The URL can be used to link to this page

Home My WebLink About05-0153 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GoLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. F/KJA AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CNIL ACTION - LAW Plaintiff Term CIVIL ACTIO~<MOATGAGE FO~eCLott~F C- O~ - IS::' d.((.>~ L l~ NOTICE l 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 for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 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 LA WYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THA T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. vs. CHRISTOPHER G. DELCAMPO Mortgagor and Real Owner 395 Peiper Road Shippensburg, P A 17257 ACTION OF MORTGAGE FORECLOSURE Defendant LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Carlisle, P A 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENT ADAS, ES ABSOLUT AMENTE 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 ESCRIT A, 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 NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE EST A 'DEMANDA. POR RAZON DE ESA DECISION, ES POSSffiLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, V A Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. EST A 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 SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 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. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either ofthe following numbers: 717-243- 9400 or . 2). Call Pennsylvania Housing Finance Agency at 800-342-2397 for a counseling agency in your neighborhood. 3). Visit HUD'S website www.hud.gov/offices/hsg/sfh/econ/econ.cfm for Help for Homeowners Facing the Loss of Their Homes. 4). Call your lender 800-641-4978 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call Carol at 215-825-6329 or Nancy at 215-825-6358 or fax 215-825-6429 or 215-825-6458. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is Edward Sparkman who can be reached at 215-825-6318 or Fax: 215-825- 6418. Please reference our Attorney File Number of CWD-4130. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER, 7105 Corporate Drive, PTX B-35 PIano, TX 75024-3632. 2. The name and address ofthe Defendant is CHRISTOPHER G. DELCAMPO, 395 Peiper Road, Shippensburg, P A 17257-9425, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On April 14, 2000 mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to AMERICA'S WHOLESALE LENDER, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book: 1607 Page: 14.. The Mortgage and Assignment( s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g) which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" . 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due September 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 08/01/2004 through 01/31/2005 at 9.2500% Per Diem interest rate at $31.84 Reasonable Attorney's Fee If the Mortgage is reinstated prior to a Sheriff's Sale the Attorney's Fees may be less than this amount based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff reserves its right to collect Attorney's fees of up to 5% of the remaining principal balance ($6,282.53) in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Late Charges from 09/0112004 to 01/31/2005 Monthly late charge amount at $53.68 Costs of suit and Title Search Monthly Escrow amount $235.79 $125,650.63 $5,858.55 $1,250.00 $268.39 $900.00 $133,927.57 7. Plaintiff is not seeking a judgment of personal liability (or in personam judgment) against the Defendant in this Action but reserves it's right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been se~t to Defendant 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 "B". The Defendant has 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 through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $133,927.57, together with interest at the rate of$31.84, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property. By: c ~j{J~ CK cCAFFERTY & McKEEVER SEPH A. GOLDBECK, JR., ESQUIRE .PI.. ORNEY FOR PLAINTIFF VERIFICATION I, Michael D. Vestal, 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: J - fo -D) ~D.V# Michael D. Vestal COUNTRYWIDE HOME LOANS INC. (4 ii3it Jl ::;- --- -.-------- -----~- - --~-. .. Lel!al Description: (As sbown on,Mortl!82e) ALL THAT CERTAIN REAL ESTATE LYING AND BEING SITUATE IN SOUTHAMPTON TOWNSHlP, CUMBERLAND COUNTY, PENNSYLV AN1~ BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN AT LINE OF LANDS NOW OR FORMERL V OF AL-HART INC., THENCE ALONG LANDS NOW OR FORMERLY Or AL-~RT INC., NORTH 65 DEGREES 53 MINUTES 31 SECONDS WEST, 607.51 FEET TO AN IRON PIN AT LINE RIGHT OF WAY OF UNITED STATES ROUTE NUMBER 81; THENCE ALONG mE RIGHT OF WAY OF UNITED STATES ROUTE NUMBER 81, NORTH 43 DEGREES 49 MINUTES 28 SECONDS EAST, 211.49 FEET TO AN IRON PIN; THENCE ALONG SAME, NORTH 43 DEGREES 49 MINUTES 28 SECONDS EAST 883.97 FEET TO AN IRON PIN; THENCE SOUTH 46 DEGREES 10 MINUTES 32 SECONDS EAST, 35.09 FEET TO AN IRON PIN IN PEl PER ROAD (TOWNSHIP ROUTE T-301); THENCE IN PEIPER ROAD, (TOWNSHIP ROUTE T-301), SOUTH 10 DEGREES 30 MINUTES 59 SECONDS WEST, 716.30 FEET TO A RAILROAD SPIKE; THENCE CONTINUING IN SAID ROAD, SOUTH 14 DEGREES 6 MINUTES 29 SECONDS WEST, 114.01 FEET TO AN EXISTING RAIL ROAD SPIKE; THENCE IN THE SAME, SOUTH 24 DEGREES 6 MINUTES 19 SECONDS WEST, 299.98 FEET TO THE PLACE OF BEGINNING. CONTAINING 9.11 ACRES, MORE OR LESS, ACCORDING TO THE DRAFT OF SURVEY OF CARL D. BERT, PLS., DATED JUNE 17, 1995 AND BEING TRACT NOS. 1 & 2 THEREON. ~iijit CB SS30 (a/02) II Countrywide' HOME LOANS P.O. BOl/660694 Dallas, TX 75266-0694 Send payments to: P.O. Box 680694 DBh. TX 75266-0694 ShfJpsnsburg. PAI7257-DOOO November 2, 2004 Certified Mail No. Return Receipt Requested Regular Mall Account No.: 1872583 Property Address: 395 Pelper Road Shippensburg, P A Christopher G Delcampo 395 Perper Road Shippensburg, PA 17257-0000 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE ThiS Is an official notice that the mortaaae on your home is in default. and the lender Intends to foreclose. Specific Information about the nature of the default is provided in the attached paaes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save ~our home. This Notice 8XJ)lains how the oroJlram works. To ,see If HEMAP can help. vou 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 Counselil\Q AQencv. The names. addresses and phone numbers of Consumer Credit Counselina AGencies servina vour County are listed at the end of this Notice. If vou have anv Questions, YOU may call the Pennsylvania HouslnQ Finance Aaency toll free at 1-800.342.2397. (Persons with impaired hearlna can call 1-717-780-1869\. This Notice contaIns important legal Information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDlDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Christopher G DelcamDo PROPERTY ADDRESS: 395 Peloer Road ShiPDensburQ, PA 1872583 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: CountrYwide Home Loans ServicinQ LP 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 Please write your account number on all checks and correspondence. BLQPA 1 2783 1012812004 1.~-;..tN';';';;" 18n583.8 . , Christopher G Delcampo 395 Peiper Road Balance Due lor charges listed above: $3.946.27 as 01 December 2, 2004 Afooup"~($4Q"F4"bo"""I"i" ""Y,.\Ilmod"I~o:ted_'-_ _...........,..!>'d1I>llodbylf'F!oalHlaw, BLOPAl 1= CountrywIde P.O. Box 660694 . Dallas, TX 75266-0694 II. ul.I.lml.lrllu.II..Il'lllll..I.lllllllll.I,"I..llll.1l 1= ,- I Check 1011I SEE OTHER SIDE FOR IMPORTANT IHFOIIMAlION PSBue dO not.... beIowtillllne. 001872583800000394627000394627 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 BEYONDYOURCONTRO~ 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 RNANCE AGENCY. TEMPORARY ~AY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty-five (35) days from the date of this Notice. During that time you must arrange and attend a "face-to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 1351 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 DEFAUI-. T" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty-five (35) days after the date of this meeting. The names. addresses and teleohone numbers of designated consumer credit counseling aaencies for the county in which the orooertv 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. APPLICATION 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 lerder, you have the right to apply for financial assistance lrom the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency 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 wjll assist you in submitting a complete application to the Pennsylvania Housing Rnance Agency. Your application MUST be flied or postmarked within thirty-five (35) days of your lace-to-face meeting. YOU MlOO: FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO 00 SO OR F YOU 00 NOT FOllOW THE OTHER nME 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 criteria established by the Act The Pennsylvania Housing Fmance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you If you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency 01 its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED 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. (" you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 395 Peiper Road, Shlppensburg, PA IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the fOllowing amounts are now past due Monthlv Pavments: $1,317.97 Other charges (explain/itemize): 3,953.91 Late Charges: Other Charges: 53.68 107.36 .00 .00 $3.946.27 Uncollected Late Charges: Uncollected Costs: TOTAL AMOUNT PAST DUE: PAYMENT INSTRUCTIONS Pt_ . Make your check payall/e 10 Countrywide Home LDans . Write your llCCOUI1I number on your c!leek or money order . Write in any additional amounts}'OlJ are Including. (If total Is more than $5000. please send certified check.) . Don' attach your chock to Ihe payment COUPOll . Don' Include correspoodence . Don' S8IId cash paymenta: All paymenls will be appIiad 10 Ihe longest outstanding installment due. unless othB/Wise IlXpressly prohibited by law. AJf premium payments for credU life Insurance will be applied after epplicallon of any principal and Inletest paymenls due, buI before any otIIer amounts due on your loan ale eppliad, Addlllonal amounta. If you submn an addiiOllBl principal amount, an adcIlional escrow amount and/or an "other amount wih yo... regular home loan paylll8ll1 01 princlpaland interest, Countrywide wi. first apply your home loan payment before any add1ion81lll'llClunt is applied. II your home loan payments are not current, Counlrywide will filS! apply any addllional principalllIllOlllll and/or addiliOllal escrow amount to outstanding principal and inle,est payments due belOTe either add'~ional amount Is appllad. Any additional amount specified as "other' will be applied liIst to past due principal and interest payments. then escrow deflCleJlCies, !hen lele charges. then fees and costa due, then outslallding principal, 8 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (DO. not use if not aoplicable) HOW TO CURE THE DEFAULT - You may cure the default within THIRTY-FIVE (35) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,946.27, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY-FIVE (35) DAY PERIOD. Pavments must.be made,either by cashier';; check. certified check or money order made oavable and sent to: C6untrywk:le at P.O. Box 660694, Dallas, TX 75266-0694. You can cure any other default by taking the folfowina action within THIRTY-FIVE (35) DAYS Of the date of this letter. 100 not use if not applicable I IF YOU DO NOT CURE THE DEFAULT -If you do not cure the default within THIRTY-FIVE (35) DAYS of the date of this Notice, the lender intends to e~rclse its rights to accelerate the mortgage debt. This means that the entire 0lJtl!taIldiDg balance of this debt wiD be considered due immediately and you may lose the chance to pay the mortgage in monthly inslaUments. If full payment of the total amount past due is not made within THIRTY-FIVE (35) DAYS, the lender a~ interds to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property wiD be sold by the Sheriff to pay off the mortg~ge debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you wiD. stil be required to pay the reasonable attomey's fees that were actually incurted, up to $50.00. However, if legal prOceedings are started against you, you will have to pay aD reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. AffoJ attorney's fees wlR be added to the amount you owe the lender, which may also include pther ,reasonable costs. If you cure the default within the THIRTY-AVE (35) 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 surns due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SKERIFPS SALE -If you have not cured the default within the THIRTY- FIVE (35) 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 costs connected with the foreclosure sale and affoJ other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing affoJ 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. EARUEST POSSIBLE SHERIFPS SALE DATE - It is estimated that the earnest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of th~ Sheriff's Sale wiD 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 affoJ time exactly what the required payment or action will be by contactingthelende~ HOW TO CONTACT THE lENDER: Name of Lender: Countrywide Home Loans Servicing LP AcIdress: P. o. Box 660694 Dallas, TX 75266-0694 ~hone Number: 1-800-669-6654 Fax Number: 1-805-577-3432 {:ontact Person: Tara Cotton, MS PTX-36 Attention: Loan Counselor EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale wil 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 _mayor _may not (CHECK ONE) sell or transfer your home to a buyer or transferee who wiD assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTfTUTION TO PAY OFF THIS DEBT. TO, HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSfTlON 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 F='ROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION I;lY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your property, The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that tM property is occ~led and/or (Ill) determine the Identity of the occupant. If you do not cure the default prior to the Inspection, other actions to protect the mortgagee's Interest In the property (Including, but not Ilmiled to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. If you are unable to cure the default on or before December 2, 2004, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property, For example: . Repayment Plan: It is possible that you may be efigible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least v.. of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. . Loan Modification: Alternatively, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure afternative, however, is limited to certain loan types. . Sale of Your Property: Alternatively, if you are wRUng to sea your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed onit. . Deed-in-Lieu: Alternatively, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noterolder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will need to evaluate whether that assistance wiD be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Please be advised that fanura to bring the loan current or to enter into a written agreement for any one of the foreclosure alternatives outlined above on or before December 2, 2004 wil result In the acceleration of the debt. Time is of the essence. If you have any questions concerning this notice, please contact Countrywide's office immediately at 1-800-669-6654, extension 7556. -p p ~ g ~ ~ \t .lrr Q f'-,..) 0 C',,:) ~ C, <--..':> 11 ........ C.r1 ::;:l ~ L. - ()' '. ~.~': 6121 6' ~ 6' F! ::::;8 ~ (~, - . C) ~2 (~J -'-. ::-,.~ '-", -f1 :?~: ~:. (') ., , _:,,' rn j ,-~ . I.D ,,-, ,-_/ ( ~. '-I '-r> ~ 0- .- ::;'J -) -'- ,-< " ---J SHERIFF'S RETURN - REGULAR CASE NO: 2005-00153 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS DELCAMPO CHRISTOPHER G 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 DELCAMPO CHRISTOPHER G the DEFENDANT , at 1908:00 HOURS, on the 11th day of January ,2005 at 395 PEl PER ROAD SHIPPENSBURG, PA 17257 by handing to CHRISTOPHER G. DELCAMPO 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 Affidavi t Surcharge So Answers: 18.00 15.54 .00 10.00 .00 43.54 .r'M:~..<~ R. Thomas Kline 01/12/2005 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscribed to before By: ~~0~~ /Depu Y Sheriff/ me this ..- j1~ day of ,....)"^"" ""'I JdtJ,s' A. D. ~'(,. r2 nu;J!~~ p'othonotary f GOLDBECK McCAFFERTY & McKEEVER BY: JDseph A. Goldbeck, Jr. -Attorney LD, #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC, F/KiA AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX 8.35 Plano, TX 75024,3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS. CIVIL ACTION LAW CHRISTOPHER G, DELCAMPO (Mortgagor(s) and Record owner(s)) 395 Peiper Road Shippensburg, P A 17257 ACTION OF MORTGAGE FORECLOSURE Defendant(.) No, 05,153 ORDER FOR JUDGMENT Please enter Judgment in favor of COUNTRYWIDE HOME LOANS, INC, F/K/A AMERICA'S WHOLESALE LENDER, and against CHRISTOPHER G. DELCAMPO for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum 01'$134,885,68, I hereby certify that the above names are correct and that the prec e sidence address of the judgment creditor is COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 Plana, TX 75024-3632 and that the name(s) and last known addressees) of the Defendant(s) is/are CHRISTOPHER G. DELCAMPO, 395 Peiper Road Shippensburg, PA 17257.9425; GOLDBE BY: Joseph Attorney for I , . ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $125,650,63 Interest trom 08/0112004 through 0212112005 $6,527,19 REASONABLE Attorney's Fee $1,250,00 Late Charges $322.07 Costs of Suit and Title Search $900,00 Escrow Balance Deficit $235,79 ($0,00) $134,885,68 GOLDBECK M BY: Joseph A, G Attorney for Plai ti Y & McKEEVER ANDNOW,thiS)S.+l day of ~sb , 2005 damages are assessed as above, fk2-fA<U~ .~ Pro Prothy . . VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, CHRISTOPHER G. DELCAMPO, is about unknown years of age, that Defendant's last known residence is 395 Peiper Road, Shippensburg, PA 17257- 9425, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: , \ l > In the Court of Common Pleas of Cumberland County COUNTRYWIDE HOME LOANS, INC, F/KlA AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 Plaintiff vs, CHRISTOPHER G, DELCAMPO (Mortgagor(s) and Record Owner(s)) 395 Peiper Road Shippensburg, P A 17257 No, 05-153 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 ofPlaintitl and against CHRISTOPHER G, DELCAMPO by default for want of an Answer. Assess damages as follows: $134,885,68 Debt Interest - 08/01/2004 to 02/21/2005 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 a at east ten days prior to the date of the filing of this praecipe, A copy of the notice is attached, R,C.P, 237,1 AND NOW Jf' .h;:)"!; , d ODS , Judgment is entered in favor of COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER and against CHRISTOPHER Q, DELCAMPO by default for want of an Answer and damages assessed in the sum of$134,885,68 as per the above certification. C1A/2~ ~ 2 Prothonotary ---------- --------- ------ ------- ------------ --------- ------ . CWD-4130 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: February 1, 200S TO: CHRISTOPHER G. DELCAMPO 395 Peiper Road Shippensburg, P A 17257-9425 COUNTRYWIDE HOME LOANS, INC. FIKJA AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff Action of Mortgage Foreclosure vs, CHRISTOPHER G, DELCAMPO (Mortgagor( s) and Record Owner( s)) 395 Peiper Road Shippensburg, P A 17257 Term No, 05-153 Defendant(s) TO: CHRISTOPHER G. DELCAMPO 395 Peiper Road Shippensburg. PA 17257-9425 IMPORTANT NOTTCF, YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRlTING WITIl TIlE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACf WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITIlOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIlER IMPORTANT RIGHTS, YOU SHOUW TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITIl INFORMATION ABOUT AGENCIES THA T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, LEGAL SERVICES INC 81rv1ne Row Carlisle,PA 170\3 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, P A 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, Jr., Esq. Attorney for Plaintiff Suite saoo - MeHon Independence Center. 701 Market Street Philadelphia, PA 19lOG 2l5-627~l322 ~ (J~~~B \) +--~-c.J -, ~ ~ r- ~ 'l tv ~ ~ r "'" ~ \) ~ ~ r ~ ,; " - PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 ,.' Joseph A. Goldbeck, Jr, AttorneyI.D,#16132 Suite 5000 ' Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215,627,1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. FIK/A AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 Piano, TX 75024,3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS. CIVIL ACTION - LAW CHRISTOPHER G, DELCAMPO Mortgagor(s) and Record Owner(s) 395 Peiper Road Shippensburg, P A 17257 ACTION OF MORTGAGE FORECLOSURE No, 05-153 Defendant( s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $134,885,68 Interest from 08/01/2004 to 02/2112005 at 9,2500% (Costs to be added) GOLDBECK M BY: Joseph A. Attorney for PIa TY & McKEEVER <f) ~ ~ ~ <( ;>. - pi. 0~ ~\>l vi":' ~~ S'-" ~Ij 5g ';1::; ~ 8 ~ \-' ~ \,) ~ Ij llo< ~ \ Q.o ,,--: u to'" '" ~o 0 \-' 6,.. ~~ o u ~ \-' ~ if, ';> ;;; O.:!) p... ,., 2. % ~ "-..1.?- r-l. \,)0.,,<- ..-:!.-o~..-' ~\.-<o4. oSpi.p... '~'i) "" o p,.~ ~.-o.;-< ,..... ~~p:~ ';:C~'n 1U p.. :!:.- 0. P- O ,., '" P< o .- \-,611 8, if) ~ 'J~ %'S Ue.. ,., ~ ... " " " ~u "" >D ~ ~ 0 ,,~- "'~"OOM ~.... <V_ (:'l 06 it) l:;l. -"" (""'l frcn ~ ..-' ~.-O.....p.. 1 ..... ,. '1) ..r-- loo<....CJ~N Q,;/- ~.?'.O - P. (:Q~ I ~ 0 ~.2'1fl U;:::,~O....... /;,Ja)..--'.-QM '$~\"-~ ~O p... "0 ~~ ~" .~ - 1 fr ----t ~ ..... ,.. ';;J u" ~... ~$ "''U o " '; ~: ~~ "''$ .. ~ u ~ llo< '"" ,,"a ~ .~ "$!. ,gp... '06 0'..... ,'" <(e ~o ~~ o ~ < ~ /" fJ;i ~ ~ ~ - :r ~ d1 .(J ~ ~ ~ ~: ::; -::: ~ \ I <J <J ~t r-~ \ (j ::T a \.i) \- "'~ <l (j 0 (j l..1 1.1) - ~ () L; l..1 Vl ~ ~ 0- <'6 '"" \...J) ("'J - - =:r ~ "t>'l- .. ALL THAT CERTAIN REAL ESTATE LYING AND BEING SITUATE IN SOUTHAMPTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: . BEGINNING AT AN IRON PIN AT LINE OF LANDS NOW OR FORMERLY OF AL-HART INC., THENCE ALONG LANDS NOW OR FORMERLY OF AL-HART INC., NORTH 65 DEGREES 53 MINUTES 31 SECONDS WEST. 607,52 FEET TO AN IRON PIN AT LINE RIGHT OF WAY OF UNTIED STATES ROUTE NUMBER 81: THENCE ALONG THE RIGHT OF WAY OF UNITED STATES ROUTE NUMBER 81, NORTH 43 DEGREES 49 MINUTES 28 SECONDS EAST, 221.49 FEET TO AN IRONG PIN; THENCE ALONG SAME, NORTH 43 DEGREES 49 MINUTES 28 SECONDS EAST 883,97 FEET TO AN IRON PIN; THENCE SOUTH 46 DEGREES 10 MINUTES 32 SECONDS EAST, 35,09 FEET TO AN IRON PIN IN PEIPER ROAD (TOWNSHIP ROUTE T-3(1); THENCE IN PEIPER ROAD, (TOWNSHIP ROUTE '1'-301), SOUTH 10 DEGREES 30 MINUTES 59 SECONDS WEST, 716,30 FEET TO A RAILROAD SPIKE; THENCE CONTINUING IN SAID ROAD. SOUTH 24 DEUREES 6 MINUTES 29 SECONDS WEST, 124.07 FEET TO AN EXISTING RAIL ROAD SPIKE; THENCE IN THE SAME, SOlrrH 24 DEGREES 6 MINUTES 29 SECONDS WEST, 299.98 FEET TO THE PLACE OF BEGINNING, CONTAINING 9,11 ACRES, MORE OR LESS, ACCORDING TO THE DRAFT OF SURVEY OF CARL D. BERT, P,L.S" DATED JUNE 17, I 995 AND BEING TRACT NOS, 1 & 2 THEREON, PARCEL NO, 39-14-017I-()()6 WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 05-153 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER, Plaintiff (s) From CHRISTOPHER G. DELCAMPO, 395 PEIPER ROAD, SHlPPENSBURG, PA 17257 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant( s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the 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 $134,885.68 Interest FROM 8/1/04 TO 2/21/05 AT 9.2500% L.L. $.50 Atty's Comm % Atty Paid $125.54 Plaintiff Paid Date: FEBRUARY 25, 2005 Due Protby $1.00 Other Costs CURTIS R. LONG (Seal) Prothonotary <--!!y i2?12-12. {} 77!-JU./'iJ / 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 ..- ~,rd1ieck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr, Attorneoy LD. #16132 Su:\:e 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INe. F/K/A AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW CHRISTOPHER G, DELCAMPO (Mortgagor(s) and Record Owner(s)) 395 Peiper Road Shippensburg, P A 17257 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No, 05-153 AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS, INC, F/K/A AMERICA'S WHOLESALE LENDER, Plaintitfin 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: 395 Peiper Road Shippensburg, P A 17257 l.Name and address ofOwner(s) or Reputed Owner(s): CHRISTOPHER G, DELCAMPO 395 Peiper Road Shippensburg, P A 17257,9425 2, Name and address ofDefendant(s) in the judgment: CHRISTOPHER G, DELCAMPO 395 Peiper Road Shippensburg, PA 17257,9425 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 ,0, Box 2675 Harrisburg, PA 17105,2675 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 @ffected 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 395 Peiper Road Shippensburg, P A 17257 (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. [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: Februarv 2 L 2005 GOLDBECK Mice F BY: Joseph A. <j;ol~. eck J Attorney for PI\til' & McKEEVER , Esg, 05-153 , GOLDRECK McCAFFERTY & McKEEVER -,," Blf': Ioseph A, Goldbeck, Ir. Attorney I.D,#16132 Suite 5000, Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215,627,1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC, F/K/A AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs, CHRISTOPHER G, DELCAMPO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 395 Peiper Road Shippensburg, P A 17257 Term No, 05-153 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TOYOUIN 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: DELCAMPO, CHRISTOPHER CHRISTOPHER G. DELCAMPO 395 Peiper Road Shippensburg, PA 17257,9425 Your house at 395 Peiper Road, Shippensburg, P A 17257 is scheduled to be sold at Sherif!'s Sale on Wednesday, June 08, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$134,885,68 obtained by COUNTRYWIDE HOME LOANS, INC, FIK/A AMERICA'S WHOLESALE LENDER 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 inunediate action: I. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER, the back payments, late charges, costs and reasonable attorney's fees due, To tind out how much you must pay call: 215,627,1322 05-153 , 2.' 'lou 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 Sheritfs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sberiff 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 SheritIthe tull amount due in the sale. To tind 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 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 Sheritfs 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. Yau 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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 Joseph A. Goldbeck, JI. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberland County CHRISTOPHER G. DELCAMPO Mortgagor(s) and Record Owner(s) 395 Peiper Road Shippensburg, PAl 7257 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) NO. 05-153 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, JI., Esquire hereby certify that I am the attorney of record tor 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. ALL THAT CERTAIN REAL ESTATE LYING AND BEING SITUATE IN SOUTHAMPTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN [RON PIN AT LINE OF LANDS NOW OR FORMERLY OF AL-HART INe., THENCE ALONG LANDS NOW OR FORMERLY OF AL-HART INe., NORTH 65 DEGREES 53 MINUTES 31 SECONDS WEST. 607.52 FEET TO AN IRON PIN AT LINE R[GHT OF WAY OF UNTIED STATES ROUTE NUMBER 81: THENCE ALONG THE RIGHT OF WAY OF UNITED STATES ROUTE NUMBER 81, NORTH 43 DEGREES 49 MINUTES 28 SECONDS EAST, 221.49 FEET TO AN IRONG PIN; THENCE ALONG SAME, NORTH 43 DEGREES 49 MINUTES 28 SECONDS EAST 883.97 FEET TO AN [RON PIN; THENCE SOUTH 46 DEGREES 10 MINUTES 32 SECONDS EAST, 35.09 FEET TO AN IRON PIN IN PEIPER ROAD (TOWNSHIP ROUTE T-301); THENCE [N PEIPER ROAD, (TOWNSHIP ROUTE T-301), SOUTH 10 DEGREES 30 MINUTES 59 SECONDS WEST, 7[6.30 FEET TO A RAILROAD SPIKE; THENCE CONTINUING IN SAID ROAD, SOUTH 24 DEGREES 6 MINUTES 29 SECONDS WEST, 124.07 FEET TO AN EXISTING RAIL ROAD SPIKE; THENCE [N THE SAME, SOUTH 24 DEGREES 6 M[NUTES 29 SECONDS WEST, 299.98 FEET TO THE PLACE OF BEGINNING. CONTAIN[NG 9. I I ACRES, MORE OR LESS, ACCORD[NG TO THE DRAFT OF SURVEY OF CARL D. BERT, P.L.S., DATED JUNE 17, 1995 AND BE[NG TRACT NOS. 1 & 2 THEREON. PARCEL NO. 39- I 4-0 171-006 . GOUlBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 . Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106-1532 215-627-1322 Attorne for Plaintiff COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 CWD-4130 06/08/2005 $134,885.68 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE CHRISTOPHER G. DELCAMPO Mortgagor(s) and Record Owner(s) Term No. 05-153 395 Peiper Road Shippensburg, P A 17257 Defendant( s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.c.P. 3129.2 (e) (2) Joseph A. Goldbeck, JI., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ~ Personal Service by the Sheriff's Office(cornpetent adult (copy of return attached). Certified rnail by Joseph A. Goldbeck, JI. (original green Postal return receipt attached). Certified mail by Sheriff's Office. ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of rnailing attached). ( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriff's Office(competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriff's Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, JI., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to t Section 4904. ----- ~ 1J (f> ~ -n c- o ~ , '3 .l> ~ '" :) '" ~ "1J 0 ,:t: .... gj -n )ll- GJ ~ 0 ~ \5 ~ 0 <U ~ ,g "1J 0 ~ S. b v-> .......,1 f!J\ ~\ ~\ '-" .l>\ wI ~%' 0_ \ Uz Q:C {~\ m\\ u~ ~~ .,,~ \\.9. O"1Jl ~ ' i.~ \ ~ '2. i \ \ () o 3 '0 Ii .. a "" .... ':a ~ '" ~ S 7' "\ '" ~ .., o ~ .., .. " ~ \c; r= -;,.~ CO" '" J>"'"' " ~O~Ulto~ ",",,,,0",0. \~r@go! "1J" "0. :x:~ " \ j>~ ~ ~ "0" 9.- .. J>"' (f> z. ~ ~ \1 % N \ \ \ \ -------- :I: 1) :I: '" -U \ (1)00\ \-~ 9 g 0 %\ " i\ ? 0 0 0 '. .' ~ r?5~~ ~ \~~~%\' \C;;~~l~ ~ <<l~~5.9.,~ 1)~ (i ~~~g% 0 . "'::;;0....)70 $.~::\ ~ 3 -,;;;' g,,::; ?J \"" >>l_. .r (Ii> 0......... 0 rn,..... ~o ~ "" ,,, r ~ ~ " 0 .... O>"'z ~)> ~ ~ ~ ac.... '" ....\ % "' g ",'6 0 5w g '3. i.o\ <i 0 "T\ z,," ". '" "';:>. -u (fJ ,. !P. ';J. ., ~ijj og g % f, \ "- g\i . ~l~;~ . 3~::;; ,,'00 ~'C~5 ~(pm OJ~\C31ia I r;;;e.!:;, "'\" @~\il~ )7 ~g\b'~a? ?J "p.%.~"9.- Z. \ \ rn '5 p:::\ 5.~ ~ \../ \/\\/ \.\ ,n 1'\\"\ \ /\ -/ \---1'--- -+\ \\\\. ~\\\m ../i / ./ II \,,\i \n ..... \ -\ /\ /f /~~ " \L t / \_- _~tj \ \ "~I \ /\ / T ... \ .~\\ :r--j=-_\=-T4 -=ig \ L-i\';\ ,/ '--\ /- -\ -- -- /\ __- +--/-=1"--- '1 ~ -r .~\r 1,1 /\. . /(/\ i.\ \ \ ' ' ----- -- ---- \ ---- \/ Ie .. "1J Z .. ,Q 'g' ~ II.! % ~ ~ -\ ~ ~r---1 - \--- .---\- r- --- \--- \y:-t/ ---' .....----- , GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. FIKI A AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE CHRISTOPHER G. DELCAMPO Mortgagor(s) and Record Owner(s) Term No. 05-153 395 Peiper Road Shippensburg, P A 17257 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS, INC. F/K1A AMERICA'S WHOLESALE LENDER, 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: 395 Peiper Road Shippensburg, P A 17257 1.N arne and address of Owner( s) or Reputed Owner( s): CHRISTOPHER G. DELCAMPO 395 Peiper Road Shippensburg, PA 17257-9425 2. Name and address of Defendant(s) in the judgment: CHRISTOPHER G. DELCAMPO 395 Peiper Road Shippensburg, PA 17257-9425 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder ofeveryrnortgage 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. Narne 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 395 Peiper Road Shippensburg, P A 17257 (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: April 21, 2005 () s: ~fjil__~ 0;) ;::; ~c, ~- F' :.i:.:~-,. ~;:.- ::'1 -<: S> "" ", "" "" "'''> <:.n ;bo '-to, ::0 "" 0\ o ..,., ? rn:tI -nF.:; i5' ),J ~._-{ <-> -~~3j -~-;~") C:')ili ~;.' -~:~: -< '"'" ~ - -e s.~ " a Wi ~ ., .. i ~":n , . ~-~ \~ T.'(tI '11= 2(i, ,,,- '!iJ;! fro ~ a g;" ~!P. 3S .' "-3> '.I;In.'" .g ~f'i <- ~~ -. 3649 4369 " I \ ~ \' i I i fit -r +-, -< < ill (jJ X" Vi Ijl "-, " .,..-\~,~fu""""'. r' .~, I "'.' ~- ,/, /"_~,,'~ ( ~~, \ ... iillll .., "1,,1 'I " /' / w " . ~ ." E ill o o co ~, 2 "i ;-~ C .,. ij) yo ~ .u~ ~~ ~g' 0-0: ",0 _0 < we "', "" a:': w' >" o o UJ:J 0, Z'l "" 0: ' ~- f :2c - , o ~ '0 ~ ~~ Ie 00 g'@ s~ -0.0.... .0 <'C = W ~ c t,5 0 ";; Vi ~~ J;~ :g On >-" _;; ;;- w 'i C) ,2::<:: JiO O:-Qi~~~ 0..'- :> '0 (t\ :=:'~~ii .~E"~ C\1Q) Q) -0 E'ffi .',' :=....:Qo ~~ "C.~ ~"E .....~"g .~'@ .~ 8 ~s ;= :=E:J\Ptt~~ ~< 4: c: %.~, () c.:>>- . J!I 's. e -~.....- .-'-'" ~ .. ~ ~ :, -~ '} ~ ., :'t. '.1'" ~ it ~-- (;".1 1: e E { ~ .~. lii , ~ . 0 fo.. .uj ,0- en e ) ,;ro -ciS. <i~uBe $,r'" ~~ ;~€-~E ~,1::;~ E3 ~: 0 ,m e ",'CU. m(l) :::f..:n: '6- ->_.~-gg-g 'l.~'~;UJ. g.~ ;,(...<lltC. . 2:' ru ~ f. ~ YiJ ~ ~ s . ~ :>' ,~~ i~ i~ ro' ~-u; ,0' ~'g-'" c'o ,sr;' -" :o:::<:\S.. :g~-~ 0- ~r~ .' ~1:'~ 0' , u__ . ~ E ~ '0 ,C:: o 0 ro ~ o :0 g' cu 12 )"co :0. ;:00 ~.c ~ to ~~ :.~ :'Ow ::;;~ :::;.0 ".- ~ ~g ~$ ;l..:=: .::.:tlI~(Q (au ~@ S ~ _.2 i~-'~ .~.=2 ,0.." ....i::'a.. 0,g~ e~~ )w, .~:=:~ ~~~,; :s~tO -0 'J ~.5!~ ~~) ~:~ (00- ~ I- ~.5! E~ Jj '%.... '0 <fj_ ._~ c:t. ca lI;I O....(:l.I--Ul o.<t!iU o::CI:IV> ~-'fg~~~ . ~:g~ - - _ ~I ~ \r'1 Ii ", 0 \)\ ~ 0 !if~\.o'. ;;;;. z 00 ~r DO o I :':It ~ t ~ i5 "'" ~ 'ill ~ ,,~ d: ~ ~ ~ "" ~ 'ill.li P ~ ,J .~ uS '<>~~ a:~ ~:= >< (l) 0 " .,; " '" ~!!l _ " 0. ~~ '" :j'"E- o 1!:!.ttl 0 u'-:S>-j1) g~ 8.95 . <<'<!!I'E'04!! ,,; ~ 1l~ ~ 'n> \1)15a.. [ij~ ii"1l "O'll!j5l1 ...:jrtJe.s~ ~g~" ,,~:;:: 0- Cl:l o!i; ~ gs- ~ wE *!;;1l"~~ o..'<t :s-.!Q.s:::- g~~ii~5 Q."'o. g<( is . . . '" <:> ..co 0- -'" I~ ~;r ~ ~ .~ " (~ " t " ~ 0 12 ;;;; 1; ..... H !Ii! f~q! ; !~ 3 g ~ ODD ill E ~= .~ & ~. J; ~ v =~ E ~ "''iI ~j ~I'- .. II ,~ 'ii ~di dls S~DD .; '" a: '" Li.! ~ ::r .:. 0,. '" o N t- ..... '" ..- iE <c Z",n. u ~ .~3 60::", Q.; ....Q :!; Cl III <( ,So '" O .. ~ D..Q. -.J "' ._ W(I)J: 0",,,, g o I~ ~ ~ ~i..: ~! a; z ~ <'> .. '!: E ".i! is .o:c '" 1e ~,. 1\) . (f) '" ::> 0- - CD " - -o"-lC/)G) -u :r:O-lo (i) - --'m Q) rJl : !;S:U15 CD 0)>00) '0 ::>. - m:;oom a : ,"'o() ~ -om'", :r:-lS:s: c ~ )>C/)m() ::> - -o-l~() Q) 3 - )> 0)> _CD -' Z"" Q) - <:D -.." 0- -' Zm 0- g 0:;0 OJ '" - qj~ -'" - , -' - (Jl mQo '" ::> - W Zs: 0- (l) N - O() 'ii - m", t Zm - ()m =j' m< :;: ()m iii' m:;o g Z -l )( g: . C 7' "I . J 'J) J -j n :n -u o en ;;! ,... (f) m ;0 < i'i m '1JC'"t)'"TJ ~(f)gi g,Jl~ h z mj:ij"" ? Qo~ ~ ;r~ (to ~. '" "'- ." '" a If r -1'llIlIlt.. - r .. _~......."""_..."",_..,_,..~....,,,.___..___._. _._. Countrywide Home Loans, Inc. f/k/a America's Wholesale Lender VS Christopher G. Delcampo In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-153 Civil Term Jody Smith, Deputy Sheriff, who being duly sworn according to law, states that on March 07, 2005 at 3:15 o'clock PM, she 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: Christopher G. Delcampo, by making known unto Christopher G. Delcampo, personally, at The Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Cpl. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on April 14, 2005 at 6: 18 0' clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Christopher G. Delcampo located at 395 Peiper Road, Shippensburg, 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: Christopher G. Delcampo, by regular mail to his last known address of 395 Peiper Road, Shippensburg, P A 17257. This letter was mailed under the date of April 18, 2005 and never returned to the Sheriffs Office. 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 Poundage Advertising Posting Handbills Law Library Prothonotary Levy Surcharge Mileage Postage 30.00 263.58 15.00t15.00 .50 1.00 15.00 20.00 29.60 .37 Certified Mail Law Journal Patriot News Share of Bills 6.87 237.50 257.98 16.47 $ 908.87 ~~~~~ This ~ day OfC~ R. Thomas Kline, Sheriff 2005, A.D. (2;(.- Q 1ru;/I,.;~By,_Jttij~1::it Pro 0 otary Real Est te Deputy Sworn and subscribed to before me 1..,1; OL. ~-bf J7 ~ /(.b'2?f> ~ '0/ Goldbeck McCatlerty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff . COUNTRYWIDE HOME LOANS, INC. F/KJA AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW CHRISTOPHER G. DELCAMPO (Mortgagor(s) and Record Owner(s)) 395 Peiper Road Shippensburg, P A 17257 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 05-153 AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS, INe. FIK/A AMERICA'S WHOLESALE LENDER, 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: 395 Peiper Road Shippensburg, P A 17257 I.Name and address of Owner( s) or Reputed Owner( s): CHRISTOPHER G. DELCAMPO 395 Peiper Road Shippensburg, P A 17257-9425 2. Name and address of Defendant(s) in the judgment: CHRISTOPHER G. DELCAMPO 395 Peiper Road Shippensburg, P A 17257-9425 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 DEPARTMENT OF PUBLIC WELFARE - Bureau of Child 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: ... <I 5. Name and address of every other person who has at'5:i record interest in or record lien on the property and whose interest may be alfected 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 395 Peiper Road Shippensburg, P A 17257 (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 BY: Joseph A. Attorney for PI & McKEEVER , Esq. DATED: February 21. 2005 05-153 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INe. F/K/A AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland COWlty Plaintiff CIVIL ACTION - LAW vs. CHRISTOPHER G. DELCAMPO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 395 Peiper Road Shippensburg, P A 17257 Term No. 05-153 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: DELCAMPO, CHRISTOPHER CHRISTOPHER G. DELCAMPO 395 Peiper Road Shippensburg, PA 17257-9425 Your house at 395 Peiper Road, Shippensburg, PA 17257 is scheduled to be sold at Sheriff's Sale on Wednesday, June 08, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$134,885.68 obtained by COUNTRYWIDE HOME LOANS, INC. FIK/A AMERICA'S WHOLESALE LENDER 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: I. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS, INC. FIK/A AMERICA'S WHOLESALE LENDER, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 05-153 . 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 coutact one, the more chance you will have of stopping the sale. (See notice below ou 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 Sheriff's Sale is uot stopped, your property will be sold to the highest bidder. You may frod 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 find out if this has happened, you may call the Sheriff of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions <reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF yOU DO NOT HA VB 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, PA 17013 An THAT CERTAIN REAL ESTATE LYlNG AND BEING SlTUATE IN SOUTHAMPTON . TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN AT LINE OF LANDS NOW OR FORMERLY OF AL-HART INe., THENCE ALONG LANDS NOW OR FORMERLY OF AL-HART INe., NORTH 65 DEGREES 53 MINUTES 31 SECONDS WEST, 607.52 FEET TO AN IRON PIN AT LINE RIGHT OF WA Y OF UNTIED STATES ROUTE NUMBER 81; THENCE ALONG THE RIGHT OF WAY OF UNITED STATES ROUTE NUMBER 81, NORTH 43 DEGREES 49 MINUTES 28 SECONDS EAST, 221.49 FEET TO AN IRONG PIN; THENCE ALONG SAME, NORTH 43 DEGREES 49 MINUTES 28 SECONDS EAST 883.97 FEET TO AN IRON PIN; THENCE SOUTH 46 DEGREES 10 MINUTES 32 SECONDS EAST, 35.09 FEET TO AN IRON PIN IN PEIPER ROAD (TOWNSHIP ROUTE T-301); THENCE IN PEIPER ROAD, (TOWNSHIP ROUTE T-30l), SOUTH 10 DEGREES 30 MINUTES 59 SECONDS WEST, 716.30 FEET TO A RAILROAD SPIKE; THENCE CONTINUING IN SAID ROAD, SOUTH 24 DEGREES 6 MINUTES 29 SECONDS WEST, 124.07 FEET TO AN EXISTING RAIL ROAD SPIKE; THENCE IN THE SAME, SOUTH 24 DEGREES 6 MINUTES 29 SECONDS WEST, 299.98 FEET TO THE PLACE OF BEGINNING. CONTAINING 9.11 ACRES, MORE OR LESS, ACCORDING TO THE DRAFT OF SURVEY OF CARL D. BERT, P.L.S., DATED JUNE] 7,1995 AND BEING TRACT NOS. 1 & 2 THEREON. PARCEL NO. 39-14-0171-006 WRIT OF EXECUTION and/or ATTACHMENT " COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-153 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC. F/K1A AMERICA'S WHOLESALE LENDER, Plaintiff (s) From CHRISTOPHER G. DELCAMPO, 395 PEIPER ROAD, SHIPPENSBURG, P A 17257 (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 attachrnent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (5) 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 $134,885.68 Interest FROM 8/1/04 TO 2/21/05 AT 9.2500% L. L. $.50 Atty's Cornm % Atty Paid $125.54 Plaintiff Paid Date: FEBRUARY 25, 2005 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) protho:a; ~y: Q,...",o ,Q .7IzOJ..Q./ic..J 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 Real Estate Sale #25 On March 03,2005 the Sherifflevied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA Known and numbered as 395 Peiper Road, Shippensburg, more fully described on Exhibit "A" Date: March 03,2005 ByJycl~ JMJiJ--- Real E~iate Deputy ....,,~ ~ ~ ~ ~ filed with this writ and by this reference incorporated herein. lS :l d l- l:\VH ~OOl 'Vd 'AlUliUJ I~d ';itUllWr~'J .:l.:lIH3HS 3Hl :JO 3::JWO PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established 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 ofthe said Cumberland Law Journal on the following dates, v\z: 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 statements as to time, olace and character of publication are true. r)L . sa Marie Coyne, "WORN TO AND SUBSCRIBED before me this 29 day of April SEAL LOIS E. SNYDER. Notary Public Catlisle 8010. Cumberland County My Commission Expires March 5. 2009 REAL ESTATE SALE NO. 211 Wrtt No. 2005-153 Civil CountIywide Home Loans, Inc. f/k/a America's Wholesale Lender VS. Christopher G. Delcampo Atty.: Joseph Goldbeck ALL THAT CERTAIN real estate lying and being situate in Southamp~ ton Township, Cumberland County. Pennsylvania, bounded and de- scribed as follows: BEGINNING at an iron pin at line of lands now or formerly of AI-Hart Inc., thence along lands now or for- merly of AI-Hart Inc., North 65 de- grees 53 minutes 31 seconds West, 607.52 feet to an iron pin at line tight of way of Untied States Route Number 81; thence along the right Df way Df United States Route Num- ber 81, North 43 degrees 49 min- utes 28 seconds East, 221.49 feet to an irong pin; thence along same. North 43 degrees 49 minutes 28 seconds East 883.97 feet to an iron pin; thence South 46 degrees 10 minutes 32 seconds East, 35.09 feet to an iron pin in Pel per Road (Township Route T -301): thence in Peiper Road, (Township Route T- 301). South 10 degrees 30 minutes 59 seconds West, 716.30 feet to a railroad spike: thence continuing in said road, South 24 degrees 6 min- utes 29 seconds West, 1.24.07 feet to an existing rail road spike: thence in the same, South 24 degrees 6 minutes 29 seconds West, 299.98 feet to the place of beginning. CONTAINING 9.11 acres, more or less, according to the Draft of Sur- vey of Carl D. Bert, P.L.S., dated June 17, 1995 and being Tract Nos. I & 2 thereon. PARCEL NO. 39-14-0171-006. ~'---=--=a. 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 and/or 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, Page 317. COpy S ALE #25 Sworn to and subsc . NOTA Y PUBLIC My commission expires June 6, 2006 PUBLICATION .4 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 257.98 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.................................................................... --='" ~ , REAL ESTATE SALE No;. WrltIl\l.;2IlII&-153. ClVlITwnI , c-. u........Lo8ns,Inc. ..,A-. miDI". MUll .'LMcIer v. Chrt......G. :=:r Atty-...........&. . ~ . AlL TIIAT. ~ '. RIl-. lyiBg and llein< ..........~ .TIl\YIISbip, Cuoi>aIiod 0uIIY,~; ~ and d!saibedjllllollows: .... 1lOOIIIIlIIIG"....... po" lioo of lands _orform!ilyol~""..-'along _ _'or ~ olAf_IDe., North 6S degIoes ~........ 31 """"" West,fJJ152 feet toanilOllpinalliDerigllt-<lf-'WayolU__ ..... NIIIIlh<< 81; -. along lIl< riPI-of-w.y of Uo,iIod SIolo;o.-- 81. _43 .....49_21""'""'~.22I.49feetto an iIOIlpin; __ _._43 dep<e8 49J1linulio~""""'lloilm.f7feet..""iIOIl pin;dJeIIo<~46dO,....lO_32 """'" East,35D9 feet to an .... pin ill Ptiper ~ (l\JwI>\hip..... T-30I); _ in Ptiper ~;(\OwDafilp_T.301).SoaIIlrodegIoes 3O_l9..~_. .1l6.30filotto. raiJroodspiR;'fI\:I!'e~insaidroad. SoaIIl24 ~~~ 29 """'" West. 124D7feet...........raiJroodspik;_in lIl<......Soo(Iiw:. 6......29_ West,299.9HeoIto olBlJllNNlNG. CONTAININQ .f\"< ......_ or tess. ~ to lhoiloJllal Suney oiOtd D.!lat, PLS.__Iw17.1m-'I!oirIllal:tNoo.l &2~ ' PAldl.Ilo.:l').144I71.e1ll. , ~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. F/KJA AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX 6-35 Plana, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CHRISTOPHER G. DELCAMPO (Mortgagor(s) and Record owner(s)) 395 Peiper Road Shippensburg, PA 17257 No. 05-153 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. ;fJItoJdg?, JOSEPH A. GOLDBECK, JR., ESQUIRE .-sr' ~,'-~ 8 ~ ~ <.-, C_~ --",'" -'-"' -':;'. (:~~,.-, .- cr' ",-. 4:~' ( :;;"\2. -2. ~ ~-n f'rte -orr. -n'=? >"),C~ '~t1~L '..--"",---- '....-:,..() ~:::-\1'1 'J ~--\ J~.j .:.:. -r' :;:: ~ r" };"