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Home My WebLink About05-5787 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-811l J.D. #75736 NOVASTAR MORTGAGE, INC. 8140 Ward Parkway, #200 Kansas City, MO 64114 VS. NO. 0:; -~1P7 Cio~L~82-~ CHRISTINE M. HAMILTON AND JASON B. HAMILTON 430 Candlewyck Road Camp Hill, PA 17001 CIVIL ACTION- MORTGAGE FORECLOSURE This is an attemvt to collect a debt and any information obtained will be used for that vuroose. NOTICE You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil Action or for any other claim or relief requested by the plaintiff. You may lose money or property of other rights important to you. LlDianelCOMPLAININOV AST AR-HAMILTON CUMBERLAND 11-05. wpd YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, TO 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. COURT ADMINISTRATOR 4TH FL., CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 J o\Diane\COMPLAININOV AST AR-HAMILTON CUMBERLAND )).05. wpd NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.s.C. !lI692 ET SEQ., YOU MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF YOU DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE YOU WITH WRITTEN VERIFICATION OF THE DEBT, AS WELL AS THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. IF YOU DO NOT DISPUTE THE DEBT, IT IS NOT AN ADMISSION OF LIABILITY BY YOU. IF YOU NOTIFY US IN WRITING WITHIN THE THIRTY (30) DAY PERIOD, WE WILL CEASE COLLECTION OF THIS DEBT, OR ANY DISPUTED PORTION OF IT, UNTIL WE HAVE OBTAINED THE REQUIRED INFORMATION AND MAILED IT TO YOU. ONCE WE HAVE MAILED YOU THE REQUIRED INFORMATION, WE WILL CONTINUE THE COLLECTION OF THIS DEBT. THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR. THIS ACTION IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. J ,\DianeICOMPLAININOV AST AR-HAMILTQN CUMBERLAND 11-05. wpd COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 LD. #75736 NOVAS TAR MORTGAGE, INC. 8140 Ward Parkway, #200 Kansas City, MO 64114 VS. NO. 05" - C~U;C{VLr; CHRISTINE M. HAMILTON AND JASON B. HAMILTON 430 Candlewyck Road Camp Hill, PA 17001 CIVIL ACTION- MORTGAGE FORECLOSURE 1. Plaintiff is NovaStar Mortgage, Inc. (hereinafter "NovaStar"), a corporation with offices located at 8140 Ward Parkway, #200, Kansas City, MO 64114. 2. Defendants are Christine M. Hamilton and Jason B. Hamilton, adult individuals with a last-known address of 430 Candlewyck Road, Camp Hill, PA 17001. 3. Under date of June 7, 2004, defendants executed and delivered to AmStar Mortgage Corp. a mortgage upon premises 430 Candlewyck Road, Camp Hill, PA 17001 to secure the payment of the sum of $223,200.00. The said mortgage is recorded in the Department of Records in and for the County of Cumberland in Mortgage Book No. 1869, page 751, recorded June 10, 2004 and is incorporated herein by reference. A copy of the legal description of the premises is attached hereto and made a part hereof as Exhibit "A". 4. Through an Assignment recorded June 30,2,004 in Bk. 709, P. 2332, the loan was assigned to NovaStar, the within Plaintiff. j,IDianeICOMPLAININOV AST AR~HAMIL TON CUMBERLAND 11~05. wpd 5. The defendants are the real owners of premises 430 Candlewyck Road, Camp Hill, PA 17001. 6. In accordance with Act 91 of 1983, as amended, a combined notice providing the information required by ~403 of Act 6 of 1974, and Act 91 aforesaid, was sent to the defendants and no response was made in the appropriate period oftime. A true and correct copy of the aforesaid notice is attached hereto and made a part hereof as Exhibit "B". 7. The said loan is in default as a result of the failure to pay the monthly installments of $1 ,844.30 due on September 1, 2004 and on the 1 st day of each month thereafter. 8. The following is due on the loan: PRINCIPAL BALANCE $ 223,085.50 INTEREST (accrued thru 10/27/05 of $25,587.43. Interest after 10/27/05 shall accrue at the per diem rate of $56.41.) 25,587.43 LATE CHARGES (accrued thru 10/27/05 of $442.64. Late charges after 10/27/05 shall accrue at the monthly rate of $110.66) 442.64 FEES BILLED 52.50 PENALTY FEE 8,297.72 RECOVERABLE BALANCE 863.69 LESS ESCROW BALANCE -788.28 LEGAL COSTS 300.00 ATTORNEY'S FEE 7.000.00 TOTAL $ 264,841.20 WHEREFORE, Plaintiff, NovaStar Mortgage, Inc. requests this Court to enter judgment for foreclosure of the mortgaged property for the sum of $223,085.50, plus interest thereon of $25,587.43 plus $56.41 per day from October 27,2005 until judgment is paid in full, late charges of $442.64, plus late charges of $110.66 per month from October 27, 2005until judgment is paid in full, fees billed of $52.50, penalty fee of $8,297.72, recoverable balance of J,\D;ane\COMPLAIN\NOVASTAR-HAMILTON CUMBERLAND II-05.wpd $863.69, legal costs of $300.00, attorney's fees of $7,000.00, plus record costs, less escrow balance of $788.28. /7: STERN ~~ RCHO BY: /StEVEN K. BERG, Attorney for Plaintiff ./' J:IDianeICOMPLAININOV AST AR-HAMIL TON CUMBERLAND 11-05. wpd VERIFICATION Nicole Tavlor is the Foreclosure Specialist of NovaStar Mortgage, Inc. and is authorized to sign this Verification on behalf of same, and states that she verifies the foregoing Civil Action- M F I . Ch" d Hamilton th f" ortgage orec osure agamst r~st:lne an Jason and avers e statements 0 lact therein contained are made subject to the penalties of 18 P A C.S. 94904 relating to the unsworn falsification to authorities, and that same are true upon the signer's personal knowledge or information and belief. ~lct~ ~~ k:~ - ~IJOLE TAYL~, Foreclosure SpeJidist DATE: . . First American Title Insurance Company Commitment Number: A104-135 SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTAIN piece and parcel of iand in Lower Allen Township, Cumberland County, Pennsylvania; BEING Lot No. 108 on Plan of Lots entitled "Section No.4 - Allendale Development Corporation", made by Damon and Foster, Civil Engineers. Sharon Hill, Pennsylvania on November 27, 1959, revised March 24, 1960- and recorded in said County in Plan Book No. 11, page 30. AND with all improvements thereon and known and identified as No. 430 Candlewyck Road. BEING the same premises which Rex A. Herberl and Susan D. Herbert, his wife, by Indenture dated March 25, 1985 and recorded at Carlisle in the County of Cumberland on November 27, 1985 in Deed Book 31-P, Page 806, granted and conveyed unto Susan D. Herberl, in fee. AL T A Commitment Schedule C (A104-135 HAMILTON.PFO/A104-135 HAMILTON/B) . EXHIBIT l~ Certiflerl Article Number September 26, ?lrl.O ftJ], 'IlIII' lII~S ~3L3 SENDERS RECORD ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort a eon oor home is io defaul aDd the lende intends to foreclose. Specific information aboot the oature of the default is provided in the attaehed pal!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM EMAP mav b able to help to save vour home. This Notice explains how the DrOl!ram works. To see if HE MAP can helD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF T E DATE OF THIS NOTICE ..',' Take tbis Notice with YOU wben YOU meet with the Counseliol! Al!encv. The na address 1IIld number of Consumer Credit CounseUn A end servin vour Coun are Ustedat tbe end of tbis Notice. If ou bave an uestions mav call the Penns Ivania Housin Finance A ene' toll free at 1-800-342-239 . (Persons with imDaired bearinl! cau call 71 7-780-1 869l This Notice cODtains important legal information. H you have any question, representatives at tbe Consumer Credit Counseling Agency may be able to he explain it. You may also want to contact ao attorney in your area. The local b association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUE AFECTA SU DERECHO A CONTlNUAR VIVIENDO EN SU CASA. SI N COMPRENDE EL CONTENIDO DE EST A NOTlFICACION OBTENGA UN TRADUCCION INMEDlTAMENTE LLAMANDO ESTA AGENC (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMER MENCIONADO ARRIBA. PUEDES SER ELGIBLE PARA UN PRESTAMO PO EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAG ASSISTANCE PROGRA:VI" EL CUAL PUEDE SALVAR SU CASA DE L PERIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT I "43 II HOMEOWNER.'S NAME: PROPERTY ADDRESS: JASON HAMILTON 4JO CANDLEWYCK RD CAMP HILL, PA 17011 0001189661 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: NOV AST AR MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROG YOU MAYBE ELJGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNE EMERGENCY MORTGAGE ASSISTAl\'CE ACT OF 1983 (THE "ACT"), YOU MAY ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: .:. IF YOUR DEFAULT HAS BEEN CAUSED BEYOND YOUR CONTROL, '. <2' IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO P YOUR MORTGAGE PAYMENTS, AND . <2' IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLIS BYTHE PENNSYL VANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to ~ tempo stay of foredosure on your mortgage for thirty (30) days from the date of this Notice. During t time you must arrange -and attend a "face-to-face" meeting with one of the consumer ere counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WIT THE NEXT 30 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGA ASSISTAN E YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF OTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW T BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIESclfyou meet with one of the consu credit counseling agencies listed at the end of this notice. the lender may NOT take action again you for thirty (30) days after the date of this meetmg. The names addresses and tele hone num of desi ated consumer credit counselin a encies for the coun in which the ro is locate are set forth at the end of this Notice. It is only necessary to schedule one face-to-face rneetin' . Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for reasonS set forth later in this Notice (see following pages for specific information about the na of your default) If you have tried and are unable to resolve this problem with the lender, you ha the right to apply for financial assistance from the Homeowner's Emergency Assistance Monga Assistance Program. To do so, you must fill out, sign and file a completed Homeowner' Emergency Assistance Program Application with one of the deSignated conswner credit counselin agencles listed at the end of this Notice. Only consumer credit counseling agencies ha applications for the program and they will assist you in submitting a complete application to Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FU..E YOUR APPLICA nON PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO IiOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER., FORECLOSURE "'lAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION-AvaiJable fuDds fOT emergency mortgage assistance are very limited. They will e disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housi Finance Agency has sixty (60) days to make a decision after it receives your application. Dwing that time:, foreclosure proceedings will be pursued against you if you have met the time requirements set forth aba You \\'ill be notified directly by the Pennsylvania Housing Finance Agency of its decisjon on yo application. NOTE: IF YOU ARE CURRENTI. Y PROTECTED BY TIlE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TIDS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (lfycu have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE yoUR. MORTGAGE DEFAULT (BriDe: it UP to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by lbe above lender on yotlf prop< located at: 430 C.ANDLEWYCK lU) CAMP HILL, PA 17011 IS SERIOUSLY IN DEFAUL:Tbecause of: NONPAYMENT YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the fnllov,ing months and following amounts are now past due: 09/01104 through 09/26/85 Other cbarges (explain/itemize): $24,307.88 Corporate advances: S842.19 TOTAL AMOUNT PAST DUE: $25,150.07 HOW TO CURE THE DEFAULT-You may cure the delilul, within THIRTY (30) DAYS of the date f this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH 1 $$25,150.07. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME D DURING THE TIIlRlY (30) DAY PERIOD. Fa nts must be made either b cashier's chock cenifi check or moneY order made oavabk and sent to: AttD: Cashieri1l2 Nov..star Mort!!:a2'e 8140 W.rd Porkwav. Suite 300 Kan... City. MO 64114 IF YOU DO NOT CURE THE DEFAULT-If you do nol cure the default within THIRTY (30) DA of the date of this Notice, the lender intends to exercise its rie.hrs to accelerate the mort2a1!C debt. This mea that the entire outstanding balance of this debt will be considered due immediately and you may Jose chance to pay the mortgage in monthly installments. If full payment of the total amount past due is nol ma within THIRIT (30) DA YS, the lender also intends to instruct its attorneys to start legal action to foreelo UDOn your mort2311ed DrODertv. ' IF THE MORTGAGE IS F'ORECLOSED UPON-The mortgaged property will be sold by 1he to payoff tbe mortgage deht. If the lender refers your case to its anorneys, hut you cure the deIinque before the lender begi[1$ legal proceedings against YOll, you win stlll be required to pay the reasona attorney's fees that v.'Cre actually incurred, up to $50.00. HO\\'e,,'er, if legal proceedings art: started agai you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exc S50.oo. Any attorney's fees will be added to the amount you owe the lender, which may also include 0 reasonable costs. If OU ClIre the default within the THIRTY 30 DAY eriod ou will oot e reauired to Dav attornev's fees. OTHER LENDER REMEDIES-The lender may also .... yon personally for the ~ priDCi balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERlFF'S SALE-Ifyou have not cured default witlun the THIRTY (30) DAY period and foreclosure proceedings have begun, ou still have the ri to cure the default and event the sale at an rime u to one hour re the Sheriffs Sale. You ma do so a in the total amount then t due Ius an late or other char es the due reasonable attornc '5 fees a costs. c nnected \\ith tile foreclosure sale and an other costs connected with the Sheriffs Sale as . cd wrilulIz bv the lender and bv nerfOmlln2 an", other reauirements under the mormaee. Curing your default the maDner set forth in thii notice wiD restore your mortgage to the same position as if you had Rev defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that rhe earliestda.. that such . Sberiff's Sale of the mortgaged property could.be held would be approximately 4 months from the date this Notice. A norice of the- actual date of the Sheriffs Sale ""ill be sent to you before the sale. Of coucse, amount needed to cure the default will increase the longer you wait You may find out at any time exa what ~e reqUired payment or action win be by cQDtacting the lender. ...,. HOW TO CONTACT THE LENDER: Name of Leoder: NovaStar Mortgage, Inc. Address: 8140 Ward Parkway, Suite 200 Kansas City, MO 64114 (888) 289-1208 (816) 237-7479 Collections Pbone Number: Fax Nnrnber: Contact Person: EFFECT OF SHERIFF'S SALE-You should realize that a Sheriffs Sale will end your ownmhip or. mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time ASSIJMPTiON OF MORTGAGE-You may not sell or transfer your hOIl1e to a buyer f>r traMferee will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: ~ TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF TIlE MORTGAGE DEB OR TO BORROW MONEY FROM ANOTHER LENDING INSTITt,TION TO PAY OFF TIllS DEBT. ~ TO HAVE THIS DEFAULT ctIll.ED BY ANY'rHIJU)PAIt'I'Y ACTINGONYOUll. BEHALF. 0) TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL l' HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEF AUL l' MORE THAN THREE TIMES I ANY CALENDAR YEAR.) ~ TO ASSERT THE NONEXIS1DICE OJ' It. DEFAULT IN ANY FORECLOSURE . PROCEEDING OR ANY OTHER LAWSUIT INSTIThTED UNDER THE MORTGAGE DOCUMENTS. .c. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. <t. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (please see attached docnmept) PREVIOUS DISCHARGE IN BANlOtUPTCY: In die c:vcnl that the underlying debt has been discharged as II. result Df a bankruptcy pruoeeding, Nm..aSta:r MortgagE: hereby acknowledges thaI Ill' not assessing personal liability for the debt to:be: borro ) Ind thet its recourse in w11ecuon matk:n; shall be hmired ta the: cl)lIateral dcscnbed in lhc: security instrument- If you have ~ y recei\"cd a discharge in bankruptl:y. this c..................tda;a iJ not and should not be construed- to be an atlCmpt to c;;(Illcct a debt., but y enforcc:ment of a lien against pmpetty. This letter is written as an auc:mpc. to coIaecta debt and any infornw.boo cblained will be usrd for that purpose.. Sincerely, NovaStar Mortgage, Inc September 26, 2 5 Certrfled Arlicle Number 1],b[\ .3'lOJ, 'WI9 14115 113Ilb SENDERS RECORD ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort a e on our home is in defaul and the lende intends to foreclose. Specific information about the nature ofthe default is provided in the attached l)aECS. he HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM EMAP may b able to heln to save vour home. This Notice explains how the proeram works. To' see if BEMAP can help, vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with vou when YOU meet with the Counseline Aeency. The lIam address and ODe "limber of Co_mer Credit Couuselin A end servin our Coun are listed at the end of this Notice. If ou have an uestions vo mav call the Pennsvlvania Housin Finance A ene toll free at 1-800-34Z-:Z39 . (Persons with impaired hearine ean call 717-780-1869) This Notice contains important legal information. If you have any question representatives at the Consnroer Credit Counseling Agency may be able to hel explain it. You may also want to contact an attorney iu your area. The local ba association may be able to help you find a lawyer. LA NOTIFlCACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUE AFECT A SU DERECHO A CONTlNUAR VlVIENDO EN SU CASA. 81 N COMPRENDE EL CONTENIDO DE ESTA NOTIFlCACION OBTENGA UN TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCI (pENNSYL V ANlA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMER MENCIONADO ARRIBA. PUEDES SER ELGIBLE PARA UN PRESTAMO PO EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAG ASSISTA1'lCE PROGRAi'\1" EL CUAL PUEDE SALVAR SU CASA DE L PERIDA DEL DERECHO A REDIMIR SU HlPOTECA. HOMEOWNER'S NAME: PROPERTY ADDRESS: CHRISTINE HAMILTON 430 CANDLEWYCK RD CAMPHILL,PA 17011 0001189661 LOAN ACCT. NO.: ORIGINAL LENl)ER: CURRENT LENDER: NOV ASTAR MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRA YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWJ\>"E EMERGENCY MORTGAGE ASSIST^"'\'CE ACT OF 1983 (THE "ACT"), YOU MAY ELIGmLE FOR EMERGENCY MORTGAGE ASSISTANCE: .:. IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTAN BEYOND YOUR CONTROL, (0 IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PA YOUR MORTGAGE PAYMENTS, AND .:. 'IF YOU MEET OTIfER ELIGIBILITY REQUIREMENTS ESTABLISHE BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Vndel" the Act, you are entitled to a tempo stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During time you must arrange and attend a "face-to-face" meeting with one of the consumer c coooseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY M RTGA ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF T NOTICE CALLED "HOW TO CO YOUR MORTGAGE DEFAULT" EXPLAINS HOW T J3RING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENClES-lfyou meet with one of the cons credit counseling agencies listed at the end of this notice, the lender may NOT take action again you for thirty (30) days after the date of this meeting. The names addresses and tel hone num of desi ated consumer credit counselin a encies for the COWl in ,vhich the TO is local are set forth al the end of this Notice. It is only necessary to schedule one face-to-face meetin Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for t reasons set forth later in this Notice (see following pages for specific information about the na of your default) If you have tried and are ooahle to resolve this problem with the lender, you ha the right to apply for financial assistance from the Homeowner's Emergency Assistance Mortga Assistance Program. To do so, you must fill out, sign and file a completed Homeown ' Emergency Assistance Program Application with one of the designated conswner credit coooselin agencies listed at the end of this Notice. Only consumer credit counseling agencies hav applications for the program and they will assist you in submitting a complcte application to t . Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days ofyoUT face-la-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERlODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HO:\IE IMMEDIATELY MiD YOUR APPLICATION FOR MORTGAGE ASSlSTA."CE WILL BE DENI!:D. AGENCY ACTION-Avail.ble fund> for emergency mong.ge assislance .,., very limited. They wiD disbursed by the Agency under rhe eligibility criteria established by the Act The PCl1IlSylvania Hous. Finance Agency has sixty {60} days to make .a decision after it receives your application. During that tiroe. 0 foreclosure proceedings wiU be pursued against you if you have met the time requirements set forth aha Yau will be notified directly by the Pennsylvania Housing Finance Agency of its decision on y application. NOTE: IF YOU ARE CUR.RE.NTL Y PROTECTED BY THE FILum OF A PETITlON IN BA."IKRUPTCY, THE FOLLOWlNG PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS Al'I ATfEMI"T TO COLLECT TIlE DEBT. (If you have med bankruptcy you can still apply for Emergency Monll"ge Assistance.) HOW TO CURE YOUR MORTGAGE DEF AUL T (Brine it un to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by We above lender on your p located at: ;;.- .,; 430 CANDLEWYCK RD CA.iUP HILL, PA 17011 IS SERIOUSLY IN DEFAULT bccauseof: NONPAYMENT YOU HAVE NOT MADE MON11lLY MORTGAGE PAYMENTS for !he following months and t foUo\\ring amounts an: now past due: 09/01104 througb 09/26/05 Other charges (explain/itemize): $24,307.88 Corporate advances: 5842.19 TOTAL AMOUNT PAST DUE: 515,150.07 HOW TO CURE THE DEFAULT-You may cure the default within nnRTY (30) DAYS of the date this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH I 5525,150.07, PLUS Al\Y' MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME D DURING THE THIRTY (30) DAY PERIOD. pa nts must he made cith ,b c..hier', che;:k cerofie check or moneY order made navable and sent to: Attn: Cashierinl! NovaStar Mort28ee 8140 Ward Parkwav. Suite 300 KaDsas Citv. MO 64114 IF YOU DO NOT CURE THE DEFAULT-If you do not CW" the default within TIllRTY (30) DAY of the date of this Notice, the lender intends to ex.ercise its rie:hts. to accelerate the mort2a2e debt. This that the entire outstanding balance of tbis debt will be considered due immediately and you may lose chance to pay the mortgage in monthly instlllments. If full payment of the total amount past due is not mad within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to st:3rt legal action to fored upon your mort2aeed Pro-oertv. . IF TIlt MORTGAGE IS FORECLOSED UPON-The ""'"Pied property Will be sold by the S If to :payoff the mongage debt. If the lender refers your case to its attorneys, but you cure the delinque y befOTe the lender begins legal proceedings against you, you will still be required to pay the reasona Ie attorney's fees that were actually incurred. up to $50.00. However. if legal proceedings are started agai t you, you win have to pay all reasonable attorney's fees actually incurred by the lender even if lhey exc d $50.00. Any attorney's fecs will be added to the: amount you owe the Jender, which may also include 0 reasonable co,ts. If on cure tbe default witbin tbe TIDRTY 30 DAY eriod \"ou will not e reauired to Da,,' attornev's fees. OTHER LENDER REMEDIES-The lender may also .... yoa personally for the UDpaid priD<i balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have .DOt cured e default within the THIRTY (30) DAY period and foreclosure proceedings have begun, u still have the ri t to cure e default and fevent the sale at an time u to one hour before the Sheriffs Sale. You ma do so a in the total amount then ast due Ius an late or other c es then due reasonable attorn's fees a c conn ted with the foreclosure sale and an other costs connected with the Sheriffs Sale as 5 cified writimz. bv the lender and by Derfonnin2 any other reauirements under the mort2a2e. Curiag your default tbe manner set forth in this Dolice It,1I restore your mortgage to the same poRtion as if you had nev defaulted. EARLIEST POSSffiLE SHERIFF'S SALE DATE-It is estimated that the earliest da" that such Sheriff's Sale of tb~ mortgaged propeny could be held would be approximately 4 months frtlm tbe date r this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, t~ amount needed to cure the default ",ill increase the longer you wait. You may find out at any time exac what the required payment or action will be br contacting lh<: Imler. HOW TO CONTACf THE LENDER; Phone Number: Fax Number: Contact Person; Name of Lender: NovaStar Mortgage, Inc. Address: 8140 Ward Parkway, Suite 200 Kansas City, MO 64] 14 (888) 289-1208 (816) 237-7479 Collections EFFECT OF SHERIFF'S SALE-You should realize that a Sheriffs Sale will end your ownership of the mOIlgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by tbe lender at any time. ASSuMPTtON OF MORTGAGE- You may not sen or transfer your hoJne to a buyer or transferee wh will assume the: mortgage debt, provided that all the outstanding payments:, charges and attorney's fees an costs are paid prior to or at the sale and that the other requirements of the mortgage are satisf1ed. YOU MAY ALSO HAVE TIlE RIGHT: (0 TO SElL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEll OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF TIDS DEBT. '" TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOm BEHALF. <I> TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEF AUL T. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) '" TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. -:. TO ASSERT ANY OTHER DEFENSE YOU BELltVE YOtl MAY HAVE TO SUCH ACTION BY THE LENDER. <- TO SEEK PROTECTION UNDER THE FEDERAL BANKRUl'TCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOl..'R COUNTY, (please see attached dOcUllleDt) PREVIOUS DISCHARGE rN BANKRUPlCY= In dtc c:vtnl1bat the underlying deb! has beep disclwged as a result of, bankruptcy proceeding. NonStar Mongage: hereby acknowledges that it is nolas5ess.ing personal liability for tht: debt to. tllI" btlTTOwu(s and 1hat its recourse in coilel::tion 'maners shall be limited to the COUltc:ra1 described in the: security instrumcm. If you have previousl recei'ved a discharge in bankruptcy, this correspondence is not and should not be c01lstrued [Q be an anempt to collect a debt, but onl enforcement ofa lien against property This letter is wrIllel'l U;u] auempt to collect a debt many inf'.ormation obtained wall be ulied flll'that purpose. Sincerely, NovaSrar Mortgage, IDc HEMAP Counseling Agencies Page 1 of 1 ~I,""'" Counseling Agencies .~crr Edward G. Rendell .c...hmrR-e.t~o..n A. William Schenck Executive Dll'ecJor Brian A. Hudson, Sr. y~ ~~PHFA CLICK & GO .~ CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 cees of Western PA 2000 Linglestown Road Harrisburg, PA 11102 888-511-2227 Community Action Commission of C8ptla1 Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 LoveShip, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762.3285 PHFA 211 North Front Street HBrrlsburg, PA 17110 800-342-2397 ~ " Effective 8/26/2004 at 3:31:05 PM Return to MAP QUJ3:stion~tr!m-ardiog..the Homeowners' Emergency Mortgage Assistance Prol;}ram sh:Ou1d be d1recledto HEMAP at 1=100-342:'2397. .' - . -.." -- - - -- ------ Home I Conferences & Events I Contact Us I Directions I Disclaimer I Future Home Buyer Pl'Ogram I Handbooks & Forms I Housing Programs I Housing Study !Interest Rates I Legislative I Links I News & Notices I Press Releases! Quarterly Disclosure I Rental Housing Properties I Request For Proposals I Right To. Know (PDF) I pow~~ Geogle- I~ Copyright@ 2004 ~!J.nsvlvani<\J:ioLu~jn9..Ei.n.in~e_Agl;!nl;Y=- All rights reserved. Search P H F A Updllled August 06,2004 "11:09 AM http://www . phfa.orglprogramslhemapnenderslheaPage21.html 09/03/2004 (::I ~ ;:J ~ Ul \t- \t In . if( - ....0 \) ~ ....0 ~ \) C> ~ ~ ~ o (~:. .-' C::~ 4....-,. ,__J1 -- t~ -- \ -, "j ,-"", q, G ::;l ." -;1 ~~~,~~ V) " ,,>,(.J -:-\~ .;-\ -cj ,n.,__, -"-:i1"1 -:",~~ --- _.- c.? ~ r<} ,~, SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05787 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOVAS TAR MORTGAGE INC VS HAMILTON CHRISTINE M 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 HAMILTON CHRISTINE M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , HAMILTON CHRISTINE M 430 CANDLEWYCK ROAD CAMP HILL, PA 17011 PER CURRENT HOME OWNER, DEFENDANTS MOVED OUT OF STATE. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 14.40 5.00 10.00 .00 47.40 ., So an~",~~ ..:;.._ .... ...._ " ...../ ._,c"'. . .... ",-:C' ,_.", ~~~/~~::/- R. Thomas Kline Sheriff of Cumberland County STERN & STERCHO 11/14/2005 Sworn and subscribed to before me this is fh day of /lkiv.z.,;\b,... ;)fJO" A.D. ~ ~~ Frot onotar SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05787 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOVASTAR MORTGAGE INC VS HAMILTON CHRISTINE M 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 HAMILTON JASON B but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT , HAMILTON JASON B 430 CANDLEWYCK ROAD CAMP HILL, PA 17011 PER CURRENT HOME OWNER, DEFENDANTS MOVED OUT OF STATE. Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 .00 5.00 10.00 .00 21.00 So answer,,: ) . ,-"ic:"' ._/ >''''''' . -4"'. /../----- _./~ ~~,' ,,' /"'/"L '/-- '- _,._~.- R. Thomas <Kline Sheriff of Cumberland County STERN & STERCHO 11/14/2005 Sworn and subscribed to before me this JS~f. day of ;JOW.M~ aOQ, ~ pro~not COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 J.D. #75736 NOVASTAR MORTGAGE, INC. 8140 Ward Parkway, #200 Kansas City, MO 64114 VS. NO.05-5787 CHRISTINE M. HAMILTON AND JASON B. HAMILTON PRAECIPE TO REINSTATE CIVIL ACTION Kindly reinstate the civil action in the above captioned matter. STERN AND STERCHO 12/12/2005 ],\DlANE\COMPLAlNlNOV ASTAR.HAMILTON CUMBERLAND 11-05. WPD ~, \"'.3 .. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 J.D. #75736 NOVASTAR MORTGAGE, INC. NO. 05-5787 VS. CHRISTINE M. HAMILTON AND JASON B. HAMILTON CERTIFICATE OF SERVICE I, STEVEN K. EISENBERG, attorney for the within Plaintiff, hereby certify that Reinstated Civil Action was mailed to the Defendants by certified mail, return receipt requested on December 20, 2005 and received by the Defendants on January 14, 2006 evidenced by copies of certified mail receipts and signed green cards attached. STERN AND EISENBERG LLP .~ >" . 0 .;....).., ,;,(//1,/'-/ / ''I''{;' ' /, d . . . . ;;..'0 " ,. '," '" \' . - i. _. ~""",~', ,jr_/,<~.rAA,.:( 'o?,\,:cl.l, :y,,"C' tl / STEVEN K. EISENBERG Attorney for Plaintiff 1/19/06 ~ 0- Lfl ru 0- I'- I'- 0- .-'l .-'l D D D D 0- fT] D Lfl D D I'- U.S. Postal Service", CERTIFIED MAIL", RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) Postage $ Certified Fee Return ReceIpt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees $ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: J?son }3. .hR:':':1:;_~.t(y' -' c, ~~.~ n:uf:to~~ SC: 2S~lD 2. Article Number (Transfer from service label) PS Form 3811 . Februal'f 2004 Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space penn its. 1. Article Addressed to: Ch~~G t ~_;;e 'H;c~.,....tl ~C'~ 1:~ ':::\1'--- 31uf::to'_) SC 2991G 2. Article Number (Transfer from service label) PS Form 3811 . Februal'f 2004 U.S. Postal Service,. ',;, f':i CERTIFIED MAIL,. RECEIPT , 1 (Domestic Mail Only; No Insurance Coverag" ProV/d~d}.~:, , ' fT] I'- ru 0- I'- I'- 0- .-'l .-'l D D D D 0- fT] D Postage $ /~ Certified Fee ifr "\) Return Receipt Fee (Endorsement Required) I", "'lO \;;, Restricled Delivery Fee ' n"Q1:; )'0 (Endorsement Required) 7 t (, > \1, , ' ~'" - -_/ / Total Postage & Fees $ ',--(JS~/ Lfl D D I'- o Agent o Addressee C. Date of Delivery D. 3. ~';.lY'ice Type " ~Certified Mail lExPress Mail o Registered Return Receipt for Merchandise o Insured Mail C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 7005 0390 0001 1977 9273 Domestic Return Receipt 102595-02.M-1540 o Agent o Addressee Date of Delivery DYes o No 3. Service Type o Certified Mail o Registered D Insured Mail o Express Mail o Return Receipt for Merchandise DC.D.D. 4. Restricted Delivery? (Extra Fee) DYes 7005 0390 0001 1977 9259 Domestic Return Receipt 1 Q2595-02.M.1 540 --' c- " cJ . COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 I.D. #75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendants CHRISTINE M. HAMIL TON AND JASON B. HAMILTON for failure of said Defendants to file a responsive pleading to the Complaint within twenty (20) days after service thereof. Please assess damages as follows: BALANCE DUE $ 223,085.50 32,638.68 INTEREST (accrued thru 3/1/06 of $32,638.68. Interest after 3/1/06 shall accrue at the per diem rate of $56.41.) LATE CHARGES (accrued thru 2/06 of $885.28. Late charges after 2/06 shall accrue at the monthly rate of $110.66.) 885.28 FEES BILLED 52.50 PENALTY FEE 8,297.72 RECOVERABLE BALANCE 863.69 LESS ESCROW BALANCE (788.28) J:\ANNE\SALESICUMBERLANDlNOVAST AR.HAMIL TON.2.06.DOC ,.., , . LEGAL COSTS ATTORNEY'S FEE TOTAL J:\ANNEISALESICUMBERLANDlNOVASTAR. HAMil TON.2.06. DOC BY: 300.00 7,000.00 $ 272,335.09 STERN AND EISENBERG LLP <'.~ ./~ /. . '--.. 1./ I F CJ\... STEVEN K. EISENBERG, Attorney for Plaintiff ~~ (.::0 -\ry.. ?\ .-D \) \) " r - ~ - -J tn. lr) ~ ~ ~ 'IJ ~ "'\:J (U -C. - . .. . ~ - . ~ r ~ , - COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVil ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG lLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 1.0.#75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF MONTGOMERY I, the undersigned, being duly sworn according to law, deposes and says, to the best of his knowledge, information and belief, Defendants': 1. last-known address is: 12 Turnberry Way, Bluffton, SC 29910 2. Are over the age of twenty-one. 3. Are not now nor have been within the last six (6) months in the Armed Services of the United States as defined in the Soldiers' Civil Relief Act of 1940, as amended. COMMONWe:Al..'j,:"~ OF PENNSYLVANIA NOTAR L SEAl HElEN CAPASSO Notary Public Jenkinlown Bore,. Montgomery County CommissiOl1I,/I;o'Qc~r21, 2008 BY: STERN AND EISENBERG llP ,~ '-~.-/ BRADLEY D. SISLEY, Attorney for Plaintiff Sworn to and subscribed befor~e this!dfaay of L YU!l/V;:?"-- ,2006. ';7- A( "y,:L/.)A"2P J:\ANNE\SALES\CUMBERLANDlNOV AST AR. HAMIL TON.2 .06 DOC ;+ >' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 1.0. #75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON CERTIFICATION UNDER RULE 237.1 I, the undersigned, attorney on the writ and attorney for plaintiff, hereby certify that a ten day notice of intention to enter judgment by default was sent to Defendants in accordance with Pa. R.C.P. 237.1. A true and correct copy of said notice is attached hereto. BY: STERN AND EISENBERG LLP '/ }~ FG- STEVEN K. EISENBERG, Attorney for Plaintiff J.IANNEISALESICUMBERLANDlNOV AST ARHAMIL TON .2.06.DOC ~ " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CML ACTION - LAW NOVASTAR MORTGAGE, INC. VS. NO. 05-5787 CHRlSTINE M. HAMILTON AND JASON B. HAMILTON To: Jason B. Hamilton 12 Tumberry Way Bluffton, SC 29910 Christine M. Hamilton 12 Turnberry Way BIuffton, SC 29910 Date of Notice: February 8, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCEPERSONALL Y ORBY 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE -YOU CAN GET LEGAL HELP:] 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. COURT ADMINISTRATOR 4TH FL., CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 STERN AND STERCHO _L~ 4f1/~ C," lu. . -"L;ut-t<1t~5( ~~&'~-y BY: STEVEN K. EISENBERG Attorney for Plaintiff 410 The Pavilion Jenkintown, P A 19046 (215) 572-811] I.D. #75736 J: \Angela\Ten Day\Cumberland\NOV ASTAR.HAMIL TON .CUMBERLAND.10.DA Y .2.06. wpd COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 1.0.#75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON CERTIFICATE UNDER ACT 91 OF 1983 It is hereby certified that the Sheriff's Sale scheduled in the above-captioned matter is not protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688, No. 621 because notice, as required, was sent to Defendants and no timely response was made. STERN AND EISENBERG LLP BY: '1 'L/L-1 FCrL STEVEN K. EISENBERG, Attorney for Plaintiff J.IANNEISALESICUMBERLANDlNOVAST AR.HAMIL TON.2.06.DOC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 1.0.#75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: NovaStar Mortgage, Inc. 8140 Ward Parkway, #200 Kansas City, MO 64114 Christine M. Hamilton and Jason B. Hamilton 12 Turnberry Way Bluffton, SC 29910 BY: STERN AND EISENBERG LLP 'l L / L/pG"-..- STEVEN K. EISENBERG, Attorney for Plaintiff J .IANNEISALESICUMBERLANDlNOVAST AR HAMIL TON.2.06. DOC ',; ..e( ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION , PRAECIPE FOR WRIT OF EXECUTION NovaStar Mortgage, Inc. Confessed Judgment x) Other File No. 05-5787 Civil Term Caption: vs. Amount Due $777. llS Og Interest from 3/1/06 at the per diem rate of $56.41 until judgment is paid in full Atty's Comm Costs Christine M. Hamilton and Jason B. Hamilton TO THE PROTHONOTARY OF THE 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. Issue writ of execution in the above matter to the Sheriff of Cumber] and for debt, interest and costs, upon the following described property of the defendant(s) 430 Candlewyck Road, Camp Hill, PA 17011 County, PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of 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). o (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 March 1, 2006 Signature: Print Name: Address: ~ \ ,j\./ r(j,~ Attorney for: Telephone: St~vp-n K. E;Rp.nhp.r~. F.~q. The Pavilion 261 Old York Road, Suite Jenkintown, PA 19046 Plaintiff 410 (215) 572-8111 Supreme Court ID No.: 75736 (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. ~ ~ r ~ AJ ....... r...', ~ t- t ~~ 2 ~:-O~ ~ ..z "6g.. --- ~ -- ~ ~ --- V1 \) 6 vel)' 0 "'- C) C 0 -t c> 'i\.f' ~ ~ C' \> Q ~ \) () r I I , R..J T--0, 0~ )0 ~ :::: - :;- 1-F t: - - "" - ~.~ - ~ '" f5. - --- :1- V l '- :,;1-24-0807-113 \ . ALL THAT CERTAIN piece and parcel ofland in Lower Allen Township, Cumberland County, Pennsylvania; BEING Lot No. 108 on Plan of Lots entitled "Section NO.4 - Allendale Development Corporation", made by Damon and Foster, Civil Engineers, Sharon Hill, Pennsylvania on November 27, 1959, revised March 24, 1960 and recorded in said County in Plan Book No. 11, Page 30. AND with all improvements thereon and known and identified as No. 430 Candlewyck Road. BEING the same premises which Susan D. Herbert, by Deed dated June 8, 2004, and recorded !une 10, 2004, in Book 263, Page 2292, granted and conveyed unto Christine M. Hamilton and Jason B. Hamilton, hu,'baJicl and wife, in fee. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5787 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY. To satisfy the debt, interest and costs due NOV ASTAR MORTGAGE, INc., Plaintiff (s) From CHRISTINE M. HAMILTON AND JASON B. HAMILTON (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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $272,335.09 LL $.50 Interest FROM 3/1106 AT THE PERDlEM RATE OF $56.41 UNTIL JUDGMENT IS PAID IN FULL Atty's Comm % Due Prothy $1.00 Other Costs Atty Paid $150.40 Plaintiff Paid Date. MARCH 7, 2006 '1 (Seal) By: Deputy REQUESTING PARTY. Name STEVEN K. EISENBERG, ESQUIRE Address: THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone. 215-572-8111 Supreme Court ID No. 75736 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 1.0.#75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON AFFIDAVIT PURSUANT TO RULE 3129.1 STEVEN K. EISENBERG, attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 430 CANDLEWYCK ROAD, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or Reputed Owner(s): Christine M. Hamilton and Jason B. Hamilton 12 Turnberry Way Bluffton, SC 29910 2. Name and address of Defendant(s) in the judgment: Christine M. Hamilton and Jason B. Hamilton 12 Turnberry Way Bluffton, SC 29910 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Richard P. Matthews 19 Blue Spruce Drive Enola, PA 17025 J.IANNE\SALES\CUMBERLANDlNOV ASTAR HAMILTON .2. 06. DOC J & J Custom Counters 15 Popps Ford Road York Haven, PA 17370 Gregory A. Denning (the address or whereabouts of the above creditor cannot be reasonably ascertained) Susan A Herbert 605 Showers Street Harrisburg, PA 17104 Duty's Lock Safe & Security, Inc. 4301 Carlisle Pike Camp Hill, PA 17011 Lower Allen Township 120 Limekiln Road New Cumberland, PA 19070 James Appollonio & Christine Appollonio 430 Candlewyck Road Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: N/A 5. Name and address of every other person who has any record lien on the property: N/A 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: N/A 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: Tax Claim Bureau Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 J.IANNEISALESlcUMBERLANDlNOVAST AR HAMILTON .2. 06'oOC <II ~.-: Domestic Relations Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Occupant 430 Candlewyck Road Camp Hill, PA 17011 J verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 3/1/2006 STERN AND EISENBERG LLP / l IV BY: Fu.,,- STEVEN K. EISENBERG, Attorney for Plaintiff J.IANNEISALESlcUMBERLANDlNOVASTAR.HAMIL TON.2.06.DOC .... ~ --,l ( ..~ -.-\ .. - COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 1.0. #75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Christine M. Hamilton and Jason B. Hamilton 12 Turnberry Way Bluffton, SC 29910 Your real estate at 430 CANDLEWYCK ROAD, CAMP HILL, PA 17011 is scheduled to be sold at Sheriff's Sale on SEPTEMBER 6,2006 at 10:00 A.M., in the Cumberland County Courthouse, Carlisle, PA, to enforce the court judgment of $272,335.09 obtained by Novastar Mortgage, Inc. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to Stern and Eisenberg the back payments, late charges, costs and reasonable attorney's fees due. To fine out how much you must pay, you may call Stern and Eisenberg, telephone (215) 572-8111. 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. J.IANNEISALES\cUMBERLANDlNoVAST AR. HAMILTON .2.06.DoC You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Stern and Eisenberg, telephone (215) 572- 8111. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call Stern and Eisenberg, telephone (215) 572-8111. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date. This Schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERENCE SERVICE COURT ADMINISTRATION CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 J.IANNEISALESICUMBERLANDlNoV ASTAR.HAMIL ToN.2 .06.DoC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 I.D. #75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON RE PREMISES: 430 CANDLEWYCK ROAD, CAMP HILL. PA 17011 Dear Sir or Madam: Please be advised that I represent the above creditor which has a judgment against the above defendant. As a result of a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of Cumberland County on SEPTEMBER 6, 2006 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, PA. The sale is being conducted pursuant to the judgment in the amount of $272,335.09 plus interest thereon entered in the above matter in favor of plaintiff against the above- named defendant(s) who are also the real owner(s) of said premises. I have discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriff's Sale upon your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice. A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days thereafter. BY: STERN AND EISENBERG LLP /t II' /) ,..--!. - / " / 0,' / _oJ y J/'- STEVEN K. EISENBERG, Attorney for Plaintiff 3/1/2006 J.IANNEISALES\cUMBERLANDlNOV AST AR. HAMIL TON.2.06.DOC 13-24-0807-113 - ALL THAT CERTAIN piece and parcel of land in Lower Allen Township, Cumberland County, Pennsylvania; BEING Lot No. ]08 on Plan of Lots entitled "Section No.4 - ABendale Development Corporation", made by Damon and Foster, Civil Engineers, Sharon Hill, Pennsylvania on November 27, 1959, revised March 24, 1960 and recorded in said County in Plan Book No. 11, Page 30. AND with all improvements thereon and known and identified as No. 430 Candlewyck Road. BEING the same premises which Susan D. Herbert, by Deed dated June 8, 2004, and recorde~ !une 10,2004, in Book 263, Page 2292, granted and conveyed unto Christine M. Hamilton and Jason B. Hamilton, husbaliO and wife, in fee. (-; --i! ~ I c~,\ \ ... COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (2]5) 572-8111 LD, #75736 NOV ASTAR MORTGAGE, INC. NO. 2005-5787 Civil Term VS. CHRlSTINE M. HAMILTON AND JASON B. HAMILTON CERTIFICATE OF SERVICE I, STEVEN K. EISENBERG, ESQ., attorney for the within Plaintiff, hereby certify that notice of the Sheriff's Sale was mailed to the Defendants by certified mail, return receipt requested on June 8, 2006. I further certify that notice of the Sheriff's Sale was mailed to each lienholder by regular, first-class, postage prepaid mail on June 8, 2006 as evidenced by copy of certificates of mailing attached. STERN AND EISENBERG LLP ~~~ STEVEN K. EISENBERG Attorney for Plaintiff 6/12/06 ~~~~~~~~~~~~i,;'m~ii:G*~~!'~~ ~~~~~~r:~~'2~J}~~~~}l~~ ,PQSTAL s~Rvlc.L.--G_ERT1E!CATE QLM~lL'NG :~fl,'~:'1~!~.\tif;li~'J::~,:_,t_~~':-:l.:4Ii:;!h;, " '~-"'" rr1 ;.;"'.':'~~..;.H!.Y..,!l&'fJ.1~i.'Ir!i_;;~,~.,~'.f~(_~l.",.,~..'.:;~f'!'!,i;.;:.n.i:.:',',,',',,':,;,'.'~'. :~" ~~9\ UF~E~ 1~~~~,2N~~S~~~~~~~~i~;NA TIONAl MAIL, DO,S N_'" ~"J;:t.~*i.lo;o'obd!~.{.!...~~"""li:OO!b""'h<':'.!'_"" ,,',.,.....:n.J.. -k.. _~.__ ___~... ,~",<_, .. ""._." ...c_,. ,'" .. r:r:~r~.:~~i~~,II.r.r.:l:,~_'_~__~:~:._.~. .~~_';~~~ ~ r~":'~: ~.~:.r.;~1Ir.~f.. . .. ~~!~'~.' _~~'~ _~'.~;i.~ '.;v~a Fram c."'w.,,~ ~ '}g ""..,~'~.~ ----.-~ ~"""nR.o.'p'F." _.~_._-- :0 Ro'"," Roco!ptF.. ~--~-- ,""~.,,.,,::.:~:' ___. ___'"Oo,._",.:::~:: c ___ . Re"lict.do.l"e<yFe" :::-~ Ilo.trtC,.dD.J1v~,yFe. ifOr>d""",mon'R"""kMI __~__~_ jcC '[ndo=n.."'R",,u"O~) _____ ,,-, To''''P'''''Q~&Foo'. $____ U"J To''''f''''''''Qa&F~"s $ ~_ -0 o <'- Arf;.le.~~er.;~ stamo' 0' me:&"'p"'l~ge a~d P<>" ,,,~o;!\.';.:lnQU"e 01 Po.tm.'ledoro.""e~' 'i'~.I'i~i , ;'~l~' VI ; V g~~~ ~~ ~ ~III J Ct R WI ~)i)(()Ce vnve - ~ ~ 0 I EIlJ1.IC\l lJH 176r95 i 1 Ifm3817. Mu.1989 .(1 STERN 8 EISENBERG UP Attom; at Law 261 orC! York Road, Sulte41 U.S, POSTAL SERVICE CERTIFICATE OF MA_IUNG MAY BE U5EO FOA OOME5TIC ANO lOlTERNATIONAl ~A'l~-')'J'_S;'J;'] PROVIOEFOR'OlSUAAOlCE_PoSTMA5TEA ---~-----_._- A'ldi<'"le. hell! in..amp. 0' ...raU' PO"18g~ and ~pO.~I1)J1Quireof "'."O"rtltol";<outfem f"". t"-, ~~ !~Ii)i r ~\;~l~" ,'~;~III ~, 011'1 0"-0'0 A.<.'..~ From STERN & EISENBERG LLP ^tto'll~'Vvl~' The avUIOl'l '1~lnVnrk~~d SuIl;e-4tO~ en ntown, P 19046-3722 v~ --;:.:;; O"f~'~'~f''''' .. ( ~ I" IICI'~~~-1(F~ , "S F"rm 3817. Mar. 1989 U.S,l'{ISTALSERVICE CERTIFICATE OF MAILING MAY BE USED FOROOMESTlC ,o,NO INTERNATIONAL M,o,'L D0F.SN{)] PROV'oEFOR INSURANCe~POSTMASTER ~ . ~;~:f~n :.e~~ ~'<4Iort=tnUJr..o' ;'::o~I,"irr~' ll.n '~I" ; ~O~I~ . ~~~111 ~~O Roco...dF,om STERN & EISENBERG UP ~:~W :~ 28101C1VOtkRoad,SUIlo4.1(f J\;il.:dlII.."..,PA1ge1,t~1X'. .n /, , .;""';......:.,.~;/ " ."-7J- CJ cL..__ PSForm3817,Mar.1989 U.S. POSTAL SEl'IVlce CERTIFICATE OF M~ MAY BEVSED FOIl DOMESTlC AND IN1liANATlONA~ ......1.., c.nes 'lOT PllOYID! ~OA 'NSVRANCE_POST......srER '-0 l'~ Affi~"he""II'I"",P' ~"...oond Ililtt . '''0' l~li)) , o I f. < ~ ~~ em ~;~III ~o~ ~~o ReeeillitGFnlm: >SForm3817. Mar. 1989 Rocol_From' ~w Affucf.n...jpIl'l8d'l!lO or,_""!SIr.JlCIII'I8Qoond ~""uio.OI - .....,... '~. {'J' , S1EIIt\&EISENBERGUP... ,,'"' 2 >Oli' ! ~ )_"O~I.n\,1' SUll8410'::"/. '.' ~::? ;,1" 0_ 112 '-;-- .~ ~,' ~ '-." , . ," '"~~~III ~OVl , ~~o U,S. POSTAL S&AVICE CERTIFICATE OF MAILING MAY BE USlD FOlIOOM!STl(: ANoltffElllNATlON.l.~M.l.ll DOES NOT PROVIO! FOIl 'NSURANC!_POSTMASTEII 's Fonn 3817. M.r. 1989 U,S. TAL SEAVICl: CERTIFIC MAILING MAY8eUSEoF(lROOM"STICA,ND,r.lI'IlNAT/ONAlM-"'l Does NOT PRoVlocFoA'..SUFlANCE._P_OSTMA_SHIl . AIIt.''''''--ilstomp. """I]' .~ pooj", 01 ;:~lt'T . ~;g" ~~~,~ ~~O Rocoi".dFrom STERN & EISENBERG UP --___ Atlom!ll':"'Law -- In::! VIM"'" 261 O!~ YorkRoad,SUlle410 J""~,I",.....,,.PA 1&0183722 Mar, 1 89 . U.. TA SERV'CE CERTIF M N ~"oVv~ie UFt~ 1~~fAON~~~!~~;:~~~;r~:NATlONA~ MAi~, OO!S!roT Roc.......dFrom. STERN 8. EISENBERG UP Atlr=",LaW T '~lgA 2810ldVorkAoad,SUlle41 PSForm 3817. Mar. 1989 ll...oj~itG From' W\,HW It Q-W..n.,-!In lI'I,,"po otnM.r~"'llo"'d ~..... ,,0"'''"1 STERN 8< EISENBERG UP !'., .~ ~1l:.~ " 'r ~ ~It) ;l 2610:::IVOrkRoad.SdI8410~.::'i: ~ ~ I~I' J;.,..k1".,.m,P:"1iQ"lL~ -.o;:~,\ ...." I ' ~f ~ ~~~III ~O~ "'~O TA I R IF =tO~:'ci'EUF~Eff~~~~A~~S!~~~~~m:NA TlON.o.L ......,L. OO!S NOT PS Form 3817, Mar. 1989 MAYlE USED FOIl DO IF I PIIDYID! FOIl 'HSUIlA::~_-r:.~,,:~~~;r~NATlONA~ MAIL. DOE' NOT ~..,oj\oitG From: fI'#:r~-. :: p . a 01 . .' _ I.n \, .' " 0 I ,. i1 .. ~~ II e: z ~lli .'<:or;,; tJ..O STERN & EISENBERG UP ~",Law 'Iv" 261otc1YorkFlosd Slite410 PSForm3817. Mar. 1989 o f: 1:1t'; 1;'11- , f;;_~ ...:.: .-< ,.- , 1"'--.,:) C..:l C~ ""~ (- c:.: o " -1 ffi:n r TIlT; '~~C) VJ. ) ,1. -;-:~ ::::'. a ')i;"j r;rn :::-... 55 -< f - .. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 26] Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 LD. #75736 NOV ASTAR MORTGAGE, INe. VS. CHRISTINE M. HAMILTON AND JASON B. HAMIL TON NO. 2005-5787 Civil Term CERTIFICATE OF SERVICE I, STEVEN K. EISENBERG, ESQ., attorney for the within Plaintiff, hereby certify that notice of the Sheriff's Sale was mailed to the Defendants by certified mail, return receipt requested on June 8, 2006 and received by the Defendants on June 17,2006 as evidenced by copy of signed green cards attached. 6/27/06 STERN AND EISENBERG LLP -r;t~~~ STEVEN K. EISENBERG Attorney for Plaintiff "~ . cD e ~ g ~ ~ "0. h~gl o.-.c. :>-(1) g~~.s:s . :Jail~t -oi'-o CD! p.. a-a;,i:5Q>Q) NO" Ej; 3- ':\'iB~.90 ~. ~c'E~ ~ c330 _ \\) cn~ ~~~~;S! "i5..q ;:... tti.r:.- EEc~~a R. 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CI ~ CI CI E n.l ~ '" ,.; 1 U'\ CI CI l"- e; 0 I OJ ~ .~ ~ ~ .. u. " . H ~ ~ <0 , '" z .l! " . E .g @ 0 lie u. N en C>. - ;:::'7v r6C' 1:230 ~7zn ~. 2'- jj ~1:5 c; lS~~ ltV1r:::>9= ,,-r -:=J ! C/~PP IILE2 1Il-1I!i o c- .. r<) (': ,.." C)'" C,) " --1 . f~l FQ 1"';'- 1':':,-: c~:' co ~~--~ =.0 ::-::c-> Li") '- (~)'I' I 0-' SJ --:;:: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CNIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 J.D. #75736 NOV ASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMIL TON AND JASON B. HAMILTON ORDER TO SATISFY JUDGMENT Please satisfy the judgment in the above captioned matter upon payment of your costs only. SEEN K. EISENBERG, Attorney for Plaintiff 9/19/2006 o ~ ~f.R -~ -" f"'~-> ~r')> ) "C" =<...:.. !<C' ~8 ):>.c: "7 =3 -.. ,...;) g f:T' c:> ~ 0) ~ ~~ ~9 Or) ~:u gc., t)fTl ~ ~ -0 :s: N .- o u:> Novastar Mortgage Inc. VS Christine M. Hamilton and Jason B. Hamilton In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-5787 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Steven Eisenberg. Sheriffs Costs: Docketing Surcharge Prothonotary Law Library Poundage Advertising Levy Posting Handbills Postpone Sale Mileage Certified Mail Share of Bills Patriot News Law Journal 30.00 30.00 1.00 .50 12.25 15.00 15.00 15.00 20.00 14.08 9.28 19.31 246.80 197.00 $ 625.22 10/01.,/0(, CA So Answers: . /~~~J .. R. Thomas Kline, Sheriff '\.~ et<6S73l1 ~.I'iYISD COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 I.D. #75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON AFFIDAVIT PURSUANT TO RULE 3129.1 STEVEN K. EISENBERG, attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 430 CANDLEWYCK ROAD, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or Reputed Owner(s): Christine M. Hamilton and Jason B. Hamilton 12 Turnberry Way Bluffton, SC 29910 2. Name and address of Defendant(s) in the judgment: Christine M. Hamilton and Jason B. Hamilton 12 Turnberry Way Bluffton, SC 29910 3. Name and last known address of every judgment creditor whose judgment is a record lien on the Teal property to be sold: Richard P. Matthews 19 Blue Spruce Drive Enola, PA 17025 J:\ANNE\SALES\CUMBERLAND\NOVASTAR.HAMIL TON.2.06.DOC J & J Custom Counters 15 Popps Ford Road York Haven, PA 17370 Gregory A. Denning (the address or whereabouts of the above creditor cannot be reasonably ascertained) Susan A. Herbert 605 Showers Street Harrisburg, PA 17104 Duty's Lock Safe & Security, Inc. 4301 Carlisle Pike Camp Hill, PA 17011 Lower Allen Township 120 Limekiln Road New Cumberland, PA 19070 James Appollonio & Christine Appollonio 430 Candlewyck Road Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: N/A 5. Name and address of every other person who has any record lien on the property: N/A 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: N/A 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: Tax Claim Bureau Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 J:\ANNE\SALES\CUMBERLAND\NOVASTAR.HAMILTON.2.06.DOC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 I.D. #75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Christine M. Hamilton and Jason B. Hamilton 12 Turnberry Way Bluffton, SC 29910 Your real estate at 430 CANDLEWYCK ROAD, CAMP HILL, PA 17011 is scheduled to be sold at Sheriff's Sale on SEPTEMBER 6,2006 at 10:00 A.M., in the Cumberland County Courthouse, Carlisle, PA, to enforce the court judgment of $272,335.09 obtained by Novastar Mortgage, Inc. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to Stern and Eisenberg the back payments, late charges, costs and reasonable attorney's fees due. To fine out how much you must pay, you may call Stern and Eisenberg, telephone (215) 572-8111. 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. J:IANNE\SALES\CUMBERLAND\NOVASTAR.HAMIL TON.2.06.DOC .. " You may need an attorney to assert your tights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two 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 Stern and Eisenberg, telephone (215) 572- 8111. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call Stern and Eisenberg, telephone (215) 572-8111. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date. This Schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERENCE SERVICE COURT ADMINISTRATION CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 J:\ANNE\SALES\CUMBERLAND\NOVASTAR.HAMIL TON.2.06.DOC . COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 1.0. #75736 NOVASTAR MORTGAGE, INC. VS. : NO. 2005-5787 Civil Term CHRISTINE M. HAMILTON AND JASON B. HAMILTON RE PREMISES: 430 CANDLEWYCK ROAD. CAMP HILL. PA 17011 Dear Sir or Madam: Please be advised that I represent the above creditor which has a judgment against the above defendant. As a result of a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of Cumberland County on SEPTEMBER 6, 2006 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, PA. The sale is being conducted pursuant to the judgment in the amount of $272,335.09 plus interest thereon entered in the above matter in favor of plaintiff against the above- named defendant{s) who are also the real owner{s) of said premises. I have discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriff's Sale upon your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice. A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days thereafter. BY: STERN AND EISENBERG LLP /i- AlA rJ / \..~/, fO;t- STEVEN K. EISENBERG, Attorney for Plaintiff 3/1/2006 J:\ANNE\SALES\CUMBERLAND\NOVASTAR.HAMIL TON.2.06.DOC 13-24-0807-113 . . ALL THAT CERTAIN piece and parcel ofland in Lower Allen Township, Cumberland County, Pennsylvania; BEING Lot No. 108 on Plan of Lots entitled "Section No.4 - Allendale Development Corporation", made by Damon and Foster, Civil Engineers, Sharon Hill, Pennsylvania on November 27, 1959, revised March 24, 1960 and recorded in said County in Plan Book No. 11, Page 30. AND with all improvements thereon and known and identified as No. 430 Candlewyck Road. BEING the same premises which Susan D. Herbert, by Deed dated June 8, 2004, and recorde~ ~une 10,2004, in Book 263, Page 2292, granted and conveyed unto Christine M. Hamilton and Jason B. HamIlton, husbanaand wife, in fee. ZZ :Zl dOl HVW qUal Vd 'AlhnJ:.; 0.. :,UU,J\' .::L:llB3HS 3Hl .:W]JI.:L:iO WRIT OF EXECUTION and/or ATTACHMENT ... COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5787 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NOV ASTAR MORTGAGE, INC., Plaintiff (s) From CHRISTINE M. HAMILTON AND JASON B. HAMILTON (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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $272,335.09 L.L. $.50 Interest FROM 3/1/06 AT THE PER DIEM RATE OF $56.41 UNTIL JUDGMENT IS PAID IN FULL Arty's Comm % Atty Paid $150.40 Plaintiff Paid Date: MARCH 7, 2006 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name STEVEN K. EISENBERG, ESQUIRE Address: THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-572-8111 Supreme Court ID No. 75736 ~\ teE; c=::; ~ . Real Estate Sale # 16 On May 16, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, P A Known and numbered as 430 Candlewyck Road, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 16,2006 By: J 6ciL/5vMI1'L Real Estate Sergeant I Z :ZI dO' HVW qOOZ Vd 'AHlnU,j tJII(lcij8~~nJ .:HI~3HS 3Hl .:10 3::11.:1.:10 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: July 21, July 28, and August 4,2006 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. TO AND SUBSCRIBED before me this 4 day of August. 2006 IAL SEAL lOtS E. SNYDER, Notary Public CarHsle Boro, Cumberland County My Commission Expires March 5, 2009 REAL ESTATE a.AL& 110. 18 Writ No. 2005-5787 CMI Novastar Mortgage Inc. vs. Christine M. Hamilton and Jason B. HamUton Atty.: Steven Eisenberg ALL THAT CERTAIN piece and parcel of land in Lower Allen Town- ship. Cumberland County. Pennsyl- vania: BEING Lot No. 108 on Plan of Lots entitled ~Section No. 4-Allen- dale Development Corporation~. made by Damon and Foster. Civil Engineers. Sharon Hill. Pennsylva- nia on November 27. 1959. revised March 24. 1960 and recorded in said County in Plan Book No. 11. Page 30. AND with all improvements thereon and known and identified as No. 430 Candlewyck Road. BEING the same premises which Susan D. Herbert. by Deed dated June 8. 2004. and recorded June 10. 2004. in Book 263, Page 2292. granted and conveyed unto Chris- tine M. Hamilton and Jason B. Hamilton. husband and wife, in fee. I.. " 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 smce; 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 19th and 26th day(s) of July and the 2nd day(s) of August 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#16 ..-.::m..-:.l 11II.11 a .........tnc; . 'Ya, . ell. '~I' J at. ....II....... 8.", . tf' ~~. L.. 1'1"1_ ... A&-__,"'_,IIIIiINJ.d ~~.~~ ...,. "Seclioa No.4. AIIiIIdIIc ~ ~,"~""'(M .......' ~ . _."~.. ....11. fWl.....MiIl:llM,l.. RlCIIIded ill ail 0.,......... .11 ..lU.hri.....~ ..~ .,;w ::.~..:~~~~~i. IIiIIlIIiltlt.....-I;~.Mo1 ".il1 -If, .........._~ .. -.,It- ~III. ....... .... - i "l~ r lj - .... ..... .1"'" IIJ CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013