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Home My WebLink About05-4835MkABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania P.O. BOX 8621 Elmhurst, IL 60126 V. Barry S. Nelson 1122 Fleetwood Drive Carisle, PA 17013 and Teresa K. Nelson 1122 Fleetwood Drive Carisle, PA 17013 and Randy Lee Goshorn 1122 Fleetwood Drive Carisle, PA 17013 Attorney for Plaintiff Cumberland County Court of Common Pleas ,P 3,g Number Q s _ )/ CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 AVISO Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPA7 DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 215 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Cumberland County Beneficial Mortgage Company of Pennsylvania Court of Common Pleas P.O. Box 8621 Elmhurst, IL 60126 V. Barry S. Nelson 1122 Fleetwood Drive Carisle, PA 17013 and Teresa K. Nelson 1122 Fleetwood Drive Number OS P3S Carisle, PA 17013 and Randy Lee Goshorn 1 122 Fleetwood Drive Carisle, PA 17013 CIVIL ACTION/MORTGAGE FORECLOSURE 01 L? , LL Ea-kl I 1. Plaintiff is Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, a corporation duly organized under the laws of Pennsylvania and doing business at the above captioned address. 2. The Defendant is Barry S. Nelson, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last-known address is 1122 Fleetwood Drive, Carisle, PA 17013. 3. The Defendant is Teresa K. Nelson, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 1122 Fleetwood Drive, Carisle, PA 17013. 4. The Defendant is Randy Lee Goshorn, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 1122 Fleetwood Drive, Carisle, PA 17013. 5. On 05/28/2002, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book1760, Page 617. 6. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 34 East Street, Mount Holly Springs, PA 17065. 7. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/03/2005 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 8 9 The following amounts are due on the mortgage: Principal Balance Interest through 07/29/2005 (Plus $ 13.55 per diem thereafter) Attorney's Fee Corporate Advance Cost of Suit Appraisal Fee Title Search $ 46,969.06 $ 3,591.96 $ 2,348.45 $ 312.55 $ 225.00 $ 125.00 $ 200.00 GRAND TOTAL $ 53,772.02 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriffs Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $53,772.02, together with interest at the rate of $13.55 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. TERRENCE J. cCABE, ESQUIRE Attorney for P1 intiff VERIFICATION The undersigned, Terrence J. McCabe, Esquire, hereby certifies that he is the Attorney for the Plaintiff in the within action, and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. Terrence J. McCab '42 nflY e9 711715 MORTGAGE CJ IF BOX IS CHECKED, THIS MORTGAGE IS AN SECURES FUTURE ADVANCES. 0zletE F DEF S 0"ry- PA. P8-1213 OPEN-END MORTG.,lgE AND THIS MORTGAGE is made this day 28TH of MAY 2002 , between the Mortgagor, THERESA K NELSON AND RANDY LEE GOSHORN AND 13ARRY S NELSON therein torrower -l ana mortgagee UMF ICI AL °CUMI' MER D lSGUUNT CUMPANY DIB/A BENEFICIAL MORTGAGE CO'OF PENNSYLVANIA , a corporation organized an existing under the laws of PENNSYLVANIA , whose address is 419 STONEHEDGE -DR WE-, SUITE 2; CAR A 17013 -- (herein "Lender"). The following paragraph preceded by a checked box is applicable. F-7-1 I WHEREAS, Borrower is indebted to Lender in the principal sum of $ 52,829.43 i , evidenced by Borrower's Loan Repayment and Security Agreement or., Secondary Mortgage an Agreement dated MAY 28, 2002 and any extensions .or renewals thereof (hdrrein "Note"), providing or monthly installments o principal and interest, including, any adjustments to the amount of payments or the contract rate if that rate is variable, with the balance-ol'-the indebtedness, if not sooner paid, due and payable on - MAY 28 , 2017 a WHEREAS, Borrower is indebted to Lender in the principal sum of $ or so much thereof as "may be advanced pursuant to Borrower's Revolving Loan Agreement aced and extensions and renewals thereof (herein "Note"), providing for monthly installments, and interest at the rate and under the terms specified in the Note, including any adjustments in the interest rate if that rate is variable, and providing for a credit limit stated in the principal sum above and an initial advance of $ ; TO SECURE to Lender the repayment of (1) the indebtedness evidenced by the Note, with interest thereon, including any increases if the contract rate is variable; (2) future advances under any Revolving Loan Agreement; (3) the payment of all other sums, with interest thereon, advanced in accordance herewith to protect the security. of-this Mortgage;-and-(4)-the performance-of the covenants- and agreements of Borrower herein contained, Borrower does hereby mortgage, grant and convey to Lender and Lender's successors and assigns the following described property located in the County of CUMBERLAND Commonwealth of Pennsylvania: ALL THAT CERTAIN PROPERTY SITUATED IN THE BOROUGH OF MT HOLLY SPRINGS IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA,BEING MORE FULLY DESCRIBED IN A DEED DATE 06106/1996 AND RECORDED 07/29/1996,AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN DEED VOLUME 143 04.291 ?G 412. TAX MAP OR PARCEL ID NO.: 23-32-2338-021A Pa0012e1 ??Illll IQ16d II ? ?? I(nli III I? ?? IRII tl?l??? YY 1!!I UW ilk 111Y i11111f W(Ilu ?Iffl?dH VIII ? ?11 ?? *IV051D8689B95MTGB000PA0012B1ONgNELSON ORIGINAL Exhibit A W-147 6 0-PG 0'6.1.7 yi -2- TOGETHER with all the improvements now or hereafter erected on the property, and all easements, rights, appurtenances and rents, all of which shall be deemed to be and remain a part of the property covered by this Mortgage; and all of the foregoing, together with said property (or the leasehold estate if this Mortgage is on a leasehold) are hereinafter referred to as the "Property." Borrower covenants that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property, and that the property is unencumbered, except for encumbrances of record. Borrower covenants that Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to encumbrances of record. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal and Interest at Variable Rates. This mortgage secures all payments of principal and interest due on a variable rate loan. The contract rate of interest and payment amounts • -may-be-subject-to-change-as-provided-in-the-Note-Borrowers shall-promptly-pay-whewdue-all amounts-' --- required by the Note. 2. Funds for Taxes and Insurance. Subject to applicable law and only if requested in writing by Lender, Borrower shall pay to Lender on the day monthly payments of principal and interest are payable under the Note, until the Note is paid in full, a sum (herein "Funds") equal to one-twelfth of the yearly taxes and assessments (including condominium and planned unit development assessments, if any) which may attain priority over this Mortgage and ground rents on the Property, if any, plus one-twelfth of yearly premium installments for hazard insurance, plus one-twelfth of yearly premium installments for mortgage insurance, if any, all as reasonably estimated initially and from time to time by Lender on the basis of assessments and bills and reasonable estimates thereof. Borrower shall not be obligated to make such payments of Funds to Lender to the extent that Borrower makes such payments to the holder of a prior mortgage or deed of trust if such holder is an institutional lender. If Borrower pays Funds to Lender, the Funds shall be held in an institution the deposits or accounts of which are insured or guaranteed by a Federal or state agency (including Lender if Lender is such an institution). Lender shall apply the Funds to pay said taxes, assessments, insurance premiums and ground rents. Lender may not charge for so holding and applying the Funds, analyzing said account or verifying and compiling said assessments and bills, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make such a charge. Borrower and Lender may agree in writing at the time of execution of this Mortgage that interest on the Funds shall be paid to Borrower, and unless such agreement is made or applicable law requires such interest to be paid, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds showing credits and debits to the Funds and the purpose for which each debit to the Funds was made. The Funds are pledged as additional security for the sums secured by - - -this-Mortgage, If the amount of the Funds held by Lender, together with the future monthly installments of ds- _ { payable prior to the due dates of taxes, assessments, insurance premiums and ground rents, shall exceed the amount required to pay said taxes, assessments, insurance premiums and ground rents as they fall due, such excess shall be, at Borrower's option, either promptly repaid to Borrower or credited to Borrower on monthly installments of Funds. If the amount of the Funds held by Lender shall not be sufficient to pay taxes, assessments, insurance premiums and ground rents as they fall due, Borrower shall pay to Lender any amount necessary to make up the deficiency in one or more payments as Lender may require. Upon payment in full of all sums secured by this Mortgage, Lender shall promptly refund to Borrower any funds held by Lender. If under paragraph 17 hereof the Property is sold or the Property 04-29-02 MTG I ????WIIWi1tYY1NUgWl?????????????¦??A????? XN0510868989SWOB000PA0012620%xNELSON * ORIGINAL PA0012B2 BKI 76OPGO6 18 -3- is otherwise acquired by Lender, Lender shall apply, no later than- immediately prior to the sale of the Property or its acquisition by Lender, any Funds held by Lender at the time of application as a credit against the sums secured by this Mortgage. 3. Application of Payments. Except for loans made pursuant to the Pennsylvania Consumer Discount Company Act, all payments received by Lender under the Note and paragraphs 1 and 2 hereof shall be applied,by Lender first in payment of amounts payable to Lender by Borrower under paragraph 2 hereof, then to interest, and then to the principal. 4, Prior Mortgages and Deed of Trust; Charges; Liens. Borrower shall perform all of Borrower's obligations under any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage, including Borrower's covenants to make payments when due. Borrower shall pay or cause to be paid all taxes, assessments and,other charges, fines and impositions attributable to the Property which-may attain a-priority over-this Mortgage; and:leasehold•payments or-ground rents, if any. 5. Hazard Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and such other hazards as Lender may require. The insurance carrier providing the insurance shall be chosen by the Borrower subject to approval by Lender; provided, that such, approval shall not be unreasonably withheld. All insurance policies and renewals thereof shall be in a form acceptable to Lender and shall include a standard mortgage clause in favor of and in a form acceptable to Lender. Lender shall have the right to hold the policies and renewals thereof, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage. In the event of loss, Borrower shall give.prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. If the Property is abandoned by Borrower, or if Borrower fails to respond to Lender within 30 days from. the date notice is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for insurance benefits, Lender is authorized to collect and apply the insurance proceeds at Lender's option either to restoration or repair of the Property or to the sums secured by this Mortgage. 6. Preservation and Maintenance of Property; Leaseholds; Condominiums; Planned Unit Developments. Borrower shall keep the Property in good repair and shall not commit waste or permit impairment or deterioration of the Property and shall comply with the provisions of any lease if this Mortgage is on a leasehold, If this Mortgage is on a unit in a condominium or a planned unit development, Borrower shall perform all of Borrower's obligations under the declaration or covenants creating or governing the condominium or planned unit development, the . by-laws and regulations of the condominium or planned unit development, and constituent documents._ =- 7. Protection" of L'endcr's`Se`cuiitq.'If Borrower fails_fo perform the covenants and agreements contained in this Mortgage, or if any action or proceeding is commenced which materially affects Lender's interest in the Property, then Lender, at Lender's option, upon notice to Borrower, may make such appearances, disburse such sums, including reasonable attorneys' fees, and take such action as is necessary to protect Lender's interest. Any amounts disbursed by Lender pursuant to this paragraph 7, with interest thereon, at the contract rate, shall become additional indebtedness of Borrower secured by this Mortgage. Unless Borrower and Lender agree to other terms of payment, such amounts shall be payable upon notice from Lender to Borrower requesting payment thereof. Nothing contained in this paragraph 7 shall require Lender to incur any expense or take any action hereunder. 04-29-02 WG PA0012133 "NO51D8689995MT08000PA0012830""NELSON ORIGINAL nul -7 &0A 0 6-19-1- h -4- 8. Inspection. Lender may take or cause to be made reasonable entries upon and inspections of the Property, provided that Lender shall give Borrower notice prior to any such inspection specifying reasonable cause therefor related to Lender's interest in the Property. 9. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of the Property, or part thereof, or for conveyance in i ieu of condemnation, are hereby assigned and shall be paid to Lender, subject to the terms of any mortgage, deed of trust or other security agreement with alien which has priority over this Mortgage. 10. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Mortgage granted by Lender to any successor in interest of Borrower shall not operate to release, in any manner, the liability of the original Borrower and Borrower's successors in interest. Lender shall not be required to commence proceedings agaihst'sucli successor 'or refuse fo'dxterid'ti`m`efor'payment'or otherwise modify 1hi6ftiiati5fi-of the sums secured by this Mortgage by reason of any demand made by the original Borrower and Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy hereunder, or otherwise afforded by applicable law, shall not be a waiver of or preclude the exercise of any such right or remedy. 11. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements herein contained shall bind, and the rights hereunder shall inure to, the respective successors and assigns of Lender and Borrower, subject to the provisions of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint and several. Any Borrower who co-signs this Mortgage, but does not execute the Note, (a) is co-signing this Mortgage only to mortgage, grant and convey that Borrower's interest in the Property to Lender under the terms of this Mortgage, (b) is not personally liable on the Note or under this Mortgage, and (c) agrees that Lender and any other Borrower hereunder may agree to extend, modify, forbear, or make any other accommodations with regard to the terms of this Mortgage or the Note without that Borrower's consent and without releasing that Borrower or modifying this Mortgage as to that Borrower's interest in the Property. 12. Notice. Except for any notice required under applicable law to be given in another manner, (a) any notice to Borrower provided for in this Mortgage shall be given by delivering it or by mailing such notice by certified mail addressed to Borrower at the Property Address or at such other address as Borrower may designate by notice to Lender as provided herein, and (b) any notice to Lender shall be given by certified mail to Lender's address stated herein or to such other address as Lender may designate by notice to Borrower as provided herein. Any notice provided for in this Mortgage shall be deemed to have been given to Borrower or Lender whengiven in the manner designated herein. 13. Governing Law; Severability. The applicable law contained in the Note shall control. Where no applicable law is contained therein, the state and local laws applicable to this Mortgage shall be the laws of the - r • jurisdiction-in.,which the-Property-is. located._The.foregoing sentence shall not limit the applicability of Federal law to this Mortgage. In the event that any provision or clause of ibis Mortgage or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Mortgage or the Note which can be given effect without the conflicting provision, and to this end the provisions of this Mortgage and the Note are declared to be severable. As used herein, "costs," "expenses" and "attorneys' fees" include all sums to the extent not prohibited by applicable law orlimited herein. 14. Borrower's Copy. Borrower shall be furnished a conformed copy of the Note and of this Mortgage at the time of execution or after recordation hereof. 15. Rehabilitation Loan Agreement. Borrower shall fulfill all of Borrower's obligations under any home rehabilitation, improvement, repair, or other loan agreement which Borrower enters into with Lender. Lender, at Lender's option, may require Borrower to execute and deliver to Lender, in a form acceptable to Lender, an assignment of any rights, claims or defenses which Borrower may have against orservicesinci ?4 2 02hMTGu I labor m law 11 111 111IN pePA 110IZB4 KNO5108689895MTG8000PA0012940xmNELSON " ORIGINAL ,? Bk?-17 6,0.- PG-0620` Y' -5- 16. Transfer of the Property. -If Borrower sells or transfers all or any. part of the- Property or an interest therein, excluding (a) the creation of*a lien or encumbrance subordinate to this Mortgage, (b) a transfer by devise, descent, or by operation of law upon the death of a joint tenant, (c) the grant of any leasehold interest of three years or less not containing an option to purchase, (d) the creation of a purchase money security interest for household appliances, (e) a transfer to a relative resulting from the death of a Borrower, (f) a transfer where the spouse or children of the Borrower become an owner of the property, (g) a transfer resulting from a decree of dissolution of marriage, legal separation agreement, or from an incidental property settlement agreement, by which the.spouse of the Borrower becomes an owner of the property, (h) a transfer into an inter vivos trust in which the Borrower is and remains a beneficiary and which does not relate to a transfer of rights of occupancy in the property, or (i) any other transfer or disposition described •in'regulations prescribed by the Federal,-Home Loan Bank Board; -Borrower shall cause- to.-be submitted information required by Lender to evaluate the transferee as if a new loan were being made to the transferee. Borrower will continue to be obligated under the Note and this Mortgage unless Lender releases Borrower in writing. If Lender does not agree to such sale or transfer, Lender may declare all of the sums secured by this Mortgage to be immediately due and payable. If Lender exercises such option. to accelerate, Lender shall mail Borrower notice of acceleration in accordance with paragraph 12 hereof. Such notice shall provide a period of not less than 30 days from the date the notice is mailed or delivered within which Borrower may pay the sums. declared due. If Borrower fails to pay such sums prior to the expiration of such period, Lender may, without further notice or demand on Borrower, invoke any remedies permitted by paragraph 17 hereof. NONUNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Acceleration; Remedies. Except as provided in paragraph 16 hereof, upon Borrower's breach of any covenant or agreement of Borrower in this Mortgage, including the covenants to pay when due any sums secured by this Mortgage, Lender prior to acceleration shall give notice to Borrower as provided in paragraph 12 hereof specifying: (1) the breach; (2) the action required to cure such breach; (3) a date, not less than 30 days from the date the notice is mailed to Borrower, by which such breach must be cured; and (4) that failure to cure such breach on or before the date specified in the notice may result in acceleration of the sums secured by this Mortgage, foreclosure by judicial proceeding, and sale of the Property. The notice shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the nonexistence of a default or any other defense of Borrower to acceleration and foreclosure. If the breach is not cured on or before the date specified in the notice, Lender, at Lender's option, may declare all of the sums secured by this Mortgage"t`"be imrriediatcly due and payable without further demand and may foreclose this Mortgage by judicial proceeding. Lender shall be entitled to collect in such proceeding all expenses of foreclosure, including, but not limited to, reasonable attorneys' fees and costs of documentary evidence, abstracts and title reports. 18. Borrower's Right to Reinstate. Notwithstanding Lender's acceleration of the sums by this Mortgage due to Borrower's breach, Borrower shall have the right to have any proceedings begun by Lender to enforce this Mortgage discontinued at any time prior to entry of a judgment enforcing this Mortgage if: (a) Borrower pays Lender all sums which would be then due under this Mortgage and the Note had no acceleration occurred; (b) Borrower cures all breaches of any other covenants or 04-29-02 MTG PA001285 xN051D8SB9B95MTG8000PAG012BSONKNELSON ORIGINAL t? 4 4; ? ,, f r BW 1`- 7 6--O-PG 0 6-21' -6- agreements of Borrower contained in this Mortgage; (c) Borrower pays all reasonable expenses incurred by Lender in enforcing the covenants and agreements of Borrower contained in this Mortgage, and in enforcing Lender's remedies as provided in paragraph 17 hereof, including, but not limited to, reasonable attorneys' fees; and (d) Borrower takes such action as Lender may reasonably require to assure that the lien of this Mortgage, Lender's interest in the Property and Borrower's obligation to pay the sums secured by this Mortgage shall continue unimpaired. Upon such payment and cure by Borrower, this Mortgage and the obligations secured hereby shall remain in full force and effect as if no acceleration had occurred. 19. Assignment of Rents; Appointment of Receiver. As additional security hereunder, Borrower hereby assigns to Lender the rents of the Property, provided that Borrower shall, prior to acceleration under paragraph 17 hereof, in abandonment of the Property, have the right to collect and ` -retain suchfents as they become due and payable. --- "' -` - " ' 4 - - "' .. Upon acceleration under paragraph 7 hereof or abandonment of the Property, Lender shall be entitled to have a receiver appointed by a court to enter upon, take possession of and manage the Property and to collect the rents of the Property including those past due. All rents collected by the receiver shall be applied first to payment of the costs of management of the Property and collection of rents, including, but not limited to, receiver's fees, premiums on receiver's bonds and reasonable attorneys' fees, and then to the sums secured by this Mortgage. The receiver shall be liable to account only for those rents actually received. 20. Release. Upon payment of all sums secured by this Mortgage, Lender shall release this Mortgage without charge to Borrower. Borrower shall pay all costs of recordation, if any. 21. Waiver of Homestead. Borrower hereby waives all right of homestead exemption in the Property under state or Federal law. 22. Interest Rate After Judgment. Borrower agrees the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate stated in the Note. 23. Arbitration Rider to Note. The Arbitration Rider attached to and made a part of the Note is hereby incorporated by reference and made a part of this Mortgage. 04-29-02 MTc ? ? ???11(?III ?uI1??? Iii 1?1?N???IINY?II?IWd f1?N PA0012BS *N051086B9B95M7G8000PA0012060'V*NELSON " ORIMAL BK;I76O.PG062:2 ?.? 1; -7- REQUEST. FOR NOTICE OF DEFAULT AND FORECLOSURE UNDER SUPERIOR MORTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, deed of trust or other encumbrance with a lien which has priority over this Mortgage to give Notice to Lender, at Lender's address set forth-on page one of this Mortgage, of any default under the superior encumbrance and of any sale or other foreclosure action. & JHHEERESA K NELSOI ae AL RANDY LEE GOSHORN -Borrower BARRY NELSON -Borrower -I hereby certify that the precise address of the Lender (Mortgagee) is: 419 STONEHEDGE DRIVE SUITE 2, CARLISLE, PA. 17013 On behalf of the Lender. By: 11 Title: BSM COMMONWEALTH OF PENNSYLVANIA, CURTIS A WERNER County ssCUMBERLAND I, NANCY J. DITZEL a Notary Public in and for said county and state, do hereby Cent y that FvFCe Y ,vFT SON RANDY LEE -OSHORN AND BARRY S NF T OX .. personally known to me to be the same persons whose names ARE subscribed to the foregoing instrument, appeared before me this day in person, and acknow edge that T hey signed and delivered the said instrument as THEIR free voluntaryact, for the uses and purposes therein set forth. Given under my hand and official seal, this 28TH _da of MAY , 2002 lIIO ARK-.8FJH. 1iAMd [NT?F1.1' *OY IDCW* som J 1440tary Pu This instrument was prepared by: - BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/ B17NEVICIAT MORTGAGE CO- Or ANIA (Name) I Certi this to be record4l STONEHEDGE DRIVE SUITE 2 pj&L PA. Lj013 In Cumberland County PA (Address) ,.Be1q?IJT1rc,9r and Recorder) J//??rr?r Wtt'urr`n'T?o: Records Processing Services 04-29-02 MTG 577 Lamont Road PA0012B7 ,,,, lm urst, IL 60126 1110 1111611 NINE MCA 11101111111111lull NN051DBBB9B95MTGB000PA0012B70""NELSON • ORIGINAL g 41 -7 6 p:PG::O 62:3 Ur? 7, jr, -o d `} N ?n r 7Q Cl =?c t SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-04835 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS NELSON BARRY S ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT NELSON BARRY S but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT , NELSON BARRY S 1122 FLEETWOOD DRIVE PA 17013 DEFENDANT WAS SERVED AT MT HOLLY ADDRESS Sheriff's Costs: So answer Docketing 6.00 Service 5.60 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 26.60 MCCABE WEISBERG CONWAY 09/29/2005 Sworn and subscribed to b fore me this iQ day of A.D. Pr one SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-04835 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS NELSON BARRY S ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT NELSON TERESA K but was unable to locate Her in his bailiwick COMPLAINT - MORT FORE , He therefore returns the NOT FOUND , as to the within named DEFENDANT NELSON TERESA K 1122 FLEETWOOD DRIVE CARLISLE, PA 1 DEFENDANT WAS SERVED AT MT HOLLY ADDRESS. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 So answergL; R, Thomas Kline Sheriff of Cumberland County MCCABE WEISBERG CONWAY 09/29/2005 Sworn and subscribed to before me this day of (JU A.D. Prbthorffotar?y SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-04835 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS NELSON BARRY S ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GOSHORN RANDY LEE but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT GOSHORN RANDY LEE 1122 FLEETWOOD DRIVE CARLISLE, PA 17013 DEFENDANT WAS SERVED AT MT HOLLY ADDRESS. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 So answers: r R. Thomas Kline Sheriff of Cumberland County MCCABE WEISBERG CONWAY 09/29/2005 Sworn and ?s?ubscribed to before me this q-?-fn day of A.D. Prothonotary-r- SHERIFF'S RETURN - REGULAR CASE NO: 2005-04835 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS NELSON BARRY S ET AL SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon NELSON BARRY S the DEFENDANT , at 1510:00 HOURS, on the 27th day of September, 2005 at 34 EAST STREET MT HOLLY SPRINGS, PA 17065 by handing to TERESA NELSON, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.00 Affidavit .00 Surcharge 10.00 .00 32.00 Sworn and Subscribed to before me this ( 4 day of OS A.D. Pr n tary So Answers: ?P R. Thomas Kline 09/29/2005 MCCABE WEISBER/G CONWAY By: k _ . Deputy Sheri SHERIFF'S RETURN - REGULAR CASE NO: 2005-04835 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FILIAL CONSUMER DISCOUNT VS NELSON BARRY S ET AL SHANNON SHERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon NELSON TERESA K the DEFENDANT , at 1510:00 HOURS, on the 27th day of September, 2005 at 34 EAST STREET MT HOLLY SPRINGS, PA 17065 by handing to TERESA NELSON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 2I day of .L iJj' A . D . Prothonotary So Answers: R. Thomas Kline 09/29/2005 MCCABE WEISBERG CONWAY By: Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2005-04835 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS NELSON BARRY S ET AL SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GOSHORN RANDY LEE the DEFENDANT , at 1510:00 HOURS, on the 27th day of September, 2005 at 34 EAST STREET MT HOLLY SPRINGS, PA 17065 by handing to TERESA NELSON, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00 09/29/2005 MCCABE WEISBERG CONWAY Sworn and Subscribed to before By: i 41 me this day of eputy Sh %f 5 D. rotho ry McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randy Lee Goshom Cumberland County Court of Common Pleas Number 05-4835 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $53,772.02 Interest from 7/30/05 - 10/31/05 $ 1,273.70 TOTAL $55,045.72 TERRENCE J. MCCABE, ESQUIRE AND NOW, this d day of +\j o ?. , 2005, Judgment is entered in favor of Plaintiff, Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania and against Defendant(s) Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn and damages are assessed in the amount of $55,045.72, plus interest and costs. BY THE PROTHONOTARY: n ? 'll C.77 V-5 5-' 1 -13? f. rn : v h% s 1 VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attomcy for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unswom falsification to authorities. / w -c?LV7c.-!i TERRENCE J. McCABE, ESQUIRE IVIcCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND: The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant(s), Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn, are over eighteen (18) years of age, and resides at 34 East Street, Mt. Holly Springs, PA 17065. SWORN TO AND SUBSCRIBED BEFOREMETHIS 31st DAYOF Oct.. 2005. t„ 1? OTAPY PUBLIC TERRENCE J. MGCABE, ESQUIRE Attorney for Plaintiff 61 -_!j Z- t,Gr! ?C?1 nz 11C:' {i!"a d :Hl a0, McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/h/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Cumberland County Court of Common Pleas Number 05-4835 CERTIFICATION I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the Complaint and is calculable as a sum certain from the Complaint. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. A true and correct copy of the notice pursuant to Pennsylvania Rule of Civil Procedure No. 237.1 is attached hereto and marked Exhibit "A". SWORN TO AND SUBSCRIBED BEFORE ME THIS 31st DAY OF Oct.. 2005. ARY PUBLIC t r -?- TERRENCE J. Mc ABE, ESQUIRE Attorney for Plaintiff (t n !` -?:a?n? b :4 Vol Z- t':1 d S0?? d "q-C:' 1LU ?G ?w,?_!C--qA Ili OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary October 18, 2005 To: Barry S. Nelson 34 East Street Mount Holly Springs, PA 17065 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshom Cumberland County Court of Common Pleas Number 05-4835 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINSTYOU WITHOUTA HBARINGAND YOU MAY LOSE YOURPROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE, A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT' AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE, TRIBUNAL SUS DEFENSAS U OBIECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DFNTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGONA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECIOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA TO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTEDNO PUEDE PROPORCIONAR PARA EMPLEAR ON ABOGADO, ESTA OFICINAA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMAC16N ACERCA DE LAS AGENCI AS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONOR-AGO. f - t Cumberland County Bar Association I !9 1 2 Liberty Avenue y A Carlisle, PA, 17013 Y% / I 800-990-9108 I/ (I? v Terrence J. McCabe, Esquire Attorney for Plaintiff McCABE, WEISBERG & CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 TJM/cmo OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary October 18, 2005 To: Teresa K. Nelson 34 East Street Mount Holly Springs, PA 17065 Cumberland County Court of Common Pleas Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania YS. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshom Number 05-4835 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO EN"rER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A ON ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A ON ABOGADO. SI USTED NO PUEDE PROPORCIONAR PAR_A EMPLEAR UN ABOGADO, ESTA OFICIN.A PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN ON HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland Countv Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 Terrence J. McCabe, Esquire Attorney for Plaintiff McCABE, WEISBERG & CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 TJM/cmo OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary To: Randy Lee Goshom 34 East Street Mount Holly Springs, PA 17065 October 18, 2005 Cumberland County Court of Common Pleas Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshorn Number 05-4835 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINS r YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOG.ADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO OF DIEZ (10) DIAS DB LA FECHA DE ESTA NOT'IFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA C-ICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLE.AR A UN ABOGADO. ST USTEDNO PUEDE PROPORCIONAR PARA EMPLEARUNABOGADO, ESTA OFICINA PUEDE SER CAPAZ OF. PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIES QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County But Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 Terrence J. McCabe, Esquire Attorney for Plaintiff McCABE, WEISBERG & CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 TJM/cmo 1-4 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Barry S. Nelson 34 East Street Mt. Holly Springs, PA 17065 Beneficial Consumer Discount Company dib/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. CtYrtis?_ . Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession if you have any questions concerning this Judgment, please call Terrence J. McCabe. Esquire at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Teresa K. Nelson 34 East Street Mt. Holly Springs, PA 17065 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randy Lee Goshom Cumberland County Court of Common Pleas Number 05-4835 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. urtis R, g Prothonotary -K Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe. Esquire at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Randy Lee Goshorn 34 East Street Mt. Holly Springs, PA 17065 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. C rtis R.?ng i Prothonotary A Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe. Esquire at (215) 790-1010. LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE BOROUGH OF MOUNT HOLLY SPRINGS, CUMBZRLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A PLAN PREPARED BY EUGENE ALBERT HOCKENSMITH, R.P.L.S, DATED JUNE 30, 1992 AND RECORDED IN PLAN BOOK 65, PAGE 48 OF THE CUMBERLAND COUNTY RECORDER OF DEEDS OFFICE, DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN SET ON PRIVATE EASEMENT AND 15 FOOT RIGHT OF WAY, SAID POINT SET ON WESTERN EDGE OF LOT NO. 2 AS SET FORTH ON SAID PLAN; THENCE ALONG LOT NO. 2, SOUTH 43 DEGREES 52 MINUTES 12 SECONDS EAST 113.25 FEET TO AN IRON PIN; THENCE ALONG LOT NO. 3, SOUTH 39 DEGREES 41 MINUTES 04 SECONDS WEST 74.50 FEET TO AN IRON PIN SET; THENCE ALONG LANES OF HARRY E. GOSHORN, NORTH 48 DEGREES 51 MINUTES 04 SECONDS WEST 106.00 FEET TO AN IRON PIN SET; THENCE ALONG PRIVATE EASEMENT AND RIGHT OF WAY, NORTH 34 DEGREES 08 MINUTES 06 SECONDS EAST 15.00 FEET, TO THE PLACE OF BEGINNING. BEING KNOWN AS 34 East Street, Mt. Holly Springs, PA 17065 Being the same premises which Dennis R. Goshorn and Janet L. Hopple, Executors of the Last Will and Testament of Minerva Grace Goshorn, by deed dated the 6/6/1996, and recorded 6/29/1996 in the Office of the Recorder in and for Cumberland County in Deed Book 143, Page 412, granted and conveyed to Barry S. Nelson. Teresa K. Nelson and Randy Lee Goshom, in fee. TAX MAP PARCEL NUMBER: 23-32-2338-021A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. FILE NO.: 05-4835 Civil Term AMOUNT DUE: $55,045.72 Barry S. Nelson Teresa K. Nelson Randy Lee Goshom TO THE PROTHONOTARY OF SAID COURT: INTEREST: from 11/1/05 - 3/8/06 $1,158.40 at $9.05 Per Diem ATTY'S COMM.: COSTS: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding tiled pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 34 East Street Mt Holly Shrines PA 17065 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named gamishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: 31 o5 Signature: i Lwyt w ,Q z4r ?. Print Name: TERRENCE J. McCABE, ESQUIRE Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attomey for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 v i it CD 0 ,Q McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshorn Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 05-4835 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 1, Terrenec J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 34 East Street, Mount Holly Springs, PA 17065 (Tax Parcel #23-32- 2338-021 A), a copy of the description of said property is attached hereto and marked as Exhibit "A." 1. Name and address of Owners or Reputed Owners: Name Barry S. Nelson Address 34 East Street Mount Holly Springs, PA 17065 Teresa K. Nelson RLmdy Lee Goshorn 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 3. 4. Name and address of Defendants in the judgment: Name Address Barry S. Nelson 34 East Street Mount Holly Springs, PA 17065 Teresa K. Nelson 34 East Street Mount Holly Springs, PA 17065 Randy Lee Goshorn 34 East Street Mount Holly Springs, PA 17065 Name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Beneficial Consumer Discount Company d/bla Beneficial Mortgage Company of Pennsylvania Address 419 Stonehedge Drive Suite 2 Carlisle, PA 17019 P.O. Box 8621 Elmhurst, IL 60126 Attn: Al Spears 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 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: Name Address Tenants 34 East Street, Mount Holly Springs, PA 17065 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 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. October 31, 2005 DATE TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff c? ? a n c ? ( ???? CJ ? 'r r ? (ilk w, N ? ?? ?? .:: ? v<7 L C"1 ? : G.) :i ? ? - ) tom? G O McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randy Lee Goshom Cumberland County Court of Common Pleas Number 05-4835 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barry S. Nelson Teresa K. Nelson Randy Lee Goshom 34 East Street Mt, Holly Springs, PA 17065 Your house (real estate) at 34 East Street, Mt. Holly Springs, PA 17065 (Tax Parcel #23- 32-2338-021A) , is scheduled to be sold at Sheriffs Sale on March 8, 2006 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $55,045.72 obtained by Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania 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: The sale will be canceled if you pay to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 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 Terrence J. McCabe, Esquire at (215) 790-1010. 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. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 l C: cry ? ? 1 { l 4 S f- 1 LJ ro STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR ATTORNEY I.D. NO: 66287 PLAINTIFF KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 WEST MAIN STREET P.O. BOX 29 LANSDALE,PA TELEPHONE: (; 19446-0029 15) 855-9521 COURT OF COMMON PLEAS CUMBERLAND COUNTY CENTRAL PENN PROPERTY SERVICES, INC. 100 S. 7th Street Akron, PA 17501, Plaintiff, V. THOMAS J. SCHRENK, JOAN SCHRENK and ANY AND ALL UNKNOWN OCCUPANTS 4 Plainview Road Camp Hill, PA 17013 Defendants. NO: 05-5001 PRACEIPE FOR ENTRY OF JUDGMENT BY DEFAULT TO THE PROTHONOTARY: Kindly enter judgment in ejectment in favor of Plaintiff and against Defendants for possession of 4 Plainview Road, Camp Hill, PA 17013 for failure to answer the complaint in ejectment in the time permitted by law. Respectfully bmitted, By: A/ `' Stephen ladik, Esquire Date: ??O? AND NOW, this 7-?k day of ,? ?rv ???r,? fl2 2005, upon filing of a Praeclpe for Entry of Default Judgment, judgment for possession of 4 Plainview Road, Camp Hill, PA 17013 is hereby entered against Defendant. // Proth otary STEPHEN M. HLADIK, ESQUIRE I.D. NO: 66287 PLAINTIFF KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 WEST MAIN STREET P.O. BOX 29 LANSDALE, PA 19446-0029 TELEPHONE: (215) 855-9521 CENTRAL PENN PROPERTY SERVICES, INC. 100 S. 7th Street Akron, PA 17501, Plaintiff, V. THOMAS J.SCHRENK, JOAN SCHRENK and ANY AND ALL UNKNOWN OCCUPANTS 4 Plainview Road Camp Hill, PA 17013 Defendants. ATTORNEYS FOR ATTORNEY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5001 CERTIFICATE OF SERVICE Stephen M. Hladik, Esquire, hereby certifies he served a true and correct copy of the Praecipe to Enter Defaul Judgment in the above-captioned matter by first class mail, postage prepaid on 1.13 , upon the parties listed below: Thomas J. Schrenk 4 Plainview Road Camp Hill, PA 17013 Joan Schrenk 4 Plainview Road Camp Hill, PA 17013 Any and All Unknown Occupants 4 Plainview Road Camp Hill, PA 17013 By: Stephen . Hladik, Esquire Attornety f 4r Plaintiff STEPHEN M. HLADIK, ESQUIRE ATTORNEY I.D. NO: 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 WEST MAIN STREET P.O. BOX 29 LANSDALE PA 19446-0029 TELEPHONE: (215) 855-9521 CENTRAL PENN PROPERTY SERVICES, INC. 100 S. 7th Street Akron, PA 17501, Plaintiff, ATTORNEYS FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: OS' 500 V. THOMAS J. SCHRENK, JOAN SCHRENK and ANY AND ALL UNKNOWN OCCUPANTS 4 Plainview Road Camp Hill, PA 17013 Defendants. AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA COUNTY OF LANCASTER s.s.: THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above named Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Thomas J. Schrenk Age: Over18 Residence: 4 Plainview Road, Camp Hill, PA 17013 Employment: Unknown Defendant: Joan Schrenk Age: Over18 Residence: 4 Plainview Road, Camp Hill, PA 17013 Employment: Unknown Defendant: Any and All Unknown Occupants Age: Over18 Residence: 4 Plainview Road, Camp Hill, PA 17013 Employment: Unknown Name: X l ??U k Shelby Shel'ro Title: Secretary Company: Central Penn Property Services, Inc. Sworn to and subscribed before me thisdl day of SHPT 05. Not NOTARY PUBLIC LAUREL D. EADLINE, Notary Public Akron Boro, Lancaster County, PA My Commission Expires Aug. 31, 2006 (File #04-188) STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR ATTORNEY I.D. NO: 66287 PLAINTIFF KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 WEST MAIN STREET P.O. BOX 29 LANSDALE,PA TELEPHONE: (: 19446-0029 15) 855-9521 CENTRAL PENN PROPERTY SERVICES, INC. 100 S. 7th Street Akron, PA 17501, Plaintiff, v. THOMAS J. SCHRENK, JOAN SCHRENK and ANY AND ALL UNKNOWN OCCUPANTS 4 Plainview Road Camp Hill, PA 17013 Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5001 CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a written Notice of Intention to Take Default Under Pa.R.CP. 237.1, was mailed to the Defendant(s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on October 18, 2005, as set forth in the copy of said Notice attached hereto, to the following Defendants: Thomas J. Schrenk, 4 Plainview Road, Camp Hill, PA 17013 Joan Schrenk, 4 Plainview Road, Camp Hill, PA 17013 Any and All Unknown Occupants, 4 Plainview Road, Camp Hill, PA 17013 Date: 10 1 8 05 By: Stephen M+HI ik, Esquire (File #04-188) Attorney forPlaintiff STEPHEN M. HLADIK, ESQUIRE ATTORNEY I.D. NO: 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 WEST MAIN STREET P.O. BOX 29 LANSDALE, PA 19446-0029 TELEPHONE: (215) 855-9521 CENTRAL PENN PROPERTY SERVICES, INC. 100 S. 7th Street Akron, PA 17501, Plaintiff, V. THOMAS J.SCHRENK, JOAN SCHRENK and ANY AND ALL UNKNOWN OCCUPANTS 4 Plainview Road Camp Hill, PA 17013 Defendants. ATTORNEYS FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5001 NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Thomas J. Schrenk 4 Plainview Road Camp Hill, PA 17013 DATE OF NOTICE: October 18, 2005 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 'YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe Ilevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o Ilame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Thomas J. Schrenk, 4 Plainview Road, Camp Hill, PA 17013 Joan Schrenk, 4 Plainview Road, Camp Hill, PA 17013 Any and All Unknown Occupants, 4 Plainview Road, Camp Hill, PA 17013 By: 11 i Stephe . Hladik, Esquire Attorney for Plaintiff (File#04-188) STEPHEN M. HLADIK, ESQUIRE ATTORNEY I.D. NO: 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 WEST MAIN STREET P.O. BOX 29 LANSDALE, PA 19446-0029 TELEPHONE: (215) 855-9521 CENTRAL PENN PROPERTY SERVICES, INC. 100 S. 7th Street Akron, PA 17501, Plaintiff, V. THOMAS J. SCHRENK, JOAN SCHRENK and ANY AND ALL UNKNOWN OCCUPANTS 4 Plainview Road Camp Hill, PA 17013 Defendants. ATTORNEYS FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5001 NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Joan Schrenk 4 Plainview Road Camp Hill, PA 17013 DATE OF NOTICE: October 18, 2005 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notification, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe Ilevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o (lame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Thomas J. Schrenk, 4 Plainview Road, Camp Hill, PA 17013 Joan Schrenk, 4 Plainview Road, Camp Hill, PA 17013 Any and All Unknown Occupants, 4 Plainview Road, Ca p Hill, PA 17013 (/ n r l r By: StephekKCHIadik, Esquire Attorney for Olaintiff (File#04-188) STEPHEN M. HLADIK, ESQUIRE ATTORNEY I.D. NO: 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 WEST MAIN STREET P.O. BOX 29 LANSDALE, PA 19446-0029 TELEPHONE: (215) 855-9521 CENTRAL PENN PROPERTY SERVICES, INC. 100 S. 7th Street Akron, PA 17501, Plaintiff, V. THOMAS J.SCHRENK, JOAN SCHRENK and ANY AND ALL UNKNOWN OCCUPANTS 4 Plainview Road Camp Hill, PA 17013 Defendants. ATTORNEYS FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5001 NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Any and All Unknown Occupants 4 Plainview Road Camp Hill, PA 17013 DATE OF NOTICE: October 18, 2005 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe Ilevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya an persona o (lame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Thomas J. Schrenk, 4 Plainview Road, Camp Hill, PA 17013 Joan Schrenk, 4 Plainview Road, Camp Hill, PA 17013 Any and All Unknown Occupants, 4 Plainview Road, Camp Hill, PA 17013 By: Stephen M. Attorney for Esquire (File#04-188) ?' l ? ? c.:> '(1 ? ? O G 'T "1 ! `?' ` -.a .? J T ? P.t ,", w r- _. STEPHEN M. HLADIK, ESQUIRE ATTORNEY I.D. NO: 66287 KERNS, PEARLSTINE, ONORATO & FATH, LLP 425 WEST MAIN STREET P.O. BOX 29 LANSDALE, PA 19446-0029 TELEPHONE: (215) 855-9521 CENTRAL PENN PROPERTY SERVICES, INC. 100 S. 7th Street Akron, PA 17501, Plaintiff, v. THOMAS J:SCHRENK, JOAN SCHF2ENK and ANY AND ALL UNKNOWN OCCUPANTS 4 PlainviewRoad Camp Hill, PA 17013 Defendants. ATTORNEYS FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5001 236 NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE-CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. URTIS LO PROTHONOTARY iI/7/os IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: StepfiA M. Hladik, Esquire I.D. No. 66287 425 W. Main Street P.O. Box 29 Lansdale, PA 19446-0029 (215) 855-9521 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 6'" day of January 2006, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." J. McCABE, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS 6" DAY OF January , 2006. Attorney for Plaintiff 04/crr,tic ! 6?an S-/??!r NOTARY PUBLIC COMMONWEALIK OF PENNSYLVANIA NOTARIAL SEAL Chrissandra Shaye Hamilton, Notary Public City of Philadelphia, Phila. County 9 M Comnussion Expires.ianuary 4, 2009 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshorn Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 05-4835 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 f, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 34 East Street, Mount Holly Springs, PA 17065 (Tax Parcel 923-32- 2338-021A), a copy of the description of said property is attached hereto and marked as Exhibit "A." 1. Name and address of Owners or Reputed Owners: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 EXHIBIT A 2 3. 4. 5 Name and address of Defendants in the judgment: Name Address Barry S. Nelson 34 East Street Mount Holly Springs, PA 17065 Teresa K. Nelson 34 East Street Mount Holly Springs, PA 17065 Randy Lee Goshorn 34 East Street Mount Holly Springs, PA 17065 Name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Address 419 Stonehedge Drive Suite 2 Carlisle, PA 17019 P.O. Box 8621 Elmhurst, IL 60126 Attn: Al Spears Name and address of every other person who has any record lien on the property: Name Address None EXHIBIT A 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 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: Name Address Tenants 34 East Street, Mount Holly Springs, PA 17065 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Commonwealth of Pennsylvania Inheritance Tax Office 1400 Spring Garden Street Philadelphia, PA 19130 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service 6th Floor, Strawberry Square Department 4280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 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 uv?sworn falsification to authorities. January 6, 2006 DATE T RREP CE J. McCABE, ESQUIRE Attorney for Plaintiff EXHIBIT A McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 DATE: January 6, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn PROPERTY: 34 East Street, Mt. Holly Springs, PA 17065 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on March 8, 2006, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT E S % J a A W N ?- "'3 0. v' v r, w a m"am.a R 3 - f/ p z ..jam av? a vn r n a'- -?p JO?p 'tia ?0_o ? 51 O ?'O RO O ?O ?? w G O ? ?tAN O ? >Fb- aC7 R?? ? C]i A? itT ? ? ? ?O?D?r] On? r' m w3' +,?'? r oo w a .w -n?ay3 a wo_3 4 w3 1 - ?33 rntn w ? ?S. owa ?ow ? -.a cwa i n 2 . a_o3. ? w 9 c ?o _. N " ? ? F ? _S'?C)"-'A ,o ., m a KO`?ca q? oo w '? ° a°n°,o °0 a £ .?o 'O ? o a z krno £ R° m o w 'b w ? ? %<?_? ?? oo ? a <=G' '? '0 ?' a 3? rv - p' ?rn? rv b > o. ?w?o? c >a. ao -? 'ox4 ^-1 p,_ >Nw ?' YO° -]w .D G) ? _ '410 = .. >a >oa? .- C1 p: j Nw o o ?rn - .- n.w a o o o >o^+1orv ++['b c <s m£ ? >w i .d ?r J o . ? c w ?a a r'-y J a v -?°?'r ? ?? ?r ay''-,.-,..? °rn? C7 o.c y? .^.o V y cPO ;? N c o c . °- C o3 _ o ??? O ? o ? m0. ,9 xo? ? b ?N O ? ?' o ? P a = ? ?O[10 ??? ? O a ? ? ? v ? a R 3 ?5 d is a dO W ^^ L ? ,a. ?< v O a n ? ?j = o a a y w rvW ?? ? ?c o ?o ?o _ 9 ? A M RS i W y? NN .d ? rd w x r uWrf +? o ;;; U y ?4 ,gym ? , A - N v V 1 ?N ?'? ° m rn ?? NCI - .;,:?? n U 3 ?Pqi ?? ,, Q ?? ?? .r a3 w? ?P n 3 ro n c ?e rt .a F O U_ A H ? 1 r w i U 3 °? fA Q K :;, ` .? , _ ?? , r ?, Beneficial Consumer Discount Company The Court of Common Pleas of d/b/a Beneficial Mortgage Company of PA Cumberland County, Pennsylvania VS Writ No. 2005-4835 Civil Term Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshom Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on December 01, 2005 at 9:00 o'clock AM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Barry S. Nelson and Teresa K. Nelson, by making known unto Teresa Nelson, personally and adult in charge for Barry S. Nelson, at 34 East Street, Mt. Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on December 01, 2005 at 9:00 o'clock AM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Randy Lee Goshom, by making known unto Randy Lee Goshorn, personally, at 34 East Street, Mt. Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on January 06, 2006 at 10:23 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn, located at 34 East Street, Mt. Holly Springs, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn, by regular mail to their last known address of 34 East Street, Mt. Holly Springs, PA 17065. These letters were mailed under the date of January 05, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Terrence McCabe. Sheriffs Costs: Docketing 30.00 Poundage Posting Handbills 15.00 Advertising 15.00 Law Library .50 Prothonotary 1.00 Mileage 11.04 Certified Mail 3.66 Levy 15.00 Surcharge 40.00 Postage 1.56 Law Journal 347.00 Patriot News 308.00 Share of Bills 21.05 $824.99 Sworn and subscribed to before me This I9 c day of " Wt4- 2006, A.D. R. Thomas Kline, Sheriff BY \, It OU Real Estate rgeant McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshorn Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 05-4835 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence 1. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 34 East Street, Mount Holly Springs, PA 17065 (Tax Parcel #23-32- 2338-021A), a copy of the description of said property is attached hereto and marked as Exhibit "A," 1. Name and address of Owners or Reputed Owners: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 ' McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randy Lee Goshom Cumberland County Court of Common Pleas Number 05-4835 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barry S. Nelson Teresa K. Nelson Randy Lee Goshom 34 East Street Mt. Holly Springs, PA 17065 Your house (real estate) at 34 East Street, Mt. Holly Springs, PA 17065 (Tax Parcel #23- 32-2338-021A) , is scheduled to be sold at Sheriffs Sale on March 8, 2006 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $55,045.72 obtained by Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania 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: The sale will be canceled if you pay to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 4. 5. 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 Terrence J. McCabe, Esquire at (215) 790-1010. 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. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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. 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. You may also have other rights and defenses, or ways of getting your real estate 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. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OR CUMBERLAND COUNTY COURT ADMINISTRATOR BAR ASSOCIATION 4TH FLOOR, 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 (717) 240-6200 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE BOROUGH OF Mom HOLLY SPRINGS, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A PLAN PREPARED BY EUGENE ALBERT HOCRENSMITH, R.P.L.8, DATED JUNE 30, 1992 AND RECORDED IN PLAN HOOK 65, PAGE 48 OF THE CUMBERLAND COUNTY RECORDER OF DEEDS OFFICE, DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN SET ON PRIVATE ZASEMENT AND 15 FOOT RIGHT OF WAY, SAID POINT SET ON WESTERN EDGE OF LOT NO. 2 AS SET FORTH ON SAID PLAN; THENCE ALONG LOT NO. 2, SOUTH 43 DEGREES 52 MINUTES 12 SECONDS EAST 113.25 FEET TO AN IRON PIN; THENCE ALONG LOT NO. 3, SOUTH 39 DEGREES 41 MINUTES 04 SECONDS WEST 74.50 FEET TO AN IRON PIN SET; THENCE ALONG LANDS OF HARRY Z. GOSHORN, NORTH 48 DEGREES 51 MINUTES 04 SECONDS WEST 106.00 FEET TO AN IRON PIN HET; THENCE ALONG PRIVATE EASEMENT AND RIGHT OF WAY, NORTH 34 DEGREES 08 MINUTES 06 SECONDS EAST 75.00 FEET, TO THE PLACE OF BEGINNING. BEING KNOWN AS 34 East Street, Mt. Holly Springs, PA 17065 Being the same premises which Dennis R. Goshom and Janet L. Hopple, Executors of the Last Will and Testament of Minerva Grace Goshorn, by deed dated the 6/6/1996, and recorded 6/29/1996 in the Office of the Recorder in and for Cumberland County in Deed Book 143, Page 412, granted and conveyed to Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshom, in fee. TAX MAP PARCEL NUMBER: 23-32-2338-021A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4835 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONS. DISC. CO. d/b/a BENEFICIAL MORTGAGGE CO OF PA Plaintiff (s) From BARRY S. NELSON, TERESA K. NELSON AND RANDY LEE GOSHORN, 34 EAST ST., MT. HOLLY SPRINGS PA 17065. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 34 EAST ST., MT. HOLLY SPPRINGS PA 17065 (SEE LEGAL DESCRIPTION). (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $55,045.72 L.L. $.50 Interest FROM 1111105 TO 3/8/06 AT $9.05 PER DIEM = $1,158.40 Atty's Comm Arty Paid $214.60 Plaintiff Paid Date: NOVEMBER 2, 2005 Due Prothy $1.00 Other CostsESCROW DEFICIT = $2,000.00 CURTIS rLOV7 Prothonotary (Seal) By: Deputy REQUE$TING PARTY: Name TERRENCE J. MCCABE, ESQ. Address: 1213 S. BROAD ST., STE 2080 PHILADELPHIA PA 19109 Attorney for: PLAINTIFF Telephone: (215) 790-1010 Supreme Court ID No. 16496 Real Estate Sale # 10 On November 30, 2005 the Sheriff levied upon the defendant's interest in the real property situated in Borough of Mount Holly Springs, Cumberland County, PA Known and numbered as 34 East Street, Mt. Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 30, 2005 By:'J644 - w t c l Real Estate Sergeant ??1 C;M 4 G'r) go 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 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 Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared 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 SALE#10 ..................................... ....................................................... Sworn to and subscrib b ore me this 16th day of February 2006 A.D. Terry L. Russell, Notary puboc N of larrldhurn NOTARY PUBLIC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 20, 27, February 3, 2006 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. Marie Coyne, AND SUBSCRIBED before me this of February. 2006 rat;1 "PJ'?' S"?+ti. V LO1S E. SNYMA, Notary Pablfr kp Ca^,L, Born, Cumberland Coup i t q ,,;,as m Exotes March 5. • ,".' RZAL TWAT` SALN NO. 10 Writ No. 2005-4835 Civil Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of PA vs. Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshom Atty.: Terrence McCabe LEGAL DESCRIPTION ALL that certain tract of land situ- ate in the Borough of Mount Holly $ Springs, Cumberland County, Penn- sylvania, bounded and described in accordance with a plan prepared by +Eugene Albert Hockensmith, R.P.L.S., dated June 30, 1992 and recorded in Plan Book 65, Page 48 of the Cumberland County Recorder of Deeds Office, described as fol- lows: BEGINNING at an iron pin set on private easement and 15 foot right of way, said point set on west- ern edge of Lot No. 2 as set forth on said plan; thence along Lot No. 2, South 43 degrees 52 minutes 12 seconds East 113.25 feet to an Iron pin; thence along Lot No. 3, South 39 degrees 41 minutes 04 seconds West 74.50 feet to an iron pin set; thence along lands of Harry E. Goshom, North 48 degrees 51 min- utes 04 seconds West 106.00 feet to an iron pin set; thence along pri- vate easement and right of way, North 34 degrees 08 minutes 06 seconds East 75.00 feet, to the place of beginning. BEING KNOWN AS 34 East Street, Mt. Holly Springs, PA 17065. Being the same premises which Dennis R. Goshorn and Janet L. Hopple, Executors of the Last Will and Testament of Minerva Grace Goshom, by deed dated the 6/6/ 1996, and recorded 6/29/1996 in the Office of the Recorder in and for Cumberland County in Deed Book 143, Page 412, granted and conveyed to Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshom, in fee. TAX MAP PARCEL NUMBER: 23- 32-2338-021A. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FILE NO.: 05-4835 Civil Term Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn AMOUNT DUE: $55,045.72 INTEREST: from 1111105 - 12/6/06 $3,620.00 at $9.05 Per Diem ATTY' S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 34 East Street, Mt. Holly Springs, PA 17065 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. ^-_-+ ?-c ?/ • /lij?-c__ DATE: Signature: Print Name: TERRENCE J. McCABE, ESQUIRE Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 44- ?Ln 1 ti fi ?V ti h w ~ "? 1 1 h '% h `1 1 `IT T t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4835 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA, Plaintiff (s) From BARRY S. NELSON, TERESA K. NELSON AND RANDY LEE GOSHORN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $55,045.72 L.L. Interest FROM 11/1/05 -12/6/06 - $3,620.00 AT $9.05 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $1052.09 Plaintiff Paid Date: AUGUST 15, 2006 (Seal) Other Costs CURT IS S R. LONG Prothonotary By: Deputy REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 McCABE, WEISBERG AND CONWAY, P.C. -BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS. Barry S. Nelson Teresa K. Nelson Randy Lee Goshom Cumberland County Court of Common Pleas Number 05-4835 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn 34 East Street Mt. Holly Springs, PA 17065 Your house (real estate) at 34 East Street, Mt. Holly Springs, PA 17065 (Tax Parcel #23-32- 2338-021A) , is scheduled to be sold at Sheriffs Sale on December 6, 2006 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $55,045.72 obtained by Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania 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 sale will be canceled if you pay to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. 2. 3. 4 5. 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 Terrence J. McCabe, Esquire at (215) 790-1010. 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. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790- 1010. 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. 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate 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. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OR COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 o C c r, 'L? C!':? 3s 'G' C_ TV f O -r} L _? 1. .-j McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshorn Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 05-4835 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 34 East Street, Mount Holly Springs, PA 17065 (Tax Parcel #23-32- 2338-021A), a copy of the description of said property is attached hereto and marked as Exhibit "A." 1. Name and address of Owners or Reputed Owners: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 f r 2 3. 4. 5. Name and address of Defendants in the judgment: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein. Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Address 419 Stonehedge Drive Suite 2 Carlisle, PA 17019 P.O. Box 8621 Elmhurst, IL 60126 Attn: Al Spears Name and address of every other person who has any record lien on the property: Name None Address 6. 7. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 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: Name Address Tenants 34 East Street, Mount Holly Springs, PA 17065 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 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. August 11, 2006 DATE TERRENCE . McCABE, ESQUIRE Attorney for Plaintiff , : Grp tlt ;"'? 3• McCABE, WEISBERG AND CONWAY, P.C. B1': 'TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 SUPPLEMENTAL AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 28th day of September, 2006, a true and correct copy of the Notice of Sheriffs Sale ol'Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFORE ME THIS 28TH DAY OF SF TEMBER , 2006. NOTARY PUBLIC COMMONWEALTH OF PENN8Yt_YANIA NOTARIAL SEAL Chrissandra Shaye Hamilton, Notary Public City of Philadelphia, Phila. County My Commission Expires January 4, 2009 j/ TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshorn Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 05-4835 Civil Term SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 34 East Street, Mount Holly Springs, PA 17065, a copy of the description of said property is attached hereto and marked as Exhibit "A." Name and address of Owner or Reputed Owner: Name Address Barry S. Nelson 34 East Street Mount Holly Springs, PA 17065 Teresa K. Nelson 34 East Street Mount Holly Springs, PA 17065 Randy Lee Goshorn 34 East Street Mount Holly Springs, PA 17065 2. Name and address of Defendant in the judgment: x ?. Name 3. 4. 5. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein. Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Address 419 Stonehedge Drive Suite 2 Carlisle, PA 17019 P.O. Box 8621 Elmhurst, fl, 60126 Attn: Al Spears Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in they property which may be affected by the sale: > ' PkIl. Name None Address 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: Name Tenants Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Address 34 East Street, Mount Holly Springs, PA 17065 P.O. Box 320 Carlisle, PA 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 1400 Spring Garden Street Philadelphia, PA 19130 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department #280601 Inheritance Tax Division Harrisburg, PA 17128 Department of Public Welfare 1411. Casualty Unit Estate Recovery Program Internal Revenue Service Nazareth National Bank Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 76 S. Main Street Nazareth, PA 18064 verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to uxswom falsification to authorities. September 28, 2006 DATE TERRENCE J. McCABE, ESQUIRE Attorney for Plain &WJ l: McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randv 1,ce Goshorn Cumberland County Court of Common Pleas Number 05-4835 t)AI :: September 28, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn PROPERTY: 34 East Street, Mt. Holly Springs, PA 17065 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on December 6, 2006, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 day s after sale. Distribution will be made in accordance with the schedule unless exceptions arc tiled thereto within 10 days after the filing of the schedule. r U -n J R g 7? o z ? b -v ro e ? n •e ? b ? ro K ? 2. C O A b R rn v nP'a 9 , o < O [mac p. V 2'. 5 tJ "n n 00 ?? nnnnn^ ' n ? IrIO 50-4 t=r- ...,Ono tt?? tir- q? o.? cD CD, L1Ni7 4 y, o t a ?a Spy r^' p -' tfs -n cn ? Y N a o? C7 N ? c m cA r.? ? tp N'?+? lc ^ CO D ? f hJ k McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 AFFIDAVIT OF SERVICE 1. Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 5th day of October, 2006, a true and correct copy of the Notice of Sheriff s Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." TE _ CE J. MCCABE, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED 111'FORI? MF. "THIS 5TH DAY OF 2006. Ck ycxu? NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Chnssandra Shaye Hamilton, Notary Public City of Philadelphia, Phila. County My Commission Expires January 4, 2009 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshorn Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 05-4835 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 34 East Street, Mount Holly Springs, PA 17065 (Tax Parcel #23-32- 2338-021A), a copy of the description of said property is attached hereto and marked as Exhibit "A. II Name and address of Owners or Reputed Owners: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 E x i '3x ' It 2. 3 4. 5. Name and address of Defendants in the judgment: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein. Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Address 419 Stonehedge Drive Suite 2 Carlisle, PA 17019 P.O. Box 8621 Elmhurst, IL 60126 Attn: Al Spears Name and address of every other person who has any record lien on the property: Name Address None Exhabit "A' 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 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: Name Address Tenants 34 East Street, Mount Holly Springs, PA 17065 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Nazareth National Bank 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 76 S. Main Street Nazareth, PA 18064 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. October 5, 2006 DATE a TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff pot Ex- , 1" "! McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 DATE: October 5, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn PROPER"I'Y: 34 East Street, Mt. Holly Springs, PA 17065 l\11)K0Vl1A1l:NTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff s Sale on December 6, 2006, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are tiled thereto within 10 days after the filing of the schedule. Exhi'bi't "B" I N ? w N Y ?, ? o G 04 0 n ? ?? acn o o. in w ro ? N or_ `d (?1CTj Op0[]O? C?k b n n b n ? O •P ? ? ? `? ? ?+? ? ? C9 Cl? v? ()G '? 'r*? w o ? •d CZ x• do £O trs ?ua? --NO???. d co p ?, = CJ3 ?, ?• ?' to c cu `< Q'. `d n r C.yoro ?• cuo.(?y... x? ?. ?, y~'ocso 0,0 "? V • C?"? .? CD ''3 "? W *? O CD CD Q? O O (jq W 'N d d u p v. ?e co cu d CS- w tl? ??, C/] "3 CD tli r-h r+ J Off' `? (J ?? • ` C coo 000 0 °? w ,? v' un v, ?' d n d r• CD CD 00 0 ' 46 r uruT ?j 7 o O x o N ST A j. 4 p 3 O m [O N ? b (D Cn? a r ? !., r'4 Y ro ro 0 w oe J J cQ W N_ O n 0 8 ro A a M A R g 0 07 ro 0 ?a n 0 ? r? C:. `=-' : _? .? Rt ??;•, T C. s -i ? -? ? C31 --- ? GD r ' -, ..;> r ?- ? • • vi -! ? ` ??: " w Beneficial Consumer Discount Company d/b/a In the Court of Common Pleas of Beneficial Mortgage Company of Pennsylvania Cumberland County, Pennsylvania VS Writ No. 2005-4835 Civil Term Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn Cpl Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 13, 2006 at 1754 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Barry S. Nelson and Teresa K. Nelson, by making known unto Keith Nelson, adult son of Barry S. and Teresa K. Nelson, at 34 East St., Mt. Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 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, to wit: Randy Lee Goshorn, 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, Randy Lee Goshorn. Keith Miller, current resident of defendant's last known address, 34 East Street, Mt. Holly Springs, PA, states the defendant has not resided at that address for over two years. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 13, 2006 at 1035 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn located at 34 East Street, Mt. Holly Springs, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Barry S. Nelson and Teresa K. Nelson, by regular mail to their last known address of 34 East St., Mt. Holly Springs, PA 17065. These letters were mailed under the date of October 10, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED per instructions from Attorney Terrence McCabe. Sheriffs Costs: Docketing 30.00 Surcharge 40.00 Poundage 16.07 Prothonotary 1.00 Advertising 15.00 Levy 15.00 Mileage 12.32 Posting Handbills 15.00 Share of Bills 15.94 Law Journal 353.00 Patriot News 306.38 $819.71 ? So Answers: R. Thomas Kline, Sheriff BY?,?" Real Es at ergeant 1Z/O q f oC McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshorn Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 05-4835 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 34 East Street, Mount Holly Springs, PA 17065 (Tax Parcel #23-32- 2338-021A), a copy of the description of said property is attached hereto and marked as Exhibit "A." Name and address of Owners or Reputed Owners: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 34 East Street Mount Holly Springs, PA 17065 iv VCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn 34 East Street Mt. Holly Springs, PA 17065 Your house (real estate) at 34 East Street, Mt. Holly Springs, PA 17065 (Tax Parcel #23-32- 2338-021A) , is scheduled to be sold at Sheriffs Sale on December 6, 2006 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $55,045.72 obtained by Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania 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 sale will be canceled if you pay to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4835 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY DB/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA, Plaintiff (s) From BARRY S. NELSON, TERESA K. NELSON AND RANDY LEE GOSHORN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $55,045.72 L.L. Interest FROM 11/1/05 - 12/6/06 - $3,620.00 AT $9.05 PER DIEM Atty's Comm % Atty Paid $1052.09 Plaintiff Paid Date: AUGUST 15, 2006 Due Prothy $1.00 Other Costs URTIS R. LO Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 f. A Real Estate Sale # 36 On August 25, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Mount Holly Springs Borough, Cumberland County, PA Known and numbered as 34 East Street, Mount Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 25, 2006 By: Real Estate Sergeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 20, October 27 and November 3, 2006 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. S r P-A isa arie Coyne, Yditor SWORN TO AND SUBSCRIBED before me this 3 day of November, 2006 NOTARIAL SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 REAL ESTATE SALE NO. 36 Writ No. 2005-4835 Civil Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsvlvania vs. Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn Atty.: Terrence McCabe LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsvlvania, bounded and de- scribed in accordance with a plan prepared by Eugene Albert Hocken- smith, R.P.L.S, dated June 30, 1992 and recorded in Plan Book 65, Page 48 of the Cumberland County Recorder of Deeds Office, described as follows: BEGINNING at an iron pin set on private easement and 15 foot right of way, said point set on west- ern edge of Lot No. 2 as set forth on said plan; THENCE along Lot No. 2, South 43 degrees 52 minutes 12 seconds East 113.25 feel to an iron pin; TIIENCE along Lot. No. 3, South 39 degrees 41 minutes 04 seconds West 74.50 feet to an iron pin set; THENCE along lands of Harry E. Goshorn, North 48 degrees 51 min- utes 04 seconds West 106.00 feet to an iron pin set; THENCE along private easement and right of way, North 34 degrees 08 minutes 06 seconds East 75.00 feet, to the place of beginning. BEING KNOWN AS 34 East Street, Mt. Holly Springs, PA 17065. Being the same premises which Dennis R. Goshorn and Janet. L. Hopple, Executors of the Last Will and Testament of Minerva Grace Goshorn, by deed dated the 6/6/ 1996, and recorded 6/29/ 1996 in the Office of the Recorder in and for Cumberland Countv in Deed Book 143, Page. 412, granted and conveyed to Barry S. Nelson, Teresa K. Nelson and Randv Lee Goshorn, in fee. TAX MAP PARCEL NUMBER: 23- 32-2338-021A. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 25th day(s) of October and the 1st and 8th day(s) of November 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. PUBLICATION1 ...................................... COPY Sworn to an s scribed before me this 15th day of November 2006 A.D. SALE #36 COMMONWEALI'H OF PE14NSYLVANIA Terry `votary r'u;;liC ' Pty Of Harrisburc 0aup1 1 o my y Commission Aires J , 2010 //?epe/r.Pannssvl .ni?iaticin of Notaries NOTAItY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 DESCRY MON ALL THAT CEUAIN tract of land situate in the Borough bf Mount Holly Springs, Cumbettw&C y ften ylvanni, bounded and described in accMilo a wish a plan papared by Eugene ARM ' RPL.S., dated June 30, 1992 ad mcatded in Plan Book 65, page 48 of die Cumbedand County Recorder of Deeds office, desabod as follows: Be&nutg at an iron pin set on private easement and 15 foot not of way, said pow set on western edge 4( La4 No. 2 as set forma said plan; ftmi *6gtc t No, Z So* 43 *pees 52 motes 12 seconds NM 11315 feet to an as WA' ?e IM M feet to an imn pin set; =1 ft, private easement and right of way, 08 mimes 06 seconds East 75.00 feet, to the plamhf begim*. Being known as: 34 Fast Street, Mt. Holly Speings, PA 17065 Being the same premises vhich Dennis R. Goshasn and Janet L. Iioppde, Eseators of the Last Will and Teatanvo of Mina Grace Goshan, by deed dated 616fl996; =d recorded 6r29/1996 in dw Of= of the ReeWer in and Car ry in Deed Book 143, page 412, Jls `tom '1bm'esa L iw&dssa ad *u* La Go"n, in fee. Tax MV Pwcel # 23-32.233&WIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn FILE NO.: 05-4835 Civil Term AMOUNT DUE: $55,045.72 INTEREST: from 11/1/05 - 9/5/07 $2,796.45 at $9.05 Per Diem ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 34 East Street Mt Holly Springs PA 17065 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: y z4 7_ Si ature: Print Name: MCCABE, WEISBERG AND CONWAY Address: 123 S. Broad Street. Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: 215 790 1010 Supreme Court ID No. °N yJ (rt .. r ' co WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4835 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY DB/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA, Plaintiff (s) From BARRY S. NELSON, TERESA K. NELSON, RANDY LEE GOSHORN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $55,045.72 L.L. Interest FROM 11/1/05 - 9/5/07 $2,796.45 AT $9.05 PER DIEM Atty's Comm % Due Prothy $2.00 Atty Paid $1895.80 Plaintiff Paid Other Costs Date: APRIL 30, 2007 (Seal) REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: MCCABE WEISBERG AND CONWAY, P.C. 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 Curti . Lon o tary By: Deputy t McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Attorneys for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Plaintiff V. Number 05-4835 Civil Term Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshorn Defendants AFFIDAVIT PURSUANT TO RULE 3129 I, the undersigned attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 34 East Street, Mount Holly Springs, PA 17065 (Tax Parcel #23-32-2338- 021 A), a copy of the description of said property is attached hereto and marked as Exhibit "A." Name and address of Owners or Reputed Owners: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17013 34 East Street Mount Holly Springs, PA 17013 34 East Street Mount Holly Springs, PA 17013 a- 2 3 Name and address of Defendants in the judgment: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17013 34 East Street Mount Holly Springs, PA 17013 34 East Street Mount Holly Springs, PA 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4 5. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein. Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Address 419 Stonehedge Drive Suite 2 Carlisle, PA 17019 P.O. Box 8621 Elmhurst, IL 60126 Attn: Foreclosure Department Name and address of every other person who has any record lien on the property: Name Address None i 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 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: Name Tenants Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 34 East Street, Mount Holly Springs, PA 17065 P.O. Box 320 Carlisle, PA 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales 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. April 25, 2007 McCABE, WEISBERG, AND CONWAY, P.C. BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE c=n d ?C trz r McCABE, WEISBERG AND CONWAY, P.C. -? BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS. Cumberland County Court of Common Pleas Number 05-4835 Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn 34 East Street Mt. Holly Springs, PA 17065 Your house (real estate) at 34 East Street, Mt. Holly Springs, PA 17065 (Tax Parcel #23-32- 2338-021A) , is scheduled to be sold at Sheriffs Sale on September 5, 2007 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $55,045.72 obtained by Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania 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 sale will be canceled if you pay to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 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 McCabe, Weisberg & Conway, PC at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call McCabe, Weisberg & Conway, PC at (215) 790-1010. 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OR CUMBERLAND COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 C-) -n . - 7,1 a cA.) c LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE BOROUGH OF MOUNT HOLLY SPRINGS, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A PLAN PREPARED BY EUGENE ALBERT HOCKENSMITH, R.P.L.S, DATED JUNE 30, 1992 AND RECORDED IN PLAN BOOK 65, PAGE 48 OF THE CUMBERLAND COUNTY RECORDER OF DEEDS OFFICE, DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN SET ON PRIVATE ZASEMBNT AND 15 FOOT RIGHT OF MAY, SAID POINT SET ON WESTERN EDGE OF LOT NO. 2 AS SET FORTH ON SAID PLAN; THENCE ALONG LOT NO. 2, SOUTH 43 DEGREES 52 MINUTES 12 SECONDS EAST 113.25 FEET TO AN IRON PIN; THENCE ALONG LOT NO. 3, SOUTH 39 DEGREES 41 MINUTES 04 SECONDS WEST 74.50 FEET TO AN IRON PIN SET; THENCE ALONG LANDS OF HARRY E. GOSHORN, NORTH 48 DEGREES 51 MINUTES 04 SECONDS WEST 106.00 FEET TO AN IRON PIN SET; THENCE ALONG PRIVATE EASEMENT AND RIGHT OF WAY, NORTH 34 DEGREES 08 MINUTES 06 SECONDS EAST 75.00 FEET, TO THE PLACE OF BEGINNING. BEING KNOWN AS 34 East Street, Mt. Holly Springs, PA 17065 Being the same premises which Dennis R. Goshorn and Janet L. Hopple, Executors of the Last Will and Testament of Minerva Grace Goshom, by deed dated the 6/6/1996, and recorded 6/29/1996 in the Office of the Recorder in and for Cumberland County in Deed Book 143, Page 412, granted and conveyed to Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshom, in fee. TAX MAP PARCEL NUMBER: 23-32-2338-021A C') a C3 _ . n7 m . r .?M =3C .3 7 rn Q3 "'C McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 AFFIDAVIT OF SERVICE I, the undersigned attorney for the Plaintiff in the within matter, hereby certify that on the 16`' day of July,2007, a true and correct copy of the Notice of Sheriff s Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFORE ME THIS 16"' DAY OF JULY, 2007. OTARY Notarial Seal Susan J. Markowitz, Notary Public City Of Philadelphia, Philadelphia County My Commission Expires Feb. 13, 2011 Member, Pennsylvania Association of Notaries McCABE, WEISBERG D ONWAY, P.C. BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Attorneys for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Plaintiff V. Number 05-4835 Civil Term Barry S. Nelson and Teresa K. Nelson and Randy Lee Gosborn Defendants AFFIDAVIT PURSUANT TO RULE 3129 I, the undersigned attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 34 East Street, Mount Holly Springs, PA 17065 (Tax Parcel #23-32-2338- 021A), a copy of the description of said property is attached hereto and marked as Exhibit "A." 1. Name and address of Owners or Reputed Owners: Name Address Barry S. Nelson 34 East Street Mount Holly Springs, PA 17013 Teresa K. Nelson 34 East Street. s Mount Holly Springs, PA 170 shorn 34 East Street Randy Lee Go Mount Holly Spgs, 4A if01?.u., 2 3. 4 Name and address of Defendants in the judgment: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshom Address 34 East Street Mount Holly Springs, PA 17013 34 East Street Mount Holly Springs, PA 17013 34 East Street Mount Holly Springs, PA 17013 Name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein. Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Address 419 Stonehedge Drive Suite 2 Carlisle, PA 17019 P.O. Box 8621 Elmhurst, IL 60126 Attn: Foreclosure Department 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 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: Name Tenants Address 34 East Street, Mount Holly Springs, PA 17065 Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance P.O. Box 320 Carlisle, PA 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales 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. s ? April 25, 2007 McCABE, WEISBERG, C BY: Attorneys for Plaintiff" TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 DATE: July 16, 2007 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn PROPERTY: 34 East Street, Mt. Holly Springs, PA 17065 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on September 5, 2007, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Exhibit B w CL N d?d?a a 9 ~ r ti tj% by .oGwo 00 C CD y o04 p. C7 ?' n a o d p `D <D X .. O p O y K ._-, c: 0 W ,? C? b C7 co .? •rs d w n b c 7r* ?, (D O O N YC b O cu o 0 5 C, 'D "?'? .- . tv ro ? a ¢. H erns ('? On Cl O 0 N v <D ? N a n'. 0 :3 to tz .O C) U4 N W ¢ FA (D O N ?' OQ W cn O O lD N of '? C `C C O r N r vi Q CD O C v ,dC? Yto ?? J C p `o c9 N ?" `Od ?O r O K > G. boy "''d w `?' :Q C tl4 d n d .0 r3 ::+I cn W N 9 ?O? rd ?p 0 b O C> 0 N O. 0 n ¢ 4 CD cs Ow 5 CD m b OQ is m ? y O ? ? Col. S a ? A ?; ?. o ? 'cs w ? ? oho cy'?s_ ?' cis w u G? a d c? n cn o= Lvi f7 N s cD, (D O C3 (fy J a cc, a ? °• coo ? N ff owa a V.a ro d 0 0 o?bal a. c??o ro c n O r t9 r? <D a a ro R H O K CJj r r b O O b O 0 ..?? n 9o?m r co ? ? N d r a v, pO ,? co ? w ?o «b 70 Q `? coo 00 00 ??c"fo Rio w q •a a?V K 00 N W O 00 ?ti , 1, 7CO ? w ??iar ?- , r;.a , f_.? ti _ •,-..? ? t °? f ? ` ' 1?-1? .. ? i- __: ?? - ` -`.7 p ?, ? . 1, ? ?? Beneficial Consumer Discount Company In the Court of Common Pleas of d/b/a Beneficial Mortgage Company of Cumberland County, Pennsylvania Pennsylvania Writ No. 2005-4835 Civil Term VS Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on May 14, 2007 at 1505 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Barry S. Nelson and Teresa K. Nelson, by making known unto Teresa K. Nelson personally, and wife of Barry S. Nelson at 34 East Street, Mt. Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on July 11, 2007 at 1340 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn located at 34 East Street, Mt. Holly Springs, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Barry S. Nelson and Teresa K. Nelson, by regular mail to their last known address of 34 East Street, Mt. Holly Springs, PA 17065. These letters were mailed under the date of July 2, 2007 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Terrence McCabe. Sheriffs Costs: Docketing 30.00 Poundage 17.53 Posting Handbills 15.00 Advertising 15.00 Prothonotary 2.00 Mileage 11.52 Levy 15.00 Surcharge 40.00 Law Journal 355.00 Patriot News 377.33 Share of Bills 15.69 $ 894.07 ? ?» So Answers: R. Thomas Kline, Sheriff BY Real stat ergeant g1407 0311 l4P3o`t' I J. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Plaintiff V. Barry S. Nelson and Teresa K. Nelson and Randy Lee Goshorn Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 05-4835 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, the undersigned attorney for-Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 34 East Street, Mount Holly Springs, PA 17065 (Tax Parcel #23-32-2338- 021A), a copy of the description of said property is attached hereto and marked as Exhibit "A." 1. Name and address of Owners or Reputed Owners: Name Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17013 34 East Street Mount Holly Springs, PA 17013 34 East Street Mount Holly Springs, PA 17013 r 2. 3. 4 Name and address of Defendants in the judgment: Name Bang S. Nelson Teresa K. Nelson Randy Lee Goshorn Address 34 East Street Mount Holly Springs, PA 17013 34 East Street Mount Holly Springs, PA 17013 34 East Street Mount Holly Springs, PA 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein. Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Address 419 Stonehedge Drive Suite 2 Carlisle, PA 17019 P.O. Box 8621 Elmhurst, IL, 60126 Attn: Foreclosure Department 5. Name and address of every other person who has any record lien on the property: Name None Address w 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 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: Name Tenants Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 34 East Street, Mount Holly Springs, PA 17065 P.O. Box 320 Carlisle, PA 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. April 25, 20072007 McCABE, WEISBERG AND CONWAY, P.C. BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE McWE, WEISBERG AND CONWAY, P.C. BY: T+ERRENCE J. McCABE, ESQUIRE - ID # 164% MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS. Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn Cumberland County Court of Common Pleas Number 05-4835 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barry S. Nelson Teresa K. Nelson Randy Lee Goshorn 34 East Street Mt. Holly Springs, PA 17065 Your house (real estate) at 34 East Street, Mt. Holly Springs, PA 17065 (Tax Parcel #23-32- 2338-021A), is scheduled to be sold at Sheriffs Sale on September 5, 2007 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $55,045.72 obtained by Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania 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: The sale will be canceled if you pay to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 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 also be able to stop the sale through other legal proceedings. You;may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES 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 McCabe, Weisberg & Conway, PC at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call McCabe, Weisberg & Conway, PC at (215) 790-1010. 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate 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. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OR CUMBERLAND COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ' LEGAL DESCRIPTION ALL TRAT C IMAIN TRA= OF ZAM BITtJATZ IN = BOROUGH OF 147CIliT R=T SnINQS, cmewaj w COUM, PENNSTLvANIA, soumm AND 1Z8C RIHZD IN ACCOMMCS wilm a PLAN PRZPARED W ZUGZNE "U" .1 n rq 'PJ181QT8, R. P.L.8, DLTZD JUNE 30, 1992 AM RZCORDZD IN PLAN SOM ' 65, PAGM 48 OF TBZ CUNDULAND COM= RZOORDZR OF DEEDS OITICS, DZSCRISZD AS FOLLONS: RZGINNING AT AN IRON PIN 82T ON PRIVATE FJI$EM= AND 15 FOOT RIMT OF IMT, RAID POINT 8ZT ON IMSTZRN ZDGE OF WT NO. 2 AS 8ZT FOItTB ON SAID PL>,N; TUC= ALONG LOT NO. 2, SOUTS 43 == = 52 IMMMS 12 8ECONDS CAST 113.25 V1= TO AN IRON PIN; ALONG LOT NO. 3, BOOM 39 DZGRZZS 41 HIMUM 04 SZOMM UZST 74.50 FZlT TO AN IROK PIN 8ZT; Tn" 1' ALONG LUMS OF SAM E. 008tIM, NORTR 48 DECRZES 51 UrWJ EB 04 SZOONDS ASST 106.00 FZET TO AN IRON PIN SZT, 410' I ALONG PRIVATZ ZABZMM AND RIGHT OF RAT, NOR= 34 team$ 08 WINUT98 06 SEOONDS ZAST 75.00 FEET, TO THE PLhCZ OF SE IMUG. BEING KNOWN AS 34 East Street, Mt. Holly Springs, PA 17065 Being the same premises which Dennis R. Goshorn and Janet L. Hopple, Executors of the Last Will and Testament of Minerva Grace Goshorn, by deed dated the 6/6/1996, and recorded 6/29/1996 in the Office of the Recorder in and for Cumberland County in Deed Book 143, Page 412, granted and conveyed to Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn, in fee. TAX MAP PARCEL NUMBER: 23-32-2338-021A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 054835 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY M . DB/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA, Plaintiff (s) From BARRY S. NELSON, TERESA K. NELSON, RANDY LEE GOSHORN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $55,045.72 L.L. Interest FROM 1111105 - 9/5/07 $2,796.45 AT $9.05 PER DIEM Atty's Comm % Due Prothy $2.00 Atty Paid $1895.80 Plaintiff Paid Date: APRIL 30, 2007 (Seal) REQUESTING PARTY: Other Costs Curgs' R. Long, Pr tary By: Deputy Name TERRENCE J. MCCABE, ESQUIRE Address: MCCABE WEISBERG AND CONWAY, P.C. 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 ftjMA Vaiap Real Estate Sale # 21 On May 8, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Mt.,Holly Springs Borough, Cumberland County, PA Known and numbered as 34 East Street, Mt. Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 8, 2007 By::?? ?ry Real Estate Sergeant too, , a i, 'k 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 Shannon D. Bilihime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of July and the 1st day(s) of August 2007. 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 SALE #21 Sworn to and subscribed before 11]A o6f S 70f ussed, Notary Public sburg: Dauphin County My Commission Expires June 6, 2010 _j M or, Ponnsyivania AssOOistion of NNtariNs NO MY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 20, July 27, and August 3, 2007 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. „ L' Marie Coyne, for SWORN TO AND SUBSCRIBED before me this 3 day of August, 2007 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary ftbft CARLISLE 8080. CUA4KWVV COURW MV Corm*0011 EXIAM Apt U. 2010 mom Mt'A'M Mil Im ft Writ No. 2005-4835 Civil Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania vs. Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn Atty.: Terrence McCabe DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Penn- sylvania, bounded and described in accordance with a plan prepared by Eugene Albert Hockensmith, R. P. L. S., dated June 30, 1992 and recorded in Plan Book 65, Page 48 of the Cum- berland County Recorder of Deeds Office, described as follows: BEGINNING at an iron pin set on private easement and 15 foot right of way, said point set on western edge of Lot No. 2 as set forth on said plan; tiwam aisag Lot No. 2, 43 dWws 33 minutes 12 noon& first 113.25 feet to an iron pin; duum aloft Lot No. 3, Smth 39 41 ohmIn 04 as=WW W487410 fiiet to an iron pin set; thence along lands of Harry E. Goshom, North 48 degrees 51 minutes 04 seconds West 106.00 feet to an iron pin set; thence along private easement and right of way, North 34 degrees 08 minutes 06 seconds East 75.00 feet, to the place of beginning. BEING KNOWN AS 34 East Street, Mt. Holly Springs, PA 17065. Being the same premises which Dennis R. Goshorn and Janet L. Hopple, Executors of the Last Will and Testament of Minerva Grace Go- shorn, by deed dated the 6/6/1996, and recorded 6 / 29 / 1996 in the Office of the Recorder in and for Cumber- land County in Deed Book 143, Page 412, granted and conveyed to Barry S. Nelson, Teresa K. Nelson and Randy Lee Goshorn, in fee. TAX MAP PARCEL NUMBER: 23- 32-2338-021A. l+tUO'.') 00A1i138MU