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Home My WebLink About05-1545 GOLDBECK McCAFFERTY & McKEEVER Bv: JOSEPH A. GOLDBECK, JR. ATTORNEV LD. #16132 SUITE 5000 - MELLON [NDEPENDENCE CENTER 701 MARKET STREET PIIILADELPHIA, PA [9106 (215) 627-1322 ATTORNEV FOR PLAINTIFF IN THE COURT OF COMMON PLEAS MANUFACTURERS & TRADERS TRUST CO. AS TRUSTEE FOR H[E BANK or NEW YORK S/B/M KEYSTONE NATIONAL BANK TIA KEYSTONE FINANCIAL MORTGAGE PO Box 840 Buffalo, NY 14240-0840 OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plainliff YS. Tenn NoDS -j.t''1S' Ciu;( "-- l&uv 1 FREDERICK M. ESHLEMAN .II<.. BECKY S. ESHLEMAN Mortgagors and Real Owners 307 E. Marble Street Meehaniesburg, P A 17055 DefendanlS CIVIL ACTION: MORTG,c"GE FO,':{ECLQSURF 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 LA WYER 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Carlisle, PAl 70 13 A VISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN EST A DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO. DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROV1SIONES DE ESTA'DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO. 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 PROVEERf: INFORMACION ACERCA AGENClAS 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 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. I). Call an attorney. 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 HUD'S website www.hud.gov/offices/hsglsth/econ/econ.ctill for Help for Homeowners Facing the Loss of Their Homes. 4). Call your lender 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 2 I 5-825-6329 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 finn's Homeowner Retention Department is Edward Sparkman who can he reached at 215-825-6318 or Fax: 215-825- 6418. Please reference our Attorney File Number ofMT-0688. Para intormacion en espanol puede communi carse con Loretta al 2] 5-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE l. Plaintiff is MANUFACTURERS & TRADERS TRUST CO. AS TRUSTEE FOR THE BANK OF NEW YORK S/B/M KEYSTONE NATIONAL BANK T/A KEYSTONE FINANCIAL MORTGAGE, PO Box 840, Buffalo, NY 14240-0840. 2. The names and addresses of the Defendants are FREDERICK M. ESHLEMAN JR., 307 E. Marble Street, Meehaniesburg, PA 17055 and BECKY S. ESHLEMAN. 307 E. Marble Street, Meehaniesburg, P A 17055, who arc the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On October 07, 1998 mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to MANUFACTURERS & TRADERS TRUST CO. AS TRUSTEE FOR THE BANK OF NEW YORK S/B/M KEYSTONE NATIONAL BANK T/A KEYSTONE FINANCIAL MORTGAGE, which mortgage is recorded in the Office ofthe Recorder of Deeds of Cumberland County as Book 1489 Page 36. The Mortgage and Assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 10 I 9(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 November 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 10/0 1/2004 through 03/31/2005 at 7.6250% Per Diem interest rate at $24.89 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. Plaintiffreserves its right to collect Attorney's fees of up to 5% of the remaining principal balance ($5,957.14) 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 ofthe amount demanded in the Action. Late Charges from 11/01/2004 to 03/31/2005 Monthly late charge amount at $55.52 Costs of suit and Title Search $119,142.76 $4,528. I 5 $1,250.00 $277.60 Escrow Monthly Escrow amount $204.53 $900.00 $126,098.5 I +$547.10 $ 126,645.61 7. Plaintitfis not seeking a judgment of personal liability (or in personam judgment) against the Detendants in this Action but reserves it's right to bring a separate Action to eswblish that right, if such right exists. lfDefendants have received a discharge of their personal liability in a Bankruptcy procecding, 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 Defcndants by Certified and regular maiL as required by Act 160 of 1998 ofthe Commonwealth of Pennsylvania, on the datc(s) set forth in thc true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants havc not had the required face-to-face meeting within the required time and Plaintiff has no knowlcdge of any such meeting being requcsted by the Defendants through the Plaintitf, the Pcnnsylvania Housing Finance Agency, or any appropriate Consumer Credit Counscling Agency. WHEREFORE, Plaintiff demands a de terris judb'lllent in mortgagc foreclosure in thc sum of$126,645.6l, together with interest at the rate of $24.89, per day and other expenscs incurrcd by the Plaintitf which are properly chargeable in accordance with the terms ofthe Mortgage and Pennsylvania law, and for the foreclosure of the Mortgage and Sheriff's Sale of the Pro erty. By: VERIFICATION I, Diana M. Robinson, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: ~Z2.-(;\ ~. l !~ , _.A/ Diana M. Robinson M&T MORTGAGE COMPANY ~ifti6it JL Tllt\T CER1'1II1.1 IIn...... -...j ) nl ."t qrOllnd ahul\tltd 1/1 ll\lt IIeco",1 "'aro of the l'OY6U!lh 'H n.ell~nil;~b""IJ, County "1 t'Iner\anll .n. Stllte af P......aylVAlll... """r.. Plio'''' WI"..!)' 1l01Uull'lf '1'"1 1l11!ltr1blld 45 fall".." r.D wi'\1 ~l, " IlliGlWnfG ~t .. ~lIi"t an tho nDrt/IOrn ,;i".. of fallt It",,.ble Str""t I!lltlfPd.", 'ilt" ""Int belll~ o:lt\e Mnd...,., s""...~-fi."" U7!i1 fR41 t ",",..cur"d olIlDnU III!> narUUtrn ';",. ~r 'Allt f1artlle SLt'l!ott .. L.."dltd in .>.. w6st~rlr dirp.~ti~h rr~ I~ nnrL~..ni enrl\qr ..t ~a5t MarDle 5tre.t ._ltt"d..~ mid ll", Lu...... II..II....d.l""'" ROAd, lhlln'" dDfl9 prnpp...t)' ".... n. lil1w of ,l,t.. blauur. "F. kill! RUllleen ll. Plaus..r I 1.1. .if". in .1 nartherly d.rodian ...." IlUnd,1M tl1;)I-nln. t15tl '/t'd lu .... five Ill} toot ease~ellt r.s~rYl!d fur pubIJc uLiliLiesJ then co .lonq ...id flve I~) roul ............"1 inl All t"4lHerly d!r"ctl'm UTty (~1 Taet tD "rupl!rt1 n.,., nl" l.-.t. 1)1' f-.ul ,.. 811ure, Anll Viol,""" "." SI1<<~r.r, hhwi1ej lMllr;v ~lOlllJ uill prOlllfrl1 Ilul< ".. late 01' r"ul T- 1I"".re, ."1I YhlJ~no1 ~I"e Sllfi'~r.r. hu ..11., In i\ 5l1ulMtl)' dL,'".:tiol\ 01'. h""dr.-d .ti.rt)l-nUlt /1:>9) "roo' 10 HIli nor~Mrn 51rle 01' East MUDle 5lr~.t eltllndellj tn.,u:. AlQng tl~ qDrl~Crn .t4~ ~f f.~.1 na..hl~ Stre_t, eJtended 1n ~ we5lerl~ dir.."lim, fifty (IiFl) f....1 In II". "hr." nf lIF.Ot~1101l. T,~hi6it r:B M&T Mortgage Corp. P.O. B()x 1288 Buffalo,NY 14240-1288 11Mal'l\btfteCorpcntian "~,,......... QIIIO/200S Certified No.: 71826389306005431008 Becky S Eshleman 307 E Marble St Mechanicsburg, PA 17055 HOMEOWNERS NA'i!E(sl: BeCky S Eshlctm<<n Pl".o.rfck M !shl....,. PROPERTY ADDRESS: 301 E Marble St Mechanlcsbt.4rg, PA 17055 L.CAN ACCr *': 000i8i1478 CURRENT LENDER/SERV1C:ER: M&T Mo,.tpge COrporation HOMEOWNER'S EMF-RGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME I<'ROM FORECLQSIJRF. AND HELP YOU MAKE FUTURE MORTGAGF: PAYMENTS IF YOU COMPLY WIlH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: fFYOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOfJR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PA Y YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELlGlBILlTY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY, TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage fOf Ihirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-fac"meeting with one of the CQnsumer credit counseling agencies listed at the end of this Notice. ~ MEETING MUST OCCUR WITHIN THE NEXT (301 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF TIUS NOnCE CALLEO"HOW TO CURE YOUR MORTGAGE DEFAULP, EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one oflhe consumer credit counseling agency listed at the end ofthis n<ttice, 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 desil!nated consumer credit counselinll: 31lencies for the county in which the nfooertv is located an: set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately OfYOUT intentions. 1 600724 1633 COfTlJspandence - P.O. Box 840, Buffalo, NY 1424(1..0640 paymants. P.O. Bo)( 62162, Baltimore MD 21264-2162 Mortgage 8ccoom informalion.jWrt a click away. www.mandtrnortgage.com . M&T Mortgage Corp. P.O. Box. \2&8 Buffalo, NY 14240..1288 PlJMlIr~~ Oll1012005 Certified No.: 7t826389.J06005430995 Frederick M Eshleman 307 E Marble St Mechanicsburg, PA 17055 HOMEOWNERS NAME(S): Frederick M Eshleman Biklky S !shlem.n PROPERTY' ADDRESS: 307 e Marble St: Mechanlcsburg, PA 17056 I..OAH ACCT NO: 0008881478 CURRENT L.ENt)ER/SERVICER: MIloT Mortga. Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FrNANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU CQMPL Y WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"~ YOU MAY BE ELIGWLE 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 ELlGmrUTY REQUIREMENTS EST ABLISUED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled 10 a temporary stay of foreclosure on yOUf mortgage for thirty (30) days from the dare of this Notice. During that time you must arrange and attend a "face-to-fae"meeting with one of the consumer credit counseling agenci~s listed at the end oftbis Notice. ~ MEETING MUST OCCUR WITHIN THE NEXT 130) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. VOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOWTO CURE YOUR MORTGAGE DEFAULT". EXPLAINS IiOWTO BRING YOUR MORTGAGE Up TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one Qftl1e consumer credit counseling agency 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 telcohone numbers of desie:nated consumer credit CQunseliDll al!encies for the county in which the nrODertv IS located are set forth at the end ofthis Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. 18007241633 Correspondence. P_O BOX lWl. Euffalo. NY 14240-0640 Paym8nts, P.O_ 8m: 52182, Baltimore, MD 21264-2182 MortgBge ilccOW1f informatkln.just II click 8Wlly. www_maodlmortgage.com '0-"_--,---.,-__ -----.--.------------- APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set f~rth later in this Notice (see following pages for specific infonnatioD about the nature of your default.) If you have tned and are Wlabie to resolve this problem with lbe lender, you have the right to apply for rmane:ial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a CQmpleted Homeowner's Emergency Assistance Program AppHcation with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housins Finance Agency. Your applicatiQn MUST be filed or postmarked within thirty (30) days of your face~to-face meeting. YOU .M!ln FILE YOUR APPLlCA nON PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OHlER TIME PERIODS SET FORTH IN THIS LETTER. FORECLOSURE MAY PROCEED AGAINST YOUR HOME lMMEDlA TEL Y AND YOUR APPLlCA nON FOR MORTGAGE ASSISTANCE WILL BE DENIED, AGENCY ACTION _ Available funds for emergency mQrtgage 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 fonh above. You witllx: notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY mE FILING OF A PETITION IN BASKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THIo: DEBT. (Uyou bave filed bankruptcy you can stili apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brin2 il un to date). NATURE OF THE D[FAULT -The MORTGAGE debt held by the above lender on your property located at: 307 E Marble St Mechantc:sbtJrg, PA 17055 IS SERIOUSLY IN DEFAULT because: yOU HAVE NOT MADE MORTGAGE PAYMENTS for the following months and the following amounts are now past due: ~lar payment. of $1110.52 for the months Qf 11/01/2004 through today's date: Qther ch.,...; Accrued Late Chars.': Accrued Other Charps TOTAL AMOUNT PAST CUE: $ $ $ $ 3407.01 46.30 0.00 3452.31 HOW TO CURE THE DEFAUl,T -You may cure the default within THIRTY (30) DAYS ofthe date of this noth,"e BY PAYING THE TOTAL AMOUNT PAST DUE TO mE LENDER, WHICH IS $3452,31, PLUS ANY MORTGAGE PAYMENTS ANl) LATE CHARGES WHICH BECOME DUE DURrNG THE THIRTY (0) DAY PERIOD. PaYments must be made either bv cash cashier'scheck. certified. check OrmOlley order made navable and sent to: M&T Mortgage Corporation One Fountain Plaza 17th Floor Attn: Payment Processing Bqffalo, NY 14203 You cafl cure any other default bv takinp the followine action within TIlIRTY (30) DAYS ofthe date of this letter: IF YOU DO NOT CURE THE DEfAULT..[fyou do not cure the default within THIRTY (30) DAYS oflhe dale of this Notice, tbe lender intends 10 exerdse Its rights '0 accelerate the mortgage d~bt. This means that the entire outstanding balance ofrhis debt will be considered due immediat~ly and you may lose the chahce to pay the mortgage jll monthly installments. If full payment oflhe total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct it!lltttomeys to start legal action to foreclose "pan your morfgaged property. 18007241633 CorTespondenoo - P,O. Box 840. Buffalo. NY 14240-084Q Paymrmts _ P_O. Box 62182. Baltimore. MD 21264-2182 Mortgage aooOlJflt infonnaHr:Jf1.juSit II click llway_ wwv,Lmandbnortgage.com IF THE MORTGAGE IS FOREe} ,o..~ED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt If the ltnder refers your case to Its attorneys, but you cure the delinquency before the lender begins legaJ proceedings against you, you will still be required to pay the reasonable attorney's fees fhat were actually incurred, up to $50.00. However, if legal proceedings are started against you, you Will have to pay all reasonable attorney's fees actuany incurred by the lender even if they exceed 550.00. Any attorney's fees will be added to the amount you owe th.e lender, which may also include other reasonable l;;OSts. UyolI cure the default wfthln the THIRTY (JD) DAY period, you will not be required to pay attorney's fees. ornER LENDER REMEDIES - The lender may also sue you personally for tbe unpaid principal balance and all other sums due under the mOrtgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- (fyou have not cW'ed the default within the THIRTY (30) DAY period and foreclosure proceedings have begun. you ~till ha.ve the right 10 cure the default and prevent the sale at any time up to one hour before the SherifrsSale. You may do so by paying the total amount then past due, plus any late or ocher charges then rlue. .reasonable attomey'sfees and costJ> carUl.ected with the foreclosure sale and any otber costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements llnder the mortgage. Curing your default in the manner set fortb In this Dotice will restore your mortgage to the S.lImt position as if you bad never defaulted. EARLIEST POSSmLE SHERlFF'S SALE DATE.. It is estimated that the earliest date that such a Sheriff's Sale ofrlJe mortgaged property could be held would be approximately 10 months from the date oHhis Notiee. A notice ofthe actual date ofthe Sheriff's Sale wilt be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will he by contacting the lender. HOW TO CONTACT TIlE LENDER: Name ofl.eoder: M&T Mortgage Corporation ~ P.O. Box 840 Buffalo, NY 14240 Phone Number; (800) 724-1633 EFFECT OF SHERIFF'S SA[,E - YOl! should realize that a Sheriff's$ale will end your ownership ofth!: mortgaged properly and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit 10 remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You_ mayor]! may not sell or tranSfer your home to a buyer or transferee who wi{J 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 MA V ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFf mE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING [NSTITUTrON TO PAYOFF nus DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT TIlE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LA WSUlT INSTITUTED t,rNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. "fa SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, .e....u....... ,;...; 'r. Russell M. Alessi Jr. Collections Manager Ene: Act 91 Notice Consumer Credit COUJJseling Ag<::ncies Serving Your County 1 600724 1633 Correspondence - P.O. Box 640, Buffalo, NY 14240-0840 Payments _ P.O. Box 62182, B<altimore, MO 21264-2182 MOItgage sccovnt informatlon,Just a click aWl.ly. www.mandtmortgag$.colTl ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an oftic::lal notice tbat the ntortl!'all!'e- on "'OUT home is in default. and the lender intends to foredose. SoedRc Information about the nature of the default Is orovlded in the attllched nl2es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM fHEMAP) mal' be able to helD to save "our home. This Notice exolaJns bow the nrouam work&. To see If REMAP can helD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. rake this Notice with 1'OU wben yon meet with the CoUnseUng APe~v. Tbe name-. addu," and obolle number of ConsuMer Credit Coun$e1inl! Aftuc:les servinl! roUt COll.tv art Ilsted at the end of this Nottee. {(voo have an'" Questions. YOU Utav ca(1 the Penun'lv_oia llousiup' Finance Al!encv toll frf'e at 1-800-342-2397iPersons wUh ImDBile<! heartng tJln can (717) 7RO.186,t This Notice coRtains .important legal information. If you have any questions, repr-esentatives at tile Consumer Credit Counseling Agency maybe able to help explain It. You may also want tocontaci an attorney in your area. The loea' bar association may be able ta help you nnd a 'awyer. LA NOTlFICACION EN ADJUNTO ES DE SUMA IMPORT ANCIA, PUES AFECT A SU DERECHO A CONTlNUAR VIVIENDO EN SU CASA. SI NO CQMPRENDE EL CONTENIDO DE EST A NOTIFICACION OBTENGA UNA TRADUCclON [NMEDlTAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING .'!NANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRmA. PUEDES SER ELEGIBLE PARA UN PREST AMO paR EL PROGRAM A LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PVEDE SAL v AR SU CASA DE LA PERDlDA DEL DERECHQ A REDIMlR SU HIPOTECA. 160072-41633 CorTBspondGnCEl - P.O. Box 640, Buffalo, NY 142"'~ Psymanls -P.O. Box 621&2. Baltimore.MD 21264.2162 Mortpe{}e account information, jus! a dic/{ away. www.mandtmortgage,c()(Tl Homeowners' Emergency Assistance Program CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 17\02 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm oftbe Capital Region 1514 Derry Street Harrisburg, P A 17104 (717) 232-9757 FAX (7]7) 234-2227 Financial Counseling Services of Franklin 3\ West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 30 I G Street Carlisle, PA 17013 (717)243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717) 334-1518 FAX (717}334-8326 ~ - \'" 1..:> - "'v ---.::) piA- rf ti \i. o ~~ ~E -f- '~ o So' -0(;] f'li f~' -,' .'-i' ~..:'(-' \~rii 'J:.:>-c: "'-:'. -::.;{ -< g~(() (~~ ~ ~ ~~ ~~ ~~~; :~~ :;Z: Zf{! ,-); ?J:i (.~ :.<. o :% ~ N <...;J - - ., GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney LD.#16132 Suite 5000 - Mellon Independence Center 170 I Market Street !Philadelphia, PA 19106-1532 ,215-627-1322 !BY: Kristina G. Murtha, Esq. !Attorney LD.#61858 !Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST CO. AS TRUSTEE FOR THE BANK OF NEW YORK S/B/M KEYSTONE NATIONAL BANK T/A KEYSTONE :FINANCIAL MORTGAGE PO Box 840 ,Buffalo, NY 14240-0840 I IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. No. 05-1545 FREDERICK M. ESHLEMAN JR. and BECKY S. ESHLEMAN 307 E. Marble Street Mechanicsburg, P A 17055 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. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, Kristina G. Murtha, Esq., in support of its Motion for Substituted Service, represents as follows: I. Plaintiff is the holder of a first mortgage upon the premises 307 E. Marble Street, I Mechanicsburg, P A, 17055, hereinafter, the "mortgaged premises". 2. Defendants, FREDERICK M. ESHLEMAN JR. and BECKY S. ESHLEMAN, are the mortgagors and real owners of the mortgaged premises. 3. The last known address of Defendant Frederick M. Eshleman, Jr. is as set forth in Paragraph 2 of the Complaint. 4. The Sheriff has been unable to effect service of the Complaint upon Defendant, Frederick M. Eshleman, Jr. at his last known address after numerous attempts with no response. 5. The following investigation was conducted in a good faith attempt to ascertain the ,whereabouts of Defendant Frederick M. Eshleman, Jr. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff ,to serve the Complaint upon Defendant, Frederick M. Eshleman, Jr. by pos' g the premises and certified ,and regular mail to the Defendant's last known address. BY: ERSAL SERVICES ..- Affidavit of Good Faith Investiaotion \Cllent provided Intormatlon: File Number: MT-0688 IAIIOrney Firm: Goldbeck, McCafferty & McKeever File Name: Eshleman , , Subject Name: Frederick M, Eshleman, Jr. Property Address: Street: 307 E, Marble Street City: Mechanicsburg State: PA Zip: 17055 iSklp Results: '. ,Verified 'IStreet: 307 E, Marble Street City: Mechanicsburg State: PA Date of Birth: March 1961 Universal File Number: 20927 Dates: As of 03/07/2005 Phone: 17055 Zip: Death Records: As of 03/07/2005, fhe Sociol Security Administration has no death record on file for Frederick M, Eshleman, Jr.. Social Security Number search completed. Employment Search: Unable to verily current employer. Creditor Informaflon: reditors indicoted the lasJ reported address for Frederick M. Eshleman, Jr. as 307 E, Marble Street, echanicsburg, PA 17055 epartment 01 Motor Vehicle Records: he Pennsylvania Department of Motor Vehicles provided no change for Frederick M. Eshleman, Jr. from 307 E, Marble Street, Mechanicsburg, P A 17055 ubllc Ucenses (Pilot, Real Estate, etc): Search performed provided no information, oter Regfstraflon InlORnaHon: he County voters Registration Office has no listing for Frederick M, Eshlemon, Jr.. aflonal Postal Address Search: Has no change for Frederick M. Eshleman, Jr. from 307 E. Marble treet. Mechanicsburg, PAl 7055 ommenls: ?17-697-8996: Spoke with mole relative, verified current address os 307 E. Marble Street, fv\echaniCsburg, PA 17055. / Notary Public -----J ,,,,,,,,,-- . -~II'I G WORKM.'N ,.,~~;\.; ". "t.,. !)UN ~.. .. .. !.;;~\~::\ ~l(lt;JIV i">dhllc, ~;tall' .of Te"',~~; ~<~..:..t ~11.' rr)rl'llll~j"IOllll(plfP.", ~:';:>i;i\\~:/ Sopl&rnbe! 30,2007 , ""111'" ate: 03/07/2005 T'.... ..~ 3290AKS lRAIL PlAZA . SUITE 202 . GIWJiK), TEXAS 75043 OFFICE: (972) 226-8883 . FAX: (972) 226-8887 T SHERIFF'S RETURN - NOT FOUND . . " C~ NO: 2005-01545 P C MONTWEALTH OF PENNSYLVANIA C TY OF CUMBERLAND I ~FACTURERS & TRADERS TRUST , VS ES HLEMAN FREDERICK M JR ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being du y sworn according to law, says, that he made a diligent search and in ~uiry for the within named DEFENDANT ES 'LEMAN FREDERICK M JR but was un~ble to locate Him in his bailiwick. He therefore returns the CO~PLAINT - - MORT FORE , , NOT FOUND , as to th ' within named DEFENDANT , ESHLEMAN FREDERICK M JR I , 30 E MARBLE STREET ME HANICSBURG, PA 17055 AL HOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UN BLE TO SERVE PRIOR TO EXPIRATION DATE. ShE riff's Costs: 0-/ S:;~._______:,:::::;::/~_/o- Dc cketing 18.00 SE rvice 20.72 ...~ ......~ -_.~-_. . . AJ fidavit 5.00 R. Thomas Kline Sl rcharge 10.00 Sheriff of Cumberland County .00 53.72 GOLDBECK MCCAFFERTY MCKEEVER 04/25/2005 Swc rn and subscribed to before me th's day of A.D. Prothonotary GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 ! Suite 5000 - Mellon Independence Center . 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST CO. AS TRUSTEE FOR THE BANK OF NEW YORK SIBIM KEYSTONE NATIONAL BANK T/A KEYSTONE FINANCIAL MORTGAGE PO Box 840 I Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. No. 05-1545 I FREDERICK M. ESHLEMAN JR. and BECKY S. ESHLEMAN 307 E. Marble Street Mechanicsburg, P A 17055 VERIFICATION I, Kristina G. Murtha, Esq., Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to 7naltieS of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. /1 ~/i/ BY: Kristina G. , Esq. / I GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 ! BY: Kristina G. Murtha, Esq. . Attorney I.D.#61858 . Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST CO. AS TRUSTEE FOR THE BANK OF NEW YORK S/BIM KEYSTONE NATIONAL BANK TIA KEYSTONE FINANCIAL MORTGAGE PO Box 840 I Buffalo, NY 14240-0840" IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. No. 05-1545 FREDERICK M. ESHLEMAN JR. and BECKY S. ESHLEMAN 307 E. Marble Street Mechanicsburg, P A 17055 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER PaRC.P. 430(a) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendant, Frederick M. Eshleman, Jr., which the Sheriff has been unable to personally serve upon Defendant, Frederick M. Eshleman, Jr. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendant, Frederick M. Eshleman, Jr. by posting the premises and certified mail and regular mail to the Defendant's last known address. ,/' Respectfully subwitted;' / . / /0/ . L// Kristina G. GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 ! Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST CO. AS TRUSTEE FOR THE BANK OF NEW YORK , S/B/M KEYSTONE NATIONAL BANK T/A KEYSTONE FINANCIAL MORTGAGE ! PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS Of Cumberland County vs. No. 05-1545 FREDERICK M. ESHLEMAN JR. BECKY S. ESHLEMAN 307 E. Marble Street Mechanicsburg, P A 17055 CERTIFICATE OF SERVICE Kristina G. Murtha, Esq., does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendant, Frederi..cc. kk M~. .'. s le~an, Jr. this 29th day of April 2005, by first class mail, postage prepaid. I. ../~ ~ ~.. BY: n "" C:.l C) C c:-..> -n r;.;""l - :~ . r~l-:; -".~ , U ; ," '_.CI ." (.1'1 \..i':" SHERIFF'S RETURN - REGULAR CASE NO: 2005-01545 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS ESHLEMAN FREDERICK M JR ET AL 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 ESHLEMAN BECKY S the DEFENDANT , at 1922:00 HOURS, on the 22nd day of April , 2005 at 1077 NANROC DRIVE MECHANICSBURG, PA 17055 by handing to BECKY ESHELMAN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ('/ // tI~ ??"",.#"-,,,..4Cf~""t''jO-~,,,c'-r/' /~ "1 ~"'~~~.f:::."'7 ' . ,~- ~ .~7 . R. Thomas Kline Sworn and Subscribed to before OS/25/2005 GOLDB::~ ~ERTY MCKEEVER /) me this 3~ day of ~C) J/H).{ A.D. .. M~U (j 'rn<€OIU Wff rothonotary , SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-01545 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS ESHLEMAN FREDERICK M JR ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ESHLEMAN FREDERICK M JR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , ESHLEMAN FREDERICK M JR 307 E MARBLE STREET MECHANICSBURG, PA 17055 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO SERVE PRIOR TO EXPIRATION DATE. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 20.72 5.00 10.00 .00 53.72 sO:~k~~~ -- " R. Thomas Kl ine Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 04/25/2005 Sworn and subscribed to before me this J "" day of ~ J(;1)<'! A.D. Ch-,O ~/ ~f';: P honotary . - .- '. MANUFACTURERS & TRADERS TRUST CO. AS TRUSTEE FOR THE BANK OF NEW YOUR S/B/M KEYSTONE NATIONAL BANK T/A KEYSTONE FINANCIAL MORTGAGE, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. FREDERICK M. ESHLEMAN, JR. AND BECKY S. ESHLEMAN, DEFENDANTS 05-1545 CIVIL TERM AND NOW, this ORDER OF COURT to day of May, 2005, upon consideration of the plaintiff's motion for substituted service under Pa. Rule of Civil Procedure 430(a), IT IS ORDERED that plaintiffs motion is granted and the Sheriff is directed to serve the complaint in mortgage foreclosure upon defendant, Frederick M. Eshleman, Jr., by posting a copy of the complaint upon the premises 307 E. Marble Street, Mechanicsburg, PA 17055, and plaintiff is directed to serve the complaint by certified and regular mail to the defendant's last known address at 307 E. Marble Street, Mechanicsburg, PA 17055, and plaintiff shall publish notice of the complaint once in a newspaper of general circulation and once in the Cumberland Law Journal, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to defendant's last known address and the notice of Sheriff Sale pursuant to Pa. Rule of Civil Procedure 3129 may be made upon defendant, Frederick M. Eshleman, Jr., by sending copies of same to defendant's last known address by certified and regular mail and by posting the premises. . . By the gourt, Kristina G. Murtha, Esquire For Plaintiff Sheriff :sal ~ 4' ~ I' ~&t L--\\ \~D'j rP\ /\10/: hr> .! 1(" . .." '-,-' ::d O! ; ','I.! f'on7 . f\ ,-H :;: u{. --~~"..- -------- GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATIORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 70] MARKET STREET PHILADELPHIA, PA 19lO6-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF MANUFACTURERS & TRADERS TRUST CO. AS TRUSTEE FOR THE BANK OF NEW YORK S/B/M KEYSTONE NATIONAL BANK TIA KEYSTONE FINANCIAL MORTGAGE PO Box 840 ButTalo, NY 14240-0840 fN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVfL ACTION - LA W ACTION OF MORTGAGE FORECLOSURE Plaintiff YS. Term No. 05-1545 FREDERICK M. ESHLEMAN JR. BECKY S. ESHLEMAN 307 E. Marble Street Mcchanicsburg, PA J 7055 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned maner. GOLDBECK, McCAFFERTY & McKEEVER Jj?Iokfs;t)n By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff -'\\ -.:-- .-'-~ ':::--: 0",' 0:1 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PIDLADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF MANUFACTURERS & TRADERS TRUST CO. AS TRUSTEE FOR THE BANK OF NEW YORK SIBIM KEYSTONE NATIONAL BANK TIA KEYSTONE FINANCIAL MORTGAGE PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE FREDERICK M. ESHLEMAN JR. and BECKY S. ESHLEMAN Mortgagor( 5) 307 E. Marble Street Mechanicsburg, PA 17055 Term No. 05-1545 Defendant(s) CERTIFICATE OF SERVICE JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on ry-1fy / f.~:l(VS he did serve upon Defendant FREDERICK M. ESHLEMAN JR. a true and correct copy of the above- captioned Complaint by certified and regular mail in accordance with the Court Order dated May 10, 2005. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. RespectfuIly sub . GOLDBECK Mc ER cKEEVER BY: JOSEPH A. GOLDBECK, JR. ESQUIRE c:.- -,-j 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 MANUFACTURERS & TRADERS TRUST CO. /!oS TRUSTEE FOR THE BANK OF NEW YORK SIBJM KEYSTONE NATIONAL BANK TlA KEYSTONE FINANCIAL MORTGAGE PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. No. 05-1545 FREDERICK M. ESHLEMAN JR. BECKY S. ESHLEMAN (Mortgagor(s) and Record owner(s)) 307 E. Marble Street Mechanicsburg, PA 17055 PRABCII?E TO DISCONTINUK AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. ;!JI~- JOSEPH A. GOLDBECK, JR., ESQUIRE ---- -'0 ~ ~ ,...., (:I" Q. ~\:,!;l~ I" :'6 ~r' ~~'\"~ .~-.. "-0 b~ ..:0\ <5 = ~ ~ Q ~: .~}\\\ fi~:,:', r;,. ~~;i~2 ""'p'~.. 3.. """ ~ I cP SHERIFF'S RETURN - REGULAR CASE NO: 2005-01545 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS ESHLEMAN FREDERICK M JR ET AL 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 ESHLEMAN FREDERICK M JR the DEFENDANT , at 1918:00 HOURS, on the 19th day of May , 2005 at 307 E MARBLE STREET MECHANICSBURG, PA 17055 POSTED PROPERTY AT 307 EAST by handing to MARBLE ST MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Additional Comments DEFENDANT WAS AT HOME WHEN POSTED. DEPUTY SPOKE WITH HIM. Sheriff's Costs: Docketing Service Posting Surcharge 18.00 8.88 6.00 10.00 .00 42.88 Sworn and Subscribed to before "" me this r ~ day of ~ ~tJ.5 A.D. I () f2 )n,f$,. I.~ ~~onotary So Answers: .~;r?6:~/~~ R. Thomas Kline OS/20/2005 GOLDBECK MCCAFFERTY MCKEEV By: ,d" 1$ ftJ/4fJ -fl{, Deputy Sheriff