HomeMy WebLinkAbout05-1612GOLDBECK McCAFFERTY & McKEE _?.
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
BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA
CORPORATION, ATTORNEY IN FACT FOR BLAZER
CONSUMER DISCOUNT COMPANY, A
PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
vs.
CHARLES J. SMEIGH
Mortgagor and Real Owner
268 Carlisle Avenue
Enola, PA 17025
Plaintiff
Defendant
NOTICE
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No.
CIVIL ACTION' M l?RTGA(..:aV:
rrr;PlFmoSU
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
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
AVISO
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 AVISO. 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 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 PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 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.
1). 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/hsg/sth/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 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 CIMD-0404.
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
Plaintiff is BLAZER CONSUMER DISCOUNT COMPANY: CITIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, ATTORNEY IN FACT FOR BLAZER CONSUMER
DISCOUNT COMPANY, A PENNSYLVANIA CORPORATION, 14415 South 50th Street, Suite 100
Phoenix, AZ 85044.
2. The name and address of the Defendant is CHARLES J. SMEIGH, 268 Carlisle Avenue, Enola, PA
17025, who is the mortgagor and real owner of the mortgaged premises hereinafter described.
3. On February 24, 2003 mortgagor made, executed and delivered a mortgage upon the premises
hereinafter described to BLAZER CONSUMER DISCOUNT COMPANY: CITIFINANCIAL
SERVICES, INC., A PENNSYLVANIA CORPORATION, ATTORNEY IN FACT FOR BLAZER
CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA CORPORATION, which mortgage is
recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1797 Page 4485. 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 15, 2003, 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 08/15/2003
through 03/31/2005 at 14.4000%
Per Diem interest rate at $11.01
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 ($1,395.76)
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
Title/Appraisal Fee
$27,915.23
$6,550.94
$1,250.00
$900.00
$36,616.17
+$225.00
$36,841.17
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 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
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $36,841.17,
together with interest at the rate of $11.01, 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 Sheriff's Sale of the Propel
By: \-?
G DBE McCAFFERTY & McKEEVER
JOSEPH A. GOLDBECK, JR., ESQUIRE
TTORNEY FOR PLAINTIFF
VERIFICATION
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 subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
Date: t
(E)C(ii6it 1`?
No. LBA-18948A
Page 3
SCHEDULE "A"
LEGAL DESCRIPTION
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BANG THE SAME PREMISES which ContiMortgage Corporation, by deed dat;d August 8 2000 and recorded August
10, 2000 in the Reoordees Office in and for Cumberland County, PA, in Dei d Book 22 , page 1099 granted and
conveyed unto Charles J Srheigh.
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ACT 91 NOTICE
DATE OF NOTICE: October 13, 2004
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 (HEMAP may be
able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this
Notice with you when you meet with the Counseling Agency.
The name, address and phone number 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) 780-1869.1
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 continuer
viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion
immediatamente llamanda 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
i
Date: October 13, 2004
Homeowners Name: CHARLES J. SMEIGH
Property Address: 268 Carlisle Avenue, Enola, PA 17025
Loan Account No.: 2000510127499
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
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you
must arrange and attend a "face-to-face" meeting with one of the designated consumer credit
counseling agencies listed at the end of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT
APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE 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 telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your
lender immediately of your intentions.
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 counseling agencies listed at the end
of this Notice. Only consumer credit counseling agencies have applications for the program and they
will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.
Your application MUST be filed or postmarked within thirty (30) days of your 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
Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 268 Carlisle Avenue, Enola, PA 17025 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:
(a) Monthly payment from 09/15/2003 thru 10/13/2004
(14 mos. at $387.00/month) $5,418.00
(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: $5,418.00
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS $ 5,418.00 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH
BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by
cashier's check certified check or money order made payable and sent to:
CITIFINANCIAL SERVICES INC.
311 New Rodgers Road
Levittown, PA 19056
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 rights to
accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be
considered due immediately and you may lose the chance to pay the mortgage in monthly installments.
If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also
intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender 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, if legal 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 attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
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, you still have
the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale.
You may do so by paving 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 any other costs connected
with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements
under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately four (4to six (6)
months from the date of this Notice. A notice of the actual date of the Sheriffs 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: 311 New Rodgers Road
Levittown, PA 19056
Phone Number: 877-675-3656
Fax Number
Contact Person: Loss Mitigation Department
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs 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 furnishings 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 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 INSTITUTION 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 POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
*• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Contact Person: Loss Mitigation Department
Phone Number: 877-675-3656
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
CCCS OF WESTERN PENNSYLVANIA INC.
2000 Linglestown Road
Harrisburg, PA 17102
(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, PA 17104
(717) 232-9757
FAX 234-2227
FINANCIAL COUNSELING SERVICES OF FRANKLIN
31 West 3rd Street
Waynesboro, PA 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, PA 17325
(717) 334-1518
FAX (717) 334-8326
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-01612 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BLAZER CONSUMER DISCOUNT
VS
SMEIGH CHARLES J
VALERIE
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn
says, the within COMPLAINT - MORT FORE was served upon
SMEIGH CHARLES J
DEFENDANT , at 2053:00 HOURS, on the 6th day of April
at 268 CARLISLE AVENUE
ENOLA, PA 17025
CHARLES SMEIGH
by handing to
a true and attested copy of COMPLAINT - MORT FORE together
and at the same time directing His attention to the contents t
to law,
2005
th
of.
Sheriff's Costs: So Answers:
Docketing
Service 18.00
11.10 001
?
Affidavit .00 /
Surcharge 10.00 R. Thomas Kline
.00
39.10 04/07/2005
GOLDBECK MCCAFFERTY MCKEEVER
Sworn and Subscribed to before By: //.
me this _/' _ day of /De
P'
e42 A.D.
Prothonotary
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
BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, ATTORNEY IN
FACT FOR BLAZER CONSUMER DISCOUNT
COMPANY, A PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
CHARLES L SMEIGH
(Mortgagor(s) and Record owner(s))
268 Carlisle Avenue
Enola, PA 17025
Defendant(s)
No. 05-1612 Civil
ORDER FOR JUDGMENT
Please enter Judgment in favor of BLAZER CONSUMER DISCOUNT COMPANY: CITIFINANCIAL
SERVICES, INC., A PENNSYLVANIA CORPORATION, ATTORNEY IN FACT FOR BLAZER
CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA CORPORATION, and against CHARLES J.
SMEIGH 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 of $37,281.57.
Joseph A
Attorney
I hereby certify that the above names are correct and that thAprecise residence address of the judgment
creditor is BLAZER CONSUMER DISCOUNT COMPANY: CITIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, ATTORNEY IN FACT FOR BLAZER CONSUMER DISCOUNT
COMPANY, A PENNSYLVANIA CORPORATION 14415 South 50th Street Suite 100 Phoenix, AZ 85044 and
that the name(s) and last known address(es) of the Defendant(s) is/are CHARLES J. SMEIGH, 268 Carlisle
Avenue Enola, PA 17025;
GOLD CFERTY & McKEEVER
ck, Jr.
BY: Joseph ffaitiff(
Attomey to
ASSESSMENT OF DAMAGES
TO-THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $27,915.23
Interest from 08/15/2003 through $6,991.34
05/10/2005
REASONABLE Attorney's Fee $1,250.00
Late Charges $0.00
Costs of Suit and Title Search $900.00
TITLE/APPRAISAL FEE $225.00
($0.00)
BY: Joseph.
Attorney for
$37,281.57
Jr.
& McKEEVER
AND NOW, this p7 day of / r .:{? , 2005 damages are assessed as above.
Pro Prothy L?
In the Court of Common Pleas of Cumberland County
BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA
CORPORATION, ATTORNEY IN FACT FOR BLAZER
CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA
CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
Plaintiff
No. 05-1612 Civil
vs.
CHARLES J. SMEIGH
(Mortgagor(s) and Record Owner(s))
268 Carlisle Avenue
Encla, PA 17025
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 CHARLES J. SMEIGH by default for want of an Answer.
Assess damages as follows:
$37,281.57
Debt
Interest- 08/15/2003 to 05/10/2005
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 maile or delivered to the party against whom judgment
is to be entered and to his attorney of record, if any, after the default occurs d least ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
Jr.
I.D. #1611321
AND NOW /ISCO T o2Ss p4 S , Judgment is entered in favor of
BLAZER CONSUMER COMPANY: CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA
CORPORATION, ATTORNEY IN FACT FOR BLAZER CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA
CORPORATION and against CHARLES J. SMEIGH by default for want of an Answer and damages assessed in the sum of
$37,281.57 as per the above certification.
Prothonotary
/
CIMD-0404
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.
To:
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
BLAZER CONSUMER DISCOUNT COMPANY: CITIFINANCIAL SERVICES, INC.,A
PENNSYLVANIA CORPORATION, ATTORNEY IN FACT FOR BLAZER
CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
Plaintiff
vs.
CHARLES 1. WEIGH
(Mortgagor(s) tmd Record Owner(s))
268 Carlisle Avenue
Enola, PA 17025
Defendant(s)
TO: CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
DATE OF THIS NOTICE: April 27, 2005
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 05-1612 Civil
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF
THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE
YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 TNFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO
HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES
TI4AT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia, PA 19106 215627-1322
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
I P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC,, A
PENNSYLVANIA CORPORATION, ATTORNEY IN
FACT FOR BLAZER CONSUMER DISCOUNT
COMPANY, A PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
Plaintiff
vs.
CHARLES J. SMEIGH
Mortgagor(s) and Record Owner(s)
268 Carlisle Avenue
Enola, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 05-1612 Civil
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
08,115/2003 to
0511012005 at
14.4000%
$37,281.57
(Costs to be added)
GOLDBECK N?TY & McKEEVER
BY: Joseph A. 1 6 Jr.
Attorney for Plai ti f
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ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF
EAST PENNSBORO, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA,
BEING BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT ON THE EASTERN LINE OF CARLISLE AVENUE, SAID
POINT BEING 154 FEET MORE OR LESS, SOUTH OF THE SOUTHEAST CORNER OF
THE INTERSECTION OF SAID CARLISLE AVENUE AND CHURCH STREET, SAID
CHURCH STREET NOW BEING KNOWN AS SHADY LANE, THENCE IN AN
EASTERLY DIRECTION ALONG THE SOUTHERN LINE OF LOT NO. 14 A DISTANCE
OF 150 FEET MORE OR LESS, TO A POINT ON THE WESTERN LINE OF A PUBLIC
ALLEY; THENCE IN A SOUTHERLY DIRECTION ALONG THE WESTERN LINE OF
SAID PUBIC ALLEY, A DISTANCE OF 100 FEET MORE. OR LESS, TO A POINT ON THE.
NORTHERN LINE OF LOT I7; THENCE WESTERLY ALONG THE NORTHERN LINE OF
SAID LOT NO. 17, A DISTANCE OF 150 FEET MORE OR LESS, TO A POINT ON TAE
EASTERN LINE OF AFOREMENTIONED CARLISLE AVENUE; THENCE IN A
NORTHERLY DIRECTION ALONG THE EASTERN LINE OF CARLISLE AVENUE, A
DISTANCE OF 100 FEET MORE OR LESS, TO A POINT, THE PLACE OF BEGINNING.
BEING ALL OF LOT'S NUMBERED 15 AND 16 IN BLOCK "B" ON TIME PLAN OF LOTS
OF ENOLA TERRACE; SAID PLAN BEING RECORDED IN THE OFFICE OF THE
RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN PLAN BOOK 1,
PAGE 3.
HAVING THEREON ERECTED A RANCH TYPE RESIDENCE KNOWN AS 268
CARLISLE AVENUE, ENOLA, PA 17025.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 05-1612 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA CORPORATION, ATTORNEY IN
FACT FOR BLAZER CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA
CORPORATION, Plaintiff (s)
From CHARLES J. SMEIGH
(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 garnishee(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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $37,281.57 L.L. $.50
Interest FROM 8/15/03 TO 5/10/05 AT 14.4000%
Ally's Comm % Due Prothy $1.00
Any Paid $121.10 Other Costs
Plaintiff Paid
Date: MAY 25, 2005
CURTIS R. LONG
Prothonota
(Seal) By: /J 2, o / ?/ nay
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
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
BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, ATTORNEY
IN FACT FOR BLAZER CONSUMER DISCOUNT
COMPANY, A PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
Plaintiff
VS.
CHARLES J. SMEIGH
(Mortgagor(s) and Record Owner(s))
268 Carlisle Avenue
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Enola, PA 17025
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 05-1612 Civil
BLAZER CONSUMER DISCOUNT COMPANY: CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA
CORPORATION, ATTORNEY IN FACT FOR BLAZER CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA
CORPORATION, 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:
268 Carlisle Avenue
Enola, PA 17025
1.Name and address of Owner(s) or Reputed Owner(s):
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
EAST PENNSBORO TOWNSHIP
98 S. ENOLA DR
ENOLA, PA 17025
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 of every mortgage of record:
RANDALL R. SMEIGH
903 PIKETOWN ROAD
HARRISBURG, PA 17112
BLAZER CONSUMER DISCOUNT CO
9-A NORTH PROGRESS AVENUE
HARRISBURG, PA 17109
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. Nance 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
268 Carlisle Avenue
Enola, PA 17025
(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 unswom falsification to authorities.
DATED: May 20.2005
GOLDBECK McC&
BY; Joseph oseph A. Gol c Es
Attorney for Plaintiff
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05-1612 Civil
-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
BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, ATTORNEY
IN FACT FOR BLAZER CONSUMER DISCOUNT
COMPANY. APENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
Plaintiff
VS.
CHARLES J. SMEIGH
Mortgagor(s) and Record Owner(s)
268 Carlisle Avenue
Enola, PA 17025
Term
No. 05-1612 Civil
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: SMEIGH, CHARLES J.
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
Your house at 268 Carlisle Avenue, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 07, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $37,281.57 obtained by BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA CORPORATION, ATTORNEY IN FACT
FOR BLAZER CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA CORPORATION against
you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
To prevent this Sheriffs Sale you must take immediate action:
05-1612 Civil
1. The sale will be cancelled if you pay to BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA CORPORATION, ATTORNEY IN FACT
FOR BLAZER CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA CORPORATION, the back
payments, late charges, costs and reasonable attorneys 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.
1 You may also be able to stop the sale through other legal proceedings
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your propertywill be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff' and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
3 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
CIMD-0404
CF: 03/28/2005
SD: 09/07/2005
$37,281.57
BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, ATTORNEY IN
FACT FOR BLAZER CONSUMER DISCOUNT
COMPANY, A PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
Plaintiff
VS.
CHARLES J. SMEIGH
Mortgagor(s) and
Record Owner(s)
268 Carlisle Avenue
Enola, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 05-1612 Civil
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendant fi?nne oti a of eriff Sale was m de y 711/ 65
Personal Se )c &)t-10' the Sheriffs Office(orr?
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are
Section 4904.
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CertltiedMail Provides: a enadlzaozeunr'0oeduaodsd
¦ A mailing receipt
¦ A unique identifier for your maiipiece
¦ A record of delivery kept by the Postal Service for two years
Important Reminders:
• Certified Mail may ONLY be combined with First-Class Mail®or Priority Mal ®.
¦ Certified Mail is notavallable for any class of International mail.
• NO INSURANCE COVERAGE l i or Registered OVIDED Mail Certified Mail. For
valuables, pease
of
For an additional fee, a Return Receipt may be requested to provide proof
delivery. To obtain Return Receipt service , prease complete antl"attach a Return to the article
the
cover
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fee. EndorrseFmellpiece.?Return Rece pt Requestedli obreceive a fee wai er for
a duplicate return receipt, a USPS® postmark on your Certified Mail receipt Is
required.
1111 For an additional fee, delivery may be restricted to the addressee or
addressee's authorized agent Advise the clerk or mark the malipiece with the
endorsement 'Res tncte livery". p
• If at the postnoHlce for Ipostmaarking.IPltla pnstmaT OnStthe Cesen ertified Mail
receipt is not needed, detach and affix label with postage and mail.
IMPORTANT: Save this receipt and present it when making an inquiry.
Internet access to delivery information is not available on mail
addressed to APOs and FPOs.
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
BLAZER CONSUMER DISCOUNT COMPANY:
CIIIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, ATTORNEY
IN FACT FOR BLAZER CONSUMER DISCOUNT
COMPANY, A PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 55044
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
CHARLES J. SMEIGH
Mortgagor(s) and Record Owner(s)
268 Carlisle Avenue
Enola, PA 17025
Defendant(s)
Term
No. 05-1612 Civil
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
BLAZER CONSUMER DISCOUNT COMPANY: CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA
CORPORATION, ATTORNEY IN FACT FOR BLAZER CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA
CORPORATION, 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:
268 Carlisle Avenue
Enola, PA 17025
1.Name and address of Owner(s) or Reputed Owner(s):
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
EAST PENNSBORO TOWNSHIP
98 S. ENOLA DR
ENOLA, PA 17025
CITIFINANCIAL SERVICES INC., Attorney-In-Fact for Blazer Consumer Discount Company
7467 New Ridge Road
STE 222
Hanover, Md. 21076
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 of every mortgage of record:
RANDALL R. SMEIGH
903 PIKETOWN ROAD
HARRISBURG, PA 17112
BLAZER CONSUMER DISCOUNT CO
9-A NORTH PROGRESS AVENUE
HARRISBURG, PA 17109
CITIFINANCIAL, INC
1111 Northpoint Drive
Building 4 Suite 100
Coppel, TX 75019
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
268 Carlisle Avenue
Enola, PA 17025
(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 unworn falsification to authorities. n
DATED: August 5, 2005
'BY: Jose-ph A. Goldbeck,
Attorney for Plaintiff
r?i' -c+ ?7n
L, J
J"C_ N A
Blazer Consumer Discount Company:
Citifinancial Services, Inc., a Pennsylvania
Corporation, Attorney in Fact for Blazer
Consumer Discount Company, a
Pennsylvania Corporation
VS
Charles J. Smeigh
The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2005-1612 Civil Term
David McKinney, Deputy Sheriff, who being duly sworn according to law, states
that on July 01, 2005 at 8:30 o'clock PM, he served a true copy of the within Real Estate
Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the
within named defendant, to wit: Charles J. Smeigh, by making known unto Charles
Smeigh, personally, at 268 Carlisle Ave., Enola, Cumberland County, Pennsylvania, its
contents and at the same time handing to him personally the said true and correct copy of
the same.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states
that on July 13, 2005 at 4:17 o'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
Charles J. Smeigh, located at 268 Carlisle Ave., Enola, 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: Charles J. Smeigh, by regular mail to his last known address of 268
Carlisle Ave., Enola, PA 17025. This letter was mailed under the date of July 06, 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.
Sheriff s Costs:
Docketing 30.00
Poundage 15.51
Posting Handbills 15.00
Advertising 15.00
Levy 15,00
Mileage 24.00
Certified Mail 2.15
Surcharge 20.00
Law Journal 347.00
Patriot News 287.81
Share of Bills 18.20
Prothonotary 1.50
$791.17
Sworn and subscribed to before me
This ja day of
2005, A.D.
Pro ary
R. Thomas Kline, Sheriff
BY l
Real Estate S rgeant
e
I,5
cv? ,ro 9? 9
?, l c s a 8s'
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
BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, ATTORNEY
IN FACT FOR BLAZER CONSUMER DISCOUNT
COMPANY, A PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
vs.
CHARLES J. SMEIGH
(Mortgagor(s) and Record Owner(s))
268 Carlisle Avenue
Enola, PA 17025
Plaintiff
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 05-1612 Civil
BLAZER CONSUMER DISCOUNT COMPANY: CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA
CORPORATION, ATTORNEY IN FACT FOR BLAZER CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA
CORPORATION, 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:
268 Carlisle Avenue
Enola, PA 17025
1.Name and address of Owner(s) or Reputed Owner(s):
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
EAST PENNSBORO TOWNSHIP
98 S. ENOLA DR
ENOLA, PA 17025
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
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 of every mortgage of record:
RANDALL R. SMEIGH
903 PIKETOWN ROAD
HARRISBURG, PA 17112
BLAZER CONSUMER DISCOUNT CO
9-A NORTH PROGRESS AVENUE
HARRISBURG, PA 17109
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
268 Carlisle Avenue
Enola, PA 17025
(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 unworn falsification to authorities.
DATED: May 20. 2005
UOLllBECK McC&& McKEEVER
BY: Joseph A. Gol r. Esq.
Attorney for Plaintiff
05-1612 Civil
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, ATTORNEY
IN FACT FOR BLAZER CONSUMER DISCOUNT
COMPANY. A PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION -LAW
ACTION OF MORTGAGE
FORECLOSURE
Plaintiff
vs.
CHARLES J. SMEIGH
Mortgagor(s) and Record Owner(s)
268 Carlisle Avenue
Enola, PA 17025
Term
No_ 05-1612 Civil
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: SMEIGH, CHARLES J.
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
Your house at 268 Carlisle Avenue, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 07, 2005, at 10:00 AM, in Commissioners Hearing Rai 2nd FL Courthouse to
enforce the court judgment of $37,281.57 obtained by BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA CORPORATION, ATTORNEY IN FACT
FOR BLAZER CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA CORPORATION 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:
05-1612 Civil
1. The sale will be cancelled if you pay to BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA CORPORATION, ATTORNEY IN FACT
FOR BLAZER CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA CORPORATION, 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.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. "Ilse sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF
EAST PENNSBORO, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA,
BEING BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT ON THE EASTERN LINE OF CARLISLE AVENUE, SAID
POINT BEING 154 FEET MORE OR LESS, SOUTH OF THE SOUTHEAST CORNER OF
THE INTERSECTION OF SAID CARLISLE AVENUE AND CHURCH STREET, SAID
CHURCH STREET NOW BEING KNOWN AS SHADY LANE, THENCE IN AN
EASTERLY DIRECTION ALONG THE SOUTHERN LINE OF LOT NO. 14 A DISTANCE
OF 150 FEET MORE OR LESS, TO A POINT ON THE WESTERN LINE OF A PUBLIC
ALLEY; THENCE IN A SOUTHERLY DIRECTION ALONG THE WESTERN LINE OF
SAID PUBIC ALLEY, A DISTANCE OF 100 FEET MORE OR LESS, TO A POINT ON THE
NORTHERN LINE OF LOT 17; THENCE WESTERLY ALONG THE NORTHERN LINE OF
SAID LOT NO. 17, A DISTANCE OF 150 FEET MORE OR LESS, TO A POINT ON THE
EASTERN LINE OF AFOREMENTIONED CARLISLE AVENUE: THENCE IN A
NORTHERLY DIRECTION ALONG THE EASTERN LINE OF CARLISLE AVENUE, A
DISTANCE OF 100 FEET MORE OR LESS, TO A POINT, THE PLACE OF BEGINNING.
BEING ALL OF LOTS NUMBERED 15 AND 16 IN BLOCK "B° ON THE PLAN OF LOTS
OF ENOLA TERRACE; SAID PLAN BEING RECORDED IN THE OFFICE OF THE
RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN PLAN BOOK 1,
PAGE 3.
HAVING THEREON ERECTED A RANCH TYPE RESIDENCE KNOWN AS 268
CARLISLE AVENUE, ENOLA, PA 17025.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 05-1612 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA CORPORATION, ATTORNEY IN
FACT FOR BLAZER CONSUMER DISCOUNT COMPANY, A PENNSYLVANIA
CORPORATION, Plaintiff (s)
From CHARLES J. SMEIGH
(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 garnishee(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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $37,281.57 L.L. $.50
Interest FROM 8/15/03 TO 5110105 AT 14.4000%
Any's Comm % Due Prothy $1.00
Atty Paid $121.10 Other Costs
Plaintiff Paid
Date: MAY 25, 2005
CURTIS R. LONG
Prothonott
(Seal) ay-: 0? 4 . 2 / P
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
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 of the said Cumberland Law
Journal on the following dates,
July 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, place and character of publication are true.
i
sa Marie Coyne, E for
SWORN TO AND SUBSCRIBED before me this
29 day of July. 2005
-NOTARIAL SEAL "
LOIS E. SNYDER, Notary Public
Carlisle Bom, Cumberland County
My Commission Expires March 5, 2009
REAL ESTATE SALE NO. 64
Writ No. 2005-1612 Civil
Blazer Consumer
Discount Company:
Citifinancial Services, Inc. a
Pennsylvania Corporation,
Attorney in Fact for
Blazer Consumer
Discount Company,
a Pennsylvania Corporation
VS.
Charles J. Smeigh
Atty.: Joseph Goldbeck
ALL THAT CERTAIN piece or par-
cel of land situate in the Township
of East Pennsboro, County of Cum-
berland and State of Pennsylvania,
being bounded and described as
follows:
BEGINNING at a point on the
eastern line of Carlisle Avenue, said
point being 154 feet more or less,
South of the southeast comer of the
intersection of said Carlisle Avenue
and Church Street, said Church
Street now being known as Shady
Lane, thence in an easterly direc-
tion along the southern line of Lot
No. 14 a distance of 150 feet more
or less, to a point on the western
line of a public alley; thence in a
southerly direction along the west-
ern line of said pubic alley, a dis-
tance of 100 feet more or less, to a
point on the northern line of Lot 17;
thence westerly along the northern
line of said Lot No. 17, a distance
of 150 feet more or less, to a point
on the eastern line of aforemen-
tioned Carlisle Avenue; thence in a
northerly direction along the east-
ern line of Carlisle Avenue, a dis-
tance of 100 feet more or less to a
point, the place of beginning.
BEING all of lots numbered 15
and 16 in Block "B" on the Plan of
Lots of Enola Terrace; said Plan
being recorded in the Office of the
Recorder of Deeds in and for
Cumberland County in Plan Book
1, Page 3.
HAVING THEREON ERECTED a
ranch type residence known as 268
Carlisle Avenue, Enola, PA 17025.
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 19th and 26th day(s) of July and the 2nd
day(s) of August 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 Miscellan eous oA "M",
Volume 14, Page 317. _
PUBLICATION
COPY
SALE #64
Sworn to and subscf ybefore 166tth day
NOTARY PUBLIC
My commission expires June 6, 2006
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 287.81
REALESIXI SALENor E4
Witt No. 20BF1612
CWHTaM
BIww Conswnsr Dlacount
Inn a Vw"WWanla Caapontim,
Awma gi cFaet for Blww
Connam WACOM R Company, a
PswlaykwkW9orpomtI0n
Vs
ChWw J. Smtalgh
11tq(:.ISOapls CaWdtisek
DESCRIPTION
ALL,T W. CBMAIN piece or peal of land
shone mtbe'[oaailip of W?msbom,Camty
of CumbedW WA SW of peawlvaoia, being
bowdcdanddwmb daefoUm
BEGBW4r, it a point m the Ew n he of
Carlisle Avmnc; said pmts being 154 fed more a
less, South of the Swtheast comer of the
intemeboa' of aid Cadide Avewe and Chinch
Sued, SW Church Saes now being bin ur
Shady Laue,thmre to an Easy direconn along
the Swtheam lime of Lot No. 14 a diwace of 150
fedmae or lm,m apomt w the Weaanfioe of -
a public. alley, thence in a Southedy diction .
doog the Western tine of said pnbtic alley, a
disnpce of 100 feet am a Im,to a pmt an the
Noahw lime of Lot 17; thence Wewdy sling the
Northern fine ofsaidLm No. 17, a didk of 150
fee sae or Im, m a point an the Bagam tine of
afar„Cadide Avenue; tbeace in a
Yft teoorded a the Office of the RaIM414f
ft6 in W for Ca balmd Cwatst
Biwa l,Pag3.
HAVING theseao etesurd a ranch type residence
(mown as 268 Cadisk Avewe,Enola,pA 17025.
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
BLAZER CONSUMER DISCOUNT COMPANY:
CITIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, ATTORNEY IN
FACT FOR BLAZER CONSUMER DISCOUNT
COMPANY, A PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
Plaintiff
vs.
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 05-1612 Civil
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly vacate the judgment upon payment of your costs only.
.16
MICHAEL T. MCKEEVER, ESQUIRE
CS
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 14106-1532
215-825-6321
Attornev for Plaintiff
BLAZER CONSUMER DISCOUNT.
COMPANY: CITIFINANCIAL SERVICES,
INC., A PENNSYLVANIA CORPORATION,
ATTORNEY IN FACT FOR BLAZER
CONSUMER DISCOUNT COMPANY, A
PENNSYLVANIA CORPORATION
14415 South 50th Street
Suite 100
Phoenix, AZ 85044
Plaintiff
vs.
CHARLES J. SMEIGH
268 Carlisle Avenue
Enola, PA 17025
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 05-1612 Civil
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of your costs only.
MICHAEL T. MCKEEVER, ESQUIRE
'` " rat
ca
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