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MEMBERS 18T FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
NO. O~-;)<!SJ> Ciu~l~8L~
NICKOLAS BUGOSH AlK/A
NICHOLAS BUGOSH
DEFENDANT
. CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE
ATTEMPTIING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
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 this
Complaint and Notice are served by entering a written appearance personally or by
attorney and filing in writing 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
claimed in the Complaint or for any other claims 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 TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VENUE
CARLISLE, PA 17013
(717) 249-3166 OR (800) 990-9108
MEMBERS 1 ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
NO.
NICKOLAS BUGOSH AlKlA
NICHOLAS BUGOSH
DEFENDANT
. CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
NOTICIA
Le han demandado a usted en la corte. Si usted guiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al
partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia
escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0
sus objectiones alas demandas en contra suya
Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar
una orden contra usted sin previo aviso 0 notification y por cualquier queja 0 alivio que
es pedido en la peticion de demanda USTED PUEDE PERDER DINERO 0 OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE 0 CONOCES UN ABOGADO, VA Y A EN PERSONA 0
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
(717)249-3166 or 1-800-990-9108
MEMBERS 1sT FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
NO.: ({).J- J-45~
NICKOLAS BUGOSH aIkIa
NICHOLAS BUGOSH
DEFENDANT
: CIVIL ACTION-LA W-MORTGAGE
: FORECLOSURE
COMPLAINT
AND NOW, comes Members 1st Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
1. Plaintiff, Members 1st Federal Credit Union ("Members Isr), is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
2. Nickolas Bugosh aIkIa Nicholas Bugosh (referred to herein as "Defendant"),
is an adult individual having a last known address of 1493 English Drive,
Mechanicsburg, PA 17055.
3. On or about October 7, 2003, Defendant borrowed from and agreed to repay
to Members 1 sl SEVENTY THOUSAND FIVE HUNDRED AND NOlI 00
($70,500.00) dollars (the "Loan"). The Loan is evidenced by a Note dated
October 7,2003 (the "Note") executed and delivered to Members 1 st by
Defendant. A copy of the Note is attached hereto as Exhibit "A" and made
part hereof.
4. As security for the Loan, Defendant executed and delivered to Members 1 st a
mortgage ("Mortgage") on all that certain tract of ground together with
improvements erected thereon situate in East Pennsboro Township,
Cumberland County, Pennsylvania, known and numbered as 142 Wyoming
Avenue, Enola, P A 17025 ("Property"). At all times relevant hereto,
Defendant has been and continues to be the record and sole owner of the
Property. A description of the Property is attached hereto as Exhibit "B" and
made part hereof.
5. On or about October 17, 2003, the Mortgage was recorded in the Cumberland
County Recorder of Deeds Office at Mortgage Book 1841, Page 1922. A true
and correct copy of the Mortgage is attached hereto as Exhibit "c" and made
part hereof.
6. The Mortgage has never been assigned by Members 1 51 and is still held by it
as a valid and subsisting obligation of Defendant.
7. Pursuant to the tenns and conditions of the Note, Defendant agreed to pay to
Members 1 st bi-weekly installments of principal and interest in the amount of
at least $278.51 each beginning on October 29, 2003 and continuing every
fourteen (14) days thereafter.
8. Defendant is in default of Defendant's obligations under the Note and the
Mortgage as a result of Defendant's failure to make the payments due to
Plaintiff as set forth therein.
9. Pursuant to the Act of January 30,1974, P.L. 13, No.6, 41 P.S. section 101,
et. seQ., and in particular section 403 thereof, Members 151 gave written notice
to Defendant of its intent to foreclose by letter dated January 3, 2005,
addressed to Defendant via certified mail, return receipt requested. A copy of
the said notice is attached hereto as Exhibit "D" and made part hereof.
10. In accordance with the Homeowners' Emergency Mortgage Assistance Act,
Act of December 23, 1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et.
seq., a Notice ofIntent to Foreclose and of Defendant's rights under said Act
was forwarded to the Defendant on January 3, 2005, via certified mail, return
receipt requested. Members 1 st believes and therefore avers that Defendant has
not applied for assistance under the Act. A copy of the said notice is attached
hereto as Exhibit "E" and made part hereof.
11. A copy of Postal form 3877 evidencing the mailing of said Notices is attached
hereto as Exhibit "F" and made part hereof.
12. Simultaneously, Members 1st forwarded to Defendant the same Notices as set
forth in paragraphs 9 and 10 above addressed to Defendant by United States
mail, fIrst class, postage prepaid, bearing the return address of Members 1st.
The Notices forwarded to Defendant in said manner have not been returned to
the offices of Members I st as undeliverable or otherwise.
13. As of the date hereof, Defendant is indebted to Members 1 st in the amount of
SEVENTY THREE THOUSAND SIXTY THREE and 62/100 ($73,063.62)
dollars itemized as follows:
a. Outstanding principal
b. Interest to May 6, 2005
c. Late fees
d. Attorney's fees
f. Total due to Members 1 st as of May 6, 2005
$68,004.83
2,377.70
181.09
2.500.00
$73,063.62
The above attorney's fees are estimated and are in accordance with
Defendant's agreements as set forth in the underlying Mortgage and Note.
14. Defendant also agreed under the terms and conditions of the Note that in the
event of default there under Defendant would pay, in addition to the amounts
set forth in paragraph 13 above, costs incurred by Members I st as a result of
the institution of these legal proceedings.
15. The obligation owed to Members 1 st continues to accrue interest at the rate of
$11.6447 per day, through the date of payment, including on and after the date
of entry of judgment on this Complaint, and continues to accrue late charges
and attorney's fees.
16. As set forth above, Members 1 st has made demand upon Defendant to cure
the default under the Mortgage and the Note. However, as of the date hereof,
Defendant continues to fail and refuses to cure the default.
WHEREFORE, Plaintiff, Members I st Federal Credit Union, demands judgment
against Nickolas Bugosh aIkIa Nicholas Bugosh in the amount SEVENTY THREE
THOUSAND SIXTY THREE and 62/100 ($73,063.62) plus interest at the rate of
$11.6447 per day, through the date of payment, including on and after the date of entry of
the judgment on this complaint, additional attorney's fees and costs of suit and for
foreclosure and sale of the mortgaged property.
Respectfully submitted,
Date: &16~~
n
"~-
arl . Lede hm, Esq.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, P A 17070-0173
(717)938-6929
Attorney for Plaintiff
NOTE
IC,I~ J
PENNSYLVANIA
. .IS!~I~i
ocrOBER 7
2003
MECHANICSBURG
..\42.WXOMIN~ AVE~UE..ENOLA,. PENNSYLVANIA 17025
. . ip;o.I'~(iv'Ad;l'~~;1 .
I. nonUOWEWS l'IU)l\lIS!-: TO P^"
l111clmll lor a 11l,11! that I have I'cn:ivcd. I pf"(ll11ise 10 pay U.S. $. ?P.,.5:Q9..P,Q...
"principal"). pIlls 111\cn:sl. \0 Ihe (llder 01 the I.cnd!.:!.
I he I.cllder is MEMBERS 1ST FEDERAL CREDIT UNION
. . ..' (this amount is called
J ulIlJcr.sland that lhe Lelldell11ay transfer Ihis Noll'. The Lemler or <lnynnc who lakes this Noll' by lrunsrcr and who is
l"lllilkd 111lTl"civc payments ll11d~1' (Ilis Nlllc is t,..;,llcd tht: "Note Ilolder."
1. INTEHLST
Inlcn.:.sl willi'!.: dwrgcJ 011 lhe 11llpaid rrilH.:ip:ilulllillhc lull illnOllnl or the principal has been paid. I will ray
illtcrest HI a vcnrly ratc uf ... .~~7.5....... %.
The i;llcrc~l raIl' rcyuircd by this Section 2 is lhe rule I will pay hoth hefore and uner llllY default deserihed in
SCl.!ion (,(11) or \hi!; Nlllc.
.1. I'A YMENT~
(A) TIllie alld '"lace or I'aYllIellt.'i
I will pay I'rlllt:ipal and irUcl'est by Illaking pllYlllents every fourteen Jays ("hi weekly").
I willlllilkc lilY biwcekly rnyrncnls heginning 011 .' O.C:I;ql}~R. .Z~............... ) .?99.3.., anu conlinuing
every IOllrtccn Jay.~ tllClcallcr. I wil1nwkc the.\c P:IYll1CIlIS cvery fOllrleen days unlill have paid all the principal and
intl.lcst ;ind ;ll1y olhcr!.:hargcs desnihed below thaI Imay owe ullder this Note. My biweekly payments will he applied to
inlelest bdmc lll'il\l:iI1i\1. It', on .. .~?I:::rrRWH:J;t. .2.6.\.70.1.&......., ..,..,.. \ :o\i\\ owe illlHHlnts under this Note. I
will pay tlHlse alllOllnl.~ in hIll 011 that date, whidl is called thc "maturity date."
I willlllakc my biweekly pi\Yl11enl.~ at .. .~Oo.q )..OUISE DRIV~ HECHAN~_C,~~1)~.G.~ .fl'-,.~ ?9..5.~
, , , . , .... .,............,... or at :1 dillerent plaee if required by the Note I!older,
(n) AlllOlIlIlllf Iliweckly I'RYlllelll~
Mv hiweddy rayment will be iuthe alllount ill" U.S. $. ~?~:-?,l...,
4. 1I0HHOWEI('S UH;IIT TO I'IH:I)^ V
I havc Ihc righl 10 make payments 01 pl'lIleip:il ;It (lilY tlllle hdlH"e they arc dlle. ^ payment of principal ollly i.~
ktltlWll as a "prepaYIIICIlI..' Whell Imakc.1 pn:paYlllelll, I willtdlthc Nole Jlolder ill wriling lhat] alII doing .~(),
I rnay Illake a lull prepayment ur panial pn:p\\)lmenls wi\holll paying .my prepilyme111 charge. .llle Nole Holder
will ll.\e all of Ill)' prepaYl11ents 10 reducl" tile alllount of prindplll that I owe undcr lhi~ Note. II I make it rartilll
prepayment. there will be 110 changes in the due date Of ill the illllOunt of my biweekly payment unless lhe Note Bukk,.
agrees in writill~ lo those changes.
5. LOAN C1IAIU;ES
II II law, which applies tn Ih.ls loan and wll'leh sets I11<lXllllLllllloan eharge.\, is finally interpreted so Ihatlhe intercst
or other IO;lllchmges collected or to he cClllcded illconllectiHIl with this loan excecd the permitted limits, tlien: (i) any
soch loan char~e sh.dl he l'edw.;cd by tile \\t\HHm\ I\cce~sar)l \0 reouc\': \hc charge to \ht: permitted hlllil; arltl (ii) any .SUl11~
.i111;adyullledcd lrolll mc whi!.:h exceeded pcrmitteu limits will be; refunded to me. The Note Holder may choose to makc
this lclllnu hy rcducing the principal I owe unucr lhis Note or hy making a direct payrnetlllu me. 1[" t\ rdul\d rnlu'.:e!'.
principal. Ihe redul.;lioll will be trcateu liS a p:nti,,1 prcpuyrncnt.
6. nOIUHJWEWS rAll.UnE TO I)AY AS HEQUIU.ED
(A) 1.Hle Chaq~c for Overdue PaYlllenls
If the Nole Holdel has not received lhe lull :lmOllllt of any hiweekly paymenl by the enu of ,.~~..., calendar
days alLer the diltc it isdu...., I win })\\y a late c\mrgc\n\he Nolc Holder. The anlOlIllt of the charge will be . ,~...O.Q, . (M, 0]
my overdue payment of prilleipal and internL I will pny lhis lale charge promptly but only OlH.:e 011 e"ell late payment.
(II) Default
II" I (10 not pay the full amount of eaell hiweekly payment on the uate it is due, I will be in uefault.
(C) Nutice or Dcfaull
If I am ill udalllt, thc Note Ilolder llWy send me iI written nOliee telling me that if I do not pay lhe overdue alllount
by a certain date, the Note 1I0luer may require me to pay iml11ediately the rull amount of principnl whidl has not been
I~\\il\ I'm! 1\11 lhe in\ele~\ \hat lowe on that amount. That datc IHust be at least 30 days after the date on which the notif.;e i.~
delivered or ll1<1ilcd ((ll11e.
(I)) No Waiva ny Note Holder
l;ven ii, atlltillle when t arll in Jdilllll, Ihe biole Hoidel' dues not require me tu pay illllllcdiaicly itllull ,is de.\crlbcJ
ahnve, the Notl,.' lIolder will still have the right 10 do so if I ,1111 ill dcfilUl1 at a later lime.
In "Hymcnl or Noll' lIulder's emts I1ml Expellse_s
II lhe N\lle Holder has requircd l11l' lo PilY inlJlleJiately ill lull a.~ de.serihed IlllOve, the Note Holder will have the
li~\\\ \\1 \)0.:: plliJ \wcK by nlC lor ,Iil 01 '11.\ costs and expenses in enlllrcing thi.~ Note to the e)l.lent not prohibited hy
;lpplicuhle law. Those expenses include, for example, reasonahle attorneys' fees.
7. (;IVIN<; OF NOTICES
lJlllc.\s appli!.:ahlc law req\lire.~ a uillefcnt rnethou. allY llotice that lIIust be given to me under this Note will he
!!-ivell hy deliverin!', it or by mailing it hy firsl c]a.~.~ mail 10 IlIe at the l)r\lperty Addrcssaho\'cor M adilkrl:ll\ \\\hhess ii"
give the Nole ]lold.er a noti\.c or my dilfen.:llt addJ'e.~s.
AllY notice thntlllllst be given 10 the Note Ilolder under this Note will he given hy mailing it by nrst c1as.~ 111ail to
Iho.:: Nnlc II nh.lcr 011 the aJdress stated in Section J(A, above or al 11 dilTerent address if I alll given a notice of that different
address.
MULTISTATE FIXED RATE NOTE-s'".'oF,mily-B,woekly
23730264 PTD 2/87
BANCONSUMER FORM US M.196 (10/85)
EXHIBIT A
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3LON SIII.L 1I.UNrl SNOSlI.d ,.0 SNOI.L V~n80 '8
ALL THAT CERTAIN lot or piece of ground with improvements thereon erected
situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and
described in accordance with a survey made by D. P. Raffensperger Associates, Engineers
and Surveyors, dated February 4,1980, as follows, to wit:
BEGINNING at a point on the eastern side of Wyorning A venue, said point being
referenced 460.00 feet in a southerly direction from the intersection of Wyoming Avenue
and Dauphin Street; thence along the dividing line with property No. 144 Wyoming
Avenue, North 79 degrees 40 minutes East, 188.07 feet to a point; thence South 02 degrees
10 minutes 05 seconds East, 25.25 feet to a point; thence along the dividing line with
property No. 140 Wyoming Avenue, and through the center of a partition wall and beyond,
South 79 degrees 40 rninutes West, 184.48 feet to a point on the eastern side of said
Wyorning Avenue, North 10 degrees 20 rninutes West, 25.0 feet to a point, the place of
BEGINNING.
BEING the same premises which Nickolas Bugosh, single man, and Rebecca Ochs,
single woman, by their Deed dated October 7, 2003 and to be recorded herewith, granted
and conveyed unto Nickolas Bugosh.
142 Wyoming Avenue
Enola, P A 17025
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EX!iIBIT B
BK I 8 4 I PG I 9 2 8
0;7 'x'. } Y
'J,I () ,7-- 'J
. I ILl _ ,\
CU~-V+-
;:.- ~~~~T P. ZIEG~ER
... \:~\ :'~ L:: C R 0;: D:: ~ [I ~:
'JEf\LAND COUNTY-
~3 OCT 17 Arl 8 35
[Space Above This line Fo, Recording Data)
MORTGAGE
THIS MORTGAGE (""Security Instrument") is given on ....o.c:r()Il.E~ }..............
.2.0.03... The mongagor is ..NlCJlQLA.5..lWGQS.1I........
..................................................... ("Borrower"). This Security Instrument is given to ..............................
.... ..~emt.e~s.l.st .Fe.de.ral.Cr~dit .lJIlloP............. .............................................. . which is organized and existing
under the laws of ..~h~...U))g.~.d...~.~;>.t.~.s..!:>~...A1n"rJ.~."........ . and whose address is .....................................
......:............. ... .50(jOlOYI?E J)ltryE..~II:c:H.A.l>i\<;:.S81!.~.G, P~.I7055................................................ (" Lender" ').
Borrower owes Lender the principal sum of ::aWENT.Y.. J:llOT,J.SMffi. .HY:1l.. JlJJNl:>.REP.. MP.. .RO.. QllE.. llT,JJmREO.l'IlS ..
............................................... Dollars (U.S. $ .7.a..sQa...o.o........). This debt is evidenced by Borrower's nOle
~:l~~j ~~~ :~~= ::::.~: :::.: :~:.:: S='2'..::-:~:" !:;:':::-":::'.~:-:: ~";.:c::";, ','..~::!; r-:-:::'::2=:': :::- :::::::::!":!~' ~3ymerHS, with the full debt, if not
paid earlier. due and payable on ..........S.E.l;'.'l'WER..2.6L2.0. .e................................. . This Security Instrumen<
secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and
modifications of the Note; (b) the payment of all other sums. with interest. advanced under paragraph 7 to protect the security
of this Security [nstrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument
and the Note. For this purpose. Borrower does hereby mongage. grant and convey to Lender the following described propeny
located in .G\l.M;IlIlRJ"ANP........ ........... ................... ................ County. Pennsylvania:
SCHEDULE "A" ATTACHED
.
which has the address of.. 142vrxO.M.INc;..A'-:l'N.U.E.....
[Slrecll
..EN()L.A........
ICiryl
Pennsylvania ....E9.?~............ ............ (""Propeny Address"):
lZip Cud~!
TOGETHER WITH all the improvements now or hereafter erected on the propeny. and all easements. appunenances.
and fixtures now or hereafter a pan of the propeny. All replacements and additions shall also be covered by thIS Security
Instrument. All of the foregoing is referred to in this Security Instrument as the "Propeny."
BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has tho nght to mongage.
grant and convey the Propeny and that the Property is unencumbered. except for encumbrances of record. Borrower warr3nts
and will defend generally the title to the Propeny against all claims and demands. subject to any encumbrances of record.
PENNSYLVANIA-Single family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT
Form 3039 9190 (p{)~ 1 ul6 pagts)
Rev. 8/97
EXHIBIT C
SK.I 8 4 I PG I 9 2 2
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onp u'4'" ".d "pdwOJd IfC4' ""'OJ10H 's,llJe4::l aIr, pur luawiedJJd ll.OJOIUI pue ledp~Pd JO IU'":,hCd ,1
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, 'l'ISUO':> 01 UOll:>lpsun( ,,(q SUO!lElJE^
...uJdoJd P:jJ aU\J;lt\o:l lUJwrulSUI ^)un.J;ls ullOJlun r ;nn _ ' . .' . .
P;>J/W!i 4Jltr. )jUr:L'';:UIO;J WJDjlun-uou pur ~sn (ruom:u JOj S"lUE'U;)r\~j l~UOnun s;;!U~qwo=, l.N3l\:n'B.LSNl AII1!.:1J3S SIHl
for the penods that L:nder requIres. The lnsurance CJrrlt;r providIng the InSUrJnce shJI! be -.:ho::.t:n by Borrower iubJect [0
Lender"s Jpproval whlc~ shall nor be unreasonably withheld. If Burrower fails (0 maintaIn (lJvcrJ~e Jescnbed above, Lender
may, at Lender"s opllon. 0blJln 2DVerJge 10 prOtect Lcnder\ rIghts ;n the Propt:rty In J(;:ordJn(~ with pJrJgraph 7
All insurance pollc!es Jnd renewals shall be acceplJble 10 Lender and shall Include a sundard mongJge clause. L~nde:""
shall have the right to hold the poliCIes and renewals. If L~nder requires, Borrower shall promptly ~pve to L::nder Jll receipts
of paid premiums and renewal nDuces. [n the event of loss, Borrower shall gIve prompt nollce to the Insurance carner and
Lender. Lender may make proof of loss if nOt made promptly by Borrower.
Unkss Lc:nder and Borrower orherwlse Jgre~ In wrHtng, insurance proceeds shall be applied to reswr:llion or rep<:Hr
of the Property damaged, if the restoration or repaIr IS economlCJlly feaSible JnJ L-=nder.s securuy IS not I~ssened. If the
restoration or repair is nO[ economlcJlly feJslble or Lender's security would be lessened, rhr.: Insurance priXeeds shall be
applied to the sums secured by this Securiry Instrumem, whether or not then due, with Jny excess paid to Borrower. If Borrower
abandons the ProperlY, or does not Jnswc' Within 30 Jays a i1O{Ice from Lender that the Insurance carner has offered to
settle J claim, then Lender may collect the i,lsurance proceeds. Lender may use the proceeds to repair or restore the Propeny
or to pay sums secured by this Security Inslrument, whether or not then due. The 30-day penod wIll begIn when the notice
is given.
Unless Lender and Borrower otherwise agree in wriung, JOY application of proceeds [Q principal shall not extend
or postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the amount of the paymems.
[funder paragraph 21 the Property is acquired by Lender. Borrower's right to any insurance policies and proceeds resulting
from'damage to the Property prior to the acquisition shall pass to Lender to the extent of the sums secured by th,s Security
Instrument immediately prior to the acquisition.
6. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application;
Leaseholds. Borrower shall occupy, establish, and use the Propeny as Harrower's principal reSIdence wilhin sixty da!,s
after the execution of this Security Instrument and shall continue to occupy the Property as Borrowers principal residerice
for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall nO{ be
unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not
destroy, damage or impair the Propeny, allow the Property [Q deteriorate, or commit waste on the Propeny. Borrower shall
be in default if any forfeiture action or proceeding. whether civil or criminal. is begun that in Lenders good faith Judgment
could result in forfeiture of the Property or otherwise materially impair the lien created by this Security Instrument or Lenders
security interesL Borrower may cure such a default and reinstate, as provided in paragraph 18, by causing the action or
proceeding to be dismissed with a ruling that. in Lender's good faith determination. precludes forfeiture of the Borrowers
interest in the Property or other matenal impairment of the Iten created by th,s Security Instrument or Lenders secumy
interest. Borrower shall also be in default if Borrower. during the loan application process. gave materially false or inaccurate
information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan
evidenced by the Note, including. but not limited to, representations concerning Borrower's occupancy of the Property as
a principal residence, If this Security Instrument is on a leasehold. Borrower shall comply with all the provisions of the lease.
If Borrower acquires fee title to the Property. the leasehold and the fee title shall not merge unless Lender agrees to the
merger in writing.
7. Protection of Lender's Rights in the Property. If Borrower fails to perform the covenants ,nd agreements
contained in this Security Instrument. or there is a legal proceeding that may significantly affecl Lenders rights in the Property
(such as a proceeding in bankruptcy. probate. for condemnatIon oc forfeiture or to enforce laws or regulations). then Lender
may do and pay for whatever is necessary to protect the value of the Property and Lenders rights in the Property, Lenders
actions may include paying'any sums secured by a lien which has priority ova this Security Instrument, appeJflng In court,
paying rea~onable attorneys' fees and entering on the Property to make repairs. Although Lender may take action under
rhis paragraph 7, Lender does not have to do so.
Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secuced by thIS
Security [nstrumenL Unless Borrower and Lender agree to other terms of payment, these amounts shall beJ.r interest from
the date of disbursement at the Nare rate and shall be payable. with interes[, upon nor ice from Lender to Borrower requesting
payment.
8. Mortgage Insurance. If Lender required mortgJge insurance as a conditIOn of mJking the loan secured by this
Securi[y Instrument, Borrower ShOll! pay [he premiums required to maintain the mortgage insurance in effect. If. for any
reason. the mortgage insurance coverage required by Lender lapses or ceases to be in effect, Borrower shall pay [he premiums
required to obtain coverage substanually equivalent to {he mongage insurance previously in dfect. at a cost substantially
equivalent to the cost to Borrower of {he mongage insurance previously in effect, from an Jltemate mongage insurer approved
by Lender. If substantially equivalenr mongage insurJnce coverage is nor available, Borrower shall pay to Lender eJch month
a sum equal to one-twelfth of the ye;lrly mongage insurance premium being paid by Borrower \l,-hen the insurance coverage
lapsed or ceJsed to be in effect. Lender will accept, use and retain these payments as a loss reserve in lieu of mongJge
insurance. Loss reserve payments mill' no longer be required, at the option of Lender, if mortgage insurJnce co\"erage (in
rhe amount :.lnd for the paioJ th:.H Lender requires) provided by an insurer approved hy Lender JgJln becurnes avajlable
Form 3039 9/90 Ipi..l.~c' J uf j piJi{I''iJ
::SK 184 I PG 192:4
and lS obtJlned B(1rrnwcr slnJl f'J}' ~l1e premiums required l\) :T1:1lntJIn mongJge lnsurance in ::ffee:. or to prnvlde ;:] lOSS
reserve, untll the rC4uirell1ClH for morrg;lge In~urJncc emls in .1(\:nrd:.lnce with ;'.lI1y written Jgrccmer1l between Borrower
and L-:nucr or JrrlicJbk la\1,.'
9. InsPfftioll. LCl1tkr I)r liS J!:'!ent rllJY mJkc rC;l.'innabi.: entrlcs UpOll ;Jnd Inspections (Jf [he Propeny l~!'"Idcr ~hJII
give Bnrrowcr nn!KC ;11 [h~ time of ,lr prior to an inspection specifYing reJ.son~blc cause for the inspectlon.
111. Condemnation. The pr11o.;ceJ.<; (l( Jny JW;Jru 11r cl.::llril for Jamages. J1r(~t.:: ,)r conscquenllJI. In connC!.,'ilon wllh
any condemnJt!on or ulher [3~dng nf <lilY parr or {he Property. or for \,;"onveyancc In lieu of condemnJIIOn, Jre hereby assig.ned
and shall be pa,d '0 Lender.
In the event of J [owl Wklilg of the ProperTY. the proceeds shall be applied to the sums secured by thiS Security Instrument.
whether or not then due. wlfh an:, C.'Less paid to Borrower. In the event of a partial ~aking of {he Property in which the
fair market value of the Propeny immt::diately before the taking is equal to or grcater than the amount of the sums secured
by this Security Instrument immedlJ.tely before the tJ.king, unless Borrower and Lender otherwise agree in writing. the sums
secured by thIS SecurJty Instrument shJ.1l be reduced hy (he Jn101lnl of the proceeds multiplied by the follOWing fraction:
(a) the IOlal amount of the sums secured immedia{ely before the taking. divided by rb) the fair market value of the Propeny
immediately before {he takIng_ Any balance shall be paid {O Borrower. In rhe -=....Cnt of a partial takJng of {he Property in
which the fair market value of the Property immediately before the taking is less than the amount of the sums secured im.
mediately before the taking. unless Borrower and lender otherwise agree in writing or unless applicable law otherwise pro.
vides. the proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due.
II the Property is abandoned by Borrower. or if. after notice by Lender to Borrower that the condemnor offers to
make an award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after [he date the notice
is given. Lender is authorized to collect and apply the proceeds. at its option. either to restoration or repair of the Property
or to the sums secured by this Security Instrument. whether or not then due.
Unless Lender and Borrower otherwise agree in writing. any application of proceeds to principal shall not e.'tend
or postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the amount of such payments.
II. norro"".er Not Released: Forbearance By Lender ~ot a Waiver. E:r;tension of the time for payment or
modification of amortization of the sums secured by this Security Instrumem granted by lender to any successor in interest
of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender
shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or
otherwise modify amortization of the .sums secured by this Security Instrument by reason of any demand made by {he original
Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be
a waiver of or preclude the exercise of any right or remedy.
n. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements of
this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower. subject to the provisions
of paragraph 17. Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security
Instrumenr but does not execute the Note~ (a) is co-signing this Security Instrument only to mortgage, grant and convey that
Borrower's interest in the Property under the terms of this Security Instrument: (b) is not personally obligated to pay the
sums secured by this Security Instrument; and (c) agrees thJt Lender and any other Borrower may agree to extend. modify.
forbear or make any accommudations with regard to the terms of this Security Instrument or the Nore without that Borrowc.r's
consent. _.
13. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets ma,imum loan
charges. anJ that law is finally interpreted so rhat the interest or otlu:r loan charges collected or to be collected in connection
with the loan ",ceed the permitted limits. then: (a) any such loan charge shall be reduced by the amount necessary to reduce
the charge to the permitted limit: and (b) any sums already collected from Borrower which e,ceeded permitted limits will
be refunded to Borrower. L~ndcr may choose to make this refund by reducing the principal owed under the NOle or by making
a direct payment to Borrower. If a refund reduces principal. the reduction will be treated as a partial prepayment without
any prepayment charge under the NOle.
14. Nutices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or
by lIli.liling it by first class milil unless applicable law requires use of Jnothcr method. The notice shall be directed to the
Property Address or any other address Borrower designates by notice to Lender. Any notice to lender shall bl:: given by
first class mail to Lender's address .stated herein or any other address Lender designates by notice to Borrower. Any notice
provided for in this Sc:curity Instrum'.:nt shJII be deemed (0 ha\'e bec:n given to Barrov,/er or Lender when given JS provided
in this paragraph.
15. Governing Law; Severability. This Security Instrumen! shall be governed by federal law and the law of the
jurisdiction in which !he Propcny is InCHed. In the event that any provision or clJuse of lhis Security Instrument or the SOle
connicls with applicJblc law. such Clllltlld shall nOl :.1ffCCI i1thcr prml"itJns Ilf this Security [nstrumem or the ,'iole Whl~h
can be given effect without the conOicting provision. Tn [hIS enli [he pwvislons of thiS Security fnstrumt:m and the ~ote
are declared to be severable.
16, Borrower's Copy, Bnrr()wcr shJl1 be givt:n one conCormed copy of [h~ ~0(e and llf Ihls St:curity Instrument.
Form 3039 91:10 (po u J of 0 pl1~W
BK I 84 I PG I 925
17. Transfer of the Property or a Beneficial Interest in Borrower. If all or any pan of the Propeny o( any
interest in it is sold or trJnsferred {or If J bend"iclJ.l int~rest in Borrower IS sold or transferred Jnl.l Borrower IS nOI a natural
person, wlthour u:nder.s, prwr wnnen cunsent, Lender may, Jt Its option. require immediate payment in full of JIl sums
secured by thiS Secumy Instrument. However, thiS option shall not be exercis~J by Leoda If e;~erClse IS prohlblled by t"eJeri.L1
law as of the date of this Security Instrument.
If Lender exercises [hiS option, Lender shall give Borrower notice of accekra[ion. The oouce shall provide a period
of not less than 30 days from the dare the oOlice is delivered or mailed within which Borrower must pay all sums secured
by this Security InslrumeOl. If Borrower fails to pay these sums pnor to thl:: ~xpiration of this period. L~nder may jnvok~
any remedies permitted by thl~ Secunty Instrument without Nnher notice or demand on Borrower.
18. Borrower's Right to Reinstate. If Borrower meets cemin conditions, Borrower shall have the right to have
enforcement of this Security Instrumenr discontinued at any time prior to the earlier of: (a) 5 days (or such other pertod
as applicable law may speCify for reinstatement) before sale of the Propeny pursuant to any power of sale contained in this
Security Instrument; or (b) entry of a judgment ~nforcing this Security Instrument. Those conditions are that Borrower:
(a) p<;iys L:nder all sums which [hen would be due under this Security fnstrument and [he Nore as if no acceleration had
occurred; (b) cures any default of any other covenants or agreemenrs; (c) pays all expenses incurred in enforcing this Security
Instrument, including, but nor limited to, reasonab;e Juorneys' fees; and (d) takes such action as Lender may reasonably
require to assure that the tien of this Security Instrument. Lender's rights in the Property and Borrower's obligation to pay
the s;ums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security In-
strument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. However. th,s
right to reinstate shall nOI apply in the case of accderation under paragraph !7.
19. Sale of Note; Change of Loan Servicer. The Note or a partial interest in the Note (together with this SecurilY
Instrument) may be sold one or more times wnhout prior notice [Q Borrower. A sale may result in J ..:hange in the entHy
(known as the "Loan Servicer") that collects monthly payments due under the Note and th,s Security Instrument. Theee
also may be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan
Servicer, Borrower will be given written notice of the change in accordance with paragraph 14 above and applicable law.
The notice will slate the name and address of the new Loan Servicer and the address to which payments should be made.
The notice will also contain any olher information required by applicable law.
20. Hazardous Substances. Borrower shall not cause or permit the presence. use. disposal. storage. or release
of any Hazardous Substances on o( to the Property. Borrower shall not do. nor allow anyone dse to do. anythtog affectlng
the Property that is in yiolation of any Environmental Law. The preceding two sentences shall not apply to the presence,
use, or storage on the Propeny of small quanmies of Hazardous Substances that are generally recogmzed to be appropriate
to normal residential uses and to maintenance of the Property.
Borrower shall promptly give lender written notice of any investigation. claim, demand, lawsuit or orher action by
any governmental or regulatory agency or private party inyolying the Property and any Hazardous Substance or
Environmental Law of which Borrower has actual knowledge. If Borrower learns. or is notified by any goyernmental or
regulatory authori[y, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary,
Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law.
As used in this paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazJrdous substances
by Environmental law and the following substances: gasoline, kerosene, other flammable or [Oxic petroleum products, toxic
pesticides and herbicides. volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As
used in this paragraph 20. ':Environmental Law" means federal laws and laws of the jurisdiction where the Propeny is located
that relate to health. safety or environmental protection.
NOO.UNIFORM COVENANTS. Borrower and Lender funher covenant and agree as follows:
21. Acceleration: Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's
breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under paragraph 17
unless applicable law pro,ides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b)
the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default
as specified may result in acceleration of the sums secured by this Security Instrument, forclosure by judicial proceeding
and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the
right to assert in the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration
and foreclosure. If the default is not cured as specified, Lender at its option may require immediate payment in full
of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument
by judicial proceeding. Lender sh;1I be entitled to collect all expenses incurred i~ pursuing the remedie~ provided in
this paragraph 21, induding, but not limited to, aUorne)'s' fees ,.lOd costs of title eyidenct to the e.''l:tent permitted by
applicable la w.
Form 3039 9190 !f'U.5~ 5 U/.; pag.:;,}
BK I 8 4 I PG I 9 2 6
I,
22. Release. Upon payment of all sums secuced by this SecurllY lnmument. thIS Security Instrument and the estlte
conveyed shall terminate and become void. After such occurrence. Lender shall discharge and satISfy this Security Instrument
without charge 10 Bormwer. Borrower shall pay any recordation costs.
23. Waivers. Borrower. to the e;(tent pennicted by applicable law. waives and releases any error or defects in pro-
ceedings to enforce this Security Instrument. and hereby waives the benefit of any present or future laws providing for stay
of e:'l:ecurion. extension of rime. exemption from 3nachmem. levy and sale. and homestead exemption.
24. Reinstatement Period. Borrower's'time 10 reinstate provided in paragraph 18 shall extend to one hour prior
to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument.
25. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire
title to the Property. this Security In,trument shall be a purchase money mortgage.
26. Interest Rate Aner Judgment. Borrower agrees that the interest rate payable after a judgment is entered on
the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note.
27. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together
with this Security Instrument. the covenants and agreements of each such rider shall be incorporated into and shall amend
and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument.
[Check applicable box(es)]
o
o
o
o Other(s) [specify]
Adjustable Rate Rider
Graduated Payment Rider
Balloon Rider
o
o
o
Planned Unit Development Rider
Condominium Rider
o 1-4 Family Rider
o
o
Biweekly Paymenc Rider
Second Home Rider .
Rate Improvement Rider
BY SIGNING BELOW. Borrower accepts and agrees to the terms and covenants contained in this Security Instrument
and in any rider(s) executed by Borrower and recorded with it.
Witnesses:
....... .. :.........................................................,(Seal)
NICHO AS BUGOSH -Borrower
~...........................................
......................................................................(Seal)
-Borrower
Social Security Number..................
[Spaee Selow T1111 Une Far ACknowledgmentl
COMMONWEALTH OF PENNSYLVANIA, CUMBERLAND
COUNTY ss:
On this, the 7TH day of OCTOBER
undersigned om~cr, personally appeared NICHOLAS BUGOSH
known to me (or salisf.lclor;!y proven) 10 be the person(s) whose name(s)
subscribcd 10 the within instrument and acknowledged that HE
purposes herein contained.
2003
, before me, a notary public the
IS
executed the same for the
In Witness Whereof, 1 hereunto set by hand and omcial seal.
My Commission expires:
{Ja4~ 1M. ~.
No/arial Seal
Oi~ne M. Smith, Notary Public
Mechanlcsburg Boro, ' ~
My Commission Expires June 22, 2004
Title of Omcer
Farm JOJ9 9190 (pag~ 6 of 6 paf~s)
BK I 8 4 I PG I 9 2 7
January 3, 2005
CERTIFIED MAIL NO. 70033110000024704246
RETURN RECEIPT REQUESTED
RE: Nickolas Bugosh
Mortgage Account # 208598 Loan # 01
Mortgage Premises: 142 Wyoming Avenue, Enola, PA 17025-2428
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The mortgage held by Members 1st Federal Credit Union, (hereinafter we, us or ours) on your
property located at 142 Wyoming Avenue, Enola, PA 17025-2428, is in serious default because
you have not made the Bi-Weekly payments of$34.77 for October 27, $278.51 for November
10, $278.51 for November 24, $278.51 December 8, and $278.51 for December 22, 2004. The
total amount now required to cure this default, or in other words get caught up in your payments, as
of the date of this letter is $1,148.81.
You mav cure this default within THIRTY (30) DAYS of the date ofthis letter, bv paving to us the
above amount of$l, 148.81 plus any additional Bi-Weeklypayments and late charges which mav fall
due during the period. Such payment must be made either by cash, cashier's check, certified check or
money order, and made at Members 1st Federal Credit Union, 5000 Louise Drive,
Mechanicsburg, P A 17055, Attention: Arlanda Dintaman.
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to
accelerate the mortgage payments. This means that whatever is owing on the original amount
borrowed will be considered due immediately and you may lose the chance to pay off the original
mortgage in Bi- Weekly installments. If full payment of the amount of default is not made within
THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose vour
mortgaged property. If the mortgage is foreclosed, your mortgaged propertv will be sold by the
sheriff to payoff the mortgage debt. Ifwe refer your case to our attorneys, but you cure the default
before they begin legal proceedings against you, you will still have to pay the reasonable attorney's
fees, even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which
may also include our reasonable costs. Ifvou cure the default within the thirty day period, vou will
not be required to pav attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage. If you have not cured the default within the thirtv dav period and foreclosure proceedings
have begun. YOU have the right to cure the default and prevent the sale at anv time up to one hour
before the Sheriffs foreclosure sale. You may do so bv paving the total amount of the unpaid Bi-
Weekly payments plus anv late or other charges then due, as well as the reasonable attorney's fees
and costs connected with the foreclosure sale (and perform anv other requirements under the
mortgage ). It is estimated that the earliest date that such a Sheriffs sale could be held would be
EXHIBIT D
approximately NINETY (90) DAYS from the date of this letter. A notice of the 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 payments will
be by calling us at the following number (717) 795-6031. This payment must be in cash, cashier's
check, certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your
right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be
started to evict you.
You have additional rights to help protect your interest in the property. YOU 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.
(YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO
THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS,
CHARGES AND ATTORNEY'S FEES AND COST ARE PAID PRIOR TO OR AT THE SALE,
AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED).
CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCE THIS RIGHT MIGHT
EXIST. YOU HAVE THE RIGHT TO HA VB THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF.
If vou cure the default, the mortgage will be restored to the same position as if no default had
occurred. However, you are not entitled to this right to cure your default more than three times in
any calendar year.
Sincerely,
?lb~.4 g;.t;.:..~
Arlanda Dintaman
Collections Officer
IMPORTANT NOTICE TO HOMEOWNERS
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983
PLEASE READ THIS NOTICE. YOU MAYBE EUGffiLE FOR
FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS
January 3, 2005
TO:
FROM:
RE:
Nickolas Bugosh
Members 1 st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, P A 17055
Account # 208598 Loan # 01
Your mortgage is in serious default because you have failed to pay promptly installments of
principal and interest, as required, for a period of at least sixty (60) days. The total amount of the
delinquency is $1,148.81. That sum includes the following: $34.77 due for October 27, $278.51
due for November 10, $278.51 due for November 24, $278.51 due for December 8, and $278.51
due for December 22, 2004.
You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you
comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983
(the "Act"). You may be eligible for emergency temporary assistance if your default has been
caused by circumstances beyond your control, and if you meet the eligibility requirements of the
Act as determined by the Pennsylvania Housing Finance Agency. Please read all of the Notice.
It contains an explanation of your rights.
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 a representative of this lender, or with a designated consumer credit
counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to
otherwise settle your delinquency. This meeting must occur in the next thirty (30) days.
If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency
identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty
(30) days after the date of this meeting.
The name, address, and telephone number of our representative is:
Arlanda Dintaman, Members 1st Federal Credit Union
5000 J.ouise Drive
Mechanicsburg, PA 17055
(717) 795-6031
The name and address of a designated consumer credit counseling agency is:
CCCS of West em PA
2000 Linglestown Road
Harrisburg, PA 17102
(888) 511-2227
EXHIBIT E
It is only necessary to schedule one face-to-face meeting. You should advise this lender
immediately of your intentions.
If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you
have the right to apply for financial assistance from the Homeowners' Emergency Mortgage
Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners'
Emergency Assistance Application with the consumer credit counseling agency listed above. An
application for assistance may only be obtained from a consumer credit counseling agency. The
consumer credit counseling agency will assist you in filling out your application and will submit
your completed application to the Pennsylvania Housing Finance Agency. Your application
must be filed or postmarked, within thirty (30) days of your face-to-face meeting.
"It is extremely important that you file your application promptly. If you do not 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 you will forfeit your eligibility for assistance".
Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act.
"It is extremely important that your application is accurate and complete in every respect".
The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it
received your application. During that additional 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 that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 211 North Front Street, P. O. Box
15530, Harrisburg, PA 17105-8029. Telephone No. (717) 780-3940 or 1-800-342-2397 (toll free
number).
Enclosed also is another notice from this lender under Act 6 of 1974. That notice is called a
"Notice of Intention to Foreclose Mortgage". You must read both notices, since they both
explain rights that you now have under Pennsylvania law. However, if you choose to exercise
your rights described in this notice, we cannot foreclose upon you during that time. Also, if you
receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot
be foreclosed upon while you are receiving that assistance.
Sincerely,
c:lJ~ :tr;i;-~
Arlanda Dintaman
Collections Officer
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VERIFlCATlON
I, Lynn Unger, Collections Officer for Mem"ers 1" Federal Credit Union, being
llIithorized to do 30 on behalf of Members 1 ,t Federal Credit Union. hereby verify that the
statements made in the foregoing pleading are truc and correct to the best of my
information knowledge and "elief I under~tand tn"! 1',,1<,-, <tllrements are made subject to
the penalties or 18 Pa. C.SA Section 4904, relating to unsworn falsification to
authorities.
Members I" Federal Credit Union
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2005-02458 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
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
BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
1493 ENGLISH DRIVE
MECHANICSBURG, PA 17055
ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO
SERVE DEFENDANT PRIOR TO EXPIRATION.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
Postage
18.00
16.28
5.00
10.00
.37
49.65
County
KARL LEDEBOHM
06/13/2005
Sworn and subscribed to before me
this
, ,Iv
1.\ --
.
day of l }J~
-lc>"O> A.D.
(l.~ tJ !h.JPh) A ~
ptS~honotary ~/-/
MEMBERS 1 ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
NO.: 05-02458 Civil Term
NICKOLAS BUGOSH alkla
NICHOLAS BUGOSH
DEFENDANT
CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
PRAECIPE
To the Prothonotary
Please reinstate the complaint filed in the above captioned matter.
Date: June 27, 2005
Respecl~ submitte
~ ......-
rl M edel>ohm, sq.
upreme Court ID #: 59012
P.O. Box 173
New Cumberland, P A 17070-0173
(717)938-6929
Attorney for Plaintiff
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RECEIVED JUN 272005 (Y""'
to
~
KENNETH BARRY QUEEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: NO. 2005-2509 CIVIL TERM
LINDSAY ELIZABETH BAKER, : CIVIL ACTION - LAW
Defendant
: IN CUSTODY
ORDER OF COURT
AND NOW, this z...' r day of 1.1- ,2005, upon
consideration of the attached Custody Conciliati n Report, it is ordered and directed as
follows:
1. The Father, Kenneth Barry Queen, and the Mother, Lindsay Elizabeth
Baker, shall have shared legal custody of Cooper Landen Baker, born September 17,
2004. Each parent shall have an equal right, to be exercised jointly with the other parent,
to make all major non-emergency decisions affecting the Child's general well-being
including, but not limited to, all decisions regarding his heaIth, education and religion.
2. Mother shall have primary physical custody ofthe Child.
3. Father shall have periods of phased-in supervised visitation as follows:
A. Phase J.
1. Beginning July 8, 2005, one evening per week provided he give
Mother one week advance notice of said day from 7:00 p.m. to 8:30
p.m.
2. Every Saturday from 9:00 a.m. to 10:30 a.m.
B. Phase II.
Once Father has had eight (8) visits in Phase [, the times shall be extended
to two hours each visit, that is, the week day visit shall be from 6:30 p.m.
to 8:30 p.m. and the Saturday visit shall be from 9:00 a.m. to 11 :00 a.m.
Father must continue to give Mother one week notice of the week day
visit.
4. Neither parent will do or say anything nor permit a third party to do or say
anything which may estrange the Child from the other party, or iJ1jure the opinion of the
Child as to the other parent or which may hamper the free and natural development of the
Child's love and respect for the other parent. This provision is to be strictly enforced by
the parents.
VIl\IV^lASNN3d
AlNnCO ("',;\('11381/11:10
Zl-J :6 Wit 6, Nnr SOOZ
Ab'if.lONOHlOl:id 3H1 :lO
30H-Jo-G31I:l
5. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions ofthis Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control. Another
Conciliation Conference is scheduled for September 1,2005 at 9:30 a.m.
BY THE COURT, (
/Ibk
J.
cc: Jessica Diamondstone, Esquire, Mid Penn Le I Services, Counsel for Father )u,...,w ~
Kristopher T. Smull, Esquire, Counsel for Mother - -, .-
t.,2'Jo_o~
0-,
RECEIVED JUN 272005 rt'
I);
KENNETH BARRY QUEEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 2005-2509 CIVIL TERM
LINDSAY ELIZABETH BAKER, : CIVIL ACTION - LAW
Defendant
: IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Cooper Landen Baker
September 17, 2004 Mother
2. A Conciliation Conference was held in this matter on June 27, 2005, with
the following individuals in attendance: The Father, Kenneth Barry Queen, with his
counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services and the Mother,
Lindsay Elizabeth Baker, with her counsel, Kristopher T. Smull, Esquire.
3. The parties agreed to the entry of an Order in the form as attached.
~ -? 7--o5~
Date
Qd . d. ~ tt. V~7'
~erney, Esquire
Custody Conciliator
MEMBERS 1 ST FEDERAL
CREDIT UNION
IN THE COlJRT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
PLAINTIFF
Vs.
NO.: 05-02458 Civil Term
NICKOLAS BUGOSH alkla
NICHOLAS BUGOSH
DEFENDANT
CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
PRAECIPE
To the Prothonotary:
Please reinstate the complaint filed in the above captioned matter.
Date: August 1,2005
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-02458 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within REINSTATED COMPLAINT & NO was served upon
BUGOSH NICKOLAS AKA NICHOLAS BUGOSH
the
DEFENDANT
, at 1100:00 HOURS, on the 19th day of July
, 2005
at 4806 VIRGINIA ROAD
MECHANICSBURG, PA 17055
by handing to
EDWINA COTSAPAS
ADULT IN CHARGE
a true and attested copy of REINSTATED COMPLAINT & NO together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
10.40
.00
10.00
.00
38.40
So Answers:
<~-., ~
R. Thomas Kline
07/20/2005
KARL LEDEBOHM
Sworn and Subscribed to before
By:
44f
tv
me this :U, - day of
Oq "00'/
IJ:~t~n~:j:J' ). ~'
A.D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2005-02458 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
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
BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
142 WYOMING AVENUE
ENOLA, PA 17025
DEFENDANT MOVED ABOUT A YEAR AGO FROM LISTED ADDRESS PER NEIGHBOR.
Sheriff's Costs:
Docketing
Service
Not Found Return
Surcharge
18.00
12.00
5.00
10.00
.00
45.00
~~,",~_/71
R. Thomas Kline
Sheriff of Cumberland County
KARL LEDBOHM
08/17/2005
Sworn and subscribed to before me
this
~Rt> day of )M~
0'>,5 A D~
ProthQ~arY
MEMBERS 1 ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF /PETITIONER
Vs.
NICKOLAS BUGOSH alk!a
NICHOLAS BUGOSH
NO.: 05-02458 Civil Term
DEFENDANT/RESPONDENT
: CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
PETITION FOR ALTERNATE SERVICE PURSUANT TO RULE OF CIVIL
PROCEDURE 431!
AND NOW, comes your Petitioner Members 1st Federal Credit Union ("Petitioner"),
by and through its attorney, Karl M. Ledebohm, Esq., and respectfully avers the
following in support of the Petition for Publication:
1. Petitioner is Members First Federal Credit Union, a National Federal Credit
Union having a principal address of 5000 Louise Drive, Mechanicsburg, P A 17055.
2. Defendant is Nickolas Bugosh NKI A Nicholas Bugosh whose last know
address is 4806 Virginia Road, Mechanicsburg, PA 17055.
3. On or about May 12,2005, Petitioner filed a complaint in mortgage foreclosure
to the above captioned matter with regards to the property at 142 Wyoming Avenue,
Enola, P A 17025 (the "Property").
4. R. Thomas Kline, Sheriff for Cumberland County, made a return of service
dated June 13,2005 which indicated that the Sheriff had obtained a forwarding address
from the US Postal Service for Defendant at 1493 English Drive, Mechanicsburg, PA
17055 and, despite numerous attempts having been made to serve the Defendant at the
above address, Defendant could not be found at that address. A copy of the Sheriff's
return and corresponding request for forwarding address for Defendant are attached
hereto as exhibit" A" and made part hereof
5. Petitioner re-instated the Complaint filed in this matter and the Sheriff made a
return of service of the Complaint upon the Defendant on or about July 19,2005 at 4806
Virginia Road, Mechanicsburg, P A 17055 pursuant to change of address received from
the US Postal Service for Defendant A copy of the Sheriffs return and corresponding
request for forwarding address for Defendant are attached hereto as exhibit "B" and made
part hereof
6. The Sheriff attempted to serve the Complaint upon the occupants of the Property
and made a return of service dated August 17, 2005 which indicated that the Defendant
had moved from the Property approximately one year prior. A copy of the Sheriffs
return is attaehed hereto as exhibit "C" and made part hereof
7. On or about August 11,2005, Petitioner, through its attorney Karl M.
Ledebohm, Esq, sent via regular mail, postage prepaid, the Important Notice required
under Rule of Civil Procedure 2371 (the "Important Notice") addressed to Defendant at
all three of the above addresses. A copy of the Important Notice and corresponding
certificates of mailing are attached hereto as exhibit "D" and made part hereof
8. All of the Important Notices were returned as either "not deliverable as
addressed" or "moved left no address unable to forward" A copy of the returned
envelopes is attached hereto as exhibit "E" and made pan hereof
9. Petitioner was informed by the US Postal Service that it is no longer possible
for a private party to request a forwarding address without a court order
10. As set forth in the affidavit of Gregory D. Fuller, Collections Manager for
Members 1st, the original of which is attached hereto as exhibit "F" and made part hereof,
Petitioner employed Roquemore & Roquemore, a "skip-tracing" firm, to locate the
Defendant and after considerable investigation Petitioner has been unable to locate
Defendant for service.
WHEREFORE, the Petitioner respectfully reqU(~sts this Honorable Court to enter
an Order permitting service by posting the Property and advertising one time in the
Cumberland Law Journal and in one newspaper of gen,eral circulation in Cumberland
County the Important Notice, under Pa. R.C.P. 237.1, Notice of Judgment, Writ of
Execution, Notice pursuant to Pa. R.C.P. 3129.2, and Notice of Sheriffs Sale and Legal
Description and all subsequent or additional documents pertaining to the foreclosure
action filed to the above captioned matter, execution on any judgment entered in
connection therewith and sale of the Property.
Date:
!a.,}-U)
Respectfully submitted,
~.:A
~M. Lede hm, sq.
~~eme Court ID #: 59012
P.O. Box 173
New Cumberland, P A 17070-0173
(717)938-6929
Attorney for Petitioner
.----...
brtbiUt t' b KIHUI<N -. NUT YUUNU
CASE NO: 2005-02458 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
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
BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
1493 ENGLISH DRIVE
MECHANICSBURG, PA 17055
ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO
SERVE DEFENDANT PRIOR TO EXPIRATION.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
Postage
18.00
16.28
5.00
10.00
.37
49.65
So answerS' /:/::::-~~"_~<'-'~;:7
""~ .._~:"---.......,..'- ~..
~. ;~:Tne
Sheriff of Cunberland County
KARL LEDEBOHM
06/13/2005
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
EXHIBIT "A"
\,\\.12 at Q[ Umbel'!)
~~~ ~It<l
R. THOMAS KLINE
Sheriff
RONNY R ANDERSON
Chief Deputy
EDWARD L. SCHORPP
Solicitor
JODY S. SMITH
Real Estate Deputy
OFFICE OF THE SHERIFF
One Courthouse Square
Carlisle, Pennsylvania 170-13
("\ e. (J, .
Agency Control No.
Date: ? ! ? 10\
To:
Postmaster
Address Information Request
Please furnish this agency with the new address, if available, for the following individual or verify whether the
address given below is one at which mail for this individual is currently b"ing delivered. If the following address is
a post office box, please furnish the street address as recorded on the boxholder's application form.
Name: B.IA~ tI ,r it' 6/0. (
Last Known Address: liP, P-"njl)Sh bf~
I certify the address information for this individual is required for the performance of this agenc 's 0 lici
(Title)
FOR POST OFFICE USE ONLY
(~IL IS DELIVERED TO ADDRESS GIVEN
() NOT KNOWN AT ADDRESS GIVEN
NEW ADDRESS
() MOVED, LEFT NO FOW ARDING ADDRESS
() NO SUCH ADDRESS
() OTHER (SPECIFY):
BOXHOLDERS' STREET ADDRESS
Agency Return Address
Postmark) Date Stamp
Address Information Request (Required Format)
Exbibit 352.44b
wn.I:d't.lrr . u l\...t:J;'Ul\.l.\J - I\...t:JIJUl.JJ-i.r\.
. CASE NO: 2005-02458 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within REINSTATED COMPLAINT & NO was served upon
BUGOSH NICKOLAS AKA NICHOLAS BUGOSH
the
DEFENDANT
at 1100:00 HOURS, on the 19th day of July
at 4806 VIRGINIA ROAD
2005
MECHANICSBURG, PA 17055
by handing to
EDWINA COTSAPAS
ADULT IN CHARGE
a true and attested copy of REINSTATED COVPLAINT & NO together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
10.40
.00
10.00
.00
38.40
So Answers:
<~-r ~
R. Thomas Kline
07/20/2005
KARL LEDEBOHIVl
Sworn and Subscribed to before
By:
~~I
( D pur rf
me this
day of
A.D.
Prothonotary
EXHIBIT "B"
JUl. n 100' n:ObAM
cumberland cO. ~herll1
~\~ ot (:,lll1l(]el'i
"'~~ ot-....q
No WI 1. 1.
,
R. THOMAS KUNE
Shorllf
RONNY R. ANDERSON
Chiof Depllly
JODY S. SMIT~
Real Estlllo Otpllly
EDWARD L. SCHDRPP
Sojicitor
OFFICE OF THE SHERIFF
One Courthouse SquarE'
Carlisle, Pennsylvania 170'13
. ,;)'/(.) ~ '" ~ '72>
To:
Postmaster
jA1t- c..~1/1 /'J lC.S ~4O-
Agency Control No.
Date: 71l~r
/
Address lDformalion Request
Please furnish this agency with tb< new address, jf available, for tb< Eonowing individual or verify whether tb<
address given below is one at whill.b mail for 1l1is individual is curreotly beina delivered. If the followina address i$
a post office box, please furnish the street address as recorded on the boxholder's application form.
Name: ;1h~ k;!,f 7Juf".r /I _
Last Known Addrtss: /"11 j e/V ,If -L.])r-/ )t?1~~
I cOTtify the addres. infonnation for this individualls required for the perf<
. ?
(8 of Age cw)
_~L
(TIde) :.:7
FOR POST OFFlCE USE ONlS
<.
() MAlI, IS DllLMllt.ED TO ADDRESS GIVEN
() NOT KNOWN AT ADDRESS GIVEN
() MOVED, LEFT NO FOW ARDING ADDRESS
() NO SUCH ADDRESS
() OTHER (SPECIFY):
/~..
I
NEW ADDRESS.."
-1-~'b'~h~, "','It ~ .
~ eJ,..yr.l(",-~t.."">'Z-j fl4-
n "".0
aOXHOLOF.RS' STREET ADDRESS
Agency ~tum Address
Address Information Request (Required FOl'lllllt)
ExI1ibit 352.44b
SHERIFF'S RETURN .. NOT FOUND
CASE NO: 2005-02458 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
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
BUGOSH NICKOh~S AKA NICHOLAS
BUGOSH
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
142 WYOMING AVENUE
ENOLA, PA 17025
DEFENDANT MOVED ABOUT A YEAR AGO FROM LISTED ADDRESS PER NEIGHBOR.
Sheriff's Costs:
Docketing
Service
Not Found Return
Surcharge
18.00
12.00
5.00
10.00
.00
45.00
~
R. Thomas Kline
Sheriff of Cumberland County
KARL LEDBOHM
08/17/2005
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
EXHIBIT nen
MEMBERS 1 ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAlNTlFF
Vs.
NICKOLAS BUGOSH alkla
NICHOLAS BUGOSH
NO. 05-02458 Civil Term
DEFENDANT
. CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
IMPORTANT NOTICE
TO Nickolas Bugosh alkla
Nicholas Bugosh
1493 English Drive
Mechanicsburg, P A 17055
Nickolas Bugosh alkla
Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, P A 17055
Nickolas Bugosh alkla
Nicholas Bugosh
142 Wyoming Avenue
Enola, PAl 7025
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I
AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY
SUBSEQUENT CORRESPONDENCE OR COMMUNICA TION IS AN
ATTEMPT TO COLLECT A DEBT AND ANY INI10RMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO TAKE
ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN
(I 0) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE
ENTERED AGAlNST YOU WITHOUT A HEARING, AND YOU MAY LOSE
PROPERTY OR OTHER IMPORTANT RIGHTS. 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP
EXHIBIT '''D"
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3 166 or (800)990-9108
August II, 2005
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PO. Box 173 \;,,"" ",/
New Cumberland, P A 17070%173"
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MEMBERS 1ST FEDERAL
CREDITVNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
PLAlNTIFF/PETITI01\'ER
Vs.
NICKOLASBUGOSH~a
NICHOLAS BUGOSH
NO.: 05-024.58 Civil Term
DEFENDANT/RESPONDENT
: CIVlL ACTION.LA W
: MORTGAGE FORECLOSURE
AFFIDAVIT
I, Gregory D, Fuller, Collections Manager fur Members First Federal Credit Union
("Petitioner"), do hereby report the following information in support of my Petition for
Publication:
I. The only addresses which Petitioner possesses with regards to the Defendant are
thOse as set forth in the Petition For Alternate Service Pur~nt to Rule of Civil
Procedute430 ("Petition for AIternRte Service") immediatc;ly proceeding. this
AffiQavit. The Petition for Alternate SelVice is in(;orporated herein by reference as
if set forth herein in full.
2. On Or about September 28, 2005, Petitioner, through its attorney, Karl M.
Ledebohm, Esq., contacted directory assistance fur both, Enola, Pennsylvania and
Mechanicsburg. Pennsylvania and was informed that no listings exist for
Defendant.
3. Petitioner referred this matter to Roquemore & Roquemore, Inc., a skip tracing
firm to locate the whereabouts of Defendant.
4, On or about September 27, 2005, Petitioner received a Status Report from
Roquen>orc & Roquemore, Inc., it copy of which :is attached hereto as exhibit "1"
and mllde part hereof, which details the efforts made to locate the Defendant,
without success.
5. On or about September 28, 2005, Petitioner, through its attorney, Karl M
Ledebohm, contacted the cen phone number set :fbrth in the attached report from
Roquemore & Roquemore, Inc., and received a computerized message which
indicated that the voice mail for this number has !lot yet been established.
6. On Or about September 28, 200S, Petitioner, through its attorney, Karl M
Ledebohm, contacted G. Patrick O'Connor, Esq., Defendant's legal council in a
prior bankruptCY proceeding and confirmed that G. Patrick O'Connor does not
represent Defendant with regards to the instant forecloSW'e action, that he has had
nopontactwith his c1ientsince ApriH; 2005 and that he 1ioesnothave any
additional contact informatiOll for Defendant not ,itlready in the possession of
Petitioner.
EXHIBIT "F"
7. A. of th~ dat~ hereof, Petitioner has not received any infonnlltion concerning the
whereabOuts of Defendant from Roquemore & Roquemore, Inc., or any other
source.
8. As set forth in the return of service by the Cumberland County Sheriffs Office
dated August 17, 2005, a copy of'which is attached to the Petition for Alternate
Service 8Jl exhibit "C" and made part thereof and hereof by reference, the Sheriff
made inquired with the neighbors of the mortgaged property and was informed
that Defendant moved approximately one year ago from the mortgaged property.
9. For the reasons set forth herein and in the Petition for Alternate Service, Petitioner
has reason to believe that Defendant has left the area.
Respectfully submitted,
Date:
~v~
/.gOry D. Fuller
Collections Manager for Members
First Federal Credit Union
Sworn and subscribed to before me,
a Notary Public, this 3 0 day of September, 2005.
J:ldOOA'f'7 ~~
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My commission expires:
COM!"ONWEALTH OF PENNSYLVANIA
. NclaIfaI Seal
Iaod8an M. WOItei. NoIary Public
Lowec Allen T..".. CunbeI1end County
My CorM1IooIOO Exp!1llS Apr. 19. 2009
Member. Pennsyfvanla ASSOCIation of Notaries
SEP-27-05 06:04 PM MEMBER$lST Feu INS. DEPT 7177955178 ~~03
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llTI"8QlWO.1OTHIiR ClLADYlIUQOIH AND It'll!! .TATIO TMATTHI DTR con NOT ITAYTHIiFUiAND
TliAT ALL 1MB CAN 1)0 II Tl'Y TO tll!T A MI!88ACM! TO HIM THROUGH PAMlL V MlllleeR" LI" MV'"
=:;JI~Jr'~:'::Ee~~H=ci~OI.A8~=.t~J=:.t~HED
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18l12151182. THEV I'l'ATID THAT THIV DO NOT KNOW WHIR! THe Dl!8TOR IS. lIVE HAVE CHIICIC!D
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EXHIBIT "1"
__ G~:05 PM MEMBERS1ST Feu INS. DEPT 7177955178 P.04
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Status Report
1M," 1488 !NQLI8H PIll APORESS IN Mt!CHANICUU"G "~~LL AI THI! 11U11!1fllAN DR ADD""
IN FREPRlCI<8BUM. OUft Iil'FCRTI WILL CONT1NUI TO :rI THE OTR
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RoQyEMORE.INC.
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VKR1FICA T10N
I, Gregory D. Fuller, Collections Manager for Members I" Federal Credit Union,
being authorized to do so on behalf of Members ]" Federsl Credit Union, hereby verify
that the statements made in the foregoing pleading are 1Il.le and correct to the best of my
information knowledge and belief I understand that false statements are made subject to
the penahies of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to
authorities.
Members ]" Federal Credit Union
By; A'1P~
~ory D. Fuller, CoUections
Manager
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MEMBERS 1sT FEDERAL
CREDIT UNION
. CTlf,' ~ WI> .
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BY__ ~___
IN THE COURT OF COMMC)NPLE S---
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF/PETITIONER
Vs.
NICKOLAS BUGOSH aIkIa
NICHOLAS BUGOSH
NO.: 05-02458 Civil Term
DEFENDANTIRESPONDENT
: CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
ORDER
AND NOW, this 21' day of October, 2005, it is hereby ORDERED that
Petitioner shall make service by posting the mortgaged property known and numbered as
142 Wyoming Avenue, Enola, P A 17025 and advertising one time in the Cumberland
Law Journal and in one newspaper of general circulation in Cumberland County the
Important Notice under Pa. R.C.P. 237.1, Notice of Judgment, Writ of Execution, Notice
pursuant to Pa. R.C.P. 3129.2, and Notice of Sheriffs Sale and Legal Description and all
subsequent or additional documents pertaining to or in connection with the foreclosure
action filed to the above captioned matter, execution on any judgment entered in
connection therewith and the Sherif[ sale of the above mortgaged property.
Ad
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-
MEMBERS 1sT FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF/PETITIONER
Vs.
NICKOLAS BUGOSH aJk/a
NICHOLAS BUGOSH
NO.: 05-02458 Civil Term
DEFENDANTIRESPONDENT
: CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
PETITION FOR ALTERNATE SERVICE PURSUANT TO RULE OF CIVIL
PROCEDURE 430
AND NOW, comes your Petitioner Members 1st Federal Credit Union ("Petitioner"),
by and through its attorney, Karl M. Ledebohm, Esq., and respectfully avers the
following in support of the Petition for Publication:
1. Petitioner is Members First Federal Credit Union, a National Federal Credit
Union having a principal address of 5000 Louise Drive, Mechanicsburg, P A 17055.
2. Defendant is Nickolas Bugosh A/KiA Nicholas Bugosh whose last know
address is 4806 Virginia Road, Mechanicsburg, PA 17055.
3. On or about May 12,2005, Petitioner filed a complaint in mortgage foreclosure
to the above captioned matter with regards to the property at 142 Wyoming Avenue,
Enola, P A 17025 (the "Property").
4. R. Thomas Kline, Sheriff for Cumberland County, made a return of service
dated June 13,2005 which indicated that the Sheriff had obtained a forwarding address
from the US Postal Service for Defendant at 1493 English Drive, Mechanicsburg, PA
17055 and, despite numerous attempts having been made to serve the Defendant at the
above address, Defendant could not be found at that address. A copy of the Sheriffs
return and corresponding request for forwarding address for Defendant are attached
hereto as exhibit" A" and made part hereof
5. Petitioner re-instated the Complaint filed in this matter and the Sheriff made a
return of service of the Complaint upon the Defendant on or about July 19, 2005 at 4806
Virginia Road, Mechanicsburg, P A 17055 pursuant to change of address received from
the US Postal Service for Defendant. A copy of the Sheriff s return and corresponding
request for forwarding address for Defendant are attached hereto as exhibit "B" and made
part hereof
6. The Sheriff attempted to serve the Complaint upon the occupants of the Property
and made a return of service dated August 17, 2005 which indicated that the Defendant
had moved from the Property approximately one year prior. A copy of the Sheriffs
return is attached hereto as exhibit "C" and made part hereof
7. On or about August 11, 2005, Petitioner, through its attorney Karl M
Ledebohm, Esq, sent via regular mail, postage prepaid, the Important Notice required
under Rule of Civil Procedure 2371 (the "Important Notice") addressed to Defendant at
all three of the above addresses. A copy of the Important Notice and corresponding
certificates of mailing are attached hereto as exhibit "D" and made part hereof
8. All of the Important Notices were returned as either "not deliverable as
addressed" or "moved left no address unable to forward." A copy of the returned
envelopes is attached hereto as exhibit "E" and made part hereof
9. Petitioner was informed by the US Postal Service that it is no longer possible
for a private party to request a forwarding address without a court order.
10. As set forth in the affidavit of Gregory D. Fuller, Collections Manager for
Members] s" the original of which is attached hereto as exhibit "F" and made part hereof,
Petitioner employed Roquemore & Roquemore, a "skip-tracing" firm, to locate the
Defendant and after considerable investigation Petitioner has been unable to locate
Defendant for service.
WHEREFORE, the Petitioner respectfully requests this Honorable Court to enter
an Order permitting service by posting the Property and advertising one time in the
Cumberland Law Journal and in one newspaper of general circulation in Cumberland
County the Important Notice, under Pa. R.C.P. 237.1, Notice of Judgment, Writ of
Execution, Notice pursuant to Pa. R.C.P. 3129.2, and Notice of Sheriffs Sale and Legal
Description and all subsequent or additional documents pertaining to the foreclosure
action filed to the above captioned matter, execution on any judgment entered in
connection therewith and sale of the Property.
Date: 10.. 1 }- u>
;:,rth.K.L.t'r '~ .K..t';TUXL\! - NUT .t'UU1\JL
CASE NO: 2005-02458 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
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
BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
but was
unable to locate Him In his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
1493 ENGLISH DRIVE
MECHANICSBURG, PA 17055
ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO
SERVE DEFENDANT PRIOR TO EXPIRATION.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
Postage
18.00
16.28
5.00
10.00
.37
49.65
So answers'...... :./....~7
~/":;.----- ,- ..../'~=--:;;::::~~:.::~'-- ----.--..'.--.
:...,.,;'~~... ./':::---
/...-- .,-
R. Thorn une .-"
Sheriff of Cumberland County
KARL LEDEBOHM
06/13/2005
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
EXHIBIT "A"
\1' ot Q[.Ulltbe
~~ 1"4
~~ /tq
R. THOMAS KLINE
Sheriff
RONNY R. ANDERSON
Chief Deputy
EDWARD L. SCHORPP
Solicitor
OFFICE OF THE SHERIFF
JODY S. SMITH
Real Estate Deputy
One Courthouse Square
Carlisle, Pennsylvania 17013
To:
Postmaster
("'\ e. r),,, .
Agency Control No.
Date: ? /9(Q\
Address Information Request
Please furnish this agency with the new address, if available, for the following individual or verify whether the
address given below is one at which mail for this individual is currently being delivered. If the following address is
a post office box, please furnish the street address as recorded on the boxholder's application form.
Name: (3,IA505/''' r/"kolc"
Last Known Address: I 'IF, ~n j (d" 'h l..
I certify the address information for this individual is required for the performance of this agenc
(Title)
FOR POST OFFICE USE ONLY
(L)~IL IS DELIVERED TO ADDRESS GIVEN
NEW ADDRESS
() NOT KNOWN AT ADDRESS GIVEN
() MOVED, LEFT NO FOW ARDING ADDRESS
() NO SUCH ADDRESS
() OTHER (SPECIFY):
BOXHOLDERS' STREET ADDRESS
Agency Return Address
Postmark I Date Stamp
Address Information Request (Required Format)
Exhibit 352.44b
wn~^Lrr w ~~~U~~ - ~DUU~n^
CASE NO: 2005-02458 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within REINSTATED COMPLAINT & NO was served upon
BUGOSH NICKOLAS AKA NICHOLAS BUGOSH
the
DEFENDANT
at 1100:00 HOURS, on the 19th day of July
, 2005
at 4806 VIRGINIA ROAD
MECHANICSBURG, PA 17055
by handing to
EDWINA COTSAPAS
ADULT IN CHARGE
a true and attested copy of REINSTATED COMPLAINT & NO together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
10.40
.00
10.00
.00
38.40
So Answers:
<C~/?-'f ~
R. Thomas Kline
07/20/2005
KARL LEDEBOHM
Sworn and Subscribed to before
By:
'~I
(~, . iit
me this
day of
A.D.
Prothonotary
EXHIBIT "B"
JUl. n L'JI)~ b:UbAM
Cumberland Co. therl!!
\\\1? of 4CUtnbei'l
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if.1 ""-:.\10'~~' '.'. ,t.,
:0 $r;ti~'" ':>to. ,1
f.:..,.~,gt~",.~. ~.. fd-A'-i(;.
..~_~ 0'..:"- .~ .. '. _"" ." '" ;,r"
No.4111 ~. 1
,
R. THOMAS KlINE
Shariff
EDWARD L. SCHORPP
Solicitor
OFFICE OF THE SHERIFF
One Courthouse Square
Carlisle. Pennsylvania 17013
. ,;)'/0 ,,, ~ '72>
RONNY R. ANOERSON
Chiaf Deputy
JODY S. SMITH
Reo! Esta'" Oaputy
To:
Postmaster
/Mt C.~1 A /'JlC-S ~ko-
Agcncy Contl:ol No.
Dale; 7~3.kr
/
Addr~8 Information Request
Name:
1....t Known Address: /y f .:5
FOR POST OffiCE USE ONLY
<.
() MAIT, IS DELIVERED TO ADDRESS GIVIlN
()NOTKNOWNATADDR~SGtVEN
() MOVED, LEFT NO FOW ARDlNG ADDRESS
() NO SUCH ADDRESS
() OTIffiR (SPECIFY):
// NEW ADDRESS.-
-i~bVl~'Ni.,. '14>.
~",J,~\"/..~[.,""~J fl'l-
II~" t)
BOXHOLDERS' STREET ADDRESS
Agency R7:mrn Address
Address Information R.equ..t (Required Format)
Exhibit 352.44b
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2005-02458 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
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
BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BUGOSH NICKOLAS AKA NICHOLAS
BUGOSH
142 WYOMING AVENUE
ENOLA, PA 17025
DEFENDANT MOVED ABOUT A YEAR AGO FROM LISTED ADDRESS PER NEIGHBOR.
Sheriff's Costs:
Docketing
Service
Not Found Return
Surcharge
18.00
12.00
5.00
10.00
.00
45.00
4~~
R. Thomas Kline
Sheriff of Cumberland County
KARL LEDBOHM
08/17/2005
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
EXHIBIT "C"
MEMBERS 1ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLA.JNTIFF
Vs
NICKOLAS BUGOSH alk/a
NICHOLAS BUGOSH
NO 05-02458 Civil Term
DEFENDANT
. CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
IMPORTANT NOTICE
TO Nickolas Bugosh alk/a
Nicholas Bugosh
1493 English Drive
Mechanicsburg, P A 17055
Nickolas Bugosh alk/a
Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, PA 17055
Nickolas Bugosh alk/a
Nicholas Bugosh
142 Wyoming Avenue
Enola, PAl 7025
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I
AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY
SUBSEQUENT CORRESPONDENCE OR COMMUNICA TION IS AN
ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO TAKE
ACTION REQUIRED OF YOU IN THIS CASE UNLESS YOU ACT WITHIN TEN
(10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE
ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE
PROPERTY OR OTHER IMPORT ANT RIGHTS. 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP
EXHIBIT nDn
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166 or (800)990-9108
August 11.2005
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MEMBERS lIT FEDERAL
CREDIT I.JNION
IN THE COURT OF COMMON PLEAS
CUMl3ERLAND COUNTY,
PENNSYLVANJA
PLAlNTIFfIPETITIO},'ER
VB.
NICKOLAS BUGOSH aJkJa
NICHOLAS BUGOSH
DEFENDANT/RESPONDENT
NO 05-02458 Civil Term
. CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
AFFIDAVIT
I, Gregory D. Fuller, Collections Manager for Members First Federal Credit Union
("Petitioner"), do hereby report the following information in support of my Petition for
Publication
1. The only addresses which Petitioner possesses with regards to the Defendant are
those as set forth in the Petition For Alternate Service Pursuant to Rule of Civil
Procedure 430 ("Petition for Alternate Service") immediately proceeding this
Affidavit. The Petition for Alternate Service is incorporated herein by reference as
if set forth herem in full.
2. On or about September 28, 2005, Petitioner, through its attorney, Karl M.
Ledebohm, Esq., contacted directory assistance for both, Eoola, Pennsylvania and
Mechanicsburg. Pennsylvania and was informed that no listings exist for
Defendant.
3. Petitioner referred this matter to Roquemore & Roquemore, Inc., a skip tracing
firm to locate the whereabouts of Defendant.
4. On or about September 27,2005, Petitioner received a Status Report from
Roquemore & Roquemore, Inc, a copy ofwhlch is attached hereto as exhibit K 1"
and made part hereof, which details the efforts made to locate the Defendant,
without success.
5. On or about September 28, 2005, Petitioner. through its attorney, Karl M
Ledebohm, contacted the cell phone number set fonh in the attached report from
Roquemore & Roquemore, Inc, and received a computerized message which
iudicated that the voice mail for Ibis number has not yet been established
6. On Or about September 28, 200S, Petitioner, through its attorney, Karl M.
Ledebohm, contacted G. Patrick O'Connor, Esq., Defendant's legal council in a
prior bankruptcy proceeding and confirmed that G Patrick O'ConnOI does not
represent Defendant with regards to the instant foreclosure action, that he has had
no contact with his client since Aprill, 2005 and that he does not have any
additional contact information for Defendant not already in the possession of
Petitioner.
EXHIBIT "F"
-.
7. As ofthe date hereot: Petitioner has not received any information concerning the
whereabouts ofDefendll1lt from R()quemore & Roquemore, Inc., ()r any other
source.
8. As set forth in the return of service by the Cumberland County Sheriff s Office
dated August 17, 2005, a copy of which is attached to the Petition for Alternate
Service as exhibit "e" and made part thereof and hereof by reference, the Sheriff
made inquired with the neighbors of the mortgaged property and was informed
that Defendant moved approximately one year ago from the mortgaged property
9. For the reasons set f()rth herein and in the Petition for Alternate Service, Petitioner
has reason to believe that Derendant has left the area.
Respectfully submitted,
Date:
IcD~~
Collections Manager for Members
First Federal Credit Union
Sworn and subscribed to before me,
a Notary Public. this 3 0 day of September, 2005.
{)OctOMY1 L'-d~
\...{Notary)
My commission expires'
COM,MONWEAL TH OF PENNSYLVANIA
'. Nola1faI Seal
Iscd&an M. Worley. Notary Public
Lower ~ T"'ll., Ct.mbertand County
My ConmioeIon Expires Apr. 19, 2009
Member, Pennsylvania ASSOCiation of Notaries
SEP-27-0S 06:04 PM MEMBERS1ST Feu INS~ DEPT ?1779551f8
P..03
r
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Status Report
w" hlYf /llIlIIvecI your lIIiQIlmlnl an tIl8 .bovt QlptIllnlld Il.tlJeol,nd heva opellld I .klP ~ Md collltlrll
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8/10/06 R.CIltVED A CAL~ FROM THli 1)TA'81lK (AEIlEOOA) AND IHE STATEO THAT 8l1! HMN"r HEARD
fflOM THIOTA IN AIIOUT 'TWO MON'T1'18IlUT THIS 18 HIS CaLM 717'1e1l233, SHE,taO STATIO TttAT
THI DTR MAV lIIIlTAYING WITH 1118 FRlSND BRVAN (NO LAST NAMI!). 8AJ1) 8HE WlU. OAU. HER
MOTHl!R AND EI! II" SHE REMEMBERS _VANS LA8T NAMe AND ll.AI.l M! ISAOt<. 9121/Oll CAW-EO 'n'I1!
tlTR'80RANDMOTHIiR QL.ADVlIIIIJQ08H AND SJoIli! ITAT!D THAT THE DTR 0018 NOT STAYTHEREANO
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~ CALlIDTH! DTA'8ax ("e..cOAl LM'I'CB. &/27/05 THROUCiM .EVER~ .IARCH" ANI) ~TA
8 WI HAW NOT 11_ A8U! Tel LOOA'nii THE DEBTO" NICHOLAS ElUOOSH. WE HAW SEARCHED
SlVlML ADM!.' auT HAW leeN U1WUl TO LOCATE THl! ceJT'O". WE HAve CHIC1C!I) THe;
Dt!ITOfU Rll.ATIVE. ADDRE!88 AT 11421 N MAI"LII VA~\.IY IN ROUCOMMON MICHIGAN PHON!"
88m_n, THEV STATED THAT THEV 00 MOT KNOW WHEIU! THI! OmOl'lls. WE HAVE CHI!CI<!D
".lnf!1rml111l1l1,1lNIded wtl/l "" '""rim IlJlIlI III1Q!\ II d1lI<I\td P'O\ItiotlrY I/1If 1lOMI\lIII1\Ill I\IlnIonQG "". III lorlM ~ aIIrI tlId \lII
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..
EXHIBIT "1"
I
e
SEP-27-05 06:05 PM MEMBERS1ST Feu INS. DEPT 7177955178 P.04
. 'ie, . SEP.2'i'.2IlI!l 1154f'M, ROIi'I..EI1CRE So ROQU:l1ORt IHC tlO.?'4l!l P.:a,S
c ~Jl'T
In
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m RoQyEMORE,INC.
'I
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Status Report
THi: '483 e!NGLI8H DFlAPORE88 IN MECHANICSBURG PA, AS WELL AS THE 11821 BRIAN Of' AODR.sa
IN FREDRICI<811UM. OUFt EFFORT' WII.L CONTINUE TO LOCATE THE DTR
i
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flIIIlII'l ....... a_lV. ",10 l"",mll'tIo/I.",. nil" d_..d to 1IlIn:I ,.rtJoo _., \hO ~1'NI _nl d Iloq....D!it llRt.._ro, MC,
..
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00<;, .1a.2a6.t166 " ""', t7wu.t720
..
.
.
.
VElUFlCA TION
I, Gregory D. Fuller, Collections Manager for Members I" Federal Credit Union,
being authorized to do so on behalf of Members J" Federal Credit Union, hereby verify
that the stateluents made in the foregoing pleading are true and correct to the best of my
information knowledge and belief I understand that false statements are made subject to
the penalties ofl8 Pa. C.S.A. Section 4904, relating to unsworn falsification to
authorities
Members lot Federal Credit Union
By: hJ OPe,
~gory D. Fuller, Collections
Manager
~,
~ )
I
-,
-
-~--
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-02458 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
ROBERT BITNER
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within NOTICE
was served upon
BUGOSH NICKOLAS AKA NICHOLAS BUGOSH
the
DEFENDANT
, at 1010:00 HOURS, on the 9th day of November, 2005
at 142 WYOMING AVENUE
ENOLA, PA 17025
by handing to
POSTED PROPERTY AT 142 WYOMING AVENUE ENOLA
a true and attested copy of NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Posting
Surcharge
Postage
So Answers:
18.00
14.40
6.00
10.00
.37
48.77
:.><',:~;:~'
".??':::L::~Y,t'....('-:'
R. Thomas Kline
11/14/2005
KARL LEDEBOHM
Sworn and Subscribed to before
me this J~/h day of
~Vlm~ AD
P~ . 0 ary
~3~
Deputy Sheriff
MEMBERS I ST FEDERAL
CREDIT UNION.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
NICKOLAS BUGOSH alkla
NICHOLAS BUGOSH
NO.. 05-02458 Civil Term
DEFENDANT
. CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY
Please enter judgment in the above captioned proceeding in favor of
Members I" Federal Credit Union, Plaintiff, and against the Defendant, Nickolas Bugosh
alkla Nicholas Bugosh, in the amount of SEVENTY-THREE THOUSAND SIXTY-
THREE AND 62/1 00 ($73,06362) plus interest at the rate of$II.6447 per day, through
the date of payment, including on and after the date of entry of the judgment on the
complaint, additional attorney's fees and costs of suit and for foreclosure and sale ofthe
mortgaged propeny, Judgment is entered pursuant to Pa. R.CP 3031 for failure to file
an Answer on behalf of Defendant, Nickolas Bugosh alkla Nicholas Bugosh, to Plaintiff's
Complaint within twenty (20) days of service thereof and after a 10-day Notice was
published and posted upon the mortgaged property pursuant to the Order of Court dated
October 27, 2005 entered in the above captioned matter
RespeC!~-
Date 12..-- 2--0) U
Kar . Ledebohm, Esquire
Su reme Court JD #59012
PO Box 173
New Cumberland, P A 17070-0173
(717)938-6929
Attorney for Plaintiff
.
I hereby certify that notices of intent to take default judgment were served upon
the Defendant, Nickolas Bugosh alkla Nicholas Bugosh, pursuant to the Order of Court
dated October 27, 2005 entered in the above captioned matter as follows
I. Publication in the Cumberland Law Journal, a copy of the proof of publication
is attached hereto as Exhibit" A"
2. Publication in the Patriot News, a copy ofthe proof of publication is attached
hereto as Exhibit "B".
3. The Sheriff of Cumberland County personally posted the notice on the
mortgaged property, a copy of the Sheriff s Return is attached hereto as
Exhibit "c",
Date f-u 11-1 (J';-
~." . I:b?!.~";"i:-
Supreme Court ID #59012
PO Box 173
New Cumberland, P A- 17070-0 \73
(7\7)938-6929
Attorney for Plaintiff
/.
,/
/
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYL VANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
November 11, 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~ ~ -----
/ Li~ Marie Coyne, Editor
'----_./
SWORN TO AND SUBSCRIBED before me this
11 day of November. 2005
~---'~) L. ~J7"'1dh\j
r'" ," ""~~'~'''~~r!;,~~~'''.;!:,:,,~-::' -- -" ".. ""'~"'~'''1
,~ t. 1'<./:." I, ,I ~
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I
,I
EXHIBIT "A"
CUMBERLAND LAW JOURNAL
NOTICE
In the Court of Common Pleas
Cumberland County. Pennsylvania
Civil Action-Law
No.: 05-02458 Civil Term
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
VS.
NICKOLAS BUGOSH. a/k/a
NICHOLAS BUGOSH
DEFENDANT
MORTGAGE FORECLOSURE
IMPORTANT NOTICE
TO: Nickolas Bugosh, a/k/a Nicho-
las Bugosh
Mortgaged property: 142 Wyoming
Avenue. Enola, PA 17025
PURSUANT TO TIlE FAIR DEBT
COLLECTION PRACTICES ACT. lAM
REQUIRED TO INFORM YOU THAT
THIS NOTICE AND ANY SUBSE-
QUENT CORRESPONDENCE OR
COMMUNICATION IS AN ATfEMPr
TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
YOU ARE IN DEFAULT BECAUSE
YOU HAVE FAILED TO TAKE AC-
TION REQUIRED OF YOU IN TIllS
CASE. UNLESS YOU ACT WITHIN
TEN (I0) DAYS FROM THE DATE
OF THIS NOTICE, A ,JUDGMENT
MAY BE ENTERED AGAINST YOU
WITIlOUT A HEARING. AND YOU
MAY WSE PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOUlD
TAKE TIllS PAPER TO YOUR LAW-
YER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AF.
FORD ONE, GO ro OR TELEPHONE
THE OFFICE SET FORTH BELOW
2
TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
Cumberland County
Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166 or
(800) 990-9108
KARL M. LEDEBOHM.
ESQUIRE
Supreme Court ID #59012
Attomey for Plaintiff
P.O. Box 173
New Cumberland, PA
17070-0 I 73
(717) 938-6929
Nov. 11
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Conunonwealth of Pennsylvania, County of Dauphin} 55
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 Conunonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street. in the City of Harrisburg, County ofD.uphin, 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 andlor Sunday/ Metro edItions which appeared in the 8th day(s) of Novemher 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 afthe 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 unammously 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 'sc laneous Book "M".
Volume 14, Page 317.
PUBLICATION
COPY
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY~
PENNSYLVANIA
No.: 0$-02451 Civil Term
MaMllRS 1ST Fl!blRAL
CRIED IT UNION
Pl.AINT/FP
V..
~:~~gt~~ :~:g~~ Q/~Q
DEFENDANT
IMPOFtTANT NOTICE
TO: Nickolas Suga:,h a/k:/a
NIcholas BtJgos/'t
Mortgaged property 142 Wyoming
Avenue, Enola,PA 17025
PURSUANT TO THE FAIR DEBT COL-
LEemON PRACTICES ACT, j AM RE.
QUIRED TO INI=ORM YOU THAT THIS
NOTICE AND ANY SUBSEQUENT COR.
RESPONDENCE OR COMMUNICATION IS
AN ATTEMPT TO COLLECT A DeBT AND
ANY INFORMATION OBTAINED WILL
&e USEe FOR THAT PURPOSE.
yOU ARE INDEf:'AUlT BECAUSE YOU
HAVE FAILEO TO TAKE ACTION RE.
QUI-RI:O OF YOU IN THIS CASE UNLESS
VOU ACT WITHIN TEN no) DAYS FROM
THE bATE 01= THIS NOTICE, A JUOG.
ME NT MAY BE ENTEREOAGAINSTYoU
WITHOUT A I1EARING AND YOU MAY
LOSE PROPERTY OROTHER'fMPOR't
ANT RIGHTS YOU SHOUI..DTAK-ETHIS
PAPER TO YOUR L,AWY.ER ATONcl:. IF
YOU 00 Not HAVE A LAWYER OR CAN-
NOT A,c-FQRO-ONc..QO TO OR TEL.E.
!'HONe THE OFFICE; SET FORTH BE-
L.OW TOF=IND OUT WHERE, YOU CAN
GET LEGAL HELP,'
Cumberland COlJnty Bor Association
2 Llb&rty Avenue
Carlisle, PA 11013
(117)249-3166or(8Q0}990-9108
Karl M. Ledobohm. Esq.
Supreme. Court rD #"Olt
fi'.Q.,ox 113
---- ~ ~~btt'land.,~W'i;~~~~~:".""
KARL M. LEDEBOHM
ATTORNEY AT LAW
P,O. BOX 173
NEW CUMBERLAND, PA. 17070.0173
Statement of Advertising Costs
To THE PATRlOT.NEWS CO.
For publishing the notice or publication attached
hereto on the above stated dates
210.82
EXHIBIT "B"
SHERIFF'S RETURN - REGULAR
.
CASE NO: 2005-02458 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MEMBERS 1ST FEDERAL CREDIT UNI
VS
BUGOSH NICKOLAS AKA NICHOLAS
ROBERT BITNER
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within NOTICE
was served upon
BUGOSH NICKOLAS AKA NICHOLAS BUGOSH
the
DEFENDANT
, at 1010:00 HOURS, on the 9th day of November, 2005
at 142 WYOMING AVENUE
ENOLA, PA 17025
by handing to
POSTED PROPERTY AT 142 WYOMING AVENUE ENOLA
a true and attested copy of NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Posting
Surcharge
Postage
18.00
14 .40
6.00
10.00
.37
48.77
So Answers:
--C-""'-r./f'/:~. //~
"7/ .....;;.~;...;~':;:.-;-ftw.~!;! ",;/~-F
R. Thomas Kline
11/14/2005
KARL LEDEBOHM
me this
day of
B~bM+ d~
Deputy Sher~ff
Sworn and Subscribed to before
A.D.
Prothonotary
EXHIBIT "C"
~ (-.'
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~
~
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~
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"- "-
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~- "-<
C~
"
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.c.P. SECTION 101 TO SECTION 149 ETC.
MEMBERS I ST FEDERAL
CREDIT UNION
Plaintiff
. IN THE COURT OF COMMON PLEAS
. CUMBERLAND COUNTY, PENNSYLVANIA
vs.
05-02458 Civil Term (Mortgage Foreclosure)
Amount Due $73,063.62
Interest from 5/6/05 at the rate of
. $11. 6447 per day to be added
. Atty's Fees. To be added
COSTS TO BE ADDED
NICKOLAS BUGOSH
alkla NICHOLAS BUGOSH
Defendant
TO THE PROTHONOTARY:' ISSUE WRIT OF EXECUTION IN THE ABOVE
MATTER,
(I) Directed to the Sheriff of Cumberland County, Pennsylvania~
(2) against Nickolas Bugosh alkla Nicholas Bugosh, 142 Wyoming Avenue, Enola,
PA 17025, Defendant~ and Nickolas Bugosh alkla Nicholas Bugosh, 4806
Virginia Road, Mechanicsburg, PA 17055~
(3) and against NI A Garnishee (s)~
(4) and index this writ against Nickolas Bugosh alkla Nicholas Bugosh, 142
Wyoming Avenue, Enola, P A 17025~ and Nickolas Bugosh alkla Nicholas
Bugosh, 4806 Virginia Road, Mechanicsburg, PA 17055~
(5) , Defendant~ and levy upon and seize the following real property of Defendant
and index this writ against the following real property of Defendant as a lis
pendens.
All that certain tract of ground together with improvements erected thereon situate in East
Pennsboro Township, Cumberland County, Pennsylvania, known and numbered as 142
Wyoming Avenue, Enola, PA 17025 and as more particularly set forth and described on
Exhibit" A" attached hereto and made part hereof by reference
I.r'"
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...
(a) Exemption has (not) been waived
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Dated ---11.- 2.-- 0 >
17070-0173
'"', ,
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.
,
ALL THAT CERTAIN lot or piece of ground with improvements thereon erected situate
in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described
in accordance with a survey made by DP Raffensperger Associates, Engineers and
Surveyors, dated February 4, 1980, as follows, to wit
BEGINNING at a point on the eastern side of Wyoming Avenue, said point being
referenced 460.00 feet in a southerly direction from the intersection of Wyoming Avenue
and Dauphin Street; thence along the dividing line with property No 144 Wyoming
Avenue, North 79 degrees 40 minutes East, 188.07 feet to a point; thence South 02
degrees 10 minutes 05 seconds East 25.25 feet to a point; thence along the dividing line
with property No 140 Wyoming Avenue, and through the center ofa partition wall and
beyond, South 79 degrees 40 minutes West, 184.48 feet to a point on the eastern side of
said Wyoming Avenue, thence North 10 degrees 20 minutes West 25.0 feet to a point, the
place of BEGINNING.
HAVING THEREON ERECTED a dwelling house known as 142 Wyoming A venue
BEING the same premises which Nickolas Bugosh, single man and Rebecca Ochs, single
woman, by their deed dated October 7, 2003 and recorded in the Cumberland County
Recorder of Deeds Office in Deed Book 259, page 4696, granted and conveyed unto
Nickolas Bugosh, single man
EXHIBIT "A"
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MEMBERS 1 ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs
NICKOLAS BUGOSH alkla
NICHOLAS BUGOSH
NO, 05-02458 Civil Term
DEFENDANT
. CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Members 1" Federal Credit Union, plaintiff, in the above action, sets forth as of
the date the praecipe for the writ of execution was filed the following information
concerning the real property located in East Pennsboro Township, Cumberland County,
Pennsylvania, known and numbered as 142 Wyoming Avenue, Enola, PA 17025.
1. Name and address of owner(s) or reputed owner(s).
Nickolas Bugosh alkla Nicholas Bugosh
142 Wyoming Avenue
Enola, P A 17025
Nickolas Bugosh alkla Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, PA 17055
2 Name and address of defendant( s) in the judgment
Nickolas Bugosh alkla Nicholas Bugosh
142 Wyoming Avenue
Enola, PA 17025
Nickolas Bugosh alkla Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, P A 17055
3 Name and address of every judgment creditor whose judgment is a record lien on
the real property to be sold
,
..
4. Name and address of the last recorded holder of every mortgage of record
Members 1 ,t Federal Credit Union
5000 Louise Drive
Mechanicsburg, P A 17055
5. Name and ~rldress of every other person who has any record lien on the property
6. Name and address of every other person who has any record interest in the
property and whose interest 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
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, P A 1701'3
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, P A 17013
I verify that the statements made in this affidavit are true and correct to the best of
my personal knowledge or information and belief I understand that false statements
herein are made subject to the penalties of 18 Pa C S Section 4904 relating to
unsworn falsification to authorities.
-
Date /L.--'2...--oS
Respectfully submitte ,
vr 7 J
arl M. Ledebohm, Esq.
Supreme Court ID # 59012
PO Box 173
New Cumberland, P A 17070-0173
(717)938-6929
Attorney for Plaintiff
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MEMBERS I ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs,
NICKOLAS BUGOSH alkla
NICHOLAS BUGOSH
NO. 05-02458 Civil Term
DEFENDANT
. CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
j~OTICE OF SHERIFF'S SALE OR REAL ESTATE
To Nickolas Bugosh alkla Nicholas Bugosh
142 Wyoming Avenue
Enola, P A 17025
Nickolas Bugosh alkla Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, PA 17055
Your house (real estate) at 142 Wyoming Avenue, Enola, PA 17025, as more
particularly set forth and described on Exhibit" A" attached hereto and made part
hereof, is scheduled to be sold at Sheriff s Sale on March 8, 2006 at 1000 a.ill in the
Office of the Sheriff, Cumberland County Courthouse, South Hanover Street,
Carlisle, PA 17013 to enforce the court judgment of$73,06362 obtained by the
above named Plaintiff against you.
NOTICE OF OWNER'S RIGHTS
YOT T MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action
1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the
amount of the judgment plus costs or the back payments, late charges, costs
and reasonable attorney's fees due. To find out how much you must pay, you
may call Karl M. Ledebohm, Esquire, at (717)938-6929
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also
ask the Court to postpone the sale for good cause
3. You may 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 to find out how
to obtain an attorney.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERJFF'S SALE DOES TAKE PLACE
1, If the Sheriff s Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price bid by calling the Sheriff at the County
Courthouse.
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 at the
County Courthouse, which number is listed below.
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 on (within thirty (30) days after the
Sheriff 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 by the Sheriff.
7. You may also have other rights and defenses, or ways of getting your house
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
Cumberland County Bar Association
. 2 Liberty Avenue
Carlisle, P A 17013
(717)249-3166 or (800)990-9108
The Sheriff s phone number is: (717)240-6390
17070-0173
ALL THAT CERTAIN lot or piece of ground with improvements thereon erected situate
in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described
in accordance with a survey made by D.P Raffensperger Associates, Engineers and
Surveyors, dated February 4, 1980, as follows, to wit
BEGINNING at a point on the eastern side of Wyoming Avenue, said point being
referenced 460.00 feet in a southerly direction from the intersection of Wyoming Avenue
and Dauphin Street; thence along the dividing line with property No. 144 Wyoming
Avenue, North 79 degrees 40 minutes East, 188.07 feet to a point; thence South 02
degrees 10 minutes 05 seconds East 25.25 feet to a point; thence along the dividing line
with property No. 140 Wyoming Avenue, and through the center ofa partition wall and
beyond, South 79 degrees 40 minutes West, 184.48 feet to a point on the eastern side of
said Wyoming Avenue; thence North 10 degrees 20 minutes West 25.0 feet to a point, the
place of BEGINNING.
HAVING THEREON ERECTED a dwelling house known as 142 Wyoming A venue
BEING the same premises which Nickolas Bugosh, single man and Rebecca Ochs, single
woman, by their deed dated October 7, 2003 and recorded in the Cumberland County
Recorder of Deeds Office in Deed Book 259, page 4696, granted and conveyed unto
Nickolas Bugosh, single man
EXHIBIT "A"
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MEMBERS I ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAJNTIFF
Vs
NICKOLAS BUGOSH a/kla
NICHOLAS BUGOSH
NO,' 05-02458 Civil Term
DEFENDANT
. CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
NOTICE OF JUDGMENT
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM
REQUIRED TO INFORM YOU THAT THIS DOCUMENT AND ANY
SUBSEQUENT CDRRESPONDENCE OR COMMUNICATION IS AN
ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE
TO Nickolas Bugosh a/k/a Nicholas Bugosh
142 Wyoming Avenue
Enola, PA 17025
Nickolas Bugosh aJk/a Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, PA 17055
You are hereby notified that on (),u.. '7 ,2005 the following
judgment has been entered against you in the above captioned case
judgment in the above captioned proceeding in favor of Members 1 ," Federal
Credit Union, Plaintiff, and against the Defendant, Nickolas Bugosh alkla Nicholas
Bugosh, in the amount of SEVENTY-THREE THOUSAND SIXTY-THREE AND
62/100 ($73,063.62) plus interest at the rate of$1l6447 per day, through the date of
payment, includin'l on and after the date of entry of the judgment on the complaint,
additional attorney's fees and costs of suit and for foreclosure and sale of the mortgaged
property Judgment is entered pursuant to Pa, RCP 303l for failure to file an Answer
on behalf of Defendant, Nickolas Bugosh a/kla Nicholas Bugosh, to Plaintiffs Complaint
within twenty (20) days of service thereof and after a IO-day Notice was published and
posted upon the mortgaged property pursuant to the Order of Court dated October 27,
2005 entered in the above captioned matter
Dated
-.
I hereby certify that the proper person to receive this notice under Pa RCP 236
IS
Nickolas Bugosh alkla Nicholas Bugosh
142 Wyoming Avenue
Enola, PA 17025
Nickolas Bugosh alkla Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, P A 17055
. .
MEMBERS I ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
PLAINTIFF
Vs.
NICKOLAS BUGOSH alkJa
NICHOLAS BUGOSH
NO. 05-02458 Civil Term
DEFENDANT
. CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
A Nickolas Bugosh alkJa Nicholas Bugosh
Por este medio se Ie esta ~,otificando que el de
2005, ellla siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el
caso men cion ado en el epigrafe.
Fecha
Protonotario
Certifico que la siguiente direccion as la del defendido/a segun indicada en el certificado
de residencia
Nickolas Bugosh alkJa Nicholas Bugosh
142 Wyoming Avenue
Enola, P A 17025
Nickolas Bugosh alkJa Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, PA 17055
Dated
--
,'z...~ yO)
R"i:~rie ~~
arl M. Ledebohm, Esquire
Supreme Court ID #590]2
PO Box 173
New Cumberland, P A 17070-0173
(717)938-6929
Attorney for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N005-2458 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MEMBERS 1ST FEDERAL CREDIT UNION Plaintiff (s)
From NICKOLAS BUGOSH a/kla NICHOLAS BUGOSH, 142 Wyoming Avenue, Enola, PA
17025; and Nickolas Bugosh a/kla Nicholas Bugosh, 4806 Virginia Road, Mechanicsburg, P A 17055.
(I) You are directed to levy upon the property of the defendant (s)and to sell All that certain tract of
ground together with improvements erected thereon situate in East Pennsboro Township,
Cumberland County Pennsylvania, known and numbered as 142 Wyoming Avenue, Enola, PA
17025 aud as more particularly set forth and described on Exhibit" A". 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 trom
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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due73,063.62
L.L.$.50
Interest from 5/6/05 at the rate of $11.6447 per day to be added
Atty's Comm
Atty Paid $348.82
Plaintiff Paid
Date: December 7, 2005
%
Due Prothy $1.00
Other Costs
(Seal)
{!ttht:x{;U
Prothono.!llJ:Y-''' ..,~
By:
Deputy
REQUESTING PARTY:
Name Karl M. Ledebohrn, Esq.
Address: P. O. Box 173
New Cumberland, PA 17070-0173
Attorney for: Plaintiff
Telephone: 717-938-6929
Supreme Court ID No. 59012
MEMBERS I ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
NICKOLAS BUGOSH alkla
NICHOLAS BUGOSH
NO, 05-02458 Civil Term
DEFENDANT
. CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, Karl M. Ledebohm, Esquire, hereby certify that on the 6th day ofJanuary, 2006,
Notice ofJudgment, Writ of Execution and Notice of Sheriffs Sale of Real Estate was
served upon the Defendant in the above captioned matter by publication in the Patriot
News, pursuant to the Order of Court entered in the above captioned matter. A copy of
the proof of publication is attached hereto as Exhibit" A"
January I], 2006
arl M. Ledebohm, Esq,
Supreme Court ID #. 590]2
PO Box ]73
New Cumberland, P A 17070-0173
(7] 7)938-6929
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 Clfculation, pnnted and published at 812 to 818 Market
Street, in the City, Connty 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
SlOce;
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 in the 6th day(s) of January 2006. That
neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of
the allegations ofthi5 statement as to the time, place and character of publication are Que; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
6th da 0 January 2006 A.D.
NOTARIAl. SEAl.
Terry l. Russell. Notary Public
CIty of Harrisburg, Dauphin County
My CommlsSlon Expi June 6, 2006
);, ; Ponn.ylvanla .oclaliono',~ I rlo.
'11/):/ ~ /
NOTA PUBLIC
My commission expires June 6, 2006
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY.
PENNSYLVANIA
NO. 05-02458 Civil Term
CIVI L ACTION.LAW MORTGAGE
FOR&CLI' URE
MEMBERS 1It FED AL
CREDIT UNION
PLAINTIF
V..
NICKOLAS BUGOSH, Ik/a
NICHOLAS BUGOSH ~1
DEFENDA'NT p,
NOTICE OF JUDGMENT lJl
PURSUANT'TO THE FAIR DEBT COL. j
LECTION PRACTICES ACT I AMRE-
QUIRED TO INFORM YOU THAT THIS Ig
DOCUMENT AND AND SUBSEQUENT io
CORRESPONDENCE OR COMMUNICA. _P'
liON IS AN ATTEMPT TO COLLECT A
DEBT AND ANY INFORMATION OB-
~~~NpEO~E WI LL BE USED FOR THAT -.1
BUTg~;h NIckolas BUgosh a/k/a Nicholas ~~
Ynu are hereby notified that on Decem- .u,
KARL M. LEDEBOHM
ATTORNEY AT LAW
PO BOX 173
NEW CUMBERLAND, PA. 17070-0173
EXHIBIT "A"
IN THE COURT OF COMMOfll PLEAS
CUMlIE.R~HD COUMTY.
PE"N5YLVAtlIA
NO. 05-02458 CIvil Term
c\V\L.I\c.,.,ON.LAW MORTGAGlE
FORECL0'3URIE
MEMBliRS b~ FEDERAL.
CREDIT UNION
PLAINTifF
V..
NICKOLAS BUGOS,", a/kiD
"",',",OLAS BUG05H
. DEFENDANT
MO't'C.EOF JUDGMENT
PURSUANT'TO THE FAIR DEBT C.O\"-
LECTION PRAC,.IC.ES ACT I AMRE-
QUIRED TO INFORM YOll THAT THIS
DOCUMENT AND AND suaseQUe.NT
C.ORRESPON.PENCE OR, COMMUN1CA-
'TION IS AN ATTEMPT TO COU...ECT A
DEeT .IlIHO ANY INFORMATION OB-
TAINED WiLL BE useD FOR THA1'
PURPOSE
TO: NiCkolas BUSIosh (Ilk/a NlcholOS
DuQOsh
you CU'e. herebY notlfled that on Decem-
ber 7, 2.005 the followIng ludgmen~ M been
entered (1~\nd you In the above captioned
case.
Judlilment In 1hlt ~"e c.d\:ltlcmed proceed-
Ing In favor of Members 1 Sf Federal Credit
union. Plaintiff. and aVQln"t tne Cefend-
ant. NIC.kolas BugOsh a/k/a Nicholas
BUgOsh, In the amount of SE\lEw.-rV-
1HREE THOuslUID SIXTy,THRee ,AND
621100 ($73,063,62) piuS Interest at the rate
of $11,6A47 pel' ca'i tt\rou~h ttle date of pay-
ment. Including on and atter the date of en-
I try of ttle ludgmen\ Q1"I the complaint. tlddl-
I "01'10\ attorney'S fees and cost of suite and
, tor foreclosure and sole of the mo\',gaged
I property.. Judoment Is entered pursuant to
I pa.R.C.P. 3031 for folwre to Ille an AnsWfli
I on be'na\1 01 oe~ndant, NICkolas Bugosh
\a/k/O NiCholas &ugosh. to Plaintiffs com-
plaint withIn twent'f t111\ doyS. ot service
thereat and after a 1G-dav Notlce was pub-
lished and posted upon the- 'ltiortGOQed
P1"~rt'i pursudnt to the Order at Court
doted october 27. 2005 entered In the obO".
cdPtlOned mnltl!lr.
Per este medlo se Ie esta notlflcando ~I)e
el 7, p,zem'01"e 'lQlJS. ellla sllJulehte
I (Orden), (oecreto, (FolIO) ha sldo onotado
en contra suya en el cmQ mef\<;\on(l(iO en el
, eplt;arafe.
NoT'tE
\f YOU wIsh to defend. '101.1 must enter a
written appearance personall'i or'tl'i atlor-
neY ana nle Yl)\lr de~en58S or obl.ctlon ll\
wrltln'il with the court. YOI) are warned
that If yout all \0 do ~ the case may pro-
ceed without yOU. you may lose mooneY or
property or other rlgl1ts \mportan\'oyau.
'fOU s.","OULD TAKE THIS PAPER TO
yOUR LAWYEIt AT oNCE. lF YOU 00
NOT 'rt~VE A LAWYER, GO TO OR TEL-
EPHONE THE OFFICE sET FORTH DE-
LOW THIS OFfICe. CAN PROVICE yOU
WITtI. INFORMATION A&OUT HIRING A
LAwYER.
1If' YOU CANNor AFFORD TO HIRE A
LAWYER. rHIS OFFICE MAY DE ABLE
TO PROVIDE yoU WITH INFORMATION
ABOUT AGENCIES THAT MAY Of-FER
L.EGAL sERVices 1'0 ELlGIBL.E pER-
SONS AT A REDUCED FeE OR NO FEE.
cumberlond Count'! B01" A,,!.OClatlon
'1 L\bert'l Avenue
carllsle,PA 17013
l1Y/) 'l49-?'66 or (800l99G-9108
WRIT OR EXECUTION ANOIOR
ATTACHMEt>lT
A writ at exeCUtion has been_ISsued bY the
ProthonotarY tor cumberland county on
oecember 7. 2005. directIng the Sherlffaf
cumberland cOl.!nfY to leVY upon on<!. to ,.n
me pr~N de$crlbed beloW fasotl,ty th~
debt.,lntJre,b Qnd costs due Member 1s
Fecle[a'l:C.:l'eo\t Unla\\, Plaintiff In the above
captlort~ matter, from Nlck.Olas 91.1gosh
alkla NiCholas 'SUIlOSh.
NOilCE Ol= SHERIFF'S SALE OR -
To: Nlckola REAL. ESTATE
Bugosh s Bugash alkla Nlchofas
Your houst {real est te
Avenue. Enolo. PA 17~ } at 142 WyomIng
larly set forth and d' as more partlcu-
schedUI~ to be escrlbed below I I
~arch 8, 2006 at 1~~':o at Sherlfrs Sal~ o~
hhe Sheriff. CUmberlg'~' In the Ortrce at
l~~lS:' ~o~~~~c~n~h:r ~tree~.o~lsl;~u~~
I $73,063.62 obtained b court lud'ilment 0'
I PlaIntiff against Y~ y _ the above named
NOTiCe uU. c
yOU ~.; ~~NER'S RIGHTS
THISSHERIFF'SSA"tBeL.E TO PREVENT
To prevent the Sh Iff'
tate4Jl1hiedlate actlo~~ 5 Sale, YOU must
. ~e Sheriff Sal
YOU paY to the ab e wlll be co~11ed f
gmount of the l\l~~e~fm,ed Plaintiff th~
ock payments I t P us costs or the
~.Qt.Ol'Iable- tlttofn~': tc:ar:e,. co,ts and
ow much YOU must 5 ue. To find out
Karl M. L.edebohm .pay" you moy call
6929, ' squIre, at (717}938-
2. You may be abl
Ing a petition o'kln~: :~stoP the ,ale by fll-
open the judgment It th court to strike or
p.raperly entered' e IUdgment was 1m-
",urt topo,tpont thtY:a~t TOY also ask the
. You may b or good cause
~~e~u~~ ~;~;n~~"f! ~~~~~e~ln~:'P ~~~ ~~~
,aoner you contact o~,:rt your rights, The
~~~ ~l~vfo o~I~~PPln,g ~ ~I~~ {;~:nn~~
attorney, , ,0\1 how to obtaIn on
YOU MAY STILL
6~~R PROPERTY BiN'6BL.E TO SAVE
IFF';~L.~'g~J~ Te,.,~~N IF ~~~ ~HAiRE_
1. If the Sheriff' S PLACE.
Ypr...oPertv will be '~\d a~~ !! naht stopped your
uU may tlt'Td t HIe Ightst bldd
the Sheriff at th~uco~net Perlc" bid by call1i,''g
I 2. YOU may be 'I ourthause
to ,etaslde the able to pemlan t~e Courf
grossly InadeqUat~le of the bId price was
of your property. compared to the "clue
3, Thesalewl\l th
~~ pays the SherIf th~Of,r only If the buY-
e Ulle. To find aut 1f t~1 amount due In
YOU may call th I hal happened
e',urthause, whlchen~~"blff, at the County
. If the amount d er I listed below
rl~:Ot~e.~~~~t:~~:1f r'~ht\~:'Y:e l~~~
appened. e sale never
5. You have 01'1 ht
ertv untll the tull ~m to remaIn In the prop-
Sheriff and the SherlWnt due Is paid to the
, ~uYer, At that time t"glbes a deed to the
.,aa1yproCeedlnlilS to ~VIC~y.uuyer may brIng
. au may be t .
mane.,. which was.n It!etl to 0 shore ot the
ro~hedUle of dl.trlb~~n foot your hoUse. A
I' your house wlll b tt1. money bid I
01,., _ {within thirty (~J '",lied by the Sheriff ;
Sale). ThIs sch YI after the Sher- :
ee reCeiving that ~~~~e will stote wl\o will
~ '.~. I).Old o.ut '1'1. <1.=.'''' Y. T.he man..Y. wltl
I Mlill.~I""1,::~,~,,:h1~;~h;~.;
...t~~tli~~L.w _~. .1'.
i 'h.''''. . of lliili'I.U 10. I. fII.d byth~
",7. Youmoy I h
rtn.~c:!r wa a so ave other rIghts an
ffYOU'Ge:t,lmrri:c,rZ,:Tttlng YOurhous..~t.
YOU SHoUL.D . y after thuole .
~g~~k~~~ELRAwy1~'S6N~~~S I~A~~IT oToO
FORO ONE e:R OR CANN .
WOFHFICE LI~~60B~'tOTWELEPHON~T .f:e
ERE yOU CAN TO FINO OU
Cumberland C GET LEGAL HELP T
2 Liberty A"&n~~r'Ity par Auacfatlon .
Carlisle, pa 17013
(717)249-3166
Th. St\erlff's C:h{800}990-9108
6390. one number Is (717\ 240-
The L:e'"gaTo
as follows escrlPHon of th
AL.L. THAT . e Property ,~
ground witt! CERTAIN lot
.sltuate In E~~P1"ovements theror pIece at
erland CO\l pennsboro tow eon erected
and descrlbedn~, PennSYlvanl~$I\I.P, cum-
made> bY 0 P Raccordanc. with aunded
engIneers and' affensPerger CI lurvev
',.1980, as fo"ow~urv, ey01"S. dQtet~O.clotel',
1d EGINNING ',OWlt, . ruary.
s eafWo a o Paint
"leferenc.J' :Jnog, A, venue, ~~ fha'.1 .,asfern
on from th . eet In a 1'1 beIng
nue and D e Inter$ectlan afsoutherly dlrec-
divIdIng IIn~OPhln Street, th Wyoming Ave_
Ing Aveno wIth prOPe'l"ty ':Jnc. glang the
:ast, 188,0i'fe~f~th 79delJree~' J~ Wyom_
1fe1'ler:s a l~~~~u~s a 65a~~:~~c.e ~~1~t~~
ne wIth . ",ence ala ast 25.25
~U:11' Clnd t~~~~:rYthNo. 140 n~}~~ldlvldlng
and be e center f ng AVe-
nutes West ~084nd. South 19 dO a partition
eastern sid .48 f~t t eIlrees 40 ml
!~e,nce Nart~ fci d said WYa~f~,lnt on f~
""" feet ro egrMS 20 Avenue
BEGINNING a POInt, t'h'lnute" West
1 HAVING THE. e place ot
ng house k EON ERE
N1"CkEING nf,:n a,s 142WYom~JgElVS dw.lI_
alas Bu orne pr enue.
Ochs, SlnglegaSh, slnvle ma~mlses which
October 7 woman. b th and Rebe
gerland c~u2,,<'t~3 :nd reior~Jr I~etehd dG~~
eed Beak 259 ecorder of 0 e Cum_
ve~:~'Mtt N.ICk:,~~eB~::~tfra~= ~~~~n
P.O, Box 1enebohm, E."UI,,:lnllle man, -
New C.umb
Z~),*~r'andl pA 17070-0173
__ rney for ~!~Inf/ff
Miscellaneous Notices
IN THE ,OURTOF COMMON PLEAS
CUMBERLAND COUNTY.
PENMSYl.","Nl"
NO. 0s.02458 Civil TerM
CIVIL ACTiON-LAW MORTGAGE
FORECLO'1URE
MEMBERS 1st FEDERAL.
CREDIT UNION
PLAINTIFF
""
NICKOLAS BUOOSH oa/k/a
NICHOLAS BUGOSH
DEFENDANT
NOTICE OF JUDGMENT
PURSUANT TO THE FAIR DEBT COL-
L.ECTION PRACilCES ACT I AMRE-
QU\REO TO INFORM YOU THAT THIS
DOCUMENT AND AND SUBSEQUE:.NT
CORRESPONDENCE OR COMMUNICA-
TiON IS AN A'TTEMPT TO COLLECT A
DEeT AND ANY lNFORMA'TION OS.
TAl NED WILL BE USED FOR THAT
PURPOSE
BJ~~h Nlc:.l<.olas Bl.lljlosh a/k/a Nicholas
you Qre herebY notifIed that on Decem-
ber 7. 2005 the folloWing ludgment has been
entered a"ainst you In ttl& abo'l8 co?t\oned
case.
Judgment In the above cOftloned proceed-
InQ In favor 01 Members 15 Federal Credit
Union, plaintiff, and against the Oetend.
ant, Nickolas Bugosh alkla NIcholas
Bugosh, In the amount of SeVENTY-
THREE 'THOUSAND SIXTY-THREe. ANO
621100 ($13,063.62) plus Interest at the rate
of $1 1 .6441 per daY through the date of pay-
ment, InclUding on and after the date 01 en-
try of the ludgment on the complaInt. addI-
tional attorney's fees and cost 01 suite and
for loreclosure and saJe of the morfgaged
prO'Olerty. Judvment 15 entered pursuant to
p(I.R.C.p. 3031 for falkJre to file an An5wer
on behalf of oefendr;mt, Nickolas Bugosh
alkla Nicholas Bugosh, to PlaIntiffs Com-
plaint withIn twen\"( (.20) daYll 01 ~rv\a:
thereot and after a 10-daY NotIce Wds pub-
lished dnd pOsted upon themortgdged
pr~erty pursuant to the order ot Court
dated October 21, 2005 entered In the above
<<lptloned matter.
Per este medlo se Ie esta notltlcando que
el 7, Oenm'On 'll)O5, .1Ik:! s..IQulente
(Orden), {Decreto, (Folio) ho sldo anotado
en Contra suya en el COSO menclonado en el
e"lgrate.
NOTICE
If you wish fo detend, you must enter a
wrItten appearance personallv or by attor-
nev one tile your <.iele"s.e:s or oblectlon In
writing with the court. You are warned
that It youl all to do so the case may pro-
ceed without you. YOU may 101& moonev or
properlY or other rluhts ImPOrtant '0 yoU.
YOU SHOU\..D TAKE THIS PApER TO
YOUR LAWYER AT ONCE. IF you 00
NOT HAVE A LAWYER, GO TO OR TEL-
EPHoNE THE OFFICE SET FORTH BE-
LOW THIS OFFiCE CAN PROVIDE YOU
t~~~~~ORN\ATION ABOUT HIRING A
IF YOU CANNOTA'FFORD TO HIRE A
LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES 11'0 ELIGIBL.E PER-
SONS AT A REDUCED FEE OR NO FEE.
cum'oerlond CO'Jntf ear A5$Qc\al1on
2 LlberlY Avenue
Carlisle, PA 11013
{717l 249.3166or {1lO0)990.9108
WRIT OR EXECUTION ANO/OR
ATTACHMENT
A writ of executIon has beeo.lssued by the
Pn~t"onotClrY lor Cumberland County on
December " 2005, dIrecting the Shllr.lff, of
cumberlarid county to levY upon ond to ..II
th'bproPtrty Q,scrlbed below to,aflsfy the
de I, Int;reJt5, and cosh d\le Member 1st
Fede,rq.l,Cretllt Union, Plaintiff In the above
. captlo~ matler, trom NIckolas Bugosh
a/k/o til.lcholas Bugosh.
NOTICEOFSHERIFF'SSA~E OR'-
To: Nlckola~EAL ESTATE I
Bugosh Bugosh erlkla Nicholas
Your house (real tat
Avenue, Enolel, PA ~:Q25e) at 142 Wvomlng
larly set forth d d' as more partleu.
scheduled to be an escrlbed below, IS
March B, 2006 at 1~~I:O ~t Sh~rlff's Sale on I
'hhe Sherl1t, Cumberlg,;:r. ~ the Office 01
OUIt, South Ha ounty Court-
: 11013 to enforcen~her Street, carlisle, PA
$73,063.62 obtained ebyco;::-t ludgment 01
Plaintiff against YOU '0 e above named
~OOTICE OF OWNER'S RIGHTS
U MAY BE ABLE T
THISSHERIFF'SSAl.E 0 PREVENT
To ):Irevent the Sh Iff'
take_ilnJ_medlate actlo~r 5 Sale, you must
1.'7f1e SherIff S I '
vou pay ~o the b a e will be cancelled 11
amount of the I~d~:e nfmed Plaintiff the
back pavments I t n plus costs or the
reasonable atto;ne~': 1~~ar3es, costs and
how much you m t S ue. To 'Inti ovt
Karl M. Ledeboh~s rfsa.Y'I' you may call
6929, ,u re, at (717)938-
2. You mQY be obi I
Ing a petition aSking. t~ stoP the sate by fIl.
o):len the ludgment 11 th e Ic~urt to strike or
properlY entered 'ya e u gment was Im-
court to postpone the sale ray al$O Clsk the
3. You may be bl or good cault.
throuvh other legal p~oce :JJ 5tOP the sale
~~e~n y~t~~~~fa to asse:t yo~~Srlvh~ 'W.~
,~ou wIll have of s~p~7~g ~~~ mfre chance
ce below to 11nd out h sa e. (See no-
attorneY. ow to obtain an
yci&~ ~~pSJk~L BE ABLE TO SAVE
?:~i~L~I~~~~ l~~~1~J~~ ~HAi':.
1. lithe Sheriff's S I I ,E.
properlY wlll be SOI/t: t~ nt~ stopped your
'fou moy Ilnd out Ih ,e ghest bidder
the Sheriff at the coun~:~ICet~ld by calling
2. you may be bl tour ouse.
to set aside the, s~'e" otO t'h't1~lo...n the Court
grOSSly Inadequate com e .... prIce WQS
01 Your property , pared to the value
3, The IOlewlil g th
er POYS the Shllrl; thror~h only 11 the buy.
the sol,. To find out ~ t~ll tmount due In
you may call the Sh I s as happened,
Co4~rr~~~:e~rri~~~~ numt:f,s ~tst:: b;I:~ty
paid to theSherl1f ~~~ ~I:r the buyer Is not
!~_ of the property as If r"hmaln the own-
,.......petWd. e sale never
5. You have a right t
erN until the fUll a 0 remaIn In the prop-
Sheriff and the Sher::'~~ntl due Is ):laid to the
buyer. At that tlm g ves a deed to tl'le
legal proceedings to ~vr~: buyer may bring
6. You may be t t'_..You.
monev wl'lld\ wa5en I ...... to a 5hare of the
schedule 01 dlStrlb POId for YOIJr house. A
lor your house WIlJutlon 01 the money bid i
on.. {within thirty (~) ~'ed by the Sheriff '
Iff Sale}. Thls sched I avs after the Sher-
be receIVIng t"at mo~:y wfl+~tate who will
1'~.~;Mliiit'~ Wlt~ ';'W~~~h~.'~ I
,1__ U 1J&""r<?o~\l(n ....tw lhl: :
It.h,!b,! l1erl11 IN. Fi'iih'''"^ ..~.':fllId )
I.Jfe'sehedU1e'O{dl'-fff~-Fr;.aft.
SherIff. u on Is tiled by the
7. You may also h
ftn"~.p:r ways ot ave other rIghts and de-
ffJioUGl:t.,mtnedlo.:rr:M your .house baCt
YOU SHOULD . er tl'le sale . '
~gUR LAWYER l'i'\iNt~'S PAPER TO
FOT HAVE A LAWYER 0.' I F YOU DO
RO ONE GO TO OR . CANNOT AF-
OFFrCE LISTED BEL6ELEPHONE THE
WHERE YOU CAN GET 't'e TO FIND OUT
Cumberland C t GAL HELP
2 LIberty Avent~n y J5ar Association .
CarHsle, Po 11013
(717) 249-3166 or (800}990-9
Th., Sherlff'!. PM. lOB
6390. ne number Is (717) 240-
--The Le'VOIoescrfPtlon of the Propertv I,.
asfollOW!o
A\..L THAT CERTAIN lot or pIece 01
groond with Improvements thereon erected
situate In East pennsboro townshIp, cum-
berland County, pennsY\'IIonld, bour\ded
and dllscrlbed In accordcmce with a survey
made bY D.P. Raffensperger Associates"
eTlVlneers and surveYOrS, dated F"bruary
4,1980,as101l0ws, to wit.
BEGINNING at a point on the eostern
side of wyomIng Avenue, sold poInt beIng
referenced 460.00 lellt \1'1 0 !.ou'he\"IY dlrec.-
tlon from the Inter5ectlon 01 wyoming Ave-
nue and DauphIn Street, thence along the
dlvldlnv line with property No. 144 Wvom-
Ing Avenue, North 79 degrees 30 mlnmes
Edst, 188.07 teet to a point, thence South 02
degrees 10 mInutes 05 seconds East 25.25
I,., to a point; 'het\Ce c.\onQ the dIVIding
line wltl1 property No. 140 wyoming Ave.
nue, and through the center of a portltlon
waH and beyond, South 19 degrees 40 mi-
nutes west, 18.4.48 teet '0 a poln' on ,he
eastern sIde of saId wyomIng ,Avenue,
t\1ence North 10 degreeS 20 minutes West
25.1) 1eet '0 a point, tne pldce 01
BEGINNING.
HAVING THEREON ERECTED IS dwell-
lI'Ig house known os 142Wyomlng Avenue.
BEING the lame pram\!." whIch
Nickolas Bugosh, single mall and Rebecca
Ochs, single woman, bv their deed dated
october 7, 1003 and recorded In the cum.
berland County Recorder 01 Deeds OffIce In
Deed Book 259, page 4696, granted ond cOrl-
""eved unto NIckolas BUgosh, single man.
Karl M. Led.bohm, EI1Ii\l\re
P.O. Box 173
New c.umberland, PA 17070-0173
{1\7l9316t19
Attorney for PlalntlH
j
, 1
r. :::l
,
CJ
. ,
.. ,) .J
<
MEMBERS I ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs
NICKOLAS BUGOSH alkla
NICHOLAS BUGOSH
NO, 05-02458 Civil Term
DEFENDANT
. CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, Karl M Ledebohm, Esquire, hereby certify that on the 6th day of January, 2006,
Notice of Judgment, Writ of Execution and Notice of Sheriffs Sale of Real Estate was
served upon the Defendant in the above captioned matter by publication in the
Cumberland Law Journal pursuant to the Order of Court entered in the above captioned
matter. A copy of the proof of publication is attached hereto as Exhibit "A"
January 30, 2006
.""~ ~bmitted
/~ejQfl
.Karl M. Ledebohm, Esq.
Supreme Court ID #. 59012
PO Box 173
New Cumberland, P A 17070-0173
(717)938-6929
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. 1.1784
COMMONWEALTH OF PENNSYL VANIA
SS.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
.,;rPN(N~'R.';/ 6, c5(OOw
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.
ORN TO AND SUBSCRIBED before me this
IP 1-17 day of J -"! /1/ [) ,4 RY" ~ txl b
L/ . . ;..
~./..o "- <l. )C .
Notary
d
/' /,.. - ,..-'
__ /;..(. I(/i//~./
/
C
EXHIBIT "A"
CUMBERLAND LAW JOURNAL
NOTICE
In the Court of Common Pleas
Cumberland County. Pennsylvania
Civil Action-Law
No.: 05-02458 Civil Term
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
VS.
NICKOLAS BUGOSH. a/k/a
NICHOLAS BUGOSH
DEFENDANT
MORTGAGE FORECLOSURE
NOTICE OF JUDGMENT
PURSUANT TO THE FAIR DEBT
COLLECTION PRACTICES ACT.
I AM REQUIRED TO INFORM
YOU THAT THIS DOCUMENT
AND ANY SUBSEQUENT COR-
RESPONDENCE OR COMMUNI-
CATION IS AN ATIEMPT TO
COLLECT A DEBT AND ANY IN-
FORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
TO: Nickolas Bugosh, a/k/a Nlcho~
las Bugosh
You are hereby notified that on
December 7, 2005 the following
judgment has been entered against
you in the above captioned case: .
Judgment in the above captioned
proceeding in favor of Members 1st
Federal Credit Union. Plaintiff, and
against the Defendant, Nickolas Bu-
gosh, a/k/a Nicholas Bugosh, in the
amount of SEVENTY-THREE THOU-
SAND SIXTY-THREE AND 62/100
($73,063.62) plus interest at the rate
of $11.6447 per day, through the
date of payment, including on and
after the date of entry of the judg-
ment on the complaint. additional
attorney's fees and costs of suit and
for foreclosure and sale of the mort-
gaged property. Judgment is entered
pursuant to Pa. R.e.p, 3031 for fail-
ure to file an Answer on behalf of
Defendant, Nickolas Bugosh, a/k/a
Nicholas Bugosh, to Plaintiffs Com-
plaint within twenty (20) days of selV-
Ice thereof and after a 10-day No-
tice was published and posted upon
the mortgaged properly pursuant to
the Order of Court dated October
27, 2005 entered in the above cap-
tioned matter.
Por este medio se Ie esta notifi-
cando que el 7, Dezembre 2005, el/
la siguiente (Orden), (Decreto), (Fallo),
ha sldo anotado en contra suya en
el caso mencionado en el eptgrafe,
NOTICE
If you wish to defend, you must
enter a written appearance person-
ally or by attorney and file your de-
fenses or objections in writing with
the court. You are wamed that if you
fail to do so the case may proceed
without you. You may lose money
or property or other rights impor-
tant to you.
YOU SHOULD TAKE THIS PA-
PER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER.
GO TO OR TELEPHONE THE OF-
FICE 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 LE-
GAL SERVICES TO ELIGIBLE PER-
SONS AT A REDUCED FEE OR NO
FEE.
3
CUMBERLAND LAW JOURNAL
Cumberland . County
Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
or .
(800) 990-9108
WRIT OF EXECUTION
AND/OR ATTACHMENT
A writ of execution has been is~
sued by the Prothonotary for Cum-
berland County on December 7,
2005, directing the Sheriff of Cum-
berland County to levy upon and to
sell the property described below
to satisfy the debt, interests and costs
due Members 1st Federal Credit
Union, Plaintiff in the above captioned
matter, from Nickolas Bugosh, a/k/a
Nicholas Bugosh.
NOTICE OF SHERIFF'S SALE OR
REAL ESTATE
To: Nikolas Bugosh, a/k/a Nicho-
las Bugbsh
Your house (real estate) at 142
Wyoming Avenue, Enola, PA 17025,
as more particularly set forth and
described below, 1s scheduled to be
sold at Sheriffs Sale on March 8.
2006 at 10:00 a.m. in the Off:lce of
the Sheriff. Cumberland County
Courthouse, South Hanover Street,
Carlisle, PA 17013 to enforce the
court judgment of $73,063.62 ob-
tained by the above named Plaintiff
against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT
THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you
must take immediate action:
1. The Sheriff Sale will be can-
celled if you pay to the above named
Plaintiff the amount of the judgment
plus costs or the back payments,
late charges, costs and reasonable
attorney's fees due. To find out how
much you must pay. you may call
Karl M. Ledebohm, Esquire, at (717)
938-6929.
2. You may be able to stop the
sale by filing a petition asking the
Court to strike or open the judg-
ment, if the judgment was improp~
erly entered. You may also ask the
Court to postpone the sale for good
cause.
3. You may be able to stop the
sale through other legal proceed-
ings. 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 to find out how to ob-
tain an attorney.)
YOU MAY STILL BE ABLE TO
SAVE YOUR PROPERlY AND
YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE
DOES 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 by calling the Sher-
iff at the County Courthouse.
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 prop-
erty.
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 at the County Court-
house, which number is listed be-
low.
4
. .
CUMBERLAND LAW JOURNAL
4. If the amount due from the
buyer is not paid to the Sheriff. you
will remain the owner of the prop~
erty 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 distribu-
tion of the money bid for your house
will be filed by the Sheriff on
(within thirty (30) days
after the Sheriff Sale). This sched-
ule will state who will be receiving
that money. The money will be paid
Qut in accordance with this sched-
ule unless exceptions (reasons why
the proposed distribution is wrong)
are filed with the Sheriff within ten
(10) days after the schedule of dis-
tribution is filed by the Sheriff.
7. You may also have other rights
and defenses, or ways of getting
your house back, if you act imme-
diately after the sale.
YOU SHOULD TAKE THIS PA-
PER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE. GO TO
OR TELEPHONE TIiE OFFICE UST-
ED BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County
Bar Association
2 Uberty Avenue
Carlisle, PA 17013
(717) 249-3166
or
(8001 990-9 I 08
The Sheriffs phone number is:
(717) 240-6390.
The Legal Description of the Prop-
erty is as follows:
ALL THAT CERTAIN lot or piece
of ground with improvements there-
on erected situate in East Pennsboro
Township, Cumberland Cormty, Perm-
sylvania, bounded and described in
accordance with a survey made by
D.P, Raffensperger Associates, En-
gineers and Surveyors, dated Feb-
ruary 4, 1980, as follows, to wit:
BEGINNING at a point on the
eastern side of Wyoming Avenue,
said point being referenced 460.00
feet 1n a southerly direction from
the intersection of Wyoming Avenue
and Dauphin Street; thence along
the dividing line with property No.
144 Wyoming Avenue, North 79
degrees 40 minutes East, 188.07
feet to a point; thence South 02
degrees 10 minutes 05 seconds
East 25.25 feet to a point; thence
along the dividing line with prop-
erty No. 140 Wyoming Avenue, and
through the center of a partition wall
and beyond, South 79 degrees 40
minutes West, 184.48 feet to a point
on the eastern side of said Wyoming
Avenue; thence North 10 degrees
20 minutes West 25,0 feet to a
point. the place of BEGINNING.
HAVlNG TIiEREON ERECTED a
dwelling house known as 142 Wyo-
ming Avenue.
BEING the same premises which
Nickolas Bugosh, single man and Re-
becca Ochs, single woman, by their
deed dated October 7, 2003 and
recorded in the Cumberland County
Recorder of Deeds Office in Deed
Book 259. page 4696, granted and
conveyed unto Nickolas Bugosh,
single man.
KARL M. LEDEBOHM.
ESQUIRE
Attorney for Plaintiff
P.O. Box 173
New Cumberland, PA
I 7070-0i 73
(7 I 7) 938-6929
Jan. 6
5
MEMBERS 1 ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
PLAINTIFF
Vs
NICKOLAS BUGOSH alkJa
NICHOLAS BUGOSH
NO. 05-02458 Civil Term
DEFENDANT
. CIVIL ACTION-LAW
. MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, Karl M. Ledebohm, Esquire, hereby certify that on the 6ili day of January, 2006,
Notice of Judgment, Writ of Execution and Notice of Sheriff s Sale of Real Estate was
served upon the Defendant in the above captioned matter by publication in the
Cumberland Law Journal pursuant to the Order of Court entered in the above captioned
matter. A copy of the proof of publication is attached hereto as Exhibit" A"
January 30, 2006
Respectfu/ submitted,
l0ei2Q~v
Karl M Ledebohm, Esq
Supreme Court 10 # 59012
PO Box 173
New Cumberland, P A 17070-0173
(717)938-6929
t(Q)[p1f
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. 1.1784
COMMONWEAL TH OF PENNSYL VANIA
55.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2,1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
JP/vVH'R.';I 1/;, &OOtO
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.
ORN TO AND SUBSCRJBED before me this
&,f-h day of J";VV,4RY,, ~t;0b
~ <~) f;. xl/'(//M/
Notary
EXHIBIT "1\."
CUMBERLAND LAW JOURNAL
NOTICE
In the Court of Common Pleas
Cumberland County. Pennsylvania
Civil Action-Law
No.: 05-02458 CMI Term
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
vs.
NICKOLAS BUGOSH. a/k/a
NICHOLAS BUGOSH
DEFENDANT
MORTGAGE FORECLOSURE
NOTICE OF JUDGMENT
PURSUANT TO THE FAIR DEBT
COLLECTION PRACTICES ACT.
I AM REQUIRED TO INFORM
YOU THAT THIS DOCUMENT
AND ANY SUBSEQUENT COR-
RESPONDENCE OR COMMUNI-
CATION IS AN ATTEMPT TO
COLLECT A DEBT AND ANY IN-
FORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
TO: Nickolas Bugosh, a/k/a Nicho-
las Bugosh
You are hereby notified that on
December 7, 2005 the following
judgment has been entered against
yOU in the above captioned case: .
. Judgment. in the above captioned
proceeding in favor of Members 1st
Federal Credit Union, Plaintiff, and
against the Defendant. Nickolas Bu-
gosh, a/k/a Nicholas Bugosh, in the
amount of SEVENlY -THREE TI-IOU-
SAND SlX1Y-THREE AND 62/100
($73,063,62) plus interest at the rate
of $11.6447 per day, through the
date of payment. including on and
after the date of entry of the judg-
ment on the complaint, additional
attorney's fees and costs of suit and
for foreclosure and sale of the mort~
gaged property, Judgment is entered
pursuant to Pa. R.C.P. 3031 for fail-
ure to file an Answer on behalf of
Defendant, Nickolas Bugosh, a/k/a
Nicholas Bugosh, to Plaintiffs Com-
plaint within twenty (20) days of serv-
ice thereof and after a lO-day No-
tice was published and posted upon
the mortgaged property pursuant to
the Order of Court dated Octoher
27, 2005 entered in the above cap-
tioned matter.
Por este medic se le esta J1otifi-
cando que el 7, Dezemhre 2005, ell
la siguiente (Orden), (Decreto}, (Fallo},
ha sido anotado en contra suya en
el caso menc1onado en el epigrafe.
NOTICE
If you wish to defend, you must
enter a wr1tten appearance person~
ally or by attorney and file your de~
fenses or objections in writing with
the court. You are warned that if you
fail to do so the case may proceed
without you. You may lose money
or property or other rights frnpor~
tant to you.
YOU SHOULD TAKE THIS PA-
PER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER.
GO TO OR TELEPHONE THE OF-
FICE SET FORTH BELOW. THIS
OFFICE CAN PROVlDE 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 LE-
GAL SERVlCES TO ELIGIBLE PER-
SONS AT A REDUCED FEE OR NO
FEE.
3
CUMBERLAND LAW JOURNAL
Cumberland County
Bar Association
2 Liberty Avenue
Carlisle. PA 17013
(717) 249-3166
or'
(800) 990-9108
WRiT OF EXECUTlON
AND/OR ATIACHMENT
A writ of execution has been is-
sued by the Prothonotary for Cum-
berland County on December 7,
2005, directing the Sheriff of Cum-
berland County to levy upon and to
sell the property described below
to satisfy the debt, interests and costs
due Members 1st Federal Credit
Union, Plaintiff in the above captioned
matter, from Nickolas Bugosh. a/k/ a
Nicholas Bugosh.
NOTICE OF SHERiFF'S SALE OR
REAL ESTATE
To: Nikolas Bugosh. a/k(a Nicho-
las Bugbsh
Your house (real estate) at 142
Wyoming Avenue, Enola. PA 17025,
as more particularly set forth and
described below, is scheduled to be
sold at Sheriffs Sale on March 8.
2006 at 10:00 a.m. in the Office of
the Sheriff, Cumberland County
Courthouse, South Hanover Street,
Carlisle, PA 17013 to enforce the
court judgment of $73,063.62 ob-
tained by the above named Plaintiff
against yOll.
NOTICE OF OWNER'S RiGHTS
YOU MAY BE ABLE TO PREVENT
THIS SHERiFF'S SALE
To prevent this Sheriffs Sale, you
must take immediate action:
1. The Sheriff Sale will be can-
celled if you pay to the above named
Plaintiff the amount of the judgment
plus costs or the back payments,
late charges, costs and reasonable
attorney's fees due. To find out how
much you must pay, you may call
Karl M. Ledebohm, Esquire, at (717)
938-6929.
2. You may be able to stop the
sale by filing a petition asking Ihe
Court to strike or open the judg-
ment, if the judgment was improp-
erly entered. You may also ask the
Court to postpone the sale for good
cause.
3. You may be able to stop the
sale through other legal proceed-
ings. You may need an attorney to
assert your rights. The sooner you
contact one, the more chance you
win have of stopping the sale. (See
notice below to find out how to ob-
tain an attorney.J
YOU MAY STILL BE ABLE TO
SAVE YOUR PROPERTY AND
YOU HAVE OTHER RiGHTS
EVEN IF THE SHERiFF'S SALE
DOES TAKE PLACE.
I. If the Sheriffs Sale is not
stopped, your property will be sold
to the highest bidder. You may find
out the price bid by calling the Sher-
iff at the County Courthouse.
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 prop-
erty.
3. The sale will go through only
if the buyer pays the Sheriff the full
amount due in the sale. To fmd out
if this has happened. you may call
the Sheriff at the County Court-
house, which number is listed be-
low.
4
CUMBERLAND LAW JOURNAL
4. If the amount due from the
buyer is not paid to the Sheriff, you
will remain the owner of the prop-
erty 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 distribu-
tion of the money bid for your house
will be filed by the Sheriff on
(wlthln thirty (30) days
after the Sheriff Sale). This sched-
ule will state who will be receiving
that money. The money will be paid
out 111 accordance with this sched-
ule unless exceptions (reasons why
the proposed distribution is wrong)
are filed with the Sheriff within ten
(10) days after the schedule of dis-
tribution is filed by the Sheriff.
7. You may also have other rights
and defenses, or ways of getting
your house back, if you act imme-
diately after the sale.
YOU SHOULD TAKE THIS PA-
PER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE. GO TO
OR TElEPHONE TIlE OFFICE US[-
ED BEWW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County
Bar Association
2 Liberty Avenue
Carlisle. PA 17013
(717) 249-3166
or
(800) 990-9108
The Sheriffs phone number is:
(7 17) 240-6390.
The Legal Description of the Prop-
erty is as follows:
ALL THAT CERTAIN lot or piece
of ground with improvements there-
on erected situate in East Pennsboro
Township. Cumberland County, Penn-
sylvania, bounded and described in
accordance with a survey made by
D.P. Raffensperger Associates. En-
gineers and Surveyors. dated Feb-
ruary 4, 1980, as follows, to wit:
BEGINNING at a point on the
eastern side of Wyoming Avenue,
said point being referenced 460.00
feet in a southerly direction from
the intersection of Wyoming Avenue
and Dauphin Street: thence along
the dividing line with property No.
144 Wyoming Avenue, North 79
degrees 40 minutes East, 188.07
feet to a point; thence South 02
degrees 10 minutes 05 seconds
East 25.25 feet to a point; thence
along the dividing line with prop-
erty No. 140 Wyoming Avenue, and
through the center of a partition wall
and beyond. South 79 degrees 40
minutes West, 184.48 feet to a point
on the eastern side of said Wyoming
Avenue: thence North 10 degrees
20 minutes West 25.0 feet to a
point, the place of BEGINNING.
HAVING THEREON ERECTED a
dwelling house known as 142 Wyo-
ming Avenue.
BEING the same premises which
Nickolas Bugosh, single man and Re-
becca Ochs, single woman, by their
deed dated October 7, 2003 and
recorded in the Cumberland County
Recorder of Deeds Office in Deed
Book 259. page 4696, granted and
conveyed unto Nickolas Bugosh,
Single man.
KARL M. LEDEBOHM.
ESQUIRE
Attorney for Plaintiff
P.O. Box 173
New Cumberland, PA
17070-0173
(717) 938-6929
Jan. 6
5
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND } SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriffs Deed in which Viktor I Ogjr.Nina N Ogir and Tatvana V Ogir is the grantee the same
having been sold to said grantee on the 8th day of March A.D., 2006, under and by virtue of a writ
Execution issued on the 7th day ofDec, A.D., 2005, out ofthe Court of Common Pleas of said County
as of Civil Term, 2005 Number 2458, at the suit of Members 1st Fed Cr Un against Nickolas Bugosh
aka Nicholas Bugosh is duly recorded in Deed Book No. 274, Page 253.
IN TESTIMONY WHEREOF, I have hereunto set my hand
~
and seal of said office this / f day of
Il~
, A.D. ;;~ C,
ecorder of Deeds
. CaunIy, CoItIl1Io, PA
El1pIreothoFirllMondilyalJ... 3.DIO
AMENDED RETURN
This affidavit is amended to reflect the correct documents posted at 142 Wyoming
Avenue, Enola, Cumberland County, Pennsylvania
Members 1st Federal Credit Union
VS
Nickolas Bugosh aIkIa Nicholas Bugosh
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2005-2458 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
made a diligent search and inquiry for the within named defendant, Nickolas Bugosh
aJk/a Nicholas Bugosh, but was unable to locate him in his bailiwick. He therefore
returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND, as
to the defendant, Nickolas Bugosh aJk/a Nicholas Bugosh. The house located at 142
Wyoming Ave., Enola, PA 17025 is vacant. The house located at 4806 Virginia Road,
Mechanicsburg, P A 17055 is occupied by the defendant's mother. The mother states the
defendant does not reside with her at 4806 Virginia Rd., Mechanicsburg, P A.
J. Michael Ickes, Deputy Sheriff, who being duly sworn according to law, states
that on January 11,2006 at 10:00 o'clock A.M., he posted a true copy of the within Real
Estate Writ, Notice of Sheriffs Sale, Notice of Judgment, Sheriffs Sale Poster and
Property Description, in the above entitled action, upon the property of Nickolas Bugosh
aJk/a Nicholas Bugosh, located at 142 Wyoming Ave., Enola, Pennsylvania, according to
law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on March 8, 2006 at 10:00 o'clock A.M. He sold the same for the
sum of $75,000.00 to Viktor Ogir. It being the highest bid and best price received for the
same, Viktor Ogir of 142 Wyoming Ave, Enola, P A 17025-2428 being the buyer in this
execution, paid to SheriffR. Thomas Kline the sum of $78,191.80.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Certified Mail
Levy
$30.00
1,500.00
15.00
15.00
30.00
10.00
.50
1.00
28.16
1.95
15.00
Surcharge
Postage
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
20.00
.78
329.00
287.60
21.05
25.00
39.50
$ 2,369.54
Sworn and subscribed to before me
2006, A.D.
~~ --/~
r ~1-- ~
R. Thomas Kline, Sheriff
BY ~ \~tW1~
Real Estate geant
Jv-A-
3/').00 ~
). ::,1)
~ 531"'1'1
~ 1717'1L
MEMBERS I ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs
NICKOLAS BUGOSH alkfa
NICHOLAS BUGOSH
NO.: 05-02458 Civil Term
DEFENDANT
: CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Members 1'1 Federal Credit Union, plaintiff, in the above action, sets forth as of
the date the praecipe for the writ of execution was filed the following information
concerning the real property located in East Pennsboro Township, Cumberland County,
Pennsylvania, known and numbered as 142 Wyoming Avenue, Enola, PA 17025.
I. Name and address of owner(s) or reputed owner(s)
Nickolas Bugosh alkla l'Iicholas Bugosh
142 Wyoming Avenue
Enola, PA 17025
Nickolas Bugosh alk/a Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, P A 17055
2. Name and address of defendant(s) in the judgment:
Nickolas Bugosh aJk/a Nicholas Bugosh
142 Wyoming Avenue
Enola, P A 17025
Nickolas Bugosh aJk/a Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, PA 17055
3. Name and address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
~())fQ)~
~
,
4. Name and address of the last recorded holder of every mortgage of record:
Members 1st Federal Credit Union
5000 Louise Drive
Mechanicsburg, P A 17055
5. Name and ~rldress of every other person who has any record lien on the property
6. Name and address of every other person who has any record interest in the
property and whose interest 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:
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, P A 1701:3
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, P A 17013
I verify that the statements made in this affidavit are true and correct to the best of
my personal knowledge or information and belief I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
-
Date: rZ---1--cS
arl M. Ledebohm, Esq.
Supreme Court ID #: 59012
PO Box 173
New Cumberland, P A 17070-0173
(717)938-6929
Attorney for Plaintiff
MEMBERS I ST FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
NICKOLAS BUGOSH alkla
NICHOLAS BUGOSH
NO.: 05-02458 Civil Term
DEFENDANT
: CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OR REAL ESTATE
To Nickolas Bugosh alkla Nicholas Bugosh
142 Wyoming Avenue
Enola, PA 17025
Nickolas Bugosh alkla Nicholas Bugosh
4806 Virginia Road
Mechanicsburg, P A 17055
Your house (real estate) at 142 Wyoming Avenue, Enola, PA 17025, as more
particularly set forth and described on Exhibit" A" attached hereto and made part
hereof, is scheduled to be sold at Sheriffs Sale on March 8, 2006 at 10:00 am. in the
Office of the Sheriff, Cumberland County Courthouse, South Hanover Street,
Carlisle, P A 17013 to enforce the court judgment of$73,063.62 obtained by the
above named Plaintiff against you.
NOTICE OF OWNER'S RIGHTS
YOTT MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
I. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the
amount of the judgment plus costs or the back payments, late charges, costs
and reasonable attorney's fees due, To find out how much you must pay, you
may call Karl M. Ledebohm, Esquire, at (717)938-6929.
2, You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also
ask the Court to postp'one the sale for good cause.
3, You may 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 to find out 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 TAKE PLACE.
I. If the Sheriff s Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price bid by calling the Sheriff at the County
Courthouse.
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 Sheriffthe full amount due
in the sale. To find out if this has happened, you may call the Sheriff at the
County Courthouse, which number is listed below.
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 on (within thirty (30) days after the
Sheriff 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 by the Sheriff.
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 THJS PAPER TO YOUR LAWYER AT ONCE IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
Cumberland County Bar Association
. 2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 or (800)990-9108
0..
The Sheriff s phone number is: (717)240-6390.
17070-0173
~
SCHEDULE OF DISTRIBUTION
SALE NO. 45
Date Filed: April 07, 2006
Writ No. 2005-2458 Civil Term
Members 1st Federal Credit Union
VS
Nickolas Bugosh aJk/a Nicholas Bugosh
142 Wyoming Ave.
Enola, P A 17025
Sale Date:
Buyer:
Bid Price:
March 08, 2006
Viktor Ogir
$75,000.00
Real Debt:
Interest:
Attorney Costs:
$73,063.62
3,551.63
348.82
Total:
$76,964.07
DISTRIBUTION:
Receipts:
Cash on account (12/12/2005):
Cash on account (03/08/2006):
Cash on account (03/24/2006):
Total Receipts:
I
L
$ 1,500.00
7,500.00
70,691.80
$79,691.80
Disbursements:
Sheriff's Costs
Legal Search
State Transfer Tax
Local Transfer Tax
Cumberland Co. Tax Claim Bureau
Debbie Lupoid, Tax Collector
East Pennsboro Township
Members 1st Federal Credit Union
Members 1st Federal Credit Union
Total Disbursements:
Balance for distribution:
So Answers:
~~ 1~t:~~~
R. Thomas Kline
Sheriff
$ 2,369.54
200.00
745.90
745.90
1,255.46
231.50
867.26
1,500.00
71,776.24
($79,691.80)
0.00
.
TITLE REPORT
THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING
ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY
EVIDENCE PERMITIING THEIR REMOVAL IS PRODUCED.
SHERIFF SALE NO. 45
Held Wednesday, March 8, 2006
Date: March 8, 2006
TAXES: Receipts for all taxes for the years 2004 to 2005 inclusive. Taxes for the current
year 2006.
WATER RENT:
Company assumes no liability for private supply of water or
sewer.
SEWER RENT
Receipts to be produced if services are lienable.
MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims.
MUNICIPAL CLAIMS
MORTGAGES: Listed Under Other Exceptions Below.
JUDGMENTS: Listed Under Other Exceptions Below.
INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to
dated , 2006, and recorded
, 2006, in Cumberland County Deed Book , Page
RECITAL: Being the same premises which Nickolas Bugosh and Rebecca Ochs by deed
October 7, 2003, and recorded October 17, 2003 in the Office of the Recorder of Deeds in
and for Cumberland County, at Carlisle Pennsylvania, in Deed Book 259, Page 4696,
granted and conveyed to Nickolas Bugosh.
OTHER EXCEPTIONS:
1. The identity and legal competency of parties at the closing of this title should be
established to the satisfaction of the closing attorney acting for this Company.
2. Rights or claims of parties in possession, if any, other than the owner.
3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in
area and encroachments which an accurate and complete survey would
disclose.
4. Payment of State and local Real Estate Transfer Taxes, if required.
5. Public and private rights in the roadbed of Wyoming Avenue.
.
6. Private rights in party wall forming a portion of the boundary lines for the
subject premises.
7. Mortgage in the amount of $70,500.00 given by Nickolas Bugosh to Members
First Federal Credit Union, dated October 7, 2003 and recorded October I7,
2003 in Mortgage Book 1841 Page 1922.
Complaint in mortgage foreclosure filed by Members First Federal Credit
Union as Plaintiff against Nickolas Bugosh, also known as Nicholas Bugosh,
as Defendant in the Office of the Prothonotary of Cumberland County to File
No. 2005-2458. Judgment in the amount of $73,063.62 entered November 9,
2005.
8. Mortgage in the amount of $19,798.00 given by Nickolas Bugosh to Members
First Federal Credit Union dated April 16, 2004 recorded April 22, 2004, in
Mortgage Book 1862, Page 349.
9. Delinquent real estate taxes turned over to the Cumberland County Tax Claim
Bureau in the amount of $1,247.21 at the time of the subject Sheriff sale.
10. Municipal lien in the amount of $710.76 entered by East Pennsboro Township
as Plaintiff against Nickolas Bugosh as Defendant, in the Office of the
Prothonotary of Cumberland County on February 6, 2006, to File No. 2006-
752.
11. Possible claim for Pennsylvania Department of Revenue for realty transfer tax
owed. Transfer dated April 28, 2000, and recorded May 1,2000, in Deed
Book 220, Page 248. Said deed recites a consideration of "EIGHTY
THOUSAND ($27,500.00) DOLLARS". Realty transfer tax was paid on
$27,500.00, but not on the stated consideration of $80,000.00.
12. Building and use restrictions set forth in instrument recorded in Deed Book
"Y," Volume 6, Page 99.
13. Under and subject to easement given by Enola Realty Company to Judson R.
Kurtz for utility easements and public railway service in public streets dated
October 3, 1905 and recorded October I I, 1905 in Deed Book "W," Volume 6,
Page 6.
14. Satisfactory evidence to be produced that proper notice was given to the
holders of all liens and encumbrances intended to be divested by subject
Sheriff Sale. It is to be noted that no notice appears to have been given to East
Pennsboro Township.
15. Real estate taxes accruing on and after July 1,2006 not yet due and payable.
It is to be noted that no search of Domestic Relations Records has been
made to determine support arrearages regarding House Bill 1412, Act 58
of 1997, nor has any search been made for environmental liens in Federal
District Court.
\~-J. ~
I
Ro6ert G. Frey, Agent
Note: This Title Report shall not be valid or i ing
until countersigned by an authorized signatory.
- .
C /- ~
ESTATE SALE NO. 45
N"n~lS8~
Members 1st Federal Credit Unton
va.
Nickolas Bugosh a/I,/a
Nicholas Bugosh
Atty.: Karl Ledebohm
EXHIBIT "A"
ALL THAT CERTAIN lot or piece
of ground with improvements there-
on erected sUuate In East Pennsboro
Township. Cumberland County I
Pennsylvania. bounded and described
In accordance with a survey made
by D.P. Raffensperger Associates.
Engineers and Surveyors, dated
February 4. 1980, as follows. to wit:
BEGINNING at a point on the
eastern side of Wyoming Avenue,
said point being referenced 460.00
feet In a southerly direction from
the Intersection of Wyoming Avenue
and Dauphin Street; thence along
the dividing line with property No.
144 Wyoming Avenue, North 79
degrees 40 minutes East, 188.07
feet to a point; thence South 02-
degrees 10 minutes 05 seconds
East 25.25 feet to a point; thence
along the dividing line with prop-
erty No. 140 Wyoming Avenue. and
through the center of a partition wall
and beyond. South 79 degrees 40
minutes West, 184.48 feet to a point
on the eastern side of said Wyoming
Avenue; thence North 10 degrees
20 minutes West 25.0 feet to a
point, the place of BEGINNING.
HAVlNG THEREON ERECTED a
dwelling house: known as 142 Wyo~
mlng Avenue.
BEING the same premises which
Nickolas Bugosh. single man and
Rebecca Ochs, single woman, by
their deed dated October 7. 2003
and recorded In the Cumberland
'<founty Recorder of Deeds Office in
peed Book 259. page 4696. granted
and conveyed unto Nickolas
Bugosh. Single man.
ALL THAT CERTAIN lot or piece of ground with improvements thereon erected situate
in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described
in accordance with a survey made by D.P. Raffensperger Associates, Engineers and
Surveyors, dated February 4, 1980, as follows, to wit:
BEGINNING at a point on the eastern side of Wyoming Avenue, said point being
referenced 460.00 feet in a southerly direction from the intersection of Wyoming Avenue
and Dauphin Street; thence along the dividing line with property No. 144 Wyoming
Avenue, North 79 degrees 40 minutes East, 188.07 feet to a point; thence South 02
degrees 10 minutes 05 seconds East 2525 feet to a point; thence along the dividing line
with property No. 140 Wyoming Avenue, and through the center of a partition wall and
beyond, South 79 degrees 40 minutes West, 18448 feet to a point on the eastern side of
said Wyoming Avenue; thence Narth 10 degrees 20 minutes West 250 feet to a point, the
place of BEGINNING
HAVING THEREON ERECTED a dwelling house known as 142 Wyoming Avenue
BEING the same premises which Nickolas Bugosh, single man and Rebecca Ochs, single
woman, by their deed dated October 7,2003 and recorded in the Cumberland County
Recorder of Deeds Office in Deed Book 259, page 4696, granted and conveyed unto
Nickolas Bugosh, single man.
EXHIBIT" A"
WRIT OF E~CUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N005-2458 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MEMBERS 1 ST FEDERAL CREDIT UNION Plaintiff (s)
From NICKOLAS BUGOSH a/k1a NICHOLAS BUGOSH ,142 Wyoming Avenue, Enola, PA
17025; and Nickolas Bugosh alkla Nicholas Bugosh, 4806 Virginia Road, Mechanicsburg, P A 17055.
(1) You are directed to levy upon the property of the defendant (s)and to sell All that certain tract of
ground together with improvements erected thereon situate in East Pennsboro Township,
Cumberland County Pennsylvania, known and numbered as 142 Wyoming Avenue, Enola, PA
17025 and as more particularly set fortb and described on Exhibit" A". 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 bas been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account ofthe defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant{s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due73,063.62 L.L.$.50
Interest from 5/6/05 at tbe rate of $11.6447 per day to be added
Atty's Comm % Due Prothy $1.00
Atty Paid $348.82 Other Costs
Plaintiff Paid
Date: December 7, 2005
(Seal)
By:
Deputy
REQUESTING PARTY:
Name Karl M. Ledebohm, Esq.
Address: P. O. Box 173
New Cumberland, PA 17070-0173
Attorney for: Plaintiff
Telephone: 717-938-6929
Supreme Court ill No. 59012
0, _. c' 3:i
.,J
~ i .
Real Estate Sale # 45
On December 12, 2005 the Sheriff levied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA
Known and numbered as 142 Wyoming Ave.,
Enola, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: December 12,2005
BY:J~~
Real Estate Sergeant
i(tl cd 9- 310 .
IIjj~\~~OjH1H;I~lN~lam
e
c;:j;}
i
I&iI
PR(JOF 01;' PUBLICATION OF NOTICE
1\ CUMBERLAND LAW JOURNAL
(Under ACI '\0.587, approved May 16, 1929), P. L.1784
STATE OFPENNSYLVAl\i \ :
ss.
COUNTY OF CUMBERLA '\i) :
Lisa Marie Coyne, F.;quire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly S\\ "'ll, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical publl,lled ill the Borough of Carlisle in the County and State aforesaid,
was established January 2. ~2, :llld de:;i;;nated by the lonl courts as the official legal
periodical for the publicatioll I! ,Illlc,;al notices, and has, sillecianuary 2, I952, been regularly
issued weekly in the said CUi,li:V, alld that the printed notice or publication attached hereto is
exactly the same as was prilll,'I! in the regular editions and iSSlles of the said Cumberland Law
Journal on the following datcc;
VIZ:
January 20,2". F'ebruary 3,2006
Affiant further depos, ,llat he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodic:" !IC gelleral circulation, and that he is not interested in the subject
matter of the aforesaid noli,' or advertisement, and that all allegations in the foregoing
statements as to time, pl:ice a. , ilaracter of publication are true.
~
S W RN TO AND Sl BSCRIBED before me this
__...l-day of _February, 2006
~~~~. ~&d~/v
.......--..J~~'Rt;~';". '''I
L 01" .IlSElk !
LOIS E. SNYDER, Notary Public I
Carlisle Boro. Cumberland COlintv
. .MY~~~i?~~!::~;::;:23:0i:C!,~
i< :'\ \ii1"' , .,Lk,_ ,
Il&AL DTAft MLB 1'10. 4lI
Writ No. 2005-2458 CMI
Members 1st Federal Credit Union
vs.
Nickolas Bugosh a/k/a
Nicholas Bugosh
Atty.: Karl Ledebohm
EXHIBIT "A"
ALL THAT CERTAIN lot or piece
of ground with improvements
thereon erected situate 1n East
, Pennsboro Township. Cumberland
. County, Pennsylvania. bounded and
deecrlbed In accordance with .. aur-
vey made by D.P. Raffenaperger
Aaaoclates, Engtneers and Survey-
ors, dated February 4. 1980. as
follows, to wit:
BEGfNNING at a point on the
eastern side of Wyoming Avenue.
said point being referenced 460.00
feet in a southerly direction from
the intersection of Wyoming Avenue
and Dauphin Street; thence along
the dMdtng line with property No.
144 Wyoming Avenue. North 79
degrees 40 minutes East. 188.07
feet to a point; thence South 02
degrees 10 minutes 05 seconds
East 25.25 feet to a point; thence
along the dividing l1ne with prop-
erty No. 140 Wyoming Avenue, and
through the center of a partition wall
and beyond, South 79 degrees 40
minutes West. 184.48 feet to a point
on the eastern side of said Wyoming
Avenue; thence North 10 degrees
20 minutes West 25.0 feet to a
point. the place of BEGINNING.
HAVING THEREON ERECTED a
dwe1l1ng house known as 142 Wyo-
ming Avenue.
BEING the same premises which
Nickolas Bugosh. single man and
Rebecca Ochs. single woman. by
their deed dated October 7, 2003
and recorded in the Cumberland
County Recorder of Deeds Office in
Deed Book 259. page 4696, granted
and conveyed unto Nickolas
Bugosh. sillgle man.
..
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16,1929
Conunonwealth ofpennsylvania, County of Dauphin} ss
Michael Morrow, being duly sworn according to law, deposes and says:
That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of
the Conunonwea1th 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 genera! 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 in the 24th and 31st day(s) of January and
the 7th day(s) of February 2006. That neither he nor said Company is interested in the subject matter of said
printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and' empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
S ALE #45
Sworn to and subscribed befo me
NOT PUBLIC
My conunission expires June 6, 2006
.
'i
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTIIOUSE
CARLISLE,PA.17013