HomeMy WebLinkAbout05-1519
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GOLDBECK McCAFFER"'V
By: JOSEPH A. GOLDBECK, JR. -"
ATTORNEY I.D. #16132
SUITE 5000 - MEbLON INDEPEN,E~CE CENTER
701 MARKET STREET
PHlLADELPfIlA, P A 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
CITIFINANCIAL SERVICES INe.
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
CNIL ACTION - LAW
vs,
GLADYS L OTT
Mortgagor and Real Owner
18 Irvin Drive
Shippensburg, P A 17257
ACTION OF MORTGAGE FORECLOSURE
Defendant
Term r C' 'C
No. 0.) -1-1 I,
CIVIL ACTION: MORTGAGE
O,~FCLoeURF
NOTICE
You have been sued in court If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of 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 LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
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LE HAN DEMANDADO A US TED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARlO QUE US TED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VISO. PARA DEFENDERSE ES
NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA,
RECUERDE: SI US TED 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
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPlEDAD U OTROS DERECHOS IMPORTANTES.
USTED D'EBE 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 FlJADA AQUI ABAJO, ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER 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, PA 17013
TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
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.
I). Call an attomey. For referrals to a qualified attorney call either of the 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 HOD'S website www.hud,gov/officeslhsg/sfh/econ/econ.cfm for Help for Homeowners Facing
the Loss of Their Homes,
4), Call your lender 877-675-3656 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 attomey 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 ofCIMD-0616.
Para informacion en espanol puede communicarse con Loretta aI215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is CITIFINANCIAL SERVICES INe, 14415 South 50th Street, Suite 100 Phoenix, AZ
85044,
2. The'name and address of the Defendant is GLADYS L. OTT, 18 Irvin Drive, Shippensburg, PA 17257,
who is the mortgagor and real owner of the mortgaged premises hereinafter described.
3. On June 28, 2001 mortgagor made, executed and delivered a mortgage upon the premises hereinafter
described to CITIFINANCIAL SERVICES INC., which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County as Book 1726 Page 3143, The Mortgage and Assignment(s)
are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule
of Civil Procedure I 019(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
August 14, 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 07/14/2004
through 03/31/2005 at 10.0000%
Per Diem interest rate at $25.69
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 Attomey'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 ($4,690.01)
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,
Costs of suit and Title Search
$93,800.28
$6,705.09
$1,250,00
Title/Appraisal Fee
$900.00
$102,655.37
+$225,00
$102,880.37
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 ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent 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
Cou)1seling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $1 02,880.37,
together with interest at the rate of$25.69, 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:
l LCA, / &i^,---
GOLDBE AFFERTY & McKEEVER
By: JOSEP,H A. 'OLDBECK, JR" ESQUIRE
A TTORNEf FOR PLAINTIFF
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VERIFICATION
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I, Joseph A. Goldbeck Jr., 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 subj ect to the penal ties of 18 Pa. C. S. 4904 relating to
unsworn falsification to authorities.
Date; J - 2 I 'G_-r~__
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F~X NO. :7172843304
Feb. 25 2005 06:00PM PS
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ACT 91 NOTICE
DATE OF NOTICE: February 14, 2005
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
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.
This is an official notice that the mortgage on your home is in default. and the
lender intends to foreclose. Specific information about the nature of the default is provided in
the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be
able to help to save vour home. This Notice explains how the program 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 Counseling Agency.
The name. address and phone number of 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 can call (717) 780-1869.)
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact any attorney in your area. The local bar association may be able
to help you find a lawyer.
La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar
viviendo en su casa. Si no comprende el contenido de esta notification obtenga una lraduccion
immediatamente Ilamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al
numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado
"Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la
perdida del derecho a redimir su hipoteca.
Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia, PA 19106
Fax (215) 627-7734
1
Date: February 14, 200S
Homeowners Name: GLADYS OTT
Property Address: 18 Irvin Drive, Shippensburg, P A 17257
Loan Account No.: 2000S10233193
Original Lender: CITIFINANCIAL SERVICES INC.
Current Lender/Servicer: CITIFINANCIAL SERVICES INC.
HOMEOWNERS'
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 HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYL VANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date ofthis Notice. During that time you
must arrange and attend a "face-to-face" meeting with one ofthe 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 UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE
YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the 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 teleohone numbers of
designated consumer credit counseling agencies for the countv in which the orooertv is located are set
2
forth at the 'end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your
lender immediatelv 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 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 a completed Homeowner's Emergency Assistance
Program Application with one of the designated consumer credit cOWlseling agencies listed at the end
of this Notice. Only consumer credit cOWlseling agencies have applications for the program and they
will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.
Your application MUST be filed or postmarked within thirty (30) days of your fact-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 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 Finance Agency has sixty (60) days to make a decision after it receives your
application. During that time, no foreclosure proceedings will be pursued against you if you have met
the time requirements set forth above, You will be notified directly by the Pennsylvania Housing
Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY 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.
(If you have filed bankruptcy you can still apply for
Emer2ency Mort2a2e Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brim! it UD to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 18 Irvin Drive, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
3
(a) Monthly payment from 08/14/2004 thru 2/14/2005
. (7 mos. at $396.00/month) $2,772.00
(b) Late charges
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $2,772.00
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS ofthe
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS $ 2,772.00 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made
either bv cashier's check. certified check or monev order made pavable and sent to:
CITIFINANCIAL SERVICES INC.
Attn: Payment Processing
6010 Fairview Road, Suite 105
Charlotte, NC 28210
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default
within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its riehts to
accelerate the morteaee debt. This means that the entire outstanding balance of this debt will be
considered due immediately and you may lose the chance to pay the mortgage in monthly installments.
If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also
intends to instruct its attorneys to start legal action to foreclose uoon your morteaeed orooerty.
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 brings 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, ifIegal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00, Any attomey's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. Ifvou cure the default within the THIRTY (30) DAY
oeriod, vou will not be required to Day attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have
the right to cure the default and prevent the sale at anv time up to one hour before the Sheriff's Sale.
You mav do so bv oaving the total amount then past due. plus anv late or other charges then due,
reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected
with the Sheriff's Sale as specified in writing bv the lender and bv performing anv other requirements
4
under the ~ortgage, Curing your default in the manner set forth in tbis notice will restore your
mortgage to tbe same position as if you bad never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately four (4) to six (6)
months from the date oftbis Notice. A notice of the actual date of the Sheriff's Sale will be sent to
you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will by contacting the
lender.
HOW TO CONTACT THE LENDER:
Name of Lender:
CITIFINANCIAL SERVICES INC.
Address:
Attn: Payment Processing
6010 Fairview Road, Suite 105
Charlotte, NC 28210
Pbone Number:
877-622-1611
Fax Number:
Contact Person:
Loss Mitigation Dept.
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriff's Sale, a lawsuit to remove you and your fumishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE - You 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 attomey's fees
and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
*
TO HAVE THIS DEF AUL T 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
5
HAVE THis RIGHT TO CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY
CAL~NDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Contact Person: Loss Mitigation Dept.
Phone Number: 877-622-1611
6
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
CCCS OF WESTERN PENNSYLVANIA INe.
2000 Linglestown Road
Harrisburg, P A 171 02
(717) 541-1757
URBAN LEAGUE OF METROPOLITAN HARRISBURG
2107 N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717)234-9459
COMMUNITY ACTION COMM OF THE CAPITAL REGION
1514 Derry Street
Harrisburg, P A 17104
(717)232-9757
FAX 234-2227
FINANCIAL COUNSELING SERVICES OF FRANKLIN
31 West 3rd Street
Waynesbaro, P A 17268
(717) 762-3285
YWCA OF CARLISLE
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
ADAMS COUNTY HOUSING AUTHORITY
139-143 Carlisle Street
Gettysburg, P A 17325
(717) 334-1518
FAX (717) 334-8326
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-01519 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIFINANCIAL SERVICES INC
VS
OTT GLADYS L
BRIAN BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
OTT GLADYS L
t e
DEFENDANT
, at 2050:00 HOURS, on the 24th day of March
, 2005
at 18 IRVIN DRIVE
SHIPPENSBURG, PA 17257
GLADYS OTT
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents t ereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
14.80
.00
10.00
.00
42.80
Sworn and Subscribed to before
me this
i ?:JJ,,!..... day of
1 VO':) A.D.
L~
ry U
-~u
So Answers:
.r>~n~'/.<::~-R
R. Thomas Kline
03/28/2005
GOLDBECK MCCA"F17FERTY
By: 111
Deputy Sheriff
GOLDBECK McCAFFERTY & McKEEVER
BY; Joseph A. Goldbeck, Jr.
Attorney J.D. #16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIFINANCIAL SERVICES INC,
14415 Sauth 50th Street
Suite 100
Phaenix, AZ 85044
IN THE COURT OF COMMON PLEAS
Plaintiff
af Cumberland Caunty
vs,
CIVIL ACTION LAW
GLADYS 1.. on
(Mortgagor(s) and Record owner(s))
18 Irvin Drive
Shippensburg, P A 17257
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No, 05-1519
ORDER FOR JUDGMENT
Please enter Judgment in favor of CITIFINANCIAL SERVICES INC., and against GLADYS 1.. OTT
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 of $103,548.3 L
Joseph A. Goldb
Attorney for Plain i
I hereby certify that the above names are correct and that the precise residence address of the judgment
creditor is CITIFINANCIAL SERVICES INe. 14415 South 50th Street Suite 100 Phoenix, AZ 85044 and that
the name(s) and last known addressees) of the Defendant(s) is/are GLADYS 1.. OTT, 18 Irvin Drive
Shippensburg, P A 17257;
GOLDBEC
BY: Joseph A. G e k, Jr,
Attorney for Plai t f
ASSESSMENT OF DAMAGES
TO THE PROTIlONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
$93,800.28
Interest from 07/14/2004 through
04/26/2005
$7,373,03
REASONABLE Attamey's Fee
$1,250,00
Late Charges
$0,00
Casts of Suit and Title Search
$900,00
TITLE/APPRAISAL FEE
$225.00
($0,00)
$103,54831
GOLDBECK M
BY: Joseph A G d
Attorney for Plaint
AND NOW, this
d~d dayaf fY)fAr
, 2005 damages are assessed as above,
~ rlJ J/di.l -J< tI(It'd
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, GLADYS L. OTT, is
about unknown years of age, that Defendant's last known
residence is 18 Irvin Drive, Shippensburg, PA 17257, 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 wi thin the
provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date:
In the Court of Common Pleas of Cumberland County
CITIFINANCIAL SERVICES INC,
144i 5 Sauth 50th Street
Suite 100
Phaenix, AZ 85044
Plaintiff
VS,
GLADYS L. OTT
(Mortgagor(s) and Record Owner(s))
18 Irvin Drive
Shippensburg, P A 17257
No, 05-1519
Defendant(s)
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
Enter the Judgment in favor of Plaintiff and against GLADYS L. OTT by default far want af an Answer.
Assess damages as follows:
Debt
$103,548.31
Interest - 07114/2004 to 04/26/2005
Total
(Assessment afDamages 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 natice af the intention ta file this praecipe was mailed ar delivered ta the party against whom judgment
is to be entered and to his attorney of record, if any, after the default accUlTed and at least ten days priar to the date of the
filing of this praecipe, A capy of the notice is attached, KCP, 237.1
Joseph A.
Attarney< l'n 'ff
LD, #16132\
AND NOW Ih '" ~/:J , ;} 00 :) , Judgment is entered in favor af
ClTlFINANCIAL SERVICES IN , and against GLADYS L. OTT by default far want af an Answer and damages assessed
in the sum of$103,548.31 as per the above certificatian,
6'f!l/JLts !< '77
Prothanotary
CIMD-0616
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF TillS NOTICE: April 14, 2005
TO:
GLADYS L. OTT
18 Irvin Drive
Shippensburg, P A 17257
CITIFINANCIAL SERVICES INC.
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Plaintiff
vs.
GLADYS L, orr
(Mortgagor(s) and Record Owner(s))
18 Irvin Drive
Shippensburg, P A 17257
Action of
Mortgage Foreclosure
Term
No, 05-1519
Defendant(s)
TO: GLADYS L. OTT
18 Irvin Drive
Shippensburg, PA 17257
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITIEN APPEARANCE
PERSONALLY OR BY ATIORNEY AND FILE IN WRITING wrrn TIlE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TIlE DATE OF
THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE
YOUR PROPERTY OR OTHER IMPORTANT RlGHTS, YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT
ONCE IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW, TIllS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO
HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WTIH INFORMATION ABOUT AGENCIES
THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
7 I 7-243-9400
CUMBERlAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle. PA 17013
GOLDBECK McCAFFER1Y & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - Menon Independence Center.
701 MarketStreet
Philadelphia, PA 19106 215-627-1322
Rul~ afCivil Procedure No, 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CITIFlNANCIAL SERVICES INC
14415 South 50th Street
Suite 100
Phoenix, A2 85044
Plaintiff
Na,05-1519
vs,
GLADYS L on
(Mortgagors and Record Owner(s))
18 Irvin Drive
Shippensburg, P A 17257
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT, ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
Curt Long
Prothanatary YfilJt:"
By: 4~$ -411
Deputy
If you have any questions concerning the above, please contact:
Joseph A Goldbeck, Jr.
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A Goldbeck, Jr.
Att6rneyLD,#16132
Suite 5000 . Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attarney far Plaintiff
CITIFINANCIAL SERVICES INC,
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
IN THE COURT OF COMMON PLEAS
Plaintiff
af Cumberland Caunty
vs,
CIVIL ACTION - LAW
GLADYS L OTT
Mortgagor(s) and Record Owner(s)
18 Irvin Drive
Shippensburg, P A 17257
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
Na, 05-1519
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$103,548.31
Interest from
07/14/2004 ta
04/26/2005 at
10,0000%
(Casts ta be added)
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NOO5-1519 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
Ta satisfy the debt, interest and casts due CITlFINANCIAL SERVICES, INC 14415 SOUTH 50TII
STREET, SUITE 100 PHOENIX, AZ 85044 Plaintiff (s)
From GLADYS L. OTT 18 IRVIN DRIVE, SHIPPENSBURG, P A 17257
(I) Yau are directed ta levy upon the property of the defendant (s)and ta seU SEE LEGAL
DlSCRlPTION
(2) Yau are aIsa directed ta attach the property of the defendant(s) not levied upan in the passessian
of
GARNISHEE(S) as foUaws:
and ta natify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the accaunt afthe defendant (s) and from delivering any property afthe defendant
(s) or otherwise e1ispasing thereof;
(3) Ifproperty afthe defendant(s) not levied upan an subject ta attachment is found in the passession
of anyane other than a named garnishee, yau are directed ta natify him/her that he/she has been added as a
garnishee and is enjained as abave stated,
Amount Due$I03,548.31
Interest From 7/14/04 to 4/26/05 at 10.0000%
Arty's Comm %
1.1.$0.50
Arty Paid $124.80
Plaintiffpaid
Date: MAY 2, 2005
Due Prothy $1.00
Other Costs
(Seal)
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR. ESQ.
Address: MELLON INDEPENDENCE CENTER SUITE 5000
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: Plaintiff
Telephane: 215-627-1322
Supreme Caurt ID Na, 16132
t'RUE COp'( FROM RECORD
lit TesdPlOny wllef8Of. I here unto set my lwld
and ttlI seal of said 1 ~ CaOisIe. PI,
rhls, ~nd~ ~ ~- (4f
~_ 4. )t.iu> rJ /~ tf
1lrothon00llf'f /
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney LD. #16132
Suite 5000'- Mellon Independence Center
70fMarket Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIFINANCIAL SERVICES INC.
14415 South 50th Street
Suite 100
Phoenix, PJ, 85044
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs,
CIVIL ACTION. LAW
GLADYS L. OTT
(Mortgagor(s) and Record Owner(s))
18 Irvin Drive
Shippensburg, P A 17257
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 05-1519
AFFIDAVIT PURSUANT TO RULE 3129
CITIFINANCIAL SERVICES INC" Plaintiff in the above actian, by its attamey, Joseph A Goldbeck, Jr., Esquire,
sets forth as af the date the praecipe for the writ af execution was filed the following information concerning the Teal property
located at:
18 Irvin Drive
Shippensburg, P A 17257
I,Name and address of Owner(s) or Reputed Owner(s):
GLADYS L on
18 Irvin Drive
Shippensburg, P A 17257
2, Name and address ofDefendant(s) in the judgment:
GLADYS L on
18 Irvin Drive
Shippensburg, P A 17257
3, Name and last knawn address of every judgment creditor whase judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Bax 320
Carlisle, P A 17013
P A DEP ARTMENT OF PUBLIC WELF ARE - Bureau af Child Suppart Enforcement
Health and Welfare B1dg, - Room 432
P,O, Bax 2675
Harrisburg, PA 17105-2675
4, Name and address of the last recarded holder af every mortgage af record:
5. Name and'fiddress of every other person who has any record interest in or record lien on the property and whose interest
may oe affected by the sale:
6, Name and address af every other person of whom the plaintiff has knowledge wha has any recard interest in the property
which may be affected by the sale,
7, Name and address af every ather persan of wham the plaintiff has knowledge wha has any interest in the property which
may be affected by the sale,
TENANTS/OCCUPANTS
18 Irvin Drive
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 persanal knawledge ar
infarmation and belief I understand that false statements herein are made subject ta the penalties of 18 Pa, C.S, Sectian 4904
relating to unsworn falsification to authorities.
GOLDBECK McCAFFE
BY: Joseph A Ga1dbeck
Attarney for Plaintiff
DATED: April 26. 2005
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GOLDBECK McCAFFERTY & McKEEVER
BY, Joseph A Goldbeck, Jr,
AttarneyLD,#16132
Suite 5000- Mellan Independence Center
70 I Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
CITIFINANCIAL SERVICES INe.
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
GLADYS L. OTT
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
18 Irvin Drive
Shippensburg, P A 17257
Term
No, 05-1519
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: OTI, GLADYS L.
GLADYS L. OTT
18 Irvin Drive
Shippensburg, P A 17257
YaUT hause at 18 Irvin Drive, Shippensburg, P A 17257 is scheduled ta be saId at Sheriffs Sale an
Wednesday, September 07, 2005, at 10:00 AM, in Cammissianers Hearing Rm 2nd FL Caurthouse ta
enforce the caurtjudgment of $103,548.31 abtained by CITIFINANCIAL SERVICES INC, against you,
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
I, The sale will be cancelled if you pay to CITIFINANCIAL SERVICES INc', 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. Yau may be able to stop the sale by filing a petitian asking the Court ta strike ar open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
05-1519
3, - You may also be able ta stap the sale thraugh ather legal proceedings,
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have af stapping the sale, (See natice belaw an haw ta abtain an attamey),
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
I, If the Sheriffs Sale is nat stapped, yaur property will be saId to the highest bidder, Yau may find
out the price bid price by calling the Sheriff of 717-240-6390,
2, You may be able ta petitian the Caurt ta set aside the sale if the bid price was grossly inadequate
campared to the value of your property,
3, The sale will ga through only if the buyer pays the Sheriff the full amaunt due in the sale, To find
aut if this has happened, you may call the Sheriff af717-240-6390,
4, If the amaunt due fram the Buyer is not paid ta the Sheriff, you will remain the awner afthe
property as if the sale never happened,
5, Yau have a right ta remain in the property until the full amaunt due is paid to the Sheriff and the
Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings ta evict yau,
6. You may be entitled ta a share of the maney which was paid for yaur house, A schedule af
distributian afthe maney bid far yaur hause will be filed by the Sheriff within thirty (30) days fram the
date af the Sheriffs Sale, This schedule will state wha will be receiving that maney, The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrang) are filed with the Sheriff within ten (10) days after the schedule af distributian is filed,
7, You may alsa have ather rights and defenses, ar ways of getting yaur house back, if yau act
immediately after the sale,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP,
LEGAL SERVICES INC
8 Irvine Raw
Carlisle, P A 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
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Joseph A. Goldbeck, Jf.
Attorney LD, #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIFINANCIAL SERVICES INC.
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
Plaintiff
IN THE COURT OF
COMMON PLEAS
vs,
of Cumberland County
GLADYS L. OTT
Mortgagor(s) and Record Owner(s)
18 Irvin Drive
Shippensburg, PA 17257
CIVIL ACTION - LAW
Defendant( s)
ACTION OF
MORTGAGE FORECLOSURE
NO, 05-1519
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
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Citifinancial Services Inc.
VS
Gladys L. Ott
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2005-1519 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per instructions from Attomey Joseph Goldbeck.
Sheriffs Costs:
Docketing
Surcharge
Poundage
Levy
Mileage
Law Library
Prothonotary
30.00
20.00
1,952.03
15.00
14.80
.50
1.00
$2,033.33
~~~~
This :2'/8 day~f 7~ . '
} R Thomas Kline, Sheriff
2005,A.D. LiliA [Dhji~<-:~BY \,'6~ Si1Ad:~
Prothonotary Real E te Deputy
Swam and subscribed to before me
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Goldbeck McCafferty & McKccver
BY: Joseph A Goldbeck, Jr.
Attorney LD, #16132
Suite 5000 ,- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CrTIFINANCIAL SERVICES INc.
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
Defendant( s)
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CIVIL ACTION -l;~~ ~ ~2
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ACTION OF MORTGAGE FdRECLO~tJlUic;k'
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vs,
GLADYS L. OTT
(Mortgagor(s) and Record Owner(s))
18 Irvin Drive
Shippensburg, P A 17257
No, 05-1519
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AFFIDAVIT PURSUANT TO RUU: 3129
CITIFINANCIAL SERVICES INC., P1aintilfin the above action, by its attomey, Joseph A Goldbeck, Jr., Esquire,
sets forth as of the date the praecipe for the writ of execution was filed the following infonnation concerning the real property
located at:
18 Irvin Drive
Shippensburg, P A 17257
] ,Name and address of Owner(s) or Reputed Owner(s):
GLADYS L OTT
18 Irvin Drive
Shippensburg, P A 17257
2, Name and address of Defendant(s) in the judgment:
GLADYS L OTT
18 Irvin Drive
Shippensburg, P A 17257
3. Name and last known address of every judgment creditor \vhosc judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, P A 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child 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 af record:
5. Name and address of every other pcr~on who has any record interest in or record lien on the property and \vhose interest
may be a!lected by !be sale:
6. Name and address of every other person of whom the plaintitThas knowledge who has any record interest in the property
which may be a!leeted by the sale,
7. Name and address of every other person of whom the plaintitT has knowledge who has any interest in the property which
may be affected by the sale,
TENANTS/OCCUPANTS
18 Irvin Drive
Shippensburg, P A 17257
(attach separate sheet ifrnore 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 26, 2005
GOlDBECK McCAFFE McKEEVER
BY: Joseph A Goldbeck L, ,S 1,
Attomey for Plaintiff
05-1519
,
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A Goldbeck, Jr.
Attamey LD. # 16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIFINANClAL SERVICES INC,
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs,
GLADYS L 01'1'
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
18 Irvin Drive
Shippensburg, P A 17257
Term
No, 05-1519
Defendant( s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE A TTEMPTlNG TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN A Tn:MPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: on, GLADYS L
GLADYS L. OTT
18 Irvin Drive
Shippenshurg, P A 17257
Your house at 18 Irvin Drive, Shippensburg, P A 17257 is scheduled to be ~old at Sheriffs Sale on
Wednesday, September 07,2005, at 10:00 AM, in Cammissianers Hearing Rm 2nd FL Courthause ta
enforce the court judgment 01'$103,548,31 obtained by CITIFlNANCIAL SERVICES INC. 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:
L The sale will be cancelled if you pay to CITlF1NANCIAL SERVICES lNe., the back payments,
late charges, costs and reasonable attomey'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.
05-1519
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 YOlllIA VE OTHER RIGHTS
EVEN IF TilE SHERIFF'S SALE DOES NOT TAKE PLACE.
1, If the Sheriffs Sale is not stopped, yaur property will be sold to the highest bidder. You may find
aut 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 amonnt due in the sale, To tind
aut if this has happened, yau 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.
O. You may be entitled to a share of the money \vhich was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sherift~s Sale. This schedule will state who will be receiving that money. The money \vill be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed,
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP,
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty A venue
Carlisle. PA 17013
SHORT DESCRIPTION
IMPROVEMENTS consist of a residential dwelling,
BEING PREMISES: 18 Irvin Drive
Shippensburg, PA 17257
SOLD as the property of GLADYS L OTT
TAX PARCEL #39-13-0102-070
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N005-1519 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITIFINANCIAL SERVICES, INC 14415 SOUTH 50TH
STREET, SUITE 100 PHOENIX, AZ 85044 Plaintiff (s)
From GLADYS L. OTT 18 IRVIN DRIVE, SHIPPENSBURG, PA 17257
(1) Yau are directed ta levy upan the property afthe defendant (s)and ta sell SEE LEGAL
DISCRIPTION
(2) Yau are a1sa directed ta attach the property afthe defendant(s) nat levied upan in the passessian
af
GARNISHEE(S) as follows:
and ta natify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjained fram
paying any debt ta or far the accaunt afthe defendant (s) and from delivering any property of the defendant
(s) or atherwise dispasing thereof;
(3) If property afthe defendant(s) nat levied upan an subject ta attachment is found in the posses sian
af anyane ather than a named garnishee, yau are directed to natify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amaunt Due$103,548.31
Interest From 7/14/04 to 4/26/05 at 10.0000%
Atty's Camm %
Atty Paid $124.80
Plaintiff Paid
Date: MAY 2, 2005
(Seal)
LL$0.50
Due Prothy $1.00
Other Casts
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Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR. ESQ.
Address: MELLON INDEPENDENCE CENTER SUITE 5000
701 MARKET STREET
PHILADELPHIA, PA 19106
Attarney for: Plaintiff
Te1ephane: 215-627-1322
Supreme Caurt ID Na, 16132
Real Estate Sale #26
On May 09, 2005 the Sherifflevied upon the
defendant's interest in the real property situated in
Southampton Township, Cumberland County, PA
Known and numbered as 18 Irvin Drive,
Shippensburg, more fully described on Exhibit "A"
Date: May 09, 2005
By: J~ ,{U s,YliJi,
Real Estate Deputy
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filed with this writ and by this reference incorporated herein.
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LO, #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
CITIFINANCIAL SERVICES INC,
14415 South 50th Street
Suite 100
Phoenix, AZ. 85044
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
GLADYS L OTT
(Mortgagor(s) and Record owner(s))
18 Irvin Drive
Shippensburg, PA 17257
No. 05-1519
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly vacate the judgment upon payment of your costs only.
f)It~
JOSEPH A. GOLDBECK, JR., ESQUIRE
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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
CITIFINANCIAL SERVICES INC,
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs,
GLADYS L OTT
(Mortgagor(s) and Record owner(sll
18 Irvin Drive
Shippensburg, PA 17257
No. 05-1519
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of
your costs only.
fJI~
JOSEPH A. GOLDBECK, JR., ESQUIRE
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