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HomeMy WebLinkAbout05-6233 II""" 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-{ / !. / - ..~ Diana M:Rooinson M&T MORTGAGE CORPORATION p,~lii6it Jl -- -- 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. - -. ~-,:;:~ ~i2~'~'~ ?,_~' \~\I ~~ //d,' 1 ~- n~ ....L4..~C....',f ... ........."'t...,._ ,'i/!"i:.~w:"t.} '.' :,.' , '.i.,,'O,?j/J'>-o(""_Qi),\"" :".. .; '., ""::-'llf,'.~\''t....'::rA:'" t,p'fJ ; .~ : ~1,,,~~'f~,.:...ift:)l:'t-".~ ~ '~'::~ y,-:"-,'v:t;:;').~~~,~..;:,,-,~ "..o.~,~ ,.;:.r,'.-':5-~~r:"" .. \"'.4.,', ~-.......'_ _:-,;..'~'~ ,Jo:,;il" ~,,: , y" ," "'-:":~'''''':" " !"'=.:'~ " ~j,./"?....'. ;~:~,..',. ',..~~.,.-.~ I ':./ ~ ' '.J ,,,,,,, ~ '11.,?C;,'::~h:'o~~ .,- ~ 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 . .....,. boodi!2,3 fl,C, fi80 p,~lii6it (8 .... """ 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 ..... - 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 - "" 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 '- .., 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 '" .., 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 - p~ 1-~~ - ~ C> ~ ~ -:cJ ~ w f- \Y-O~ J::- \ r-...) .' , co g 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 / ;2cCL,(P !3~~~ . protKonot~'---+:?k 1 this J{~ So answ",X",a~" ) _./"-/ " 'J . .-..:..._ '~~;:::-~;; , 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: -' '-~? .---,' ,'- . /C.. .<>?....?"~ ;..---- - -,:~~ //:::~?" ~/ 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 tcJ C r-- ~ D (:') \:l::.. ~ ru; ~ ('1'\ ...... ~ ~ C -- I;:). ..c I:> 0v ~ ~ ~ ~ ~ 0 ~n --- 'i--')" --' -CQ" "';) V'1. ~ .J;:. ..,.., :'C--T"", :<<l. :X ~ "- ,-^> ,.,-' n 1 ~;:" :-- -0 ~ ~ lU l'/ t.;;:J -- \ ; \..~' 8 \) f' 'G c t/1 "-> ..() v -< \> ~ IJ Cr) "- V I \ I \ ~r;J - --- ?" ~ ... .' - - 1-~ (~J r ... - ::: ... f....) - ... - - - - ... f/Jt- 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 ~':~ c> C:' --n (", ~ ..,., rq L'"l . -,,' :::"."" .f'_,,) f',) 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. ...,., r" C~) t --l .~~ Co) :D f"") .< 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. m .... IT' IT' m m o:c CJ ~Ll~ I f. .' t) ''.IIM'L ;-JC\~Llt I (Dornestll- 11..131 Orlly /.;( 1/, I ' (' f" 7.,'1 I r ,'( I ru CJ CJ CJ "-" . ee_ Fee .< Ie" e ( i .- I Here ___Fee (ElMfofWl._lt Reqund) CJ Restrtciod 0e!!W<Y Fee IT'_fleqUIIod) m c:J 0903 6/7I06 1'otalfmelt~ , I.ll c:J o l'- llO;iitAi><'1Ii>.;...--..J:la.r.r..i.sbu..r..t;j.,..--SiA-..:i.-7..1.:i.-<:.._.__,... orP08ox'No. ao.;-Siiii;Zi....---...-.....---...-.-...---.---.-........-.----...-.......-....... m lJ'T l'- IT' m m o:c c:J . ~. ru CJ CJ o ...... (Encao_...~=r~ CJ IT' ~~![wIyF" m Roqiilnlcl) CJ CenifIed Fee <.;-, I I.ll ~tro"'fr, MT::C'!Jt)B 6'11106 c:J . f2 ~Ai><m:;..--..ge-t.~~ 9.~~ 0 1 ~ .~.~_?.~ e.h 0 U se ;;~-;...._._...._.._..._.._~....._~~.~_.~~-=:.__..:._~~~~_:~!._~~~ '~t\ ' \ ' \ ~_____--+---:-r- ..~. r-------.~ ~ ~ ~ ___J --+- -----t~ ~:~ \~ ~\ 'o!' u~/-(/ ../ u '0 \1- ___________+-------' +-----'.----------' \~ . 1 ~ ~_____ --- \ ,~s.~ i~ !~/ .-~ ______ --~r--r . "" '., . \ '.\~ . i"'.' .~< ".' . ~~ \, . . , ~:. / ./J-\--' ' . Jt% ,15 ~~ ~m ----- " "0 . ./ l\\\%i~~ \' :0(.<.1'1.0:< ",Ill .....Q} \.L- ':E ~e.s~ 3"'ta ~~o ~ ..~--r-~ ~ \ \. -+' ~ 1ii t ~ !g \ \ 0 \' "O~\ z ui i \"! ,!\ ~> \ ~~N l\~\\'Il\\t ~ ~~~ ~$;\'" ""0.. 'J . "E\ ~'" a::o::~Vi;l0 (.) \9.~g \O~ ounO \ ~\~ ~~~' \ ~~~~' ~ ~~,% <g ~ \ ~ '~ & ~ 5 '6 g,a;.b ~ ~ ~ i _ \:J: - 0- ,,0 (l. "..: _ i _ . ~ 'Q ~f ~ <;:.\' 'i ~ ~ S ~? ~ (l._ '5 E~\-$ if;,j, ui g ~;g"": s.,,'8> t ~ ~:'J,~\ \\g~ ",:i ~ 0: "'t~~(l.. Q6'~ ~ l. g !~. i ~'\ \ ui it. ~ ~ i=' ~ ?\ (l.~ ~ o~..~ ..' ~~. ~.. 0. 0' U 0 oJ EO \~ 0 S'~ 'if, z ~ ~ ui '" s; %\ ..: \7, '" ?;' no~]nc ziSo"ii :z?(!I~~ 0 ~'a's ~~'"% t \, 1~~~!\.gB~8.. Y.! .!~ I-~(!I v ___ - \ .~--=-t .~ \ / \1 I \ I \ \ \ \ \ \ ~ \ \. \ '" \\ \ \ \ ~ ~~ \ ~ \ \ \. \ $ If)_ \ ,~\~~\. \ \ \ "~"'~~~\' \ . \ . N <:'i ... "" ----------- ----- -~.-I J \ \l \\ \\ ~ \~ _J\~ \n \~ii \$'::. :~~ \n \- \1 oa> \$~ \E"" ~s \~i ~-3 /\\=\ ~.-~ \....--...~ <9~; \ ~~-- \~,~\ /\ ~ ~~~:~ ~ \ t ~~ ~\ '\ \ '6. '(..} <,4~ ~ ~~::1 ~%% - \ Iii Q3l1"" ' . ~ '\ ~ 'e 0- , .. ~ \ ----~ ------ .~ \ \ \ \ \ \<.0 \ \ \ \ \ \ \c6 ,"" ~ ~ ~ ~ G " .. "" 'a '& ~ III :; ! .: ~ \ 'Ii '- to o I,) ~ "6 g, !!:. ~ ~ 1:' "l Cl :g 0 0 '" Cl ,.: a: ~ '" '" ~ E 0 '" ~ '0 0 '" , <f) ~ v 0- .' N\T -Oqo3 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 (') ~'"~ lJt:'~, fT'1r: --...--., (J)) ~~~ ~~:~ "'~" :~ ,.." = <"-' cr> ::ll: :;.t-,,;.> -< o ." :Ii." rn~ ""'0 :rJL ~~? ~+~ ~--,-,~O t:5rn .-.--1 ;C; ~ co .." - -'" ~) CJ1 CO 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 ~ ..,,~ 3D vV' ':)'b J. Ck.sLJ~SI ~ 1~'D~) -. ~ 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 ~ ~ (:.(~~ \SSv " 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 1tfiN......_~ .. WrltNo.:.,...t. ~~ ..T_..==.....~. ....aIontN .,....... ,~ " .."p.., . ,...."'........ . ...~.......~ Ii ~'~. ~ - ALL.'l'BAT." ... ... r ......<i_: siIule ... ViIIp CluclIIon;aco-. TonIIip. l:W' ~ ~ CoIIly,.~ ' boa8dI4.........1IlDoln: - I (>>f._"'~ _<< tiwJIwdy of ' &)' UIilk fa die.. bJ . 6y; ._Saulb ' bYJllllI*l1'- <<baiiIy llfSlllfr~ or , MunIJ ...._4 .. OR lIIe Westby MaiD . SInlr.t . CON'Wt4INO 33 feet il.l'rod em SlIili Main' ~_~~ ~~~."':IOOfeetlouil*Y. 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, . . ,. ~""'j'" h 5 I)(IOCl ~' '.' r,. ' '" <-^ohdC"",..," . '\11 \,;_" " ___ ~:m>sr~~~:'l"...,;,,:,,";...~~.,.:.~....,~