HomeMy WebLinkAbout05-6233
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GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH'A. GOLDBECK, JR.
ATTO\"NEY I.D. #16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 825-6318
WWW.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
M&T MORTGAGE CORPORATION S/B/M FARMERS
TRUST COMPANY
PO Box 840
Buffalo, NY 14240-0840
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
vs.
STEVEN P. DOODAN
Mortgagor and Real Owner
339-339B Old Stonehouse Road
Boiling Springs, P A 17007-9666
Defendant
CIVIL ACTION - LAW
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE
PERSONS AT A REDUCED FEE OR NO FEE.
ACTION OF MORTGAGE FORECLOSURE
CIVIL ACTION: MORTGAGE
FQiIl~Cl.OOUR~'Nrm.- J "'l]) /7, 'L
o. 0.. --..0 L: tUl
18t.~
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VISO. PARA DEFENDERSE ES
NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A EST A DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMAND ANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE EST A DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINE~D, PROPIEDAD U OTROS DERECHOS IMPORT ANTES.
USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, V A Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQuI ABAJO. EST A OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
I). Call an attorney. For referrals to a qualified attorney call the following number: 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call Beth at 215-825-6329 or fax 215-825-6429. The
figure and/or package you requested will be mailed to the address that you request or faxed if you leave a
message with that information. The attorney in charge of our firm's Homeowner Retention Department is David
Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
MT-0903.
Para informacion en espanol puede communicarse con Loretta aI215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
I., Plaintiff is M&T MORTGAGE CORPORATION S/B/M FARMERS TRUST COMPANY, PO Box
840, Buffalo, NY 14240-0840.
2. The name and address of the Defendant is STEVEN P. DOODAN, 339-339B Old Stonehouse Road,
Boiling Springs, P A 17007-9666, who is the mortgagor and real owner of the mortgaged premises
hereinafter described.
3. On August 01, 1991 mortgagor made, executed and delivered a mortgage upon the premises hereinafter
described to M&T MORTGAGE CORPORATION S/B/M FARMERS TRUST COMPANY, which
mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1023, Page
674. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference
in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from
its obligation to attach documents to pleadings if those documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for July 01,2005, and each month thereafter and by the terms of the Mortgage, upon default in such
payments for a period of one month, the entire principal balance and all interest due and other charges
are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance
Interest from 06/01/2005
through 11/30/2005 at 5.3330%
Per Diem interest rate at $5.43
Reasonable Attorney's Fee as more fully explained in the
next numbered paragraph
Late Charges from 07/01/2005 to 11/30/2005
Monthly late charge amount at $26.22
Costs of suit and Title Search
Corporate Advance
Escrow
Monthly Escrow amount $32.27
$37,182.55
$993.68
$2,000.00
$131.09
$900.00
$1,078.00
$752.23
$43,037.55
7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff reserves its right to collect Attorney's
fees of up to 5% ofthe remaining principal balance in the event the Property is sold to a third party
purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the
amount demanded in the Action.
8. Plaintiff is not seeking a judgment of personal liability (or and "in personam" judgment) against the
Defendant in this Action but reserves it's right to bring a separate Action to establish that right, if such
right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding,
this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that
was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law.
r
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been .sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the
. Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B". The Defendant has not had the required face-to-face meeting within the
required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de tems judgment in mortgage foreclosure in the sum of $43,037.55,
together with interest at the rate of $5.43, per day and other expenses costs and charges incurred by the Plaintiff
which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the
Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property.
By:
~
K McCAFFERTY & McKEEVER
By: Jos H A. GOLDBECK, JR., ESQUIRE
A DORNEY FOR PLAINTIFF
VERIFICATION
I, Diana M. Robinson, as the representative of the Plaintiff corporation within named do
hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff
corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my
knowledge, information and belief. I understand that false statements therein are made subject to the
penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
Date: 12{,1 D-{
/
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Diana M:Rooinson
M&T MORTGAGE CORPORATION
p,~lii6it Jl
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EXHIBIT wA.
ALL that certain house and lot of ground situate in the Village
of Churchtown, Monroe Township, Cumberland County, Pennsylvania,
bounded and described as follows:
On the North by property now or formerly of Riley Urich: on the
east by an alley; on the South by property now or formerly of
Sarah Garver or Murray Brownawell; and on the West by Main
Street.
CONTAINING 33 feet in front on said Main Street and extending in
depth 200 feet to said alley.
HAVING THEREON on erected a two and one-half story brick dwelling
house and outbuildings, known and numbered 339 and 339B Old
stonehouse Road, Boiling springs, Pennsylvania, 17007.
BEING the same premises that Isabella E. Lear, by her deed dated
in the Office of the Recorder of Deeds in and for Cumberland
County , Pennsylvania, in Deed Book II II, Volume , Page
, granted and conveyed unto steven P. Doodan and Pamela Jo
Irwin, the Mortgagors herein.
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State of Pennsylvania } SS
County of Cumberland
Recorded in the office for the recording of Deeds
8'. c,!n;nd for <;umberland countylJ"'(!
in \, it Book.t~ol. --....:- Page I"' l
witruiss my hand .nd seal of office.~ r ' [; I
Ca(li.18.PA'hi..4~ :f9~~
Recorder .
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boodi!2,3 fl,C, fi80
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mM.l!l'~Corporatlan
~~,,--
M&T Mortgage Corp.
P.O. Box 1288
Buffalo, NY 14240-1288
09/1212005
Certified No.: 71826389306006799886
Steven P Doodan
197 Village Rd
Harrisburg, PA 17112
HOMEOWNERS NAME(S): St.v8n P Doodan
PRDPUT'I ADDRESS: 338 01 cI storwhou.. Rd
Bolling sprtngs, PA 17007
LOAN ACCT NO: OOOn172el
CURRENT L!NDERISERVICER: MAT Mort~.g. Corporation
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE FA YMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"~ YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
IF YOUR DEF AUL T HAS BEEN CAUSED BY CmCUMST ANCES
BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY
YOUR MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGmILITY REQUIREMENTS
ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay offoreclosure
on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a
"face-to-fac"meeting with one of the consumer credit counseling agencies listed at the end oflhis Notice..rma
MEETING MUST OCCUR WITHIN TilE NEXT 130) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS
NOTICE CALI ED"HOWTO CURE YOUR MORTGAGE DEFAULT" EXPLArNS HOW TO BRING YOUR
MORTGAGE UP TO DATE
CONSUMER CREDIT COUNSELING AGENCIES -If you meet with one of the consumer credit counseling
agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the 4ate
of this meeting. The names addresses and telenhone numbers of designated conswner credit counsclinll B(!'erlcies for
the county in which che nronertv is located are set forth at the end oEthis Notice. It is only necessary to schedule one
face-to-face meeting. Advise your lender immediately ofyouT intentions.
18007241633 CcmuspondfJnce -P.O. Box 840, Buffalo, NY 1424().0840 Payments - P.O. Box 62182, Bellimore. MD 21264-2182
Morlgage account information. just a click away. www.mandtmortgag8.c:om
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APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later
in this Notice (see following pages for specific infonnalion about the nature ofyouT default.) If you have tried and
arc unable to resolve this problem with the lender. you have the right 10 apply for fmandal assistance from the
Homeowner'sEmergency Mortgage Assistance Program. To do 50, you must fill out, sign and file a completed
Homeowner'sEmergency Assistance Program Application with one orlhe designated consumer credit counseling
agencies listed al the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they willlSsist you in submitting. complete application to the Pennsylvania Housing Finance Agency.
Your application MUST be filed or postmarked within thirty (30) days of your face-ta-face meeting.
YOU.Mlln: FILE VOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW TIlE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed
by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has
sixty (60) days to make a decision after it receives your application. Owing that lime, no foreclosure proceedings
will be pursued against you if you have met the time requirements set forth above. You will be notified directly by
the Pennsylvania Housing Finance Agency ofits decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECfED BY mE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES
ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you han filed bankruptty you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brim!' It uo to date).
NATURE OF THE DEFAUL T -The MORTGAGE debt held by the above lender on your property located at
33' Old StonehoUse Rd
lolling Springs, PA 17007
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MORTGAGE PAYMENTS for the following months and the following amounts are
now past due:
R.gular payments 0' $&24.41 for the nonths of 07{01{2oo5
through today's da.t.:
Other charges:
Acc~d Lat. Charges:
Accrued Other Cha"..s
.
.
.
.
1838.8t
3&.1'
111.150
1711. II
TOTAL AMOUNT PAST DUE:
HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this
notice BY PAYING THE TOTAL AMOUNT PAST DUE TO mE LENDER, WHICH IS $1788.99. PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) OA Y
PERIOD. Pavments must he made either bv cash cashicr'scheck certified check or money order made oavable and
Wl!.lO;
M&T Mortgage Corporation
One Fountain Plaza/7th Floor
AUn: Payment Processing
Buffalo, NY 14203
You can cure anv other defaultbv takinl!" the followinll action within THIRTY (]O) DAYS Rfthe date ofthi!lletler:
IFYOU DO NOT CURE THE DEFAUL T-Ifyou do not cure the default within THIRTY (30) OA YS of the date
of this Notice, the lender Intendl to nercise Its rights to acceleute the mortgsge debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chanee to pay the
mortgage in monthly installments. IffuJl payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged
property.
18007241633 ColTespondef/CfJ . P.O. Box 840. Buffalo. NY 14240-0&40 Payments. P.O. Box 82182. Baltimore, MD 21264-2182
Mortgage account Information. just 8 click away. www,mandtmortgage.tom
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IF THE MORTGAGE IS FORECLOSED UPON .. The mortgaged property will be sold by the Sheriff to payoff
the mortgage debt. If the lender refers your case to its attomeys, but you cure the delinquency before the lender
begins legal proceedings against you, you will still be required to pay the reasonable attorney'sfees that were
actually incurred, up to $50.00. However, iflegal proceedings are started against you, you will have to pay all
reasonable attorney's fees actually incurred by the lender even ifthcy exceed $50.00. Any attorney'srees witt be
added to the amount you owe the lender, which may also include other reasonable costs. Uyou cure the default
within the THIRTY (30) DAY period, you wUl not be required to pay atlorney" fee..
OTHER LENDER REMEDIES _ The lender may also sue you personally for the unpaid principal balance and all
other slUIlS due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE~. If you have not cured the default within
the THIRTY (30) DAY period and foreclosure proceedings have begun. you still have the right to cure the default
and prevent the sale at any time up to one hour before the Sheriff'sSale. You may do so by paying the total amoWlt
then past due, plus any latc c:I other charges then due, reasonable attorney's fees and costs connected with the
foredos\ltt sale and any other costsconnl:\:\ed willi the Sheriff'sSale as specifled in writing by the lender and by
performing any othcr requirements under the mortgage. Curing your default In the manner sel forth In thi,
notice wUl restore your morteale to the same position as if YOIl had never defauUed.
EARI.IEST pOSSIBLE SIIERIFF'S SALE DA TE~. It is estimated that the earliest date that such a Sheritrs Sale
of the mOl1gagcd property could be held would be approximately 10 months. from the dale oHM, Notke. A
notice of the actual date of the Sheriff's. Sale will be sent to you before the sale. Of course. the amount needed to
cure the default will increase the longer you wait. You may find out at any time exactly what the required payment
or action win be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: M&T Mortgage Corporation
Address: P,O. Box 840
Buffalo, NY 14140
Phone Number: (800) 724-1633
EFFECT OF SHERIFF'S SALE _ You should realize that a ShcrirrsSale will end your oWt\ership of the
mOl1gaged property and your right to occupy it. If you continue to live in the property after the SheritrsSalc, a
laws.uit to remove YOll and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE You_ mayor 2f may not sell or transfer your home to a buyer or
transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's
fees and costs are paid prior to or at the sale and that the other requirements of the mortgage arc satisfied.
YOU MAY ALSO HAVE THE R[GHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO rAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF nus DEBT.
TO HAVE THIS DEFAUL'fCURED BY ANYTlflRD PARTY ACTING ON YOUR BEHALF.
TO HA VB THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR AJN
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTlON BY THE
LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Sincerely,
.e....a""'^ ~ <J..
Russell M. Alessi Jr,
Collections Manager
Ene: Act 91 Notice
Consumer Credit COWlseling Agencies Serving Your County
1 aoo 72.<1 1633 ComJ$pOOdence ~P.O. Box MO, B\Jff8\o. NY 1424l).()840 Payments . P.O. Box 62182, Baltimore, MD 21264-2182
Mortgage account iflformat/cll,jlJsla elkk away. www.mandtmoltgag8.com
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ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This I. an official notice that the mortp'an on "our home is In defauU. IDd the lender Intends to foreclose.
Snectnc Information ahout the nature of the default is nrovtded In the attached DUtl.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM IHEMAPl mill" be able to helD to lave
your home. This Notlet exolalns how the OfOl!'ram works.
To see If HEMAP un hdD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with
the Coun.ellaR' Al!'encv.
The name. addren and ohoRe number of Consumer Credit Coon.ellnl!' Agencies servinI!' your Conntv are
listed at the end Drihls Notice. Ifvou have any QuestIons. YOU may call tbe Pennsylvania Housinp' Finance
Apron toll free at 1.80o.342.2397.CPenoRI with Imoalred hurlnl! ran rail (717\780-1869\.
This Notlre rontaln. Important legal Information. If you have any quesClons, representatlvetl at the
Consumer CredIt Coun.ellnr; Agency may be able to help explain U. You may also want 10 contact an
aUorney In your area. The local bar association may be able 10 help YOIl find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORT ANCIA, PUES AFECT A SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIT AMENTE LLAMANDO EST A
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS ALNUMERO
MENCIONADO ARRmA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIRSU HIPOTECA.
1800 7241633 Correspondence .P.O. Box 840. Buffalo, NY 1424l>-O840 P.ym&nt~. P.O. Box 82182, Baltimore, MD 21264-2182
Mortgage KCOunt information. Just a click away. www.mandtmortgage.com
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Homeowners' Emergency Assistance Program
CUMBERLAND COUNTY
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, P A 17325
(717) 334-1518
CCCS ofWestemPA
2000 LinglestownRoad
Harrisburg, PA 17102
1-888-511-2227
Community Action Commission or Captial Region
1514 Deny Street
Harrisburg, PA 17104
(717) 232-9757
Loveship, Inc.
2320 North 5th Street
Harrisburg, P A 17110
(717) 232-2207
Maranatha
43 PhiladelphiaAvenue
Waynesboro,PA 17268
(717) 762-3285
PHFA
211 North Front Street
Harrisburg, PA 17110
1-800-342-2397
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2005-06233 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
M&T MORTGAGE CORPORATION
VS
DOODAN STEVEN P
R. Thomas Kline
duly sworn according to law, says, that he made a diligent search and
,Sheriff or Deputy Sheriff, who being
inquiry for the within named DEFENDANT
DOODAN STEVEN P
unable to locate Him in his bailiwick. He therefore returns the
but was
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, DOODAN STEVEN P
339-339B OLD STONEHOUSE ROAD
BOILING SPRINGS, PA 17007-9666
HOUSE IS VACANT.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
Postage
18.00
8.64
5.00
10.00
1. 27
42.91
Sworn and subscribed to before
1
day of "-~" ,., ^'J
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protKonot~'---+:?k 1
this
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_./"-/ " 'J . .-..:..._
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, R. Thomas in~
Sheriff of Cumberland County
GOLDBECK MCCAFFERTY MCKEEVER
01/05/2006
me
SHERIFF'S RETURN - OUT OF COclliTY
CASE NO: 2005-06233 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
M&T MORTGAGE CORPORATION
VS
DOODAN STEVEN P
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to Wlt:
DOODAN STEVEN P
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
County, Pennsylvania, to
serve the within COMPLAINT - MORT FORE
On January
5th , 2006 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Dauphin County
6.00
9.00
10.00
37.25
.00
62.25
01/05/2006
GOLDBECK MCCAFFERTY
So answers:
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R.Thomas Kline (
Sheriff of Cumberland County
MCKEEVER
this
.v
JI-
subscribed to before
day Of()~~'-"_.,
/
AD~
I'J .
(y
" Proth ar
me
Sworn and
1.. i..'>-O l,.
. In The Court of Common Pleas of Cumberland County, Pennsylvania
M&T Mortgage Corporation
VS.
Steven O. Doodan
No.
05-6233 civil
Now,
Dec~ber 7, 2005
, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Dauphin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
r~~
Sheriff of Cum berland County, P A
Affidavit of Service
Now,
,20_, at
o'clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this _ day of ,20_
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
@iiitr of tq~ ~4eriff
William T. Tully
Solicitor
Charles E. Sheaffer
Chief Deputy
Mary Jane Snyder
Real Estate Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin Couuty
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
M & T MORTGAGE CORPORATION S/B/M
vs
County of Dauphin
DOODAN STEVEN P.
Sheriff's Return
No.2077-T - -2005
OTHER COUNTY NO. 05-6233 CIVIL
AND NOW: December 21, 2005 at 1: 12PM served the within
MORTGAGE FORECLOSURE
upon
DOODAN STEVEN P.
by personally handing
to JOHN HYLAND, FRIEND OF DEFT
1 true attested copy(ies)
of the original
MORTGAGE FORECLOSURE
and making known
to him/her the contents thereof at 197 VILLAGE ROAD
HARRISBURG, PA 17112-0000
Sworn and subscribed to
before me this 27TH day of DECEMBER, 2005
So Answers,
:; Kc/f~
~cdJ
By
)~
Deputy Sheriff
Sheriff's Costs: $37.25 PD 12/09/2005
RePT NO 212895
Sheriff
Pa.
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept. 1,2006
GM
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney J.D. #16132
Suite 5000 - Mellon Independence Center
70 I Market Strect
Philadelphia, P A 19 I 06
215-627-1322
Attorncy for P1ain1iff
M&T MORTGAGE CORPORATION S/B/M FARMERS
TRUST COMPANY
PO Box 840
Buffalo, NY 14240-0840
Plaintiff
VS.
STEVEN P. DOODAN
(Mortgagor(s) and Record owuer(s))
339-339B Old Stonehouse Road
Boiling Springs, P A 17007-9666
Defendanl(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 05-6233
ORDER FOR JUDGMENT
Please cnter Judgmenf in favor of M&T MORTGAGE CORPORATION S/B/M FARMERS TRUST
COMPANY, and against STEVEN P. DOODAN for failure 10 file an Answer in the above action within (20)
days (or sixty (60) days if defcndant is the United States of America - om the date of service of the Complaint, in
the sum of $43,469.47.
Joseph A '0 dbeck, Jr.
Attorney - r Plaintiff
I hereby certify thai the above names are correct and that the precise residence address of the judgment
creditor is M&T MORTGAGE CORPORATION S/B/M FARMERS TRUST COMPANY PO Box 840 Buffalo,
NY 14240-0840 and that the name(s) and last known addressees) of the Defendant(s) is/are STEVEN P.
DOODAN, 197 Villiage Road Harrisburg, PA 17112;
GOLDBECK
BY: Joseph A. - Idbcck, Jr.
Attorney for Plain1iff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 05-6233 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION S/B/M
FARMERS TRUST COMPANY, Plaintiff (s)
From STEVEN P. DOODAN
(I) 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 garuishee(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) uot levied upou 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 $43,469.47
Interest FROM 61l/05 TO 1127 /06 AT 5,3330%
L.L. $.50
Atty's Comm
%
Due Prothy $1.00
Other Costs
Atty Paid $187,16
Plaintiff Paid
Date: FEBRUARY 7, 2006
f
Pr
onotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
Goldbeck McCatTerty & McKeevcr
BY: Joseph A. Goldbcck, Jr.
AlldrneyJ:'D #16132
Suite 5000 - Mellon Independcnce Centcr
70 I Market Street
Philadelphia, I' A 19106
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION S/B/M
FARMERS TRUST COMPANY
PO Box 840
ButTalo, NY 14240-0840
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plainliff
vs.
CIVIL ACTION - LAW
STEVEN P. DOODAN
(Mortgagor(s) and Record Owner(s))
339-339B Old Stonehouse Road
Boiling Springs, PA 17007-9666
ACTION OF MORTGAGE FORECLOSURE
Detendant( s)
No. 05-6233
AFFIDAVIT PURSUANT TO RULE 3129
M&T MORTGAGE CORPORA nON S/B/M FARMERS TRUST COMPANY, Plaintiff in the above action, by its
attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the \\Tit of execution was filed the
following infonnation concerning the real property located at:
339-339B Old Stonehouse Road
Boiling Springs, P A 17007-9666
I .Name and address of Owncr(s) or Reputed Owner(s):
STEVEN P. DOODAN
197 Village Road
Harrisburg, P A 17112
2. Name and address of Defcndant(s) in the judgment:
STEVEN P. DOODAN
197 Village Road
Harrisburg. P ^ 17112
3. Name and last knov/ll address of every judgment creditor whose judgment is a record lien on the property to he sold:
MONROE TOWNSHIP MUNICIPAl. AUTHORITY
1220 Boiling Spring Road
Mcchanicsburg, PA 17055
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
1'0 Box 320
Carlisle, P A \ 70 13
PA DEPARTMENT OF PUBUC WELFARE - Bureau of Child Support I'nt()rcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg. P^ 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
. .
5. Name and address of every other person who has any record interest in Of record lien on the property and \vhose interest
may bc affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affccted by thc sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be aflected by the sale.
TENANTSiOCCUP ANTS
339-339B Old Stonehouse Road
Boiling Springs, P ^ \ 7007-9666
(attach separate sheet if more space is needed)
1 verify that the statements made in this atl-idavit afe true and correct to the best of my personal kno\\.'ledge Of
information and belief I understand that false statements herein are made subject to the penalties of l8 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: January 27.2006
GOLDBECK McC
BY: Joseph A. Gol
Attorney for Plaintiff
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05-6233
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
70 I Market Street
Philadelphia. P A 19106
215-627,1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION S/B/M
FARMERS TRUST COMPANY
PO 80x 840
Buffalo, NY 14240-0840
IN TilE COURT OF COMMON PLEAS
of Cumberland Counfy
Plainliff
CIVIL ACTION - LAW
VS.
STEVEN P. DOODAN
Mortgagor( s) and Record Owner( s)
ACTION OF MORTGAGE
FORECLOSURE
339-3398 Old Stonehouse Road
Boiling Springs, PA 17007-9666
Tenn
No. 05-6233
Defendant( s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
['(): DOODAN. STEVEN P
STEVEN P. DOODAN
197 Village Road
Harrisburg, P A 17112
Your hom,;c al 339-339B Old Stonehouse Road. Boiling Springs, P ^ ] 7007-9666 is scheduled to
be sold at Sherifl\ Sale on \Vednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd
FL Courthouse to enforce the court judgment of$43.469.47 obtained by M&T MORTGAGE
CORPORA nON S/B/M FARMERS TRUST COMP ANY 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:
I. lhe sale will be cancelled ifYOll pay to M&T MORTGAGE CORPORATION S/B/M FARMERS
TRUST COMPANY, the back payments, latc charges, costs and reasonable attomey's tees due. To find out
how much you must pay calL 215-627-1322
2. Y Oll may be able to stop the sale by filing a petition asking the Court to strike or open judgment. if
the judgment \vas improperly entered. You may also ask the Court 10 postpone the sale for good cause.
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 . Mellon Independence Center
701 Market Street
Philadelphia, PA 19106.1532
215-627.1322
Attome for Plaintiff
M&T MORTGAGE CORPORATION S/BIM FARMERS
TRUST COMPANY
PO Box 840
Buffalo, NY 14240-0840
MT-0903
CF: 12/02/2005
SD: 06/07/2006
$43,469.47
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
ACTION OF MORTGAGE FORECLOSURE
STEVEN P. DOODAN
Mortgagor(s) and
Record Owner(s)
Term
No. 05-6233
.
339-339B Old Stonehouse Road
Boiling Springs, PA 17007-9666
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.c.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants of the Notice of Sheriff Sale was made by:
~
( )
( )
( )
( )
Personal Service by IJI. ilklliW, Elffi~Ucompetent adult (copy of return attached).
Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
Certified mail by Sheriffs Office.
Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S.
Section 4904.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL V ANlA
M&T MORTGAGE CORPORATION STEVEN P. DOODAN
(Petitioner) Plaintiff VS. (Respondent) Defendant
CASE and/or DOCKET: 05-6233
I Declare that 1 am a Pennsylvania State Deputy Constable and/or Process Server, in and for the County of
Montgomery, that I am not a party to this action, not an employee of a party to this action, or an attorney to
the action, and that within the boundaries of the state were service was effected, 1 was authorized by law to
perform the said service.
SERVICE UPON: STEVEN P. DOODAN
ADDRESS: 197 VILLAGE RD, HARRISBURG, PA 17112
On: '2-{'l-~ I~v At: 1 ~ S'f ('(VI
Description: Approximate Age5> HeightS"J'Weightl'" Race: ~Sex: ~Hair:~
With the documents: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
MANNER OF SERVICE
By handing a copy to:
;.(1.) Defendant(s) personally served
D 2.) Adult family member with whom said Defendant(s) reside.
Name: Relationship:
D 3.) Adult in charge of defendants residence.
Name: Relationship:
D 4.) Posted Property
D 5.) Agent or person in charge of Place of Business.
Name: Title:
Comments:
Defendant was not served because:
_Moved_Unknown No Answer_Vacant Other:
Service was attempted on the following dates and times:
1.) 2.) 3.)
Date: Time: Date: Time: Date:
SERVER INFORMATION
Time:
UNIVERSAL LAWYERS' SERVICE
93 EAST MAIN ST.
BAY SHORE, NY 11706
631.666.6168
Sworn to and subscribed
before me this _6>___.day
of _.&1.~_.____ 200!!..
,-JiM.M~
Notary Publi .
COMMONWEALTH OF' PENNSYLVANIA
NOTARIAL SEAL
TERESA A. MINZOLA, Notary Public
Washington Twp., Berks County
Mv Commission Expires December 5, 2009
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon independence Center
701 Market Street
Philadelphia, P A 19106
215-825-6320
Attorney for Plaintiff
M&T MORTGAGE CORPORATION S/BfM
FARMERS TRUST COMPANY
PO Box 840
Buffalo, NY 14240-0840
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
STEVEN P. DOODAN
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE FORECLOSURE
339-339B Old Stonehouse Road
Boiling Springs, PA 17007-9666
Term
No. 05-6233
Defendant( s)
AFFIDAVIT PURSUANT TO RULE 3129
M&T MORTGAGE CORPORATION SIB/M FARMERS TRUST COMPANY, Plaintiff in the above action, by its
attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the
following infonnation concerning the real property located at:
339-339B Old Stonehouse Road
Boiling Springs, P A 17007-9666
l.Name and address ofOwner(s) or Reputed Owner(s):
STEVEN P. DOODAN
197 Village Road
Harrisburg, PA 17112
2. Name and address ofDefendant(s) in the judgment:
STEVEN P. DOODAN
197 Village Road
Harrisburg, P A 17112
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
MONROE TOWNSHIP MUNICIPAL AUTHORITY
1220 Boiling Spring Road
Mechanicsburg, PA 17055
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PAl 70 13
. .
, .
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, P A 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
339-339B Old Stonehouse Road
Boiling Springs, PA 17007-9666
(attach separate sheet if more space is needed)
I verify that the statements made in thIs affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: May 11,2006
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
}SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriffs Deed in which Michael J Home is the grantee the same having been sold to said grantee on
the 7th day of June A.D., 2006, under and by virtue of a writ Execution issued on the 7th day of Feb,
A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2005 Number 6233, at
the suit ofM&T Mtg Crop against Steven P Doodan is duly recorded in Deed Book No. 275, Page
3612.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this
/1
day of
~,A.D. .)-ecl?
/YyL~ft~
~J.~
ecorder of Deeds
RIcoIdIr of DeIclI, CumbIItInd COUIIlf CIIIIII, M
M,Collli...., Exp/rII,. AII""";aI__
M&T Mortgage Corporation slb/m
Farmers Trust Company
VS
Steven P. Doodan
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2005-6233 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a
diligent search and inquiry for the within named defendant, to wit: Steven P. Doodan, but was
unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County,
Pennsylvania to serve the within Real Estate Writ, Notice of Sheriffs Sale and Description
according to law.
Dauphin County Return: I, Jack Lotwick, Sheriff of the County of Dauphin, State of
Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Steven P.
Doodan, the defendant named in the within Real Estate Writ, Notice & Description and that I am
unable to find him in the County of Dauphin, and therefore return same NOT FOUND, May 4,
2006. Attempted service eight times. So Answers: Jack Lotwick, Sheriff of Dauphin County,
PA.
William Cline, Deputy Sheriff, who being duly sworn according to law, states that on
April 06, 2006 at 6:00 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice,
Poster and Description, in the above entitled action, upon the property of Steven P. Doodan,
located at 339-339B Old Stonehouse Road, Boiling Springs, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due
and legal notice had been given according to law, he exposed the within described premises at
public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June
07,2006 at 10:00 o'clock A.M. He sold the same for the sum of$55,200.00 to Michael 1. Home.
It being the highest bid and best price received for the same, Michael J. Home of 1059 E. York
Rd., Dillsburg, P A 17019, being the buyer in this execution, paid to SheriffR. Thomas Kline the
sum of $58,878.40.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
$30.00
1,104.00
15.00
15.00
30.00
10.00
.50
1.00
6.16
3.10
15.00
20.00
263.00
257.00
19.57
25.00
Sheriffs Deed
39.50
$1,853.83 / qllt/lbl.. . Lr
So Answers:
r~?L,
R. Thomas Kline, Sheriff
By\Jac4{ ~
Real Estate Sergeant
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J. Ck.sLJ~SI
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I
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney J.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintitl
It
, f
M&T MORTGAGE CORPORATiON S/B/M
FARMERS TRUST COMPANY
PO Box 840
Buffalo, NY 14240-0840
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTiON - LAW
STEVEN P. DOODAN
(Mortgagor(s) and Record Owner(s))
339-339B Old Stonehouse Road
Boiling Springs, PA 17007-9666
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 05-6233
AFFIDAVIT PURSUANT TO RULE 3129
M&T MORTGAGE CORPORATION S/B/M FARMERS TRUST COMPANY, Plaintiff in the above action, by its
attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the
following information concerning the real property located at:
339-339B Old Stonehouse Road
Boiling Springs, P A 17007-9666
l.Name and address ofOwner(s) or Reputed Owner(s):
STEVEN P. DOODAN
197 Village Road
Harrisburg, P A 17112
2. Name and address of Defendant(s) in the judgment:
STEVEN P. DOODAN
197 Village Road
Harrisburg, P A 17112
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
MONROE TOWNSHIP MUNICIPAL AUTHORITY
1220 Boiling Spring Road
Mechanicsburg, P A 17055
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, P A 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, P A 17105-2675
~
4. Name and address of the last recorded holder of every mortgage ofrecord:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUP ANTS
339-339B Old Stonehouse Road
Boiling Springs, P A 17007-9666
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
GOLDBECK McC
BY: Joseph A. Gol
Attorney for Plaintiff
DATED: January 27,2006
05-6233
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION SIB/M
FARMERS TRUST COMPANY
PO Box 840
Buffalo, NY 14240-0840
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
STEVEN P. DOODAN
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
339-339B Old Stonehouse Road
Boiling Springs, P A 17007-9666
Term
No. 05-6233
Defendant(s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE. '
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: DOODAN. STEVEN P.
STEVEN P. DOODAN
197 Village Road
Harrisburg, P A 17112
Your house at 339-339B Old Stonehouse Road, Boiling Springs, P A 17007-9666 is scheduled to
be sold at Sheriff's Sale on Wednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd
FL Courthouse to enforce the court judgment of$43,469.47 obtained by M&T MORTGAGE
CORPORATION S/B/M FARMERS TRUST COMPANY 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 M&T MORTGAGE CORPORATION S/B/M FARMERS
TRUST COMPANY, the back payments, late charges, costs and reasonable attorney's fees due. To find out
how much you must pay call: 215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
05-6233
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed 9istribution is
wrong) are filed with the Sheritf within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, P A 17013
ALL that certain house and lot of ground situate in the Village of Churchtown, Monroe Township,
Cumberland County, Pennsylvania, bounded and describ:d as follows:
On the north by property now or formerly of Riley Urich; on the east by an alley; on the south by
property now or formerly of Sarah Garver or Murray Brownawell; and on the west by Main Street.
Containing 33 feet in front on said Main Street and extending in depth 200 feet to said alley.
Having thereon erected a two and one-half story brick dwelling house and outbuildings, known and
numbered 339 and 339B Old Stonehouse Road, Boiling Springs, Pennsylvania, 17007.
BEING the same premises which Pamela Jo Doodan, by Deed dated November 8, 2004 and recorded in
the Cumberland County Recorder of Deeds Office on December 15, 2004 in Deed Book 266 Page 3546,
granted and conveyed unto Steven P. Doodan.
TAX PARCEL # 22-28~2401-103
MUNICIP ALITY: MONROE TOWNSHIP
PROPERTY ADDRESS: 339-339B OLD STONEHOUSE ROAD, BOILING SPRINGS, P A 17007-
9666
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-6233 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION S/B/M
FARMERS TRUST COMPANY, Plaintiff(s)
From STEVEN P. DOODAN
(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 himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $43,469.47 L.L. $.50
Interest FROM 6/1/05 TO 1/27/06 AT 5.3330%
Atty's Comm %
Atty Paid $187.16
Plaintiff Paid
Due Prothy $1.00
Other Costs
Date: FEBRUARY 7, 2006
(Seal)
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, P A 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
Real Estate Sale # 49
On February 17,2006 the Sheriff levied upon the
defendant's interest in the real property situated in
Monroe Township, Cumberland County, PA
Known and numbered as 339-339B Old Stonehouse Road,
Boiling Springs, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: February 17,2006
By:
JDA u1Sw\Jl
Real E;t4te Sergeant
011 : \I 'V B - 93~ QOOl
Vd ')"HmOJ OlfvlM38WIlO
.:L:fIH3HS 3Hl dO 331.:1.:10
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SCHEDULE OF DISTRIBUTION
SALE NO. 49
Date Filed: July 07, 2006
Writ No. 2005-6233 Civil Term
M&T Mortgage Corporation slb/m Farmers Trust Company
VS
Steven P. Doodan
339-339B Old Stonehouse Road
Boiling Springs, P A 17007
Sale Date:
Buyer:
Bid Price:
June 07, 2006
Michael J. Home
$55,200.00
Real Debt:
Interest:
Attorney Costs:
$43,469.47
1,524.00
187.16
Total:
$45,180.63
DISTRIBUTION:
Receipts:
Cash on account (02/17/2006):
Cash on account (06/07/2006):
Cash on account (06/22/2006):
$ 1,500.00
5,520.00
53,358.40
Total Receipts:
$60,378.40
Disbursements:
Sheriffs Costs
Legal Search
Transfer Tax - Local
Transfer Tax - State
Mary Murray, Local Tax Collector
Monroe Township Lien #2004-2258
Attorney Joseph Goldbeck
M&T Mortgage Corporation
Monroe Township Judgement #2003-1605
Civil Term
Total Disbursements:
Balance for distribution:
So Answers:
C~~r4Jt
R. Thomas Kline
Sheriff
~
$1,853.83
200.00
1,187.20
1,187.20
1,111.57
6,633.29
1,500.00
45,180.63
1,524.68
($60,378.40)
0.00
TITLE REPORT
THE PREMISES ENDORSED HEREON ARE SUBJECf TO THE FOLLOWING
ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACfORY
EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED.
SHERIFF SALE NO. 49
Held Wednesday, June 7, 2006
Date: June 7, 2006
TAXES: Receipts for all taxes for the years 2003 to 2005 inclusive. Taxes for the current year
2006.
WATER RENT:
SEWER RENT
Company assumes no liability for private supply of water or sewer.
Receipts to be produced if services are lienable.
MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims.
MUNICIP AL CLAIMS
MORTGAGES: Listed Under Other Exceptions Below.
JUDGMENTS: Listed Under Other Exceptions Below.
INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to
dated , 2006, and recorded
, 2006, in Cumberland County Deed Book , Page
RECITAL: Being the same premises which Isabella E. Lear, widow, by deed dated August 1,
1991 and recorded August 1, 1991 in the Office of the Recorder of Deeds for Cumberland
County in Deed Book "G," Volume 35, Page 34, granted and conveyed to Steven T. Doodan,
single man.
OTHER EXCEPTIONS:
1. The identity and legal competency of parties at the closing of this title should be
established to the satisfaction of the closing attorney acting for this Company.
2. Rights or claims of parties in possession, if any, other than the owner.
3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in
area and encroachments which an accurate and complete survey would disclose.
4. Payment of State and local Real Estate Transfer Taxes, if required.
5. Public and private rights in the roadbed of Main Street, also known as Old
Stonehouse Road, and in an unnamed public alley.
6. Mortgage in the amount of $54,400.QO, given by Steven P. Doodan to Farmers
Trust Company dated August 1,1991 and recorded August 1, 1991 in Mortgage Book 1023,
Page 674.
Complaint in Mortgage Foreclosure filed by M & T Mortgage Corporation, successor
by merger to Farmers Trust Company, as Plaintiff against Steven P. Doodan as Defendant on
December 2, 2005 in the Office of the Prothonotary of Cumberland County to file number 2005-
6233. Judgment entered in the amount of $43,469.47.
7. Judgment in the amount of $3,000.00 entered by Monroe Township Municipal
Authority as Plaintiff against Steven P. Doodan as Defendant, in the Office of the Prothonotary
on April 8, 2003 to File No. 2003-1605.
8. Subject to Declaration of Taking recorded in Miscellaneous Record Book 629,
Page 631.
9. Rights granted to Monroe Township Municipal Authority by instrument recorded
in Miscellaneous Record Book 638, Page 323.
10. Municipal lien filed by Monroe Township Municipal Authority as Plaintiff,
against Steven P. Doodan as Defendant in the Office of the Prothonotary on May 19, 2004 to
File No. 2004-2258.
11. Subject to shared well for water use as recorded in Deed Book "Z," Volume 5,
Page 157.
12. Satisfactory evidence to be produced that proper notice was given to the holders
of all liens and encumbrances intended to be divested by subject Sheriff Sale.
13. Real estate taxes accruing on and after July 1,2006 not yet due and payable.
It is to be noted that no search of Domestic Relations Records has been made to
determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any
search been made for environmental liens in Federal District Court.
~~-:d
Robert G. Frey, Agent
Note: This Title Report shall not be valid or
until countersigned by an authorized signatory.
;..& ~
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Conunonwealth 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 Conunonwealth 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 April and the
3rd day(s) of May 2006. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COpy
S ALE #49
Sworn to and s
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CON'Wt4INO 33 feet il.l'rod em SlIili Main'
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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
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:
Apri17,14,21,2006
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.
REAL ESTATE SALE NO. 49
Writ No. 2005-6233 Civil
M & T Mortgage Corporation
s/b/m Farmers TIust Company
vs.
Steven P. Doodan
Atty.: Joseph Goldbeck
ALL that certain house and lot of
ground situate in the Village of
Churchtown. Monroe Township,
Cumberland County, Pennsylvania,
bounded and described as follows:
On the north by property now or
formerly of Riley Urich; on the east
by an alley; on the south by prop-
erty now or formerly of Sarah Garver
or Murray Brownawell; and on the
west by Main Street.
Containing 33 feet In front on said
Main Street and extending In depth
200 feet to said alley.
Y.I........:__ ....1-...____ ___....-.....1 _ ................ __...t
SWORN TO AND SUBSCRIBED before me this
21 day of April. 2006
No
N~)T SEAL
, LClP!:, .'lO'-R, Notlry Public
I, C',:',' ", i',fY , f,>Jrnb"E', :lmi) county,
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