may be requested tOcfrovide prool of delivery. To obtain Return Receipt service, please complete an atttich a Return Receipt (PS Form 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 USPS,,~ postmark on your Certified Mall receipt IS reqUired . For an additional lee. delivery may be leslricteo tc tt'e addressee or addressee's authorized aQenl. Advise the derk or mark the mailpiece.with the endorsement "Restrlcted7)elivery" . If a postmark on tile Certified Mail rt~c"'lpl is rJesirecj ple,';ge presen: the arti," cle al the post office for postlTlarkLl19. if a postmark on the Certified Mail receipt ;::: not needed, detach and aHix label with pos\age and m~i 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. Manufacturers & Traders Trust Company VS Donald J. Valois and Janelle M. Valois In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-6096 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Joseph Goldbeck. Sheriffs Costs: Docketing Surcharge Poundage Levy Advertising Mileage Posting Handbills Share of Bills Law Journal Patriot News Postage Prothonotary 30.00 30.00 2,142.23 15.00 15.00 11.84 15.00 16.47 246.80 297.40 .74 1.50 $2,821.98 Sworn and subscribed to before me \ This .2 ?~ay of '------J~ / 2005, A.D. (),1'- () In.;//L, ~ Prothonotary so:~ ~ "4t:~~ R. Thomas Kline, Sheriff J, ~1) Or..- 5-0:J. If.- ~. I'S':J 1'{ GolObeck McCafferty & McKeever , BY: Joseph A. Goldbeck, Ir. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW DONALD J. VALOIS JANELLE M. VALOIS (Mortgagor(s) and Record Owner(s)) 11 Ashburg Drive Lot 59 Mechanicsburg. PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 04-6096 AFFIDAVIT PURSUANT TO RULE 3129 MANUFACTURERS & TRADERS TRUST COMP ANY SIBIM KEYSTONE FINANCIAL BANK NA, 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: 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 I.Name and address of Owner(s) or Reputed Ovmer(s): DONALD J. VALOIS 11 Ashburg Drive Lot 59 Mechauicsburg, P A 17055 JANELLE M. VALOIS 11 Ashburg Drive Lot 59 Mechauicsburg, P A 17055 2. Name and address of Defendant(s) in the judgment: DONALD J. V ALOlS 11 Ashburg Drive Lot 59 Mechanicsburg, PA 17055 JANELLE M. VALOIS II Ashburg Drive Lot 59 Mechanicsburg, P A 17055 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 P A DEP ARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 W ATERFORD SQUARE VILLAGE HOMEOWNERS ASSOC 2961 SPANGLER ROAD MANHEIM, PA 17545 4. Name and address of the last recorded holder of every mortgage of record: GMAC MORTGAGE CORP 3200 PARK CENTER DRIVE SUITE 150 COSTA MESA, CA 92626 PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street PO BOX 15057 Harrisburg. P A 1710 I 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/OCCUP ANTS 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 (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. GOLDBECK McC BY: Joseph A. Gal Attorney for Plainti DATED: January 13. 2005 04-6096 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttomeyI.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST COMPANY S/B/M KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. DONALD J. VALOIS JANELLE M. VALOIS Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 11 Ashburg Drive Lot 59 Mechanicsburg, P A 17055 Term No. 04-6096 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: VALOIS. DONALD). DONALD d. VALOIS 11 Ashburg Drive Lot 59 Mechanicsburg, PA 17055 Your house at 11 Ashburg Drive Lot 59, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 08, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $117,744.97 obtained by MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: L The sale will be cancelled if you pay to MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 04-6096 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 fmd out the price bid price by calling the Sheriff 0017-240-6390. 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 thc Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff 0017-240-6390. 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 maybe 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 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 Sheriffwilhin ten (10) days after the schedule of distrihution is filed. 7. You may also have other rights and defenses, or ways ofgetling 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 04-6096 GOLDBECK McCAFFERTY & McKEEVER BY, Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. DONALD J. VALOIS JANELLE M. VALOIS Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 1 I Ashburg Drive Lot 59 Mechanicsburg, P A 17055 Term No. 04-6096 Defendant(s TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. TillS 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: VALOIS. JANELLE M. .JANELLE M. VALOIS 11 Ashburg Drive Lot 59 Mechanicsburg, PA 17055 Your house at 11 Ashburg Drive Lot 59, Mechanicsburg, PA 17055 is scheduled to be sold at Sberiffs Sale on Wednesday, June 08, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $117 ,744. 97 obtained by MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale yon must take immediate action: 1. The sale will be cancelled if you pay to MANUFACTURERS & TRADERS TRUST COMPANY SIBIM KEYSTONE FINANCIAL BANK NA, the back payments, late charges, co.ts and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 04-6096 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 7 17-240-6390. 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 [md 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 maybe 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 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 SERVJCES me 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ALL THAT CERTAIN BUILDING LOT DESIGNATED AS LOT NO. 59, LOCATED IN SILVER SPRING TOWNSHIP, CUMERBLAND COUNTY, PENNSYLVANIA, AS SHOWN ON A FINAL LAND SUBDIVISIO PLAN OF PHASE I OF W ATERFORD SQUARE, PREPARED BY H. EDWARD BLACK AND ASSOCIATES AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN SUBDIVISION PLAN BOOK 67, PAGE 74 AND BEING MORE FULLY BOUNDED AND DESCRIBED AS FOLLOWSI: BEGINNING AT A POINT, SIAD POINT BEING LOCATED ALONG THE SOUTHERN RIGHT OF WAY LINE OF ASHBURG DRIVE; THENCE CONTINUING ALONG THE SOUTHERN RIGHT OF WAY LINE OF ASHBURG DRIVE, BY A CURVE TO THE LEFT, SAID CURVE HA VING A RADIUS OF 660.00 FEET, A TANGENT LENGTH OF 7.00 FEET, AND AN ARC LENGTH OF 13.99 FEET TO A POINT, SAID POINT LOCATED ALONG THE SOUTHERN RIGHT OF WAY LINE OF ASHBURG DRIVE; THENCE CONTINUING ALONG SAME, BY A BEARING OF NORTH 53 DEGREES 5 MINUTES 42 SECONDS EAST, A DISTANCE OF 23.16 FEET TO A POINT; THENCE CONTINUING ALONG LANDS NOW OR FORMERLY OF WATERFORM SQUARE, LOT 58, BY A BEARING OF SOUTH 29 DEGREES 36 MINUTES 43 SECONDS EAST, A DISTANCE OF 138.28 FEET TO A POINT, SAID BEING LOCATED ALONG LANDS NOW OR FORMERLY PF W A TERFORD SQUARE LOT 60 BY A BEARING OF NORTH 29 DEGREES 36 MINUTES 43 SECONDS WEST. A DISTANCE OF 135.00 FEET TO A POINT, SAID POINT BEING THE PLACE OF BEGINNING. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MANUFACTURERS & TRADERS TRUST COMPANY S/B/M KEYSTONE FINANCIAL BANK NA Plaintiff (s) From DONALD J. VALOIS AND JANELLE M. VALOIS NO 04-6096 Civil CIVIL ACTION - LAW (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 garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $117,744.97 Interest FROM 3/1104 TO 1113/05 AT 10.7500% L.L. $.50 Atty's Comm % Due Prothy $1.00 Other Costs Atty Paid $132.66 Plaintiff Paid Date: JANUARY 19, 2005 CURTIS R. LONG (Seal) Prothonotary ~ p~~ {7 P .7[r/l4-'J~ ~ Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQillRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale #14 On February 14,2005 the Sherifflevied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA Known and numbered as 11 Ashburg Drive, Lot 59, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 14,2005 By:JD~~ Real Estate Deputy c=T) c::v\l c::;:;:;] s::;::::::l ~ g;;;l Sl :l d f l NVr ~OOl Vd 'AIHIIOj ON Vlti-)[NilJ :HIH3HS 3Hl ..-JO 35,.:i..-JO f~~, THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant 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 The Sunday 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 andlor Sunday! Metro editions which appeared on the 26th day(s) of April and the 3rd and 10th day(s) of May 2005. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M". Volume 14,Page317. COpy SA L E #14 bed befO~S 25th day of PUBLICATION Sworn to and su CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 297 AO Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... .~4' ~ AIL nw <3TAINbuiJding lot designaIed uLotNo..59Jilail<dioSlMr SjlriDg Townsbip, ~ o.uar,~." _...fiDaltlDiISoIidlriiilIIPlaiof_I en Watafotd ~, ~ by H. I!dwaRI B1ackandAsaocialeaaof~in1beOfficeof 1be Roi:oo\or of Decda .in and for CumbcrIand Colmly, ~lvaoia. iD SubdMsioo Pbn IlODk 67, l"F 74 and beinB ..... folly bounded and _aafollowa: BI!llINIlING " . poiIl, aid . bliiIIg 1ocatod~'1be""""rif'l-<il-::'liDeof Ashbulg Drive; -. ........., aIoog 1be soadJ<mript.<Jt:.wayliDeofAallllorgom.,by' curve to 1be Idl. aid ""'" having . _ en 61i1JDfeel,._la>&thof7.oofeet.andanan: lalgthof13~leolto.poial.aidpoint- aIoog 1be _ ~.<Jt:.way IiDe of AalIluq Drive;-..' t' t-.by........, enDm1hS3__S.-.42_...... ms.-of23.I6feetto.poinI;_COllIiIlIIing aIoog_aow..~WalafeimSqum, Lot58,by........,ensOulb29de&tW<a36 minutes45_....,._oft38.21lfeet to . point,aid...locall:d.aIODi__ .. fcamaIy ofw.iol(" Lot~by........, ofDm1h29~.36_43_-.. _of~~......aidpoilllllilli lbopl8a1. . . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEAL TH OF PENNSYL VANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, ofthe 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, V1Z: April 15,22,29,2005 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 state1T'_~nts as to time, place and character of publication are true. ditor SWORN TO AND SUBSCRffiED before me this 29 day of April NOTARIAL SEAL LOIS E. SNYDER, Notary Public Ca~isle Bora, Cumberland County My Commission Expires March 5, 2009 REAL ESTATE SALE NO. 14 Writ No. 2004-6096 CMl Manufacturers & Traders Trust Company. sJb/m Keystone Financial Bank N.A. vs. Donald J. Valois and Janelle M. Valois Atty.: Joseph Goldbeck ALL THAT CERTAIN buildIng lot designated as Lot No. 59. located in Silver Spring TownshIp. Cumer- bland County, Pennsylvania. as shown on a Final Land Subdivisio Plan of Phase r of Water ford Square. prepared by H. Edward Black and Associates and recorded in the Of- fice of the Recorder of Deeds in and for Cumberland County. pennsylva- nia, in subdivision Plan Book 67, Page 74 and being more fully bounded and described as follows: BEGINNING at a point, siad point being located along the southern right of way line of Ashburg DI1ve; thence continuing along the south- ern right of way line of Ashburg Drive. by a curve to the left, said cunre having a radius of 660.00 feet, a tangent length of 7.00 feet, and an arc length of 13.99 feet to a point, said point located along the southern right of way l1ne of Ash~ burg Drive: thence continuing along same, by a bearing of North 53 de- grees 5 minutes 42 seconds East, a distance of 23.16 feet to a point; thence continuing along lands now or formerly of Waterform Square, Lot 58. by a bearing of South 29 degrees 36 minutes 43 seconds East, a distance of 138.28 feet to a point, said being located along lands now or formerly pfWaterford Square Lot 60 by a bearing of North 29 degrees 36 minutes 43 seconds West, a distance of 135.00 feet to a point. sajd point being the place of beginning.