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HomeMy WebLinkAbout01-4941GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. RANDI S. SWEENEY Mortgagor(s) and Real Owner(s) 91 Cold Springs Road Carlisle, PA 17013 Defendant(s) iN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL ACTION: M(~RTGAGE FORECLOSURE THIS 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 de fend against the claims set forth in the following pages, you must take action within twenty (20) days afier the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the eour~ 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 Mthout you and a judgment may be entered against you by the Court wifllout fm~her notice for any money claim in the Complaint of for any other claim or relief requested by the Plainfi~ You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COIONq~5 BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-940~ AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QLrE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA y AVISO. PARA DEFENDERSE ES NECESSARIO QLrE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED y CUALQUIER OB JECCION CONTRA LAS QUEIAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGU1R CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USIED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (2I 5) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 LiberOj Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is FIRST NATIONWIDE MORTGAGE CORP., PO Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481. 2. The name(s) and address(es) of the Defendant(s) is/are RANDI S. SWEENEY, 91 Cold Springs Road, Carlisle, PA 17013, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On August 20, 1999 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to CTX MORTGAGE CO., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1565 Page 708. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned mortgage was assigned to: FIRST NATIONWIDE MORTGAGE CORP. by Assignment of Mortgage dated December 17, 1999 as Book 633 Page 894; and these documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payment of principal and interest upon said mortgage due December 01, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 11/01/2000 through 08/31/2001 at 8.5000% Per Diem interest rate at $21.69 Attorney's Fee at 5.0% of Principal Balance Late Charges from 12/01/2000 to 08/31/2001 Monthly late charge amount at $41.78 Costs of suit and Title Search Escrow Debit Monthly Escrow amount $0.00 $91,851.30 $6,593.76 $4,592.57 $376.02 $750.00 $104,163.65 +$1,107.94 $105,271.59 The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. Notice of Intention to Foreclose and a Notice of Homeowners, Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $105,271.59, together with interest at the rate of $21.69, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. ;0~LDBI~K McCAF~ERTY & McKEEVER B~: JOSEPHA. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Sherry Stinson, 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 belie£ I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. POBERT F. ZIEOLER- REOORDER OF DEEDS CU&IDERLAND COUNTY-pA '99flUG83 fl~lO3~ PARCEL I.D.NO; 08-32-2326-022 THIS DEED, ' MADETHE2 day of August in the year one thousand nine hundred nlnety.nlne (1999), BETWEEN KENNETH D. HYKES and DIANA M. H Y/~E S, his wife, o f Gardners, Cumberland County, Pennsylvania, here/heifer called Grantors, AND RANDI SWEENEY, of Mechanicsbutg, Cumberland County, Pennsylvania, hereinafter called Grantee: P/1TNE$$ETH, that in consideration of ~he sum of Ninety Thousand Nine Hundred no/100 ($90,900.00) Dollars, in hand paid, the receipt whereof is hereby ackno ededged, the said Grantor does hereby grant and convey unto the said Grantee, his he/rs and assigns ALL that certain tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded/md described ~s BEGINNING at a post on the eastern side of the Cold Springs Road at the comer of lands previously conveyed to M. A.~.hur Naylor and Grace Lac Naylor, his wife; thence along said Cold Springs Road, North 23 degrees East 140 feet to a point at llne of lands previously conveyed to Chm'les Lithe; thence by said latter lands, South 72 degrees East 250 feet to a point; thence by the same, North 23 degrees East i0 feet to a point; thence by the same, South 72 degrees East 100 feet to a point at line of lands now or formerly of ~'ohn P. McCoy; thence by the same, South 23 degrees West I50 feet to a point; thence by l~nds of M. Arthur Naylor, et ux, North 72 degree~ West 350 feet to a post on the e~tem side of the Cold Springs R6ad, the Place of BEGINNING. UNDER AND SUBJECT to the restrict/oas which shall be binding upon the Gramecs, thek heirs and vssigns, that no temporary or permanent pazk/ng of any trailer or mobile type home shall be caroled out on said premises, or any par~ thereof. BEING the same premises which Diana M. Hykes, grated and conveyed to Kenneth D. Hykes and Diana M. Hykes, his wife, Oramar~ herein, by their deed dated Aprll 14, 1995 and recorded in Cumberland County Deed Book 120, Page 1058. IN WITNESS I~HE~OF, said grantors have hereunto set their hands and seals thc day, month and year first above written. Sealed and Delivered in the presence of KENNETH D. HYK~S ~rYKES 206 ~E 257 ($-~) 'IST NATIONWIDE MORTF_U ~0. B~x Gai~ersburg. MD 208~8-9481 EXHIBIT A June 20, 2001 Certified Mail Return Receipt Requested Randi S Sweeney 9! Cold Springs Rd Carlisle PA 17013-9109 RE: Loan No. 0022163646 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice tha5 the mortqaqe on your home is in default, and the lender intends 5o foreclose. Specific information about the nature of the default is provided in the at~ached pages, The HOMEOWNER'S MORTGAGE ASSISTkNCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the counseling agency. The name, address, and phone number oX the Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearing ca~ call (717)780-1869.) This Notice contains, important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traducc±on immediata/nente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes set elegible para un prestamo por el programa llamado "Homeowner's ~mergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF400-003/C30 June 20, 2001 Loan No. 0022163646 Page 2 PA ACE 91 Homeowner's Name: Randi S Sweeney Property Address: 91 Cold Springs Ro Carlisle PA 17013 Loan Account NO.: 0022163646 Original Lender: CTX Mortgage Co. Current Lender/Servicer: First Nationwide Mortgage 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 PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIOIBLE FOR EMERGENCY 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 ESTANLISHED BY THE PENNSYLVANIA HOUSIN~PINANCE 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 aEtend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE TO DATE. THE PART OF THIS NOTICE CALLED "BOW TO CURE YOUR MORTGAGE DEFAULT," EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. DF403-001/C30 June 20, 2001 Loan NO. 0022163646 Page 3 CONSUMER CREDIT COUNSELING AGENCIES - I9 you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of the designated consumer credit counselin~ a~encies for coU/~ty in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATIONS FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at 5he end of this Notice. Only consumer credit counseling agencies have applications for the progra~ and they will assist you in s~bmitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE }{AY 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 eligi- bility criteria established by the Act. The Pennsylvania Housing DF403-001/C30 June 20, 2001 Loan No. 0022163646 Page 4 PA Act 91 Finance Agency hag sixty (60) days to make a decision after i% receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. YOU will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brin~ it up to date) First Nationwide Mortgage Corporation (FNMC) acknowledges that you have previously filed for protection under the Bankruptcy Code. Accordingly, FNMC is not attempting to impose personal liability against you to collect the debt that has been discharged under bankruptcy. The purpose of this letter is to notify you of the present intent of FNMC to initiate foreclosure proceedings solely against the above-referenced real property used to secure your mortgage loan, should the sLatus of your loan remain delinquent. Any information FNMC obtains from you will be used for the purpose of foreclosing on the real property. NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 91 Cold Springs Ro Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVENOTMADE YOUR MONTHLY MORTGAGE PAYMENTS Cot the following months and the following amounts are now past due: 7 Months at $835.69 = Months at $ Months at $ = Late Charges Bad Check Fees Foreclosure Fees Bankruptcy Fees Other Fees Less suspense Balance TOTAL AMOUNT DUE 5,849.83 .00 .00 66.86 .00 .00 890.00 7.00 471.84 6,341.85 AS OF THIS DATE DF404-001/C30 June 20, 2001 Loan No. 0022163646 Page 5 PA Act 91 MOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTA/~ AMOUNT PAST DUE TO THE LENDER WHICH IS $ 5,923.69 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES W~ICH BECOME DUE DURING THE THIRTY (3-0) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check~ or money order made payable and sent to: First Nationwide MortGage Corporation Dept. 0107 Palatine, IL 60055-0107 IF YOU DO NOT CURE THE DEFAULT - If yOU do not cure 5he default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise 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 of the total a~ount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attor- neys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the a~ount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, will not be required to pay attorney's fees. DF404-001/C30 June 20, 2001 Loan No. 0022163646 Page 6 PA ACt 91 OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR THE SHERIFF'S SAJuE - 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's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and cost connected with the foreclosure sale and other cost connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately 6 months from the date of this Notice. A notice o~ the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action wall be by contacting the lender. HOW TO CONTACT THE LENDER: First Nationwide Mortgage Corporation 5280 Corporate Drive Frederick, MD 21703 Department 2S2 ~-800-888-4333 EFFECT OF TEE SHERIFF'S SALE - You should realize that the Sheriff's Sale wall end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You, UPON OUR CONSENT may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. ¥OU MA¥ ALSO MA%rE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO KAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALF~VDARY~AR.) * 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. DF405-001/C30 C4)LDBECK MCCAFF~RTY & MCKEE~ JOSEPH A. ~OLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEV~K, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. : IN THE COURT OF CfH~4ON PLE~ PO Box 9481 : ~ Mail Code: 22-528-1011 : OF CUMBERI2h%~ coUnTY -' Gaithersburg, ~ 20898-9481 : : vs : NO. 01-4941 Civil RANDI S. SWEEN~Y : (Mortgagor and Real Owner) : 91 Cold Springs Road : Carlisle, PA 17013 : Plaintiff, by and through its attorney, McKeever, Esquire, in support of its Motion for Service, represents as follows: 1. Plaintiff is the holder of a premises 91 Cold Springs Road, Carlisle, the "mortgaged premises.. 2. Defendant, RA~DI S. SWEENEY, owner of the mortgaged premises. Michael T. Substituted first mortgage upon the PA 17013, hereinafter, is the mortgagor and real 3. The last known address of Defendant is 91 Cold Springs Road, Carlisle, PA 17013 as set forth in Paragraph 2 of the Complaint. 4. The Sheriff has been unable to effect service of the Complaint upon Defendant at her last known address after numerous attempts. 5. The following investigationwas conducted in a good faith atte~m~t to ascertain the whereabouts of Defendant. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the C~laint upon Defendant byposting the premises and certified and regular mail to the Defendant's last known address. B : MICHA~""~. MCKEEvER, ESQUIRE GOLDBECKMCCAFFERTY &MCKEEVER JOSEPH A. GOLDBRCK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MC~E~, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff FIRST NATIONWIDEMORTC4%GE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, ~D 20898-9481 vs RANDI S. SWEENEY (Mortgagor and Real Owner) 91 Cold Springs Road Carlisle, PA 17013 : IN T~ COURT OF CO~W~N PLRAS OF CUMBERLANDCOUNTY No. 01-4941 Civil I, MICHAEL T. MCKEEVER, ESQUIRE, Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. BY: MIC~A~ T. MCKEE~K, ESQUIRE GOLDBECK MCCAFFERTY &~CK~EVER JOSEPH A. ~OLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MC~EVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff FIRST NATIONWIDEMORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 vs RANDI S. SWEENEY (Mortgagor and Real Owner) 91 Cold Springs Road Carlisle, PA 17013 IN -r.~Js COURT OF CO~40N PT.R~,S OF CUMBERLAND COUNTY NO. 01-4941 Civil M~MORAND~OFLAW IN SUPP~gT OF MOTIn~ FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendant which the Sheriff has been unable to personally serve upon Defendant. As noted in the attached Motion, Plaintiff has made a good faith attest to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). For reasons stated above and in the attached Motlon, the Court should enter an order allowing Plaintiff to serve the Cuu~laint in Mortgage Foreclosure upon Defendant by posting the premises and certified mail and regular mail to the Defendant's last known address. Respectfully submitted, /~ k~AE~ T. 'M(IKEE~K, ESQUIRE PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: Attorney Firm: Case Number: Subject: A.K.A.: Property Address: Last Known Address: FN-0259 GOLDBECK, MCCAFFERTY & MCKEEVER RANDI S SWEENEY RANDI SCOTT SWEENEY 91 COLD SPRINGS ROAD CARLISLE, PA 17013 91 COLD SPRINGS ROAD CARLISLE, PA 17013 Last Known Number: ( ) Michael K Gross, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of President for Players National Locator. 2. On 08/16/2001, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - a. SOCIAL SECURITY NUMBER: - - B. EMPLOYMENT SEARCH: Unable to locate a good employer for Randi. C. INQUIRY OF CREDITORS: The creditors indicated that Randi is living at 91 Cold Springs Road, Carlisle, Pa. 17013 with no valid home phone number. Randi filed chapter 7 bankruptcy in May 2001 with attorney Matthew Eshelman. Case # 2001-2777 with no release date given. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: The directory assistance has no listing for Randi Sweeney. Contacted 562-943-3962 and spoke with a relative who stated Randi is living at 91 Cold Springs Road, Carlisle, Pa. 17013. INQUIRY OF NEIGHBORS - NIA INQUIRY OF POST OFFICE - A, NATIONAL ADDRESS UPDATE: As of August 13, 2001 the National Change of Address (NCOA) has no change for Randi from 91 Cold Springs Road, Carlisle, Pa. 17013. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Randi listed at 91 Cold Springs Road, Carlisle, Pa. 17013. OTHER INQUIRIES - A. DEATH RECORDS: As of August 13, 2001 the Social Security Administration has no death record on file for Randi S Sweeney and or a.k.a.'s under her social security number. PUBLIC LICENSES ( PILOT, REAL ESTATE, ETC. )'. None Found COUNTY VOTER REGISTRATION: The Cumberland County Voters Registration Office has Randi listed at 91 Cold Springs Road, Carlisle, Pa. 17013. OTHER SEARCHES- Social security number provided was verified. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: 02163 /~ y at~ona/ Locater 113 Old State Road, Suite 104 St. Louis, MO 63021 Phone: (636) 230-g922 Fax: (636) 230-0558 SHERIFF'S RETURN - NOT SERVED CASE NO: 2001-04941 p COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS SWEENEY RANDI S R. Thomas Kline , Sheriff according to law, says, that he made a diligent the within named DEFENDANT , to wit: SWEENEY R3LNDI S unable to locate Her in his bailiwick. He COMPLAINT - MORT FORE who being duly sworn search and inquiry for but was therefore returns the the within named DEFENDANT NOT SERVED , as to SWEENEY RANDI S UNABLE TO SERVE PRIOR TO EXPIRATION. Sheriff's Costs: Docketing 18.00 Service 6.50 Affidavit .00 Surcharge 10.00 .00 34.50 SHERIFF OF CUMBERLAND COUNTY GOLDBECK MCCAFFERTY MCKEEVER 09/24/2001 Sworn and subscribed to before me this day of A.D. Prothonotary GOLDBECKMCCAFF~/(TY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MC~VER, ESQUIRE Attoz~ley I.D. #56129 Attorney for Plaintiff FIRST NATIONWIDEMORTC4~GE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, ~) 20898-9481 vs RANDI S. SWEENEY (Mortgagor and Real Owner) 91 Cold Springs Road Carlisle, PA 17013 IN Tg~ COURT OF C09~K)N PLEAS OF COMBEPJ~ND COUNTY No. 01-4941 Civil CERTIFICAT~ OF SERVIC~ MICHAEL T. MCK~EV~R, Esquire, do hereby certify that true and correct copies of the the foregoing Motion for Substituted Service have bccn served upon the Defendant this ~ day of October, 2001, by first class mail, postage prepaid. BY: MICHAEL T. MC~E~K, ESQUIRE ~OLDBECKMCCAF~KTY & MCKE~ JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff FIRST N~TIONWIDEMORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 vs ~ANDI S. SW~ENEY (Mortgagor and Real Owner) 91 Cold Springs Road Carlisle, PA 17013 : IN THE COURT OF CO~WON PLEAS OF CD]~BERLAND COUNTY NO. 01-4941 Civil AND NOW, this upon consideration of Service under Pa.R.C.P. ~ day of (~ 2001, the Plaintiff's Motion for Substituted 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant has been unsuccessful, it is, O~n~U and DECREED: that Plaintiff's Motic~ is granted and the Sheriff and/or Plaintiff is directed to Serve the Co,a~laint in Mortgage Foreclosure upon Defendant by posting a copy of the Complaint upon the premises 91 Cold Springs Road, Carlisle, PA 17013 and Plaintiff is directed to serve the Complaint by certified and regular mil to the Defendant's last known address of 91 Cold Springs Road, Carlisle, PA 17013 and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and rec3ular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by se~ding copies of s~ to Defendant's last known address by certified and regular mail and by posting the premises. BY T9~ COURT: / GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 $. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. RANDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 Defendant(s) 1N THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4941 CIVIL PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff SHERIFF'S RETURN - CASE NO: 2001-04941 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS SWEENEY RANDI S REGULAR SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SWEENEY RANDI S the DEFENDANT , at 1402:00 HOURS, on the 9th day of November , 2001 at 91 COLD SPRINGS RD CARLISLE, PA 17013 POSTED PROPERTY AT a true and attested copy of by handing to 91 COLD SPRINGS RD CARLISLE COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 4.55 Posting 6.00 Surcharge 10.00 .00 38.55 Sworn and Subscribed to before me this =IL ~ day of A.D. ~ ~rotK~notary ~ / / So Answers: R. Thomas Kline 11/13/2001 GOLDBECK .FF~~ MCCAFF ~ MCK ~ R ~ By: Q~ Depu~y;t~ f ~--- "~ GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECI~ JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-101l Gaithersburg, MD 20898-9481 VS. RANDI S. SWEENEY Mortgagor(s) 91 Cold Springs Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4941 CIVIL CERTIFICATE OF SERVICE JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on il -Iq-'~ I he did serve upon Defendant(s) RANDI S. SWEENEY a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated OCTOBER 22, 2001. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, GOLDI~'~rC~[ ~cCAI~L~tl>Y & McKEEVER BY: JOSEPH A.K~OLDBECK, JR. ESQUIRE 1N THE COURT OF COMMON PLEAS OF Cumberland COUNTY 'FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff Vs. RANDI S. SWEENEY (Mortgagor and Record Owner) 91 Cold Springs Road Carlisle, PA 17013 Defendant No. 01-4941 CIVIL PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES 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. Kindly enter judgment in favor of the Plaintiffand against RANDI S. SWEENEY, Defendant for failure to file an Answer to Plaintiffs Complaint within 20 days (or 60 days if defendant is the United States of America) from the date of service of the complain and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest - 9/1/01 - 12/28/01 Late Charges TOTAL $105,271.59 $ 2,581.11 $ 167.12 $108,019.82 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. (~ Jose~A. Gold,ok, Jr. Att~ey for Plaintiff I.Eb~16132 DAMAGESDATE: k.~,.~.~a~ARE HEREBY ASSESSED AS INDICATED. ~_-d.,~ ~ '~. PRO PROTHY AND NOW ,._ J ~ ~ , ~ ~ ~,~ , Judgment is entered in favor of FIRST NATIONWIDE MORTGAGE COR~P. and against RAI~DI S. SWEI~NEY by default for want of an Answer and damages assessed in the sum of $108,019.82 as per the above certification.~,~.~a_)~ ~ _ /r)~ -~ Prothonotary 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 10, 2001 TO: RANDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 VS. RANDI S. SWEENEY (Mortgagor(s) and Record Owner(s)) 91 Cold Springs Road Carlisle, PA 17013 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 01-4941 CIVIL TO: RANDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITfEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LEGAL SERVICES ][NC 8 ]rvlne Row Carlisle, PA 17013 717-243-94~0 Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 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. relating to unsworn falsification to authorities. 4904 1. That the above named Defendant, PJ%NDI S. SWEENEY, is about unknown years of age, that Defendant's last known residence is 91 Cold Springs Road Carlisle, PA 17013 and is engaged in the unknown business located at unknown address. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: December 28, 2001 ~~ Jos~ A. G//dbeck, Jr. Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. No. 01-4941 CIVIL RANDI S. SWEENEY (Mortgagor and Record Owner) 91 Cold Springs Road Carlisle, PA 17013 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/~u. Curt Long Prothonotary {. - vefiuty If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 FIRST NATIONWIDE MORTGAGE CORP. Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA VS. : NO: 01-4941 CIVIL RANDI S. SWEENEY Defendant : PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 12/28/01 to sale date at $17.76 per diem Total $108,019.82 Plus Costs Philadelphia, PA 19106 Attorney for Plaintiff Note: Please attach description of property. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff Vs. RANDI S. SWEENEY (Mortgagor and Record Owner) 91 Cold Springs Road Carlisle, PA 17013 Defendant IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - L~W ACTION OF MORTGAGE FORECLOSURE Term No. 01-4941 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 91 Cold Springs Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner{s): PJ~NDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 2. Name and address of Defendant(s} in the judgment: RANDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: December 28, 2001 GOLD~K McCAF~TY & McKEEVER SY:~U~eph A.~ldbeck, Jr., Esq. ArVey for ~Flaintiff Jospeh A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff Vs. RANDI S. SWEENEY (Mortgagor and Record Owner) 91 Cold Springs Road Carlisle, PA 17013 Defendant IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE TERM NO. 01-4941 CIVIL CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Jospe~/A. Gol~ck, Jr. Atto~y for~aintif f GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-948 l Plaintiff Vs. RANDI S. SWEENEY (Mortgagor and Record Owner) 91 Cold Springs Road Carlisle, PA 17013 Defendant 1N THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4941 CIVIL 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: SWEENEY, RANDI S. RANDI $. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 Your house at 91 Cold Springs Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 05, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $108,019.82 obtained by FIRST NATIONWIDE MORTGAGE CORP. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE p. lll,E TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORP., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to 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. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 71%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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES 1NC 8 Irvine Row Carlisle, PA 17013 ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a post on the eastern side of the Cold Springs Road at the comer of lands previously conveyed to M. Arthur Naylor and Grace Lee Naylor, his wife; thence along said Cold Springs Road, North 23 degrees East 140 feet to a point at line of lands previously conveyed to Charles Lillie; thence by said latter lands, South 72 degrees East 250 feet to a point; thence by the same, North 23 degrees East 10 feet to a point; thence by the same, South 72 degrees East 100 feet to a point at line of lands now or formerly of John P. McCoy; thence by the same, South 23 degrees West 150 feet to a point; thence by lands of M. Arthur Naylor, et ux, North 72 degrees West 350 feet to a post on the eastern side of the Cold Springs Road, the place of BEGINNING. Tax Parcel #08-32-2326-022 Being known as 91 Cold Springs Road, Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff Vs. RANDI S. SWEENEY (Mortgagor and Record Owner 91 Cold Springs Road Carlisle, PA 17013 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 01-4941 Civil 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: Personal Service by the Sheriffs Office/competent adult (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 Attomey for Defendant(s) (proof of acknowledgment attached). Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF~ERVICE WAS ACCOMPLISHED BY COURT ORDER. ~}~c 7'0~ W_ $~n-h' e 5h,,-,~'(-S O¢~'1" ~)o?lniSO Premises was posted by Sheriffs Office/c___~._~. ' - ~'" ,'__~_~ _f ........... ! "~,~ ' 2,~ ] f'l O~-- , Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectful~d, ~.~ o BY: Joseph"A./C~ldbeck, ~r[/ Attorney for PVntiff First Nationwide Mortgage Corp. VS Randi S. Sweeney In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4941 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on February 15, 2002 at 8:54 o'clock pm, EST, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Randi S. Sweeney, by posting the premises located at 91 Cold Springs Road, Carlisle, Cumberland County, Pennsylvania, pursuant to a court order. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on April 5, 2002 at 8:44 o'clock P.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Randi S. Sweeney located at 91 Cold Springs Road, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Randi S. Sweeney, by regular mail to his last known address of 191 Cold Springs Road, Carlisle, PA 17013. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriff's Office. Sworn and subscribed to before me This 2002, A.D. __ day of Prothonotary So Answers: R. Thomas Kline, Sheriff Real Estate Deputy GOLDBECK M~CAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATION-WIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. RANDI S. SWEENEY (Mortgagor and Record Owner) 91 Cold Springs Road Carlisle, PA 17013 Defendant IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4941 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 1.Name and address of Owner(s) or Reputed Owner(s): R3%NDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: RA/qDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 91 Cold Springs Road Carlisle, PA 17013 FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: December 28, 2001 716D 3901 9844 6553 5509 TO: SWEENEY, RANDI S;' RANDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER December 28, 2001 REFERENCE: SWEENEY, RANDI S./FN-0259 PS Form 3800, June 2000 RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees POSTMARK OR bAT~E US Postal Service /;,/ Receipt for (~i Certified Mail V .~, No Insurance Coverage Provided Do Not Use for International Mail X.~~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND )[ SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Veterans Affairs, Sec is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2002, under and by virtue of a writ Execution issued on the 2nd day of January, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 4941, at the suit of First Nationwide Mtg Corp against Randi S Sweeney is duly recorded in Sheriff's Deed Book No. 252, Page 3749 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~ay of~, A.D. 20~_~. 5~L- Recorder of Deeds First Nationwide Mortgage Corp. VS Randi S. Sweeney In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4941 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on February 15, 2002 at 8:54 o'clock pm, EST, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Randi S. Sweeney, by posting the premises located at 91 Cold Springs Road, Carlisle, Cumberland County, Pennsylvania, pursuant to a court order. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on April 5, 2002 at 8:44 o'clock P.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Randi S. Sweeney located at 91 Cold Springs Road, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Randi S. Sweeney, by regular mail to his last known address of 191 Cold Springs Road, Carlisle, PA 17013. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 5' 2002 at 10:00 o'clock A.M. He sold the same for the sum of $I.00 to Attorney Joseph Goldbeck for Secretary of Veterans Affairs. It being the highest bid and best price received for the same, Secretary of Veterans Affairs of 5000 Wissahickon Ave., Philadelphia, PA 19144, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $624.01, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 12.24 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Service 8.28 Certified Mail 1.79 Levy 15.00 Surcharge 20.00 Posting 6.00 Law Journal 204.95 Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 174.55 25.20 25.00 29.50 $624.01 paid by attorney 07/10/02 Sworn and subscribed to before me This .2o ~e&"dayof 2002, A.D.~, Tromonotary ' - ' So Ans~we~ R. Thomas Kline, Sheriff Real Estate 'Deputy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland COUNTY: NO. 01-4941 .CIVIL ~ TERH CIVIL ACTION - LAW - To satisly Ihe debt. interest and costs due _Fi~_st Nationwide Mortrgage Corp. PLAINTIFF(S) from Randi S. Sweeney, 91 Cold Springs Road, Carlisle, PA 17013 .... DEFENDANT(S) (1) You are directed Io levy upon the properly of the defendant(s) and to self S~_e r~,~gal Description (2) You are also directed to attach lhe property of Ihe defendant(s) nol levied upon in lhe possession of GARN SHEE(S) as follows: and Io notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of Ihe defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; · (3) If properlyof the defendant(s) not levied upon an subject to attachment is found in ihe POSSession of anyone other than a named garnishee, you are directed to notify hinVher that ha/she has been added as a garnishee and is enjoined as above stated. Amount Due $108,019.82 L.L. $. 50 frcm 12/28/01 to sale date at -.- .... per ..... Due Prolhy. $1. nn Atty's Corem % Olher Costs Arty Paid $145.05 Plaintiff Paid January 2~ 2002 REQUESTING PARTY: Name Joseph A. Goldbeck, Jr., Esq. Address: Suite 500 - The Bourse Bldg. 11 ~~qc~atl East-- Philadelphia__, PA 19106 Altorney for: ~ Telephone: 215-6:)7-1322._ Supreme Court ID No. 16137 Curtis R. Long Prothonotary, Civil Division Deputy GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff Vs. R3~NDI S. SWEENEY (Mortgagor and Record Owner) 91 Cold Springs Road Carlisle, PA 17013 Defendant IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4941 CIVIL AFFIDAVIT PURSU~'~T TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 91 Cold Springs Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): RANDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: R3~NDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: · 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, DATED: December 28, 2001 BY:~eph A./~ldbeck, Jr., Esq. ArVey for ~Flaintiff GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff Vs. RANDI S. SWEENEY (Mortgagor and Record Owner) 91 Cold Springs Road Carlisle, PA 17013 De~ndant IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4941 CIVIL THIS LAW FIRM IS A DEBT COLLECTOR AND ~VE 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: SWEENEY, RANDI S. RANDI S. SWEENEY 91 Cold Springs Road Carlisle, PA 17013 Your house at 91 Cold Springs Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 05, 2002, at 10:00 AM, in Commissioners Heating Rm 2nd FL Courthouse to enforce the court judgment of $108,019.82 obtained by FIRST NATIONWIDE MORTGAGE CORE. 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 FIRST NATIONWIDE MORTGAGE CORP., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to 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. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriffof 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 Sheriffthirty (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 FrND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liben'y Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a post on the eastern side of the Cold Springs Road at the comer of lands previously conveyed to M. Arthur Naylor and Grace Lee Naylor, his wife; thence along said Cold Springs Road, North 23 degrees East 140 feet to a point at line of lands previously conveyed to Charles Lillie; thence by said latter lands, South 72 degrees East 250 feet to a point; thence by the same, North 23 degrees East 10 feet to a point; thence by the same, South 72 degrees East 100 feet to a point at line of lands now or formerly of John P. McCoy; thence by the same, South 23 degrees West 150 feet to a point; thence by lands of M. Arthur Naylor, et ux, North 72 degrees West 350 feet to a post on the eastern side of the Cold Springs Road, the place of BEGINNING. Tax Parcel #08-32-2326-022 Being known as 91 Cold Springs Road, Carlisle, PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and 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 Mamh 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the 7th day(s) of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M', Volume 14, Page 317. PUBLICATION COPY '~ ~wurn tu =.d =uuov.. .... ~.;:'; m;~l~ 17th dav~f M~002 A.D / ~a~, Oa~n C~n~y ~ ~ ~,~m~/~. ,~.,~ My C~misslon E~ires June 6, 2~ ~ ' ~ ~ ~ ~' r~ ~a~ Me.er, P~nsy~ania As~at~ ot Nota~c°mmlssi°n expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs BB3a~N~3 .*. ~ ~'~ ~ ~ of ~ To TH E PATR I OT-N EWS CO., D r. cola st~ t~,d~ ~ ~ of lad~' For publishing the notice or publication attached ~ ~ N,ylor. his wit',; ~ ahi~ raid hereto on the above stated dates $ 1 72.80 Cohi s~ ~ No~ ~ ~ca~-a I~ast ~40 Probating same Notary Fee(s) $ 1.75 ~, to OjFI~ U~e; +,~ b~ ~ I~- lands, Total $ 174.55 by I~e a~rn=, N~ 23 ~ Eaat 10 feet to. pohit;am=~,.~a~m Publisher's Receipt for Advertising Cost I00 f~et t~ atv. nt at line of lan~h ww ur formerly ~Ja~a_P..McCoy;ttm~bytt~um~soath23 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. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 26, MAY 3, 10, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 19 Writ No. 2001 4941 Civil First Nationwide Mortgage Corp. VS. Randi S. Sweeney Atty.: Joseph A. Goldbeck ALL THAT CERTAIN tract of land situate in Dickinson Township. Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a post on the eastern side of the Cold Springs Road at the corner of lands previ ously conveyed to M. Arthur Naylor and Grace Lee Naylor. his wife: thence along said Cold Springs Road, North 23 degrees East 140 ~enthal, Editor SWORN TO AND SUBSCRIBED before me this 10 dayof MAY, 2002_ , L~'~ ~.~r0ER, ~lot~ ~ REAL ESTATE SALE No. Iff On February 7, 2002, the sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA, known and m~mbered as 91 Cold Springs Road, Carlisle and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 7, 2002 By: ',.J o _~ jgt4~( ~ Real Estate Dep~ity AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELE(~¥ED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- Jng left to right across perf. Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits. Otherwise affix to back of mailpiece. 2. If you do not want the receipt postmarked, stick the article # label to lhe right of the return address, date receipt and retain the receipt. 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mailcenter, or post office service window. (SEE ILLUSTRATION) 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt. ......... 5, Save this receipt and present it if you make an inquiry. .................................................................... : ................... :~:;~...: ................