HomeMy WebLinkAbout06-1146
. GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR.
ATTORNEY I.D. #16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 825-6318
WWW.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
CITlMORTGAGE INC.
PO Box 9481
Mail Code: 22-528-101 I
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
vs.
CIVIL ACTION - LAW
ANN B. KAGEORGE
BRUCE C. KAGEORGE
Mortgagors and Real Owners
I Tanwood Court
Camp Hill, PA 17011-1551
ACTION OF MORTGAGE FORECLOSURE
Defendants
Term /J' J
..J\lo D~ - /ll.{ Ie, u,,,L
CIVIL AI.,; I 'ON: MORTGAGE~I2.....
F'~:l:CL~U,qF -~'l
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 INFORMA nON ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THA T MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 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 ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES
NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE US TED 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 PAR nCIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
,FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE EST A DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
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 P AGARLE A UN ABOGADO, EST A 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, PAl 70 13
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.
1). 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
FN-0907.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is CITIMORTGAGE INC., PO Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-
9481.
2. The names and addresses of the Defendants are ANN B. KAGEORGE, I Tanwood Court, Camp Hill,
PA 17011-1551 and BRUCE C. KAGEORGE, I Tanwood Court, Camp Hill, PA 17011-1551, who are
the mortgagors and real owners ofthe mortgaged premises hereinafter described.
3. On December 29, 1995 mortgagors made, executed and delivered a mortgage upon the Property
hereinafter described to HART MORTGAGE CORP., which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County as Book 1298, Page 200. The mortgage has been assigned to:
CITIMORTGAGE INC. by assignment of Mortgage which assignment is lodged for recording. The
Mortgage and assignment(s) are matters of public record and are incorporated by this reference in
accordance with Pennsylvania Rule of Civil Procedure I 019(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 November 0 I, 2005 and each month thereafter and by the terms the Mortgage, upon default in such
payments for a period of one month or more, 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 10/0 1/2005
through 02/28/2006 at 8.0000%
Per Diem interest rate at $21.63
Reasonable Attorney's Fee at 5% of Principal Balance as
more fully explained in the next numbered paragraph
Late Charges from 11/01/2005 to 02/28/2006
Monthly late charge amount at $41.55
Costs of suit and Title Search
Foreclosure Charges
Servicing Fees
Unpaid Previous Late Charges
Escrow
Unapplied Funds
Monthly Escrow amount $216.26
$98,679.60
$3,266.13
$4,933.98
$192.27
$900.00
$18.00
$27.00
$27.55
-$116.92
-$30.00
$107,897.61
7. If the Mortgage is reinstated prior to a Sheriffs 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 is entitled to collect Attorney's fees of up
to 5% of the 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 an "in personam" judgment) against the
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have 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.
9. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing
Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983 or Act 160 of
1998.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $107,897.61,
together with interest at the rate of $21.63, 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:
,
B McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR., ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
I, Malinda A. Caywood, 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: 2/ Z '-f-C)c
tUJ{1
Malinda A. Caywood, Vice P e dent
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p,~lii6it .Jl
EIlIIBIT "A"
ALL THAT CKaTAIN pieoe o~ paroel at land, situete in aempden ~ownsb1p,
Cumberland county, Pennsylvenia, more partioular1y bounded and
d.."cril>ed .. tOllows, to wit:
BEGINNINC st . pOint on the interseotlon of tile southerly rl;ht ot
"ay linl of Tlnwood Oourt, a 50 foot vide right of ..aYt and the .astlrly
right of wey line of Mandy Lane, also a 50 foot wide r~ght of ,,"y ..
ahown on tile Plan of Loto known.. "countryside, Seotion IB)" I tIlence
from said polnt of bag inning Ilong the southerly right of WlY line
ot 'ranwood Court, lIorth 81 de91'e.a 21 1I1nut.. 00 leoond. laat, . dbtano
of 85 feet to a point on tha dividing 11ne betw.an LOts Nos. 81 alld
ea, on the afor.eaid Plan of Lots, thence fr~ said point along the
dividing line batween Lot. Nos. 81 and 82, SOUth os do91'S.. 44 minut..
00 second. Eaa~, . 4ietano. of 118 f..t to a monuaent on the dlvid1nq
lin. bat"een loota No.. U and t4 on tl1e aforeeaid Plan of Lot., tl1.n"a
trom said point along tha dividing line bltwean Lot. Nos. 82, 84 and
83, 80utl1 81 dlgrees 21 lIinut.s 00 .eoon41 W..t, a 41stance at 87.4j
fe.t to . point on the e..terly riqht ot way 1i". ot Handy """"I the"".
trom said point 110nq the ..astal"ly rlqnt of way Une of Handy Lane,
N"l"th 05 degre.. 3. minut.. 45 .eoonde WIst, a 4istanoa of 4l.86 tlat
too . pointl tl1.n"e frol .aid point oontinuing &1on9 tl1. S81I., Nortl1
08 degree. 33 minut.. 00 lleonds Wa.t, . dietan"a at 11.21 teet to .
point, the point an4 pla". of BEGINNING.
IIING LOt No. 82 On ths P1an ot Lots known as "countryside, Seotion
(8)" prep.red by Charll. W. JUnkins, aagi.tared Su>:veyor, Olted Daoa..ber
4, 1913 end reoor41d in the Oftioo of tl1e aeoorder ot Deedl ot CumDerlan
County on April 11, 1914, in Plan Bo"k 25, PSg's 7.
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GOLDBECK MeCAFFERTY & McKEEVER
By: MICHAEL T. MCKEEVER, ESQ.
ATTORNEY !.D. #56]29
SUITE 5000 - MELLON ]NDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA ]9]06-]532
(2]5) 627-]322
ATTORNEY FOR PLAINTIFF
CITIMORTGAGE INC.
PO Box 9481
Mail Code: 22-528-]0]]
Gaithersburg, MD 20898-948]
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
Plaintiff
vs.
ACT]ON OF MORTGAGE
FORECLOSURE
ANN B. KAGEORGE
BRUCE C. KAGEORGE
(Mortgagor and Record Owner)
1 Tanwood Court
Camp Hill, PA 17011-155]
Term
No. 06-] ]46
Defendant(s)
PRAECIPE TO CORRECT CAPTION
Kindly correct the docket to reflect the correct caption of CITIMORTGAGE INC. FIKJA
FIRST NATIONWIDE MORTGAGE CORP.
Respectfully submitted,
GOLDBECK, McCAFFERTY & McKEEVER
By:
Michael T. McKeever, Esquire
Attorney for Plaintiff
,,:'
,\
In the Court of Common Pleas of Cumberland County
CITIMORTGAGE INC. F/K1A FIRST NATIONWIDE
MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-101 I
Gaithersburg, MD 20898-948 I
Plaintiff
vs.
ANN B. KAGEORGE
BRUCE C. KAGEORGE
(Mortgagor(s) and Record Owner(s))
I Tanwood Court
Camp Hill, PA 17011-1551
No. 06-1146
Defendant( s)
PRAECIPE FOR JUDGMENT
THIS LAW 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.
Enter the Judgment in favor of Plaintiff and against ANN B. KAGEORGE and BRUCE C. KAGEORGE by default
for want of an Answer.
Assess damages as follows:
$109,494.73
Debt
Interest - 10/01/2005 to 04119/2006
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certifY that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
Jose h A. oldbeck, Jr.
Att ey fo Plaintiff
I.D. 16132
AND NOW ~ ..:l-~ , ~~ , Judgment is entered in favor of
CITIMORTGAGE INC. F/ 1\ FIRST NATIONWIDE MORTGAGE CORP. and against ANN B. KAGEORGE and
BRUCE C. KAGEORGE by default for want of an Answer and damages ass sed in the sum of $ I 09 494 73 as per the
above certification.
FN-0907
THIS LAW 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.
DATE OF THIS NOTICE: March 31, 2006
TO:
BRUCE C. KAGEORGE
1 Tanwood Court
Camp Hill, PA 17011-1551
In the Court of Common Pleas
of Cumberland County
CITIMORTGAGE INC.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
CIVIL ACTION - LAW
Plaintiff
ACTION OF
MORTGAGE FORECLOSURE
vs.
ANN B. KAGEORGE
BRUCE C. KAGEORGE
(Mortgagor(s) and Record Owner(s))
I Tanwood Court
CampHill,PA 17011.1551
Term
No. 06-1146
Defendant(s)
TO: BRUCE C. KAGEORGE
\ Tanwood Court
Camp Hill, PA \7011-155\
IMPORT A NT NOTTeR
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE
MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, PA 17013
JOSl?pfi)f. qo{dfje(~ Jr
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - 70 I Market Street.
Philadelphia, P A 19106 215-825-6318
FN-0907
THIS LAW 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.
DATE OF THIS NOTICE: March 31, 2006
TO:
ANN B. KAGEORGE
1 Tanwood Court
Camp Hill, PA 170] 1-]551
CITIMORTGAGE INC.
PO Box 9481
Mail Code: 22-528-101]
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
Plaintiff
VS.
ANN B. KAGEORGE
BRUCE C. KAGEORGE
(Mortgagor(s) and Record Owner(s))
1 Tanwood Court
Camp Hill, PA 17011.1551
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-1146
Defendant(s}
TO: ANN B. KAGEORGE
] Tanwood Court
Camp Hill, PA 170] 1-]551
IMPORTANT NOTICF.
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING W]TH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGA]NST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF
THIS NOT]CE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE
YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFF]CE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO
HIRE A LAWYER, THIS OFF]CE MAY BE ABLE TO PROVIDE YOU WITH INFORMA T]ON ABOUT AGENCIES
THAT MAY OFFER LEGAL SERVICES TO EUGlBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
G
B . osepl1 A Goldbeck., Jr., Esq.
Attorney for Plaintiff
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106 215-627-1322
FN-0907
THIS LAW 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.
DATE OF THIS NOTICE: March 31, 2006
TO:
ANN B. KAGEORGE
22 S. 36th Street
Camp Hill. PA 17011-1551
In the Court of Common Pleas
ofCumherland County
CITIMORTGAGE INC.
PO Box 9481
Mail Code: 22-528-101]
Gaithersburg, MD 20898-9481
CIVIL ACTION - LAW
PlaintifJ
ACTION OF
MORTGAGE FORECLOSURE
vs.
ANN B. KAGEORGE
BRUCE C. KAGEORGE
(Mortgagor(s) and Record Owner(s))
1 Tanwood Court
Camp Hill, PA 170] ]-155]
Term
No. 06-] 146
Defendant(s)
TO: ANN B. KAGEORGE
22 S. 36th Street
Camp Hill, PA 17011-1551
IMPORT A NT NOTWR
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE
MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 lrvine Row
Carlisle, P A 17013
717-243-9400
CUMBERLAND COUNTV BAR ASSOClATlON
2 Liberty Avenue
Carlisle, P A 17013
Joseph}t. qo(d6e(~ Jr
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attomey for Plaintiff
Suite 5000 - 70] Market Street.
Philadelphia, PA 19106 215-825-6318
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized
to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of
Non-Military Service are true and correct to the best of my
knowledge,
information and belief.
I understand that false
statements therein are made subject to penalties of 18 Pa. C.S.
4904 relating to unsworn falsification to authorities.
1. That the above named Defendant, ANN B. KAGEORGE, is
about unknown years
of age,
that
Defendant's
last
known
residence is 22 S. 36th Street, Camp Hill, PA
17011-1551, and
is engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or otherwise wi thin the
provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date: \ i <\ \DY'
1,\ \l
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized
to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of
Non-Military Service are true and correct to the best of my
knowledge, information and belief. I understand that false
statements therein are made subject to penalties of 18 Pa. C.S.
4904 relating to unsworn falsification to authorities.
1. That the above named Defendant, BRUCE C. KAGEORGE, is
about unknown years of age, that Defendant's last known
residence is 1 Tanwood Court, Camp Hill, PA 17011-1551, and is
engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or otherwise wi thin the
provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date:
q\l~~V4'
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE INC. F/K/A FIRST NATIONWIDE
MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION LAW
ANN B. KAGEORGE
BRUCE C. KAGEORGE
(Mortgagor(s) and Record owner(s))
I Tanwood Court
Camp Hill, PA 17011-1551
ACTION OF MORTGAGE FORECLOSURE
No. 06-1146
Defendant( s)
ORDER FOR JUDGMENT
Please enter Judgment in favor of CITIMORTGAGE INC. F/K1A FIRST NATIONWIDE MORTGAGE
CORP., and against ANN B. KAGEORGE and BRUCE C. KAGEORGE for failure to file an Answer in the
above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of
service of the Complaint, in the sum of $1 09,494.73.
I hereby certifY that the above names are correct and that precise residence address of the judgment
creditor is CITIMORTGAGE INC. FIKJA FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail
Code: 22-528-1011 Gaithersburg, MD 20898-9481 and that the name(s) and last known addressees) of the
Defendant(s) is/are ANN B. KAGEORGE, 22 S. 36th Street Camp Hill, PA 17011-1551 and BRUCE C.
KAGEORGE, I TanwoodCourtCampHill,PA 17011-1551;
TO THE PROTHONOTARY:
ASSESSMENT OF DAMAGES
Kindly assess the damages in this case to be as follows:
Principal Balance
Interest from 10101/2005 through
04/19/2006
Attorney's Fee at 5.0000% of principal
balance
Late Charges
Costs of Suit and Title Search
F orec1osure Charges
Servicing Fees
Unpaid Previous Late Charges
Escrow Balance Deficit
Escrow
Unapplied Funds
AND NOW, this
day of
/'t
$98,679.60
$4,347.63
$4,933.98
$275.37
$900.00
$18.00
$27.00
$27.55
$432.52
-($116.92)
-($30.00)
$109,494.73
GO BE K McCAFFERTY & McKEEVER
B : Josep A. Goldbeck, Jr.
Att rney ~ r Plaintiff
, 2006 damages are assessed as above.
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
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
CITIMORTGAGE INC. F/K1A FIRST NATIONWIDE
MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION .- LAW
ANN B. KAGEORGE
BRUCE C. KAGEORGE
Mortgagor(s) and Record Owner(s)
1 Tanwood Court
Camp Hill. PA 17011-1551
ACTION OF MORTGAGE FORECLOSURE
No. 06-1146
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$109,494.73
Interest from
10/01/2005 to
04/19/2006 at
8.0000%
(Costs to be added)
GOLDB CK CAFFERTY & McKEEVER
BY: Jose h A. G Idbeck, Jr.
Attorney Pial tiff
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All that certain piece or parcel ofland, situate in Hampden Township, Cumberland County,
Pennsylvania, more particularly bounded and described as follows, to wit:
Beginning at a point on the intersection of the southerly right of way line of Tanwood Court, a 50 foot
wide right of way, and the easterly right of way line of Mandy Lane, also a 50 foot wide right of way as
shown on the Plan of Lots known as "Countryside, Section (B)"; thence from said point of beginning
along the southerly right of way line of Tanwood Court, North 81 degrees 27 minutes 00 seconds East, a
distance of 85 feet to a point on the dividing line between Lots Nos. 81 and 82, on the aforesaid Plan of
Lots; thence from said point along the dividing line between Lots Nos. 81 and 82, South 08 degrees 44
minutes 00 seconds East, a distance of 118 feet to a monument on the dividing line between Lots Nos.
82 and 84 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots
Nos. 82, 84 and 83, South 81 degrees 27 minutes 00 seconds West, a distance of 87.49 feet to a point on
the easterly right of way line of Mandy Lane; thence from said point along the easterly right of way line
of Mandy Lane, North 05 degrees 39 minutes 46 seconds West, a distance of 41.86 feet to a point;
thence from said point continuing along the same, North 08 degrees 33 minutes 00 seconds West, a
distance of 76.21 feet to a point, the point and place of beginning.
Being Lot No. 82 on the Plan of Lots known as "Countryside, Section (B)" prepared by Charles W.
Junkins, Registered Surveyor, dated December 4,1973 and recorded in the Office of the Recorder of
Deeds of Cumberland County on April 11, 1974, in Plan Book 25, Page 7.
MUNICIPALITY: Hampden Township
PROPERTY ADDRESS: 1 Tanwood Court, Camp Hill, P A 17011
TAX PARCEL #: 10-19-1598-293
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-1146 Civil
CIVIL ACTION - LA W
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Citimortgage Inc. f/k/a First Nationwide Mortgage Corp.
P. O. Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff (s)
From Ann B. Kageorge
Bruce C. Kageorge
I Tamvood Court
Camp Hill, PA 17011-1551
(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 gamishee(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 himiher that helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due$109,494.73
L.L.$.50
Interest from 10/0112005 to 04119/2006 at 8.0000%
Atty's Comm
Ally Paid $152.40
Plaintiff Paid
Date: April 25, 2006
%
Due Prothy $ 1.00
Other Costs
(Seal)
By:
Deputy
REQUESTING PARTY:
Name Joseph A. Goldbeck, Jr., Esq.
Address: Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
Attorney for: Plaintiff
Telephone: 215-627-1322
Supreme Court ID No. 16132
Go1db'\j.k McCafferty & McKeever
EtY: Joseph A. Goldbeck, Jr.
Attorney J.D. #16132
Suite 5000 ~ Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE INC. F/KJA FIRST
NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION. LAW
ANN B. KAGEORGE
BRUCE C. KAGEORGE
(Mortgagor(s) and Record Owner(s))
I Tanwood Court
CampHill,PA 17011-1551
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 06-1146
AFFIDAVIT PURSUANT TO RULE 3129
CITIMORTGAGE INC. FIKlA FIRST NATIONWIDE MORTGAGE CORP., 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:
I Tanwood Court
Camp Hill, PA 17011-1551
I.Name and address ofOwner(s) or Reputed Owner(s):
ANN B. KAGEORGE
22 S. 36th Street
Camp Hill, PA 17011-1551
BRUCE C. KAGEORGE
I Tanwood Court
Camp Hill, PA 17011-1551
2. Name and address ofDefendant(s) in the judgment:
ANN B. KAGEORGE
22 S. 36th Street
Camp Hill, PA 17011-1551
BRUCE C. KAGEORGE
1 Tanwood Court
Camp Hill, PA 17011-1551
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
,
.
""
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
BLUE VIEW CORP.
3015 ST. CHARLES PLACE
SAN DIEGO, CA 92110
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
I TANWOOD COURT
CAMP HILL, PA 17011-1551
(attach separate sheet if more space is needed)
I veritY 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: April 19, 2006
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06-1146
h
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney 1.0.#16132
Suite 5000- Mellon Independence Center
70 I Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE INC. F/KJA FIRST
NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION. LAW
vs.
ANN B. KAGEORGE
BRUCE C. KAGEORGE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
I Tanwood Court
Camp Hill, PA 17011-1551
Tenn
No. 06-1146
Defendant( 5
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: KAGEORGE, ANN B
ANN B. KAGEORGE
22 S. 36th Street
Camp Hill, PA 17011-1551
Your house at I Tanwood Court, Camp Hill, PA 17011-1551 is scheduled to be sold at Sheriffs
Sale on Wednesday, September 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of$109,494.73 obtained by CITlMORTGAGE INC. F/KlA FIRST
NA TlONWIDE MORTGAGE CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
I. The sale will be cancelled if you pay to CITIMORTGAGE INC. FIKIA FIRST NATIONWIDE
MORTGAGE CORP., the back payments, late charges, costs and reasonable attorney's fees due. To find
out how much you must pay call: 215-627-1322
,.
..
06-1146
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.
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.
I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriffof717-240-6390.
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 fmd
out if this has happened, you may call the Sheriffof717-240-6390.
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 Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
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 SERVlCES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
:,\
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06-1146
~ GOLDBECK McCAFFERTY & McKEEVER
~ BY: Joseph A. Goldbeck, Jr.
Attorney 1.0.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
ClTIMORTGAGE INC. F/K/A FIRST
NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
ANN B. KAGEORGE
BRUCE C. KAGEORGE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
1 Tanwood Court
Camp Hill, PA ]701 ]-]551
Term
No. 06-] 146
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: KAGEORGE, BRUCE C.
BRUCE C. KAGEORGE
1 Tanwood Court
Camp Hill, PA 17011-1551
Your house at 1 Tanwood Court, Camp Hill, PA 17011-1551 is scheduled to be sold at Sheriff's
Sale on Wednesday, September 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FI. Courthouse
to enforce the court judgment of$109,494.73 obtained by CITlMORTGAGE 1Ne. F/K/A FIRST
NA TlONWIDE MORTGAGE CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
I. The sale will be cancelled if you pay to CITlMORTGAGE INC. FIK/A FIRSTNATlONWIDE
MORTGAGE CORP., the back payments, late charges, costs and reasonable attorney's fees due. To find
out how much you must pay call: 215-627-1322
..
06-1146
"".
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.
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.
I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid 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 fmd
out if this has happened, you may call the Sheriff of717-240-6390.
4. (fthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as ifthe 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 distribution is
wrong) are filed with the Sheriff 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. lFYOU DO NOT HAVE A
LA WYER 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, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
,
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Joseph A. Goldbeck, Jr.
Attorney 1.0. #16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
CITlMORTGAGE INC. FIKIA FIRST NATIONWIDE
MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MO 20898-9481
IN THE COURT OF
COMMON PLEAS
Plaintiff
vs.
of Cumberland County
ANN B. KAGEORGE
BRUCE C. KAGEORGE
Mortgagor(s) and Record Owner(s)
I Tanwood Court
Camp Hill, PA 17011-1551
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
Oefendant(s)
NO. 06-1146
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Joseph A. Goldbeck, Jr., Esquire hereby certifY that I am the attorney of record for the Plaintiff in this
action, and 1 further certifY that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all
the provisions of the Act.
c
.-"..
SHORT DESCRIPTION
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 1 Tanwood Court
Camp Hill, PA 17011-1551
SOLD as the property of ANN B. KAGEORGE and BRUCE C. KAGEORGE
TAX PARCEL #10-19-1598-293
.'
-'
.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01146 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIMORTGAGE INC
VS
KAGEORGE ANN B ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
KAGEORGE BRUCE C
the
DEFENDANT
, at 1050:00 HOURS, on the 9th day of March
, 2006
at 1 TANWOOD COURT
CAMP HILL, PA 17011
by handing to
BRUCE KAGEORGE
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
13 .20
.00
10.00
.00
29.20
~;.' ~,.I.,.+~/
,?~.... .-;.:'/ '." ;t<~.r.~~/'
-4"'" ?i ",~"",'!.;',~-""'-t~' 1'~ <t~'<,'_~"'-ri"-!.~
.-(' ii.-"'-i<":--'l'!"- -, " ,,'<,', -"1 ,..'-'
R. Thomas Kline
03/16/2006
GOLDBECK MCCAFFERTY MCKEEVER
Sworn and Subscribed to before
me this ,l.!Ak
day of
By: ~~4I---'
Deputy S riff
~ ~{r100\. A.D.
(!,~
.
SHERIFF'S RETURN - REGULAR
.
CASE NO: 2006-01146 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIMORTGAGE INC
VS
KAGEORGE ANN B ET AL
SHARON LANTZ
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
KAGEORGE ANN B
the
DEFENDANT
, at 1757:00 HOURS, on the 10th day of March
, 2006
at 22 S 36TH STREET
CAMP HILL, PA 17011
by handing to
ANN B KAGEORGE
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
13.20
.00
10.00
.00
41.20
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R. Thomas Kline
03/16/2006
GOLDBECK MCCAFFERTY MCKEEVER
me this ..2IAlfr
day of
Sworn and Subscribed to before By:
J....{!~~D
proth ary
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE INC. FIKJA FIRST
NATIONWIDE MORTGAGE CORP.
PO Box 948\
Mail Code: 22-528-1011
Gaithersburg, MD 20898-948\
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
ACTION OF MORTGAGE FORECLOSURE
ANN B. KAGEORGE
BRUCE C. KAGEORGE
Mortgagor(s) and Reeord Owner(s)
Term
No. 06-1146
1 Tanwood Court
Camp Hill, PA \7011-\55\
Defendant( s)
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
C1TIMORTGAGE INC. FfKlA FIRST NATIONWIDE MORTGAGE CORP., 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:
1 Tanwood Court
Camp Hill, PA 17011-1551
l.Name and address ofOwner(s) or Reputed Owner(s):
ANN B. KAGEORGE
22 S. 36th Street
Camp Hill, PA 17011-1551
BRUCE C. KAGEORGE
I Tanwood Court
Camp Hill, PA 17011-1551
2. Name and address ofDefendant(s) in the judgment:
ANN B. KAGEORGE
22 S. 36th Street
Camp Hill, PA 17011-1551
BRUCE C. KAGEORGE
1 Tanwood Court
Camp Hill, PA 17011-1551
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
MARY DISSINGER
28 N. 32ND STREET
CAMP HILL, PA 17011
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
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
BLUE VIEW CORP.
3015 ST. CHARLES PLACE
SAN DIEGO, CA 92110
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.
TENANT~OCCUPANTS
I TANWOOD COURT
CAMP HILL, PA 17011-1551
(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
infonnation and belief. 1 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: August 14, 2006
D
B : Jo ph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney 1.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorn for Plaintiff
ClTlMORTGAGE INC. FfK/A FiRST NATIONWIDE
MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
FN-0907
CF: 02/28/2006
SD: 09/06/2006
$109,494.73
IN TIIE COURT OF COMMON PLEAS
of Cwnberland County
CIVIL ACTION - LAW
Plaintiff
VS.
ACTION OF MORTGAGE FORECLOSURE
ANN B. KAGEORGE
BRUCE C. KAGEORGE
Mortgagor(s) and
Record Owner(s)
Term
No. 06-1146
I Tanwood Court
Camp Hill, PA 17011-1551
Defendant(s)
CERT,lFlCA.l't: OF SERVICE
PlLNYAN1' ~C,P, ~U9.Z eel (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:
~~@~PaHo llM~~.
(,)(:) Personal Service by the Sheriff's Offic r"t>...t l(.!P, 8. tlIadl..d):
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
( ) Certified mail by Sheriff's Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriff's 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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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney 1.0. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE INC. F/KlA FIRST NATIONWIDE
MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
ANN B. KAGEORGE
BRUCE C. KAGEORGE
(Mortgagor(s) and Record owner(s))
1 Tanwood Court
Camp Hill, PA 17011-1551
No. 06-1146
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly vacate the judgment upon payment of your costs only.
fJ't~-
JOSEPH A. GOLDBECK, JR., ESQUIRE
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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
215-825-6321
Attorney for Plaintiff
-'
CITIMORTGAGE INC. FIK/A FIRST
NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
ANN B. KAGEORGE
BRUCE C. KAGEORGE
(Mortgagor(s) and Record owner(s))
1 Tanwood Court
Camp Hill, PA 17011-1551
No. 06-1146
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of your costs only.
!J't~
JOSEPH A. GOLDBECK, JR., ESQUIRE
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Citimortgage Inc.
VS
Ann B. Kageorge and Bruce C. Kageorge
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2006-1146 Civil Term
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on July 17,2006 at 7:27 o'clock PM, he served a true copy of the within Real Estate
Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the
within named defendant, to wit: Ann B. Kageorge, by making known unto Ann B.
Kageorge, personally at 22 South 36th Street, Camp Hill, Cumberland County,
Pennsylvania, its contents and at the same time handing to her personally the said true
and correct copy of the same.
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on July 17,2006 at 2:15 o'clock PM, he served a true copy of the within Real Estate
Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the
within named defendant, to wit: Bruce C. Kageorge, by making known unto Bruce C.
Kageorge, personally at 1 Tanwood Court, Camp Hill, Cumberland County,
Pennsylvania, its contents and at the same time handing to him personally the said true
and correct copy of the same.
Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states
that on July 3, 2006 at 4:49 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
Ann B. Kageorge and Bruce C. Kageorge located at 1 Tanwood Court, Camp Hill, P A
17011 according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendants, to wit: Ann B. Ka~eorge and Bruce C. Kageorge, by regular mail to their last
known address of22 South 26 Street, Camp Hill, PA 17011 and 1 Tanwood Court,
Camp Hill, PA 17011, respectively. These letters were mailed under the date of July 26,
2006 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per instructions from Attorney Joseph Goldbeck.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Law Library
Prothonotary
Mileage
30.00
355.32
15.00
15.00
.50
1.00
26.40
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Postpone Sale
15.00
30.00
407.00
369.20
19.31
20.00 (]
$1,303.73 V IIJb3Jt>& I
So ~~w~ ~
~~~ 'CI('
R. Thomas Kline, Sheriff
BY \J ccl'v .~ ~
Real Estate ergeant
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.'
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 Plaintiff
CITIMORTGAGE INC. F/KIA FIRST
NA TIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LA W
ANN B. KAGEORGE
BRUCE C. KAGEORGE
(Mortgagor(s) and Record Owner(s))
1 Tanwood Court
Camp HilI, PA 17011-1551
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 06-1146
AFFIDAVIT PURSUANT TO RULE 3129
CITIMORTGAGE INC. F/KJA FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above actioD, 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 cODcerning the real property located at:
1 Tanwood Court
Camp HilI, PA 17011-1551
I.Name and address of Owner(s) or Reputed Owner(s):
ANN B. KAGEORGE
22 S. 36th Street
Camp HilI, PA 17011-1551
BRUCE C. KAGEORGE
1 Tanwood Court
Camp HilI, PA 17011-1551
2. Name aDd address ofDefeDdant(s) in the judgmeDt:
ANN B. KAGEORGE
22 S. 36th Street
Camp HilI, PA 17011-1551
BRUCE C. KAGEORGE
1 Tanwood Court
Camp HilI, PA 17011-1551
3. Name aDd last known address of every judgment creditor whose judgment is a record lieD on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
f'
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage ofreeord:
BLUE VIEW CORP.
3015 ST. CHARLES PLACE
SAN DIEGO, CA 92110
5. Name and address of every other persoD who has aDY record interest in or record lieD 00 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 persoD of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
1 TANWOODCOURT
CAMP HILL, PA 17011-1551
(attach separate sheet if more space is needed)
I verify that the statements made iD this affidavit are true and correct to the best of my persoDal knowledge or
information and belief. I understaDd that false statemeDts herein are made subjeet to the peDalties of 18 Pa. C.S. SectioD 4904
relating to unsworn falsification to authorities.
DATED: April 19. 2006
Il :E d q l HdV qOOl
Vd 'AIHI:uJ Urll1.U8Wi,:)
.:l.:l1~3HS 3Hl .:10 3:JI.::l.:lO
.
t
06-1146
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
Attorney for Plaintiff
CITIMORTGAGE INC. FIKIA FIRST
NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
ANN B. KAGEORGE
BRUCE C. KAGEORGE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
1 Tanwood Court
Camp Hill, PA 17011-1551
Term
No. 06-1146
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: Ann B. Kageorge
Ann B Kageorge
1 Tanwood Court
Camo Hill, Pa 17011-1551
Your house at 1 Tanwood Court, Camp Hill, P A 17011-1551 is scheduled to be sold at Sheriff's
Sale 00 Wednesday, September 06,2006, at 10:00 AM, in CommissioDers Hearing Rm 2nd FL Courthouse
to enforce the court judgment of $ 109,494.73 obtaiDed by CITIMORTGAGE INe. F/K/A FIRST
NATIONWIDE MORTGAGE CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To preveDt this Sheriff's Sale you must take immediate actioD:
.
~
06-1146
1. The sale will be cancelled if you pay to CITIMORTGAGE INC. F/KJA FIRST NATIONWIDE
MORTGAGE CORP., the back payments, late charges, costs and reasoDable attorney's fees due. To fmd
out how much you must pay call: 215-627-1322
2. You may be able to stop the sale by filing a petitioD asking the Court to strike or opeD judgmeDt, if
the judgmeDt was improperly eDtered. You may also ask the Court to postpoDe the sale for good cause.
3. You may also be able to stop the sale through other legal proeeedings.
You may need an attorney to assert your rights. The SOODer you cODtact ODe, the more chance you
will have of stopping the sale. (See Dotice 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 Sheriffs Sale is Dot stopped, your property will be sold to the highest bidder. You may fmd
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 priee was grossly inadequate
compared to the value of your property.
3. The sale will go through oDly if the buyer pays the Sheriff the full amouDt due iD the sale. To fmd
out if this has happeDed, you may call the Sheriff of7 1 7-240-6390.
4. If the amount due from the Buyer is Dot paid to the Sheriff, you will remain the owner of the
property as if the sale Dever happeDed.
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 eDtitled to a share of the mODey which was paid for your house. A sehedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that mODey. The mODey will be
paid out in accordance with this schedule unless exceptioDs (reasoDs why the proposed distributioD is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defeDses, 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
06-1146
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE INC. FIKJA FIRST
NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
ANN B. KAGEORGE
BRUCE C. KAGEORGE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
1 Tanwood Court
Camp Hill, PA 17011-1551
Term
No. 06-1146
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: KAGEORGE, BRUCE C.
BRUCE C. KAGEORGE
1 Tanwood Court
Camp Hill, PA 17011-1551
Your house at 1 Tanwood Court, Camp Hill, PA 17011-1551 is scheduled to be sold at Sheriff's
Sale on Wednesday, September 06, 2006, at 10:00 AM, in CommissioDers Hearing Rm 2nd FL Courthouse
to enforce the courtjudgmeDt of$109,494.73 obtained by CITIMORTGAGE INC. F!K/A FIRST
NATIONWIDE MORTGAGE CORP. 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 CITIMORTGAGE INC. F!K/A FIRST NATIONWIDE
MORTGAGE CORP., the back payments, late charges, costs and reasonable attorney's fees due. To fmd
out how much you must pay call: 215-627-1322
06-1146
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 eDtered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The SOODer 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 fmd
out the price bid price by calling the Sheriff of 717-240-6390.
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 fmd
out if this has happened, you may call the Sheriff of 717-240-6390.
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 exceptioDs (reasons why the proposed distribution is
wrong) are filed with the Sheriff 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, PA 17013
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty A venue
Carlisle, P A 17013
All that certain piece or parcel ofland, situate in Hampden Township, Cumberland County,
Pennsylvania, more particularly bounded and described as follows, to wit:
Beginning at a point on the intersection of the southerly right of way line of Tanwood Court, a 50 foot
wide right of way, and the easterly right of way line of Mandy Lane, also a 50 foot wide right of way as
shown on the Plan of Lots known as "Countryside, Section (B)"; thence from said point of beginning
along the southerly right of way line of Tanwood Court, North 81 degrees 27 minutes 00 seconds East, a
distance of 85 feet to a point on the dividing line between Lots Nos. 81 and 82, on the aforesaid Plan of
Lots; thence from said point along the dividing line between Lots Nos. 81 and 82, South 08 degrees 44
minutes 00 seconds East, a distance of 118 feet to a monument on the dividing line between Lots Nos.
82 and 84 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots
Nos. 82, 84 and 83, South 81 degrees 27 minutes 00 seconds West, a distance of 87.49 feet to a point on
the easterly right of way line of Mandy Lane; thence from said point along the easterly right of way line
of Mandy Lane, North 05 degrees 39 minutes 46 seconds West, a distance of 41.86 feet to a point;
thence from said point continuing along the same, North 08 degrees 33 minutes 00 seconds West, a
distance of 76.21 feet to a point, the point and place of beginning.
Being Lot No. 82 on the Plan of Lots known as "Countryside, Section (B)" prepared by Charles W.
Junkins, Registered Surveyor, dated December 4, 1973 and recorded in the Office of the Recorder of
Deeds of Cumberland County on April 11 , 1974, in Plan Book 25, Page 7.
MUNICIPALITY: Hampden Township
PROPERTY ADDRESS: I Tanwood Court, Camp Hill, PA 17011
TAX PARCEL #: 10-19-1598-293
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) J
COUNTY OF CUMBERLAND)
NO 06-1146 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and eosts due Citimortgage Inc. f/k/a First Nationwide Mortgage Corp.
P. O. Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff (s)
From Ann B. Kageorge
Bruce C. Kageorge
1 Tanwood Court
Camp Hill, PA 17011-1551
(1) You are directed to levy upon the property of the defendant (s)and to sell see legal description.
(2) You are also direeted to attaeh 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 attaehment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the aeeount of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attaehment is found in the possession
of anyone other than a named garnishee, you are direeted to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due$109,494.73 L.L.$.50
Interest from 10/0112005 to 04/19/2006 at 8.0000%
Arty's Comm
Arty Paid $152.40
Plaintiff Paid
Date: April 25, 2006
%
Due Prothy $ 1.00
Other Costs
!~
(Seal)
By:
Deputy
REQUESTING PARTY:
Name Joseph A. Goldbeck, Jr., Esq.
Address: Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
Attorney for: Plaintiff
Telephone: 215-627-1322
Supreme Court ID No. 16132
Real Estate Sale # 18
On May 16, 2006 the Sheriff levied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County, PA
Known and numbered as 1 Tanwood Court,
Camp Hill, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
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FE
C$j
Date: May 16, 2006
By:
e Sergeant
Ol :[ d 'll HdV qUUl
~J,j'~~~ SlJj;H l' ~v~uI15/~] 8 J
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
SSe
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
VIZ:
July 21, July 28, and August 4, 2006
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
SWORN TO AND SUBSCRIBED before me this
4 day of August. 2006
NOTARIAL SEAL
LOIS E. SNYDER, Notary Public
CarKsle Boro, Cumberland County
My Commission Expires March 5, 2009
REAL ESTATE SALE NO. 18
Writ No. 2006-1146 Civil
Citimortgage Inc. fka First
Nationwide Mortgage Corp.
vs.
Ann B. Kageorge and
Bruce C. Kageorge
Atty.: Joseph Goldbeck
All that certain piece or parcel of
land, situate in Hampden Township,
Cumberland County, Pennsylvania,
more particularly bounded and de-
scribed as follows, to wit:
Beginning at a point on the in-
tersection of the southerly right of
way line of Tanwood Court, a 50
foot wide right of way, and the east-
erly right of way line of Mandy Lane,
also a 50 foot wide right of way as
shown on the Plan of Lots known
as ~Countryside, Section (B)"; thence
from said point of beginning along
the southerly right of way line of
Tanwood Court, North 81 degrees
27 minutes 00 seconds East, a dis-
tance of 85 feet to a point on the
dividing line between Lots Nos. 81
and 82, on the aforesaid Plan of
Lots; thence from said point along
the dividing line between Lots Nos.
81 and 82, South 08 degrees 44
minutes 00 seconds East, a distance
of 118 feet to a monument on the
dividing line between Lots Nos. 82
and 84 on the aforesaid Plan of Lots;
thence from said point along the
dividing line between Lots N08. 82,
84 and 83, South 81 degrees 27
easterly right of way line of Mandy
Lane; thence from said point along
the easterly right of way line of
Mandy Lane, North 05 degrees 39
minutes 46 seconds West, a dis.
tance of 41.86 feet to a point; thence
from said point continuing along the
same, North 08 degrees 33 minutes
00 seconds West, a distance of
76.21 feet to a point, the point and
place of beginning.
Being Lot No. 82 on the Plan of
Lots known as "Countryside. Sec-
tion (B)" prepared by Charles W.
Junkins, Registered Surveyor, dated
December 4, 1973 and recorded In
the Office of the Recorder of Deeds
of Cumberland County on April II,
1974, in Plan Book 25, Page 7.
MUNICIPALITY: Hampden Town-
ship.
PROPERTY ADDRESS: 1 Tan-
wood Court. Camp H1Il, PA 17011.
TAXPARCEL#: 10-19-1598-293.
~ .
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A.
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Aet No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been eontinuously published ever
smee;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of July and the
2nd day(s) of August 2006. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COpy
SALE#18
s~~;;;.;;~.;~~ me this 16th day..
..,.. I _Ii" !.l \.
CD:F. PENNSYLVANIA
Notarial Seal
Terry L. Russ\;'lI, Notary Public
Ity Of Harrisbury. Dauphin County
ion Expires June 6, 2010
naytvanie Association of Notaries
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
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