HomeMy WebLinkAbout06-1914
GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR.
ATTORNEY I.D. #16132
SUITE 5000 MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
DEUTSCHE BANK FIK/A BANKERS TRUST
COMPANY OF CALIFORNIA ON BEHALF OF
VENDEE MORTGAGE TRUST
7105 Corporate Drive
PTX C 35
Plano, TX 75026
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
Plaintiff
ACTION OF EJECTMENT
VS.
TOO H. MUTHlG
and OCCUPANT(S)
318 Stumpstown Road
Mechanicshurg, PA 17055
Term
No. c" /9/1 tJ
Defendant( s)
CIVIL ACTION: EJECTMENT
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 yOll 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 offar any other claim or relief requested by the Plaintiff You may lo~ money or pm}}erty 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP
CUMBERLAND COUNTY BAR ASSOCIATiON
2 Liberty Avenue, Carlisle, PA 17013
800-990-9108
LEGAL SERVICES INC
81rvinc Row, Carlisle, PA 170]3
717-243.9400
A VISO
LE HAN DEMANDADO A usrED EN LA CORTE 51 DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECESSARIO QUE USTED RESPONOA DENTRO DE 20 DlAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARlO QUE USTED, 0 SU ABOGADO, REGl5TRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUlER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTADEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTlCIPACION
ENTONCES, LA COUTE PUEDE, SIN NOTIFICARJO, DEC]DJR A FAVOR DEL DEI\1ANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS
PROVISIONES DE EST A DEMANDA. POR RAZON DE ESA DECIS]ON, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAO U orROS
DERECHOSIMPORTANTES
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE
238-6300
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERV]CIO DE REFERENCIA DE ABOGADOS), (215)
CUMBERLAND COUNTY BAR ASSOCIAT]ON
2 Liberty Avenue, Carlisle, PA 170]3
800-990-9\ 08
LEGAL SERVICES INC
8 Irvine Row, Carlis]e, PA 17013
7]7-243-9400
CIVIL ACTION - EJECTMENT
1. On, February 12,2004, DEUTSCHE BANK F/K/A BANKERS TRUST COMPANY
OF CALIFORNIA ON BEHALF OF VENDEE MORTGAGE TRUST entered into an
Installment Contract with Defendant(s) TOO H. MUTHIG for the purchase of the premises
known as (A true and correct copy of said Installment Contract is attached as Exhibit A).
2. Plaintiff, DEUTSCHE BANK F/K/A BANKERS TRUST COMPANY OF
CALIFORNIA ON BEHALF OF VENDEE MORTGAGE TRUST, is the owner of premises
known as 3 I 8 Stumpstown Road, Mechanicsburg, PAl 7055, having acquired said premises by deed
from Secretary of Veterans Affairs an officer of the United States of America dated October 20,
2003, and as such acquired the rights under the Installment Sales Contract referred to in
Paragraph 1.
3. Under the terms of the Installment Contract, at the successful completion of said
installment plan, and full payment by Defendant( s), title to the premises is to be transferred by
Plaintiffto Defendant(s).
4. Defendant(s) have failed to make the required installment payments since August 1,
2005, and are presently 8 months in default of said payments.
5. Plaintiff, by virtue of the annexed title, is the owner in fee of the said premises, and is
entitled to possession thereof. The Defendant(s), TOO H. MUTHIG and OCCUP ANT(S), have
failed to make agreed payments under the Installment Contract for Sale of Real Estate, are
occupying the said premises without right, and so far as the Plaintiff is informed, without claim
of title.
6. Plaintiff has repeatedly demanded possession of the premises from the said
Defendant(s), who have refused to deliver up possession of the same.
7. On, November 1, 2005, Plaintiff sent to Defendant(s) Notice ofIntention to Terminate
Installment Plan and Notice of Homeowners' Emergency Assistance as required by Act 160 of
1998. To date, Defendant(s) have not made payments as outlined in that Notice (Exhibit B).
WHEREFORE, Plaintiff demands Judgment for Possession of premises known as 318
Stumpstown Road, Mechanicsburg, PA 17055.
~~~
J . P A. GOLDBE K, JR., ESQUIRE
VERIFICA TrON
I,
, 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:'3-30~O~
~~-
CO TRY~ME LOANS INC.
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()fflQer of tho Uaile4 StlW:I of A.IIIlIrica. wbolc JddreIa 18 ~lwwt of VOIClmU A1I'aIra, WuhiB8lCD, D.C.
20420, be1'e.llIaftcr called tbc <huIor lIII4 P<oI--"'" BIIIk NII!cmI1 ~ Company, A. ThIsIee Por Vendee
Mortpp TNII 2003-2, WJtbout B.-.n...... JIxmpt As PlQ~ In.A PooliD.& Am ScrMln, ApeIIIaU Dated
~or 1. 2003. a tN&t 'fIbk:I1 ill!IIIblllhed II1lIIer tb& InI of tba STATB,OP CAIJPORNIA. ~ving. ita prI.uclpal
plal:e of buiness at c/o CoImIrywlde Home LoalIs, 1800 TIIpO Canyon J.d., MSN SY.103. Simi VIl.ley, CA
93063.
'bmilI C\l!Iad Ckaoteo:
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TO 1D: 22-11.0271-018
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mlOltllt, 1n0Jnll\Y. daUDs, lI2l4 6amaud wbmoever of tbe said Chaurot, ill law. eqoity. Of odlRwiIe howlOe\'er, of,
in. and to the SllIIIe and evt:lY pllllheteof.
TO]IA VE AND 'to BOLD the Illid lot or piece of lIJ:OlIIId ebImI ~ with tbe bldU~"'I''''pI ,: :;
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Lou II: 05-4-095734
J1Gr~.)' MUTIDG. TOD H.
Exhibit' A'
DISTRlcr: ~; CITY: MONROE TOWNSHIP; ASSESSOR'S MAP REFERENCE: MAP
0278
BRIEF DESCRIPTION: MONROE MEADOWS RESIDEN'IlAL WITH BUILDINGS
. ...
/- v 1\.,!!<9RM 26-63360 (eg)
, 'Revised SEPI' 1998
10-10-6-0453377
10-10-7-0018299
INSTALLMENT CONTRACT FOR SALE OF REAL ESTATE . PENNSYL VANIA
THIS LOAN MAY NOT BE ASSUMED WITHOUT THE PRIOR
APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS
OR ITS AUTHORIZED AGENT, SUCCESSORS OR ASSIGNS.
1. THIS AGREEMENT, made the 30th day of Dec~mber .2002. by and betw~en the S~retary of Veterans Affairs,
an officer of the United States of America, whose address IS Department of VeterilIlS AfflUfS, Washmgton, DC 20420, (of the
first part) hereinafter called "Seller". and his/her successors in such office, as such. lUld
TOO H_ MUTHIG
(party of the second part)
herei.nafter called ~Buyer~ .
2. WITNESSETH. That it is mutually agreed as foUows:
The Seller herebY agrees to sell to the Buyer, and the Buyer hereby agrees to purchase from the Seller, all that real
property situated in M.on-roe Township county of
CUmberland and Commonwealth of Pennsylvania, herein referred to as "the property"
and more fuUy described aa follows:
TAX PARCEL 22-11-0278-058
318 Stumpsto~ Road
MechanicBburg, FA 17055
~~ilumlll~li,ilmi~ilimilimlllll~~lmlililllllllllluijll
610 025091234 Ie 001 801
3. This Agreement is made subject to:
(1) Existing leases and to rights, if any, ofpcrsons in possession,if any.
(2) The general taxes and special assessments which the Buyer hereinafter covenants to pay.
(3) Building line and building and liquor restrictions of record.
(4) Zoning and building laws or ordinances.
(5) Party wall rights or agreements.
(6) Roads and higb-w'ays.
(1) Covenants, conditions, exceptions. reservations. restrictions.. or easements of record.
(8) Rights of all parties claiming by, through, or under the Buyer.
(9) Any state of facts which an accurate survey would show.
(10) All unpaid watt-I snd seW?t.gt.-d\'bpoo.a1 c.naTg,es fOT SetV\Cl'S Tendered after the date of delivery of this Agreement.
(11) All contracts or agreements, recorded or unrecorded, for furnishing gas, electricity, water, or sewage-dispOllal
service.
(12) The constitution bylaws, rules. regulations, restrictions. charges, or assessments of any civic improvement or
other associatiott, corporation, or district, which affect the property.
(13) Coal Notice under the Bituminous Mine Subsidence and Land Conservation Act of 1966 attached.
The Buyer shall indemnity and save harmless the Seller from all loss and liability that arise by reason of any and all
obligations and liabilities existIng or arising out of any of the foregoing matters.
4. Buyer shall pay to Seller for the property the sum of
($ 14n59.00 ) in lawful money of the United StateS of America at the (Regional Office) (Center), DepartmeJ1t of
Veterans Affairs, an agency of the United States,or at sl1Ch other place witbitt the United States as the Seller or the Seller's
Agent, may 'from tim~ to time 6e:loignate in writing, at the limes, in the amounts, and in the manner following:
($ 12.59.00 ) in cash prior to or upon the execution and delivery of th~ Agreement~ and the balance of
($ 146000.00 ) herein referred to as ~principal sUm~ or as ~principal~ with interest thefeQn at the rate of
SIX petcent ( 6.00 )% per annum, from the date of December 30, 2002,
which said principaJ and lnterest on the unpaid portion thereof shall be payable in equal mottthly installments as follows:
($ 875.34 ) on the fust day of Fcbroary ,2003, and a like HUIfl on the first day of each and every
month thereafter for 359 consecutive, additional months, until said principal and interest shall have been fully paid.
Unless sooner paid, the unpaid balance of principal plus the accrued and unpaid interest shall be dl..le and payable on the First day
of January . 2033 '
Of the total purchase price paid for the said described property, the amount of $ ------------- is a rehabilitation loan
granted pucsl!ant to Public Law 100~ 198. to be disbursed ondec a separate Ew.:roV/ A.gteem~t which lebabi\ita1.1on loan bears the
same rate of mterest as the balance of the amount remaining and to be paid for the Except as hereinafter otherwise provided, each
payment made hereunder shall be credited first on the interest then due as herein provided and the remainder shall be credited
upon unpaid principal. Additional payments of principal in any amount not less than the amount of the monthly installments
ab?v~ provid~ or One f!undred Dollars ($100), whichever is less, may be made at any time and shall be credited on the unpaid
prmclpal sum In such manner as the Buyer may elect, or in the absence of such election, as Seller may elect
.5, An real estate taXes, water rents, sewer charges, assessments, and other charges payable in years subsequent to the year
2002 or levied after the date of execution of this Agreement. or for improvements whkh are not tben completed upoJ'l the
property, are and shall be the obligation of the Buyer, and Buyer covenants to pay the same in the manner provided in paragraph
seven hereof. Water/sewer and special BSSCflsmen(s to be paid directly by buyer.
E.'tI'\\%\T ....'N1
6. Buyer shall obtain and. continuously mainlain hazard insurance of such type o~ types ~d amoun!S as the Seller ~ay from time
to time notify Buyer to obtain on tbe improvements now or hereafter made on scud premlSe8 and wIll pay any premIums therefor
promptly when due. All insurance shan be carried in companies approved by SeUer and policies and renewal. the.reof shall be
held by Seller and have attached thereto loss payable clauses in favor of Seller as Secretary of V~rans Affam:! III acceptable
form. In the event of loss, Buyer will give immediate notice by !DaU to Seller.and Seller may, but 1,5 not und~r duty to make
proof of loss, if such proof is not made promptly by Buyer. All Itl.!lura,nce earners are hereby authonzed and directed to make
payments for such loss directly to Seller instead of to Buyer and SeUef Jointly. The proceeds from the payme~t of such loos or
any part thereof may be applied by Seller either to reduction of the indebtedness or to the restoration and repair of the property
damage.
7, Together witb and in addition to the monthly payments of principal and interest payable und.er th~ terms hereof: Buyer will
pay the Seller on the first day of each month until the teons of this contract have been fully comphed WIth, (he followmg sums:
(a) Such amount or amounts as may be necessary to equal all or any of the premiums which next become due and payable
on Ole policy or policies of fire and other hazard insurance covering the property, plus taxes, ~e~t due on the property
(all as estimated by Seller and of which Buyer is notified) less aU sums already paid therefor diVLded by tbe number of
months to elapse before o~ month prior to tbe date when such premiums, taxes will become delin.quent, such sums to .be
held by Seller in Trust (irrevocable until all of Buyer's obligations under this Agreement are discharged) to pay sald
premimns, taxes.
(b) The installment for principal and interest s~tt;d in J?Magraph 4 which sum plus the amounts paya~le purs~ant !o
subparagrapn (a) of this paragraph shall be pald 10 a smgle: payment each month. Except as otherwise provtded 10
paragraph 14, such payment shall be applied to the items and in the order stated below:
I. Taxes, fire and other bazard insurance premium:
11. Interest on the unpaid portion of the principal; and
m. Unpaid principaL
(c) Any deficiency in any such payment shall, unless made good prior to the due date of the next payment, constitute an
event of default hereunder. The Seller may collect a "late charge" not to exceed an amount equal to four (4%) per
centum of the installment which is not paid within fifteen (is) days from the due date tbereof. to cover the extra expense
involved in bandling delinquent payments.
(d) Iftbe total of the payments made by Buyer under subparagraph (a) of this paragraph.shaJl at any time in the opinion
of Seller exceed the amount required for the payment of taxea or insurance premiums, as the case may be, such excess
shall be credited on subsequent payments to be made by the Buyer for such items. If, however. such monthly payments
shall not be sufficien( to pay such items when the same shall become due and payable, the Buyer shall pay the Seller any
amount necessary to make up the deficiency.
(e:) All payments of said items made by Seller may be in such amounts as are shown by records, or by biUs obtained by
Seller, or on the basis of any other infonnat1on .received by Seller, or be due, payable, past due, or delinquent on
account thereof. If requested by Seller, Buyer shall promptly obtain, approve and deliver to Seller all bills for said
itelll3.
8. Buyer COVenants and agrees to deposit with Seller at the execution and delivery of this Agreement an amoWlt to be determined
by Seller to be required to meet the payments of taxes and any premiums for hazard insurance which it lllflY be necessary to pay
prior to the accumulation of Il fund sufficienr therefor as provided herein.
9. All payments of principal, interest and other items required to be made by the terms of this contract, shall be made to the
Agent Cashier at the office of the Department of Veterans Affairs designated in paragraph 4, to the order of the Department of
Veterans Affairs, unless the Buyer sbali be notified in writing to make such payments to another payee or place,and only such
payments all shall be receipted for by the said Agent Cashier, Of other payee after notice to the Buyer, shall be recognized by lhe
Seller, and all other payments. if any, shall be made at the risk of the Buyer.
10. All moneys paid to Seller hereunder shall be deposited with the Treasurer of the United States who is hereby authorized to
commingle the same with the general funds of the United State!. No interest shall be payable on the funds received by Seller for
any purpose pursuant to any provision of this Agreement.
11. Buyer covenants not to commit, permit. or suffer any waste to the property, to keep the property in a good state, order and
repair. Buyer further covenants not to abandon said property and not to use, permit, or suffer the use of any of the property for
any iUegal or immoral purpose, and agrees to comply with all Jaws and ordinances which may in any manner affect the property.
12. 'J1?e Buyer is authorized and permitted to make such repairs, alterations, and renovations to said property as desired and
detennmed to be nece5s~ at Buyer's own expense .and without any liability on the part of the Seller for same, as are approved in
advance by the Seller. Fmlure of the Buyer to obtam advance approval for repairs, alterations, and renovations, to said property,
may at the option of the Seller, be considered a breach of the terms of this agreement and an act of default, Buyer further
covenants and agrees to make prompt payment for all labor and materials in such behalf expended and not to suffer any
mechanics' or materialmen's Hens to attach to aaidproperty. All such repairs and alterations made by the Buyer shall inure to the
benefit of the property and the Seller in the event of a default in the tenus of this Agreement by the Buyer. Buyer also covenants
and agrees to complete and pay for the following repairs of alterati01l$ within ( )
days after execution of this Agreement and that breach of this covenant will constitute an act of default.
13. No part of the property shall be used in the manufacture, sale, or distribution of intoxicating liquors.
14. In the eyent Buyer faUs, neglects, or refuses to perform, in whole or In part, any of the covenants. agreements, or obligations
herein proVIded upon the part of Buyer to be performed, SeUer is hereby authorized and empowered without notice and at tbe cost
of Buyer. to penorm or cause to be perfonned, any or all of said covenants, agreements and obligations, and to expend such
sums of m?ney as may be reaso,na~le t~refor, or for any other purpose which in the opinion of Seller is reasonably necessary for
~he protechon of SeUer. SelIor s hen, mvestment or property. AU such sums of money so expended by Seller, together with
!nterest thereon, at the rate aforesaid, from the several dates of expenditure thereof until paid, shall become so much additional
mdebtedness under this Agreement and sball be repaid by Buyer to SeUer, in lawful money of the United States of America
immediately and witl,1out d~lUl~, at ~e same place or places &'j other sums are payable hereunder, unless Seller shaH agree that
such sums be otherwIse rep8.ld, m WblCh even! such repayment shall be made by Buyer to Seller at such times and in such manner
as Seller !bBll require. Any failure, neglect, or refusal by Buyer to repay such sums 38 herein provided shall constitute default
hereunder. Any payments made under the terms of this Agreement may, at the election of SeUer, be applied fust to the
repayment of any sums Sellcr shall have expended in accordance with the tenus hereof.
'\ l .~
."
.,,-
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15. Buyer hereby assigns. transfers. and sets over to Seller. up to the an;toun.' of the t'?tal ~debtedness o~ Buyer to Seller
hereunder, all of Buyer's right, title, and interest in or to aU awards and clanns 18 connectlOn wIth condem~tton of any of the
property for pUblic use, Of for injury to any portion thereof, and the proceeds of, all such ~wards or clauns. a~er payment
therefrom of all reasonable expenses incurred, mcluding fees for attorneys representmg Seller ID any such proceedmg, shall be
paid to SeUer and Buyer's obligation hereunder sh~ thereby be reduced an ~qual amount ex.cept .to the extent SeUer ejects to use
the funds to improve the property in accordance with paragraph 16. Selter UI hereby authorIzed In the name of Buyer to execute
and deliver valid acquittances thereof and to appeal from or otherwise appropriately litigate any c:r all of, such awards. or cl~im~.
Seller shall be under no obligation hereunder to sell or convey all or any part of the property, or nght or mterest therem WhICh IS
condemned.
16. All moneys received by Seller under any policy or policies of insurance of any condemnation award or other a:;vard after
payment therefrom of all reasonable expenses incurred in co~on therev.:ith, incl~ing ~ees for attorneys representmg Seller,
may at the option of Sener be used for the purpose of repalnng, restonng, or Improvmg the damaged structure upon the
property, or may be credited on the indebtedness in accordance with the provisions of this Agreement.
17. Execution and acceptance of this Agreement by the Buyer col15titutes delivery to and acceptance by Buyer of possession of
the property herein described, and the buildings and improvements tber~n erected, and ac~owledgment by ,the ~uyer th,at ~e
property, and the buildings and improvements there~n erected, ~ave been mspected and exarll1~ed, that bu~e! IS satlsfi.ed WIth Its
and their condition, and that the property and the buildings and Improvements thereon eree.ted 1-';1 such condition are bemg bought
and accepted without any representation wbatsoever by the Seller, except as may be provIded tn paragraph 11 of Agreement of
Sale dated , The Buyer assumes responsibility for injury or death on or arising out of the
property and also assumes the risk of 10!s or damage to the buildings now situate, or hereafter con.structed, in or upon said
property by fire, casualty, or other happening and shall indemnify and save the Seller harmless from all loss arising from or by
reason of these events or incidents.
18. Time is of the essence of this Agreement and if default be made and continue for a period of thirty (30) days in the payment
of any of the installments of principal, interest. or any other items hereinbefore stipulated, when the same become severally due
hereunder, or in the payment of any other sum herein agreed to be paid by Buyer, or if default be made in the perfoIntance by
Buyer of any other agreement, covenant, or obligation of Buyer hereW1der, then in either, or any of said events, the whole
unpaid balance due under the tenus of this Agreement shall, at the option of Seller, immediately become due and payable and
Seller may, at his/her option, (a) terminate by simple declaration of an election so to do with or without notice, all of Buyer's
rights under this Agreement and all of Buyer's right, title, and interest in the property; or (b) terminate all of Buyer's rights
under Ihis Agreement and all of Buyer's right, title, and interest in the property in any appropriate proceeding, legal or
equitable; or (c) enforce Buyer's obligations hereunder in any appropriate proceeding, legal or equitable. Buyer agrees to pay all
costs and ex:penses, including a reasonable sum for attorney's fees incurred by Seller in terminating Buyer's rights under this
Agreement or claims to the property or in enforcing any or all of the tenus of this Agreement, and in appropriate judicial
proceedings, if any are initiated to establish or maintain Seller's right or tiUe to, and possession of said property after breach by
Buyer, free of any tiUe or claims of Buyer.
19. Upon Seller ex:ercising the right of termination as provided herein, all rights, estate and interest hereby created and then
existing in Buyer and in any and all persons claiming under Buyer, shall wholly cease and determine. Buyer shall thereupon quit
and surrender to Seller without demand, peaceful possession of said premises in as good condition as they now are, reasonable
wear and tear alone excepted, In the event Buyer neglects or refuSe!! to surrender such possession when obligated so to do it
shall be lawful for Seller to enter upon and take possession of such premises without notice and remove all persons and their
property .
20. The Provisions of paragraph 19 and 20 of tl1is Agreement shall also apply, at the option of Seller, to (1) any violal:ion or
breac.b of any of lhe covenants, conditions, or restrictions, indicated in this Agreement or which may be of record, and (2) to
any violation of any laws or ordinances in any manner affeeting said property.
21. Seller agrees upon receipt of payments in accordance with the provisions hereof, of the entire principal sum with interest, to
ex:ecute and deliver a special Warranty Deed on V A Fonn 26-6436a conveying the title to said property to Buyer in such manner
and form as Seller elects. Such deed may be delivered at such earlier time as Seller may elect, Said Deed will be on Seller's
form and conveyance shall be made under and subject to any restrictions, reservations, and ex.ception of record and also subject
to all National and State laws, statutes, and regulations, then affecting the trlU\llfer of real estate or of any right therein. (n the
event any part of said principal swn shall not have been paid at the time of the execution and delivery of the deed to said
property, Buyer shall simultaneously execute and deliver to Seller a Mortgage Note in the just or principal sum remaining
unpaid, together with interest thereon at the rate provided in paragraph 4 hereof, payable in installmenls of the same amounts as
stated in said paragraph, and a purchase money mortgage of said premises to secure the same, whiCh mortgage shall be a first
lien on the property; the Mortgage Note and Mortgage shall bear the same date as said Deed; they shall be on the forms of such
instruments then in use br. the Department of Veterans Affairs or its successor in interest, modified and amended as to such
terms, conditions and detalled proVIsions as are in conflict with this Agreement.
22. Buyer represents and covenants that Seller's title is satisfactory to Buyer as of the date hereof.
23, Buyer shall pay for all recording, transaction, transfer, conveyance, and other taxes upon this Agreement and upon any
deed, bond, mortgage, or other instrument ex.ecuted under the teInts and provisions of Ihis Agreement and for all revenue
documentary, or other stamps required to be affixed to any such instrument and shall also pay the fees for ~ecording: the deed and
the mortgage, if any, when executed, as well as all costs and expenses. for such title search as the Buyer may elect to have made.
24, The Buyer shall notify the Seller of an assigrunent of the Buyer's interest in this contract. Seller may at any time sell and
convey the property subject to this Agreement and may assign this Agreement and any and all rights hereunder without the
consent of the Buyer.
25., Any n?tices from one party hereto to the other party shall be in writing and delivered in person or forwarded by certified
mad. NotIces shall be addressed to the property hereinabove described unless written of a different address shall have been
previously delivered to Seller, in which event notice shall be sent to such address. Notices to Seller shall be addressed to the
Lo!D?- Guaranty Officer, Department of Veterans Affairs at the Office where this Agreement is executed until Buyer is nOlified in
wntmg of a changed address. Thereafter any notice shall be sent to the last address of which Buyer shall have been notified.
26, Buyer hereby authorizes and empowers any attorney of any court in the Commonwealth of Pennsylvania or elsewhere to
appear for them and eac~ of them ,in any and all actions to be brought for any breach or default of the terms of this Agreement
and ~ereby confesses judgment m favor of the Seller for the whole amount of the principal sum and any interest remaining
unpatd the,reon, ~hether t~e same ~I have been due or not, together with an attorney's commission or fee of five (5%)
percent, WIth or WithOut pnor decJaration made, waiving stay of ex:ecution, inquisition, and all exemption laws.
27. And the said Buyer hereby, upon the breach of any of the conditions of this Agreement, authorizes any attorney of any court
of Record to appear for them and each of them and enter an amicable action of ejectment and confess a judgment of ejectment
therein for the premises herein described and do authorize the immediate issuing and execution of a writ of habere facias
possessionem with clauses of fieri facias for costs and five (5%) percent attorney's commission or fee, without asking leave of
court.
28. All moneys paid by Buyer to Seller under the tenns of this Agreement shall be retained by Seller as compensation for the use
and occupancy of the property, consideration for the execution of this Agreement and not as liquidated damages to Seller for
default or as a penalty.
29. Failure or delay of the Seller to enforce any right or to exercise any op~on hereunder ~vailabJe bec.ause of any defau!t shall
not operate as a waiver of the right of the Seller to thereafter enforce such right Of to exercIse such option or any other nght or
option, for the same or for any subsequent default.
30. Buyer expressly agrees that the rights and remedies herein granted Seller in the event of default, to enforce the terms and
conditions of this Agreement, the recovery of damages for any breach, or possession of the above described property, may be
exercisable as often as rhere is default on the part of Buyer and shall not be exhausted by one or more uses thereof, and that it
shall not be necessary to file the original of this contract as a warrant of attorney if a true copy hereof shall be filed in any action.
3 t. The covenants, obligations, liabilities, terms and provisions herein contained sball be binding upon, and the benefits IUld
advantages hereunder shall inure to the Buyer jointly and severally and to their and each of their respective heirs, executors,
administrators, and assigns, and to the successors and a.'lsigns of the Seller.
32. This Agreement shall not be recorded in the office for the re<:ording of deeds Dr any other office or place of pubJic record.
If Buyer causes it to be recorded he/she will be considered in default with the right of Sener to forthwith tenninate this
Agreement and to enforce and exercise Seller's dghts hereunder because of such default.
33. Buyer understands and agrees that if this Installment Agreement is tenninated by Buyer or Seller, any remaining amount of
the rehabilitation loan in the hands of an escrow agent shall immediately be returned to Seller (Department of Veterans Affairs).
34. This loan may be declared immediately due and payable upon transfer of the property securing such loan to any transferee,
unless the acceptability of the assumption of the loan is established either punuant to the provisions of section 3714 of chapter
37, title 38, United State Code, or by the Loan holder if the loan has been sold without recourse.
35. A fee equal to one-half of 1 percent of the balance of this loan as of the date of transfer shall be payable to the Department of
Veterans Affairs at the time of transfer. If the assumer fails to pay this fee at the time of transfer, the fee shall constitute an
additional debt to that already secured by this instrument and shall bear interest at the rate herein provided, and, at the option of
the payee of the indebtedness hereby secured or any transferee hereof, the full indebtedness hall be immediately due and payable.
This fee is automatically waived if the assumer is exempt under the provisions of 38 V.S.C. 3729(b). The assumer is not
Obligated to pay this fee if the Department of Veterans Affairs has sold Ihis loan without recourse.
36. Upon applicatwn for approval to allow assumption of this loan, a processing fee may be charged by the Department of
Veterans Affairs or its successors or assigns for determining the creditworthiness of the assumer and subsequently revising the
ownership records when an approved transfer is completed. The amount of this charge shall not exceed $300.
IN WITNESS WHEREOF, the Seller has caused this instrument to be signed and sealed in his/ber name an din his/her behalf by
the undersigned employee, being thereunto duty appointed, qualified and acting pursuant to title 38. United States Code, sections
2t2 and 1820, and title 38, Code of Federal Regulations, sections 36.4342 and 36.4520. pursuant thereto, as amended, and who
is authorized to execute this instrument. and the Buyer has hereunto set hislher individual hand and seal on the day and year first
above written.
NOTICE. THIS DOCUMENT MAY NOT/DOES NOT SELL, CONVEY, TRANSFER, INCLUDE OR INSURE
THE TITLE TO THE COAL AND RIGHT OF SUPPORT UNDERNEATH THE SURFACE LAND DESCRlBED OR
REFERRED TO HEREIN, AND THE OWNER OF OWNERS OR SUCH COAL MAY HA VElHA VE THE COMPLETE
LEGAL RIGHT TO REMOVE ALL OF SUCH COAL AND, IN THAT CONNECTION, DAMAOE MAY RESULT TO THE
SURFACE OF TIlE LAND AND ANY HOUSE, BUILDING OR OTIlER STRUCTURE ON OR IN SUCH LAND, THE
INCLUSION OF THIS NOTICE DOES NOT ENLARGE. RESTRICT OR MODIFY ANY LEGAL RIGHTS OR ESTATES
OTHERWISE CREATED, TRANSFERRED, EXCEPTED OR RESERVED BY THIS INSTRUMENT. (Thia notice is set forth
in the manner provided in Section 1 of the Act of July 17, 1957, P.L. 984, as amended, and is not intended as notice of
unrecorded inSlnlmeuts. if any.)
SEALED AND DELIVERED
IN THE PRESENCE OF
"",Qa.:t.,Q[:~~,
e S retary of Vetc;[aJlS AIfjUcsLL,
By' ' $),();~
.. .........u...._.........~Lm................~.............._.
Janice P. DiBenedetto
.. [SEAL]
"'~..,~."..._"
Title: .._.~~.~!~&.~~..9.~.~Jy_.Qffi~~..._
V A Regional Office or Regional Office &
Insurance Center, Philadelphia, PA.
TeIephone:215.842.2000
Pursuant to a delegation of authority in 38 CFR
~~6~5~;.3qp~"[SEAL]
................_...................................[SEAL]
(Buyer)
.........,.........'iiiuyerT" ,.......fSEALJ
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.Cal.lh.. ~*
HCII'II LaAN.
P{)Box90A6
rll'mtlCUla, CA92~89-904B
~~~I~ ~~~I~~IIIII
Send Payments To:
PO BOX 660694
DaUas, TX 75266-0694
0700563917
Send Corrospondence to.'
POBox 5170, US SV31<iB
81ml Valley, CA 93065
1",III",III""I,I"I.I.I,I",II'III""ll,I,I.I,1
Tad H Muthig
318 STUMPSTOWN RD
MECHANICSBURG, PA 17055-9602
~~\etT'''' I
O~110Z-BLQPIl'
PRESORTED
First-Class Mail
U,S. Postage
and Fees Paid
WSo
.Counb3llLide'
HOME LOANS
P. Q. Box 660694
Dallas, TX 75266-0694
Send Payments to.
PO Box 660694
Dallas, TX 75266-0694
November 1 , 2005
Certified Mail:
0700563917
Return Reciept Requested
Regular Mail
Tad H Muthig
318 STUMPSTOWN RD
MECHANICSBURG, PA 17055-9602
Account No.: 25091234
Property Address:
318 Stumpstown Rd
Mechanicsburg, PA
Current SSN'icer:
Countrywide Home Loans, Inc.
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortGaGe on your home is in default. and the lender intends to foreclose. SD.cifie
information about the nature of the default is Drovided in the attached Daaes.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM fHEMAP) may be able to helD to save your
home. This Notice exnlains how the oroaram works.
To see if HEMAP can hel[J. YOU must MEET WITH A CONSUMf:R CREDIT COUNSf:L1NG AGENCY WITHIN 30 DAYS OF
THE DATE OF THlS NOTICE. Take this Notice with YOU wh8ll YOU meet with the CounselinQ AGencv.
The names. addresses and phone numbers of Consumer Credit CounselinG AGencies serving YOUr County are listed at
the end of this Notice. If YOU have anY Questions, YOU may call the Pennsvlvania HousinG Finance AGencv toll free at
1.800.342-2397 lPersons with imoaired hea...inu can call1-717-78D-1869},
This Notice contains important legal information. If you have any questions, representatives at the Consume... Credit
Counseling Agency may be able to help answer them. You may also want to conta<:t an attorney in you... area. The
local bar association may be able to help you find a lawyer.
LA NOTIFICACIOO EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR
VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC'DN OBTENGA UNA
TRADUCCIOO INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN
CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU
CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDERlSERVICER;
Tod H Muthig
318 Stumostown Rd
Nechanicsbura, PA
25091234
HOMEOWNER'S NAME(S);
PROPERTY ADDRESS:
CountrYwide Home Loans Inc.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELlGIBLF FOR FINANCIAl ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSlIRE: ANO
HELP yOU MAKE FUTURE MORTGAGE PAYMENTS
?'Ift1lIf!Wr'l\eyoura:t:(lunlnumb@roYlallchf!ck:Sal'doolrespordtnoe
W. maycha;le youa fee fOr any payment r<<urnedor l@jec:ledbyyollfinal'lCial instllJion, !U~to app~cable 13\1I
. M<W.e'jOJlCnet\tptlyIDlllID
Counlrywide Home Loans
. Writeyouraccountnumberon
. ~~:e~~y~~~?~':~nlll
you are includiflQ(WTtt31is
morethan$50[)Q,pleaoosaM
cemtiedffietl\)
. Dont<itachyourcllecktolhe
. ~~f~~~:;reB~ndence
. Dontsen.dcasll
Account Number: 25091234-2
TodH Mulhig
318 Stumpstown Rd
Balance Dueforcnerges listed Eloove:$3,555.52 asof1i1112005.
PleIl.aeupdale....mail informalbn on tIlIIflf1IQrJlll side'Jl'\t\il.mu\"l<l
Addil.,rIiU
Pmoipal
BLQPI\1
IAddilbOal
"-
Countrywide
PO BOX 660694
Dallas, TX 75266-0694
11",1,1.1",1,1,11,,,11,,11,,,,11,,1.1,,,1,,11,1,,,1..1,,1,11I,,,1
~
j"Ci;i
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025091234200000355553000355553
IF' YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF
1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE;
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL.
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of fureclosure on your
mortgage for thirty-five (35) days from the date of this Notice. During that time you must arrange and attend a "face-to-face"
meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR
WITHIN THE NEXT THIRTY-FIVE 135\ DAYS IF YOU DO NOT APPI Y FOR EMF.:RGENCY MORTGAGE ASSISTANCE
YOU MIIST BRING YOUR MORTGAGF.: UP TO DATE THE pART OF THIS NOTICE r,ALLFO "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGA.GE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES _ If you meet with one of the consumer credit counseling agencies listed at
the end of this notice, the lender may NOT take action against you for thirty -fi....e (35) days after the date of this meeting. ~
names l'Iddresses l'Ind teleohone numbers of desianated r.onSlJmer cmdit cnunselina am~ncies for the countv in which the
Drooertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to.face meeting. Advise your
lender immediatelv of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see
following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this
problem with the lender, you have the right to apply for financial assistance frum the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, si9f' and file a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling agencies listed at the end of ttlis Notice. Only consumer
credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the
Pennsylvania Housing Finance Agency. Your application MUST be fried or postmarked within thirty-five (35) days of your
face-to-face meeting.
YOU M!:!.lll FILE YOUR APPLICATION PROMPTLY. IFYOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER
TIME PERIODS SET FORTH IN THIS LETIER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY
AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION _ Available fLllds 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. During that time, no foredosure 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 of its
decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE 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 have flied bankruptcy you can stili apply for Emergency Mortgage Assistance.)
NOTICE OF INTENT TO FORECLOSE
YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE.
YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM fORECLOSURE
NATIJRE OFTHE DEFAULT _ The MORTGAGE debt held by the above lender on your property located at:
31B Stumpstown Rd Mechanicsburg, PA
IS SERIOUSLY IN DEFAULT because
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now
past due
Monthlv Pavments: September, 2005
November,2005 (3 mos. @ $1, 139,69/month)
$3,419.07
Late Charaes: September, 2005
October,2005 (2 mos. @ $45.59/month)
$91.18
TOTAL DUE:
$45.28
$0.00
($0.00)
$3,555.53
Other Late Charaes: Total Late Charges:
Uncollected Costs:
Partial Payment Balance:
YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION {Do not use if not ;:molicablel
E-maIILl6e:ProvJdIr1Qyoure--mailaddressbeIONwillallowustosendyouird<<matiDnonyouracrount
Accaurt Number: 2.aD912.34
TodHMLrthlgE-rnailaddress
How we post your pavments~ All aCC(l~tu:I.
pa'!l1enlSdprinclpalalldirrterll6twillbeappliedtD
the longest oUllltBOOir1Q Irw;tallment due, unless
otoorWseexpre65t>{ \1oolbltOOot llmllBdby 1a>II. II
you submit an amount in addition to yo,," sd'teduled
mOflthly amount, we will apply your payments 1Ill
fQllQ1M;: (I) to mtstanding mort~ payments d
prindpal andinlllrast" (lIjescrnwdeflciencies, (Iilj lale
charges and other an'loonm you owe in connection
with'tOO\io&\M'I.1(N}tCllld\D'lthe~rg
princi~al balance d yoUI' loan. Pleeisespecift' ifyoo
want an alklitional amouri applied to future
pa'f!'ler.ts,r:ll'lertmr.pTintipalrnd\lC'lim.
Postdated checks: Coun!r',Wide'spoli~ is to nDt
a~tpostdi't~ctmOO;,un~sspecifica\iya9l'eed
to bVa loan OOUrlSelor or technician.
I-tOW TO CURE THE DEFAULT - You may cure the default within THIRTY -FIVE 135\ DAYS of the date of this notice BY
PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,555.53, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY-FIVE (35) DAY PERIOD.
Payments must be made either bv cashier's check certified check or mone" order made oa"able and sent to:
Countrywide at P.O. Box 660694, Dallas, TX 75266-0694.
You can cure anv other default bv takina the followina action within THIRTY-FIVE (351 DAYS of the date of this letter. (Do not
use if not aoolicable 1
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY-FIVE (35\ DAYS of the date of this
Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding
balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly
installments. tf full payment of the total amount past due is not made within THIRTY_FIVE /35\ DAYS, the lender also intends to
instruct its attorneys to start legal action to foreclose upon your mortgaged property
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage
debt. tf the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings
against you, you will still be required to pay the reasonable attomey's fees that were actually incurred, up to $50.00. However, if
legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually inclJred by the lender even
if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other
reasonable costs. tf you cure the default within the THIRTY_FIVE 135\ DAY period, you will not be required to pay
attorney's fees. YOU HAVE THE RIGI-tTTO REINSTATE AFTER ACCELERATION AND THE RIGl-tT TO ASSERT IN THE
FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO
ACCELERATION AND FORECLOSURE.
OTHER LENDER REMEDIES - The lender may also sue you pernonally for the LIlpaid principal balance and all other sums due
under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY -FIVE
~ DAY period and foreclosure proceedings have begun, you still have the right to CLJ'"e the default and prevent the sale at any
time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other
charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with
the Sheriffs Sale as specified in writing by the lender and by perfoffiling any other requirements under the mortgage. Curing
your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the
mortgage property could be held would be approximately six (6) months from the date of this Notice. 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 will be by contacting the lender.
HOW TO CONTACT THE LENDER;
Name of Lender:
Countrywide Home Loans, Inc.
P. O. Box 660694 Dallas, TX 75266-0694
1-800-669-4578
1-805-577-3432
MS PTX-36
Attention: Loan Counselor
Address.
Phone Number:
Fax Numher:
Contact Person:
EFFECT OF SHERIFF'S SALE - You shoold realize that a Sheriff's Sale will end your ownernhip of the mortgaged property and
your right to occupy it. If you continue to live in the property after the Sheriffs sale, a lawsuit to remove you and your fumishings
and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee 'NIlo will assume the mortgage
debt, provided that all the outstanding payments, charges and attomey's fees and costs are paid prior to or at the sale and that
the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE 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
0700563917
IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT
INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BYTHE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your
property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the
property is occupied and/or (iii) determine the identity of the oCUJpant. If you do not cure the default prior to the inspection, other
actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and
valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be
charged to your account as provided in your security instrument.
If you are unable to cure the default on or before December 1, 2005, Countrywide wants you to be aware of various options that
may be available to you through Countrywide to prevent a foreclosure sale of your property. For eJ:ample:
. Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide.
Our basic plan requires that Countrywide receive, up front, at least % of the amount necessary to bring the account
current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a
defined period of time. Other repayment plans also are available.
. Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the
loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This
foredosure alternative, however, is limited to certain loan types.
. Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale
of your home can be approved through Countrywide even if your home is worth less than what is owed on it.
. Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious
financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder
and avoid the foreclosure sale.
If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If
you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime,
Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees
otherwise in writing. Failure to bring your loan current or to enter into a written agreement by December 1, 2005 as outlined
above will result in the acceleration of your debt.
Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at
1-800-669-4578.
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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
215-825-6319
Attorney for Plaintiff
DEUTCHE BANK F/KIA BANKERS TRUST COMPANY
OF CALlFORNIA ON BEHALF OF VENDEE
MORTGAGE TRUST
7105 Corporate Drive
PTX C 35
PIano, TX 75026
IN COURT OF COMMON
PLEAS
Plaintiff
of Cumberland County
FIVIL ACTION - LAW
A~TION OF EJECTMENT
vs.
TOD H. MUTHIG
and OCCUPANTS
318 Stumpstown Road
Mechanicsburg, PA 17055
Term
No. 06-1914
Defendants
EJECTM NT
Kindly enter Judgment in Ejectment in favor of the Plaintiff, DEUT HE BANK F/KIA BANKERS
TRUST COMPANY OF CALIFORNIA ON BEHALF OF VENDEE MOR GAGE TRUST and against the
Defendants TOD H. MUTHIG and OCCUPANTS for failure to file an Ans er in the above action within
(20) days of service.
I HEREBY CERTIFY THAT ACCORDING TO rule 237.1, written 10 day notice of Plaintiff's
intention to file a Praecipe for Entry of Default Judgment was mailed to De ndants, a true and correct copy
of which is attached hereto.
I hereby certifY that the above names are correct and that the precis
judgment creditor is DEUTCHE BANK F /KI A BANKERS TRUST COMP
BEHALF OF VENDEE MORTGAGE TRUST, 7105 Corporate Drive, PT
the name(s} and last known addressees} of the Defendants is/are TOD H.
Stumpstown Road, Mechanicsburg, PA 17055.
residence address of the
OF CALlFORNIA ON
C 35, Piano, TX 75026 and that
THIG and OCCUPANTS 318
LD ECK McC ERTY & McKE R
: Joseph A. Gol beck, Jr.
Attorney for Plaint ff
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - MeUon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6319
Attorn for Plaintiff
DEUTCHE BANK F/KJA BANKERS TRUST COMPANY
OF CALIFORNIA ON BEHALF OF VENDEE
MORTGAGE TRUST
7105 Corporate Drive
PTXC35
PIano, TX 75026
IN HE COURT OF COMMON
PLEAS
of Cumberland County
IVIL ACTION - LAW
Plaintiff
vs.
A TION OF EJECTMENT
TOD H. MUTHIG
and OCCUPANTS
318 Stumpstown Road
Mechanicsburg, P A 17055
Tenn
No. 06-1914
Defendants
CERTIFICATION PURSUANT TO PA R.C.P. 0.237
I, Joseph A. Goldbeck, Esquire, attorney for Plaintiff, certify t a true and correct copy of the
Praecipe for Judgment was sent to the following parties, via first class ail, postage prepaid:
TOD H. MUTHIG
OCCUPANTS
318 Stumpstown Road
Mechanicsburg, PA 17055
GOLDBECK Mc AFFERTY & McKEEVER
~-
DATED: May 15,2006
GOLDBECK McCAFFERTY & McKEEVER
By: JoSEPH A. GoLDBECK, JR.
ATIORNEY I.D. #16132
SIDTE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
ATIORNEY FOR PLAlN'fIFF
DBUTCHE BANK. FIKIA BANKERS TRUST
COMPANY OF CALIFORNIA ON BEHALF OF
VENDEE MORTGAGE TRUST
71 05 Corporate Drive
PTX C 35
Piano, TX 75026
IN THE CcjURT OF COMMON PLEAS
OF qumberland COUNTY
C
ACTION - LAW
Plaintiff
AC
vs.
Term
No. 06-1914
TOD H. MUTHIG
and OCCUPANTS
318 Stumpstown Road
Mechanicsburg. PA 17055
Defendants
DATE OF THIS NOTICE: May 3, 2006
TO: OCCUPANTS
318 Stumpstown Road
Mecbanicsburg, PA 17055
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATIORNEY AND Fn..E IN G WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH A ST YOU. UNLESS YOU
ACT WI1HIN TEN (10) DAYS FROM THE DATE OF TInS NOllC A RJDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY SE YOUR PROPERTY OR
OTHERIMPORTANTRlGHfS. YOU SHOULD TAKE THIS PAPER TO OUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE 0 CE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT G A LAWYER. IF YOU
CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE AB TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCmS THAT MAY OFFER LEGAL SERVICES TO EUmBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMIIE/U.AND COU>lI'V BAR ASSOCIATION
2LibertyAWIIIIC
c.disJe,PAI1013
lEGAL SIlRVlCES INC
a kviDe Row
c.1iaIe,PA 17013
.. McXUVER
Jr. Esq.
GOLDBECK McCAFFERTY & McKEEVER
BY: JOSEPH A. GoLDBECK, JR.
ATIORNEY I.D. #16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
ATIORNEY FOR PLAINTIFF
I
I
I
I
I
I
I
I
I
DEUTCHE BANK FOOA BANKERS TRUST
COMPANY OF CALIFORNIA ON BBHALF OF
VENDEE MORTGAGE TRUST
71 05 Corporate Drive
PTX C 35
Piano, TX 75026
IN 1HE CduRT OF COMMON PLEAS
OF qumberland COUNTY
ACTION - LAW
Plaintiff
vs.
Tenn
No. 06-1914
TOD H. MUTHIG
and OCCUPANTS
318 Stumpstown Road
Mechanicsburg, PA 17055
Defendants
DATE OF TInS NOTICE: May 3, 2006
TO: TOD H. MUTInG
318 Stumpstown Road
Mechanicsburg, PA 17055
IMPORTANTNOTICB
YOU ARB IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITfBN
APPEARANCE PERSONALLY OR BY ATIORNEY AND FILE IN G wrrn 1HE COURT
YOUR DEFENSES OR OBJECTIONS TO 1HE CLAIMS SET FORlH AG ST YOU. UNLESS YOU
ACT WITHIN TEN (10) DAYS FROM 1HE DATE OF TInS NOTrC A JUDGMENT MAY BB
ENTERED AGAINST YOU wrrnOUT A HEARING AND YOU MAY SE YOUR PROPERTY OR
01HER IMPORTANT RIGHTS. YOU SHOULD TAKE TInS PAPER TO OUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE 1HE 0 CE SET FORlH BELOW.
TInS OFFICE CAN PROVIDE YOU wrrn INFORMATION ABOUT G A LAWYER. IF YOU
CANNOT AFFORD TO lDRE A LAWYER, TInS OFFICE MAY BE AB TO PROVIDE YOU wrrn
INFORMATION ABOUT AGENCIES mAT MAY OFFER LEGAL SERVICES TO EUGmLE
PERSONS AT A REDUCED FEE OR NO FEE.
CllMIIIlRLAND COUNTY BAR ASSOCIATION
2 Liba1y AWIlUCl
CadbIe, PA 17013
LE.GALSERVlCES INC
8 IMIIe Row
c.rIiIIc,PA 170J3
" M<XUVER
Jr.,EIq.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01914 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK
VS
MUTHIG TOD H
CPL. TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sw rn according to law,
says, the within COMPLAINT - EJECTMENT
was se ed upon
MUTHIG TOD H
the
DEFENDANT
, at 2029:00 HOURS, on the 12th da of April
, 2006
at 318 STUMPSTOWN ROAD
MECHANICSBURG, PA 17055
by handi g to
HEATHER MUTHIG, WIFE
a true and attested copy of COMPLAINT - EJECTMENT
together with
and at the same time directing Her attention to t e contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
10.56
.00
10.00
.00
38.56
So Answers:
r-~~
R. Thomas Kline
04/13/2006
GOLDBECK MCCAFFERT
Sworn and Subscribed to before By:
me this
day of
A.D.
Prothonotary
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01914 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK
VS
MUTHIG TOD H
CPL. TIMOTHY REITZ
Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sw rn according to law,
says, the within COMPLAINT - EJECTMENT
was se ed upon
OCCUPANT
the
DEFENDANT
, at 2029:00 HOURS, on the 12th da of April
, 2006
at 318 STUMPSTOWN ROAD
MECHANICSBURG, PA 17055
by handi g to
HEATHER MUTHIG
OCCUPANT
a true and attested copy of COMPLAINT - EJECTMENT
together with
and at the same time directing Her attention to t e contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
So Answers:
-"r'/ ~--
r~ f~
R. Thomas Kline
04/13/2006
GOLDBECK MCCAFFERT
Sworn and Subscribed to before By:
me this
day of
A.D.
Prothonotary
1
. .
VERIFICATION OF NON-MILITARY SERjv~
I
The undersigned, as the representative for the Plaintiff corpo~ation within named do hereby
verify that I am authorized to make this verification on behalf of th~ Plaintiff corporation and that
i
the facts set forth in the foregoing verification of Non-Military Se~ice are true and correct to the
best of my knowledge, information and belief. I understand that fal e statements therein are made
subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsificati n to authorities.
1. That the above named Defendant, TOD H. MUTHI , is about unknown years of
age, that Defendant's last known residence is, 318 Stumpstown Ro Mechanicsburg, P A 17055,
and is engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Servo e of the United States or its
Allies, or otherwise within the provisions of the Soldiers' and S 'Iors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date: DS\~ DCJ
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C.P. 109 - P
Praecipe for Writ of Possession
(ACTION OF EJECTMENT)
THE COMMONWEALTH OF PENNSYL v,lrnIA
COUNTY OF Cumberland
DEUTCHE BANK F/KIA BANKERS TRUST
COMPANY OF CALIFORNIA ON BEHALF OF
VENDEE MORTGAGE TRUST
7105 Corporate Drive
PTX C 35
Piano, TX 75026
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
Plaintiff
06.1914
vs.
TOD H. MUTHIG
and OCCUPANTS
318 Stumpstown Road Mechanicsburg,PA 17055
Defendants
PRAECIPE FOR WRIT POSSESSION
TO THE PROTHONOTARY:
Issue the Writ of Possession in the above matter, for possession of (describe property)
SEE ATTACHED LEGAL DESCRIPTION
Ejectment
Quiet Title
A.
5 - 116 (Rev. 10/76)
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EIhibit 'A'
DISTRlCf: 02e; CITY: MONROE TOWNSHIP; ASSESSOR'S REFERENCE!: MAP
0278
BRIEF DESCRIPTION: MONROE MEADOWS RESlDENJ'lAL BUILDINGS
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WRIT OF POSSESSION (Ejectment Proceedings PRQP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO
Y, PENNSYLVANIA
DEUTCHE BANK F!KJA BANKERS
TRUST COMPANY OF CALIFORNIA
ON BEHALF OF VENDEE MORTGAGE
TRUST
VS.
No. 06-1914 Civil Te
TOD H. MUTIDG AND OCCUPANTS
318 STUMPSTOWN ROAD
MECHANICSBURG, P A 17055
Costs
Attorney's
Plaintiff s
Prothonotary
$ 134.06
$
$ 1.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(I) To satisfy the judgment for possession in the above matter y u are directed to deliver
possession of the following described property to: (plaintiff (s))
DEUTSCHE BANK F!KJA BANKERS TRUST COMPANY OF CAL ORNIA ON BEHALF
OF VENDEE MORTGAGE TRUST
being: (Premises as follows):
SEE ATTACHED LEGAL DESCRIPTION
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
Co rtof umberland County, PA
Date MAY 16, 2006
(Seal)
-
20f2
No 06-1914 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V A NT.
DEUTCHE BANK FfKJA BANKERS TRUST COMPANY OF
CALIFORNIA ON BEHALF OF VENDEE MORTGAGE T UST
VS.
TOD H. MUTHIG AND OCCUPANTS
318 STUMPSTOWNROAD
MECHANICSBURG, PA 17055
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y
Plff(s}
Prothy
Sheriff
$ 134.06
$-
$ 1.00
$-
Plaintiff (s) attorney name and address:
JOSEPH A. GOLDBECK, JR., ESQUIRE
GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE cm TER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for Plaintiff (s)
Where papers may be served
By virtue of this writ, on the _ day of , . I caused the within
named , to have possession of the premi es described with the
appurtenances, and
Sworn and subscribed to before me this
Day of ,
So Answers,
Sheriff
By
Prothonotary
Deputy
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Berro~.), MUTHJG. TOD H.
Exhibit' A'
DISTRICT: 02a; CITY: MONROE TOWNSHIP; ASSESSOR'S
0278
BRIEF DESCRIPTION: MONROE MEADOWS RESIDENTIAL
BUILDINGS
41
,~~
ECK McCAFFERTY & McKEEVER
h A. Goldbeck, Jr.
Attorn 1.0. #16132
Suite 5 00 - Mellon Independence Center
701 M ket Street
Philad phia, PA 19106-1532
215-82 -6321
Attorn y for Plaintiff
DEUT HE BANK FfKJA BANKERS TRUST
COMP Y OF CALIFORNIA ON BEHALF
OF V EE MORTGAGE TRUST
7105 orporate Drive
PTX 35
Piano, 75026
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
No. 06-1914
TOO . MUTInG
(Mo agor(s) and Record owner(s))
318 S pstown Road
Mec 'csburg, PA 17055
PRAECIPE TO DISCONTINUE AND END
TOT PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of your costs only.
fJI~-
JOSEPH A. GOLDBECK, JR., ESQUIRE
rJlf-
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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, PA 19106-1532
215-825-6321
Attorney for Plaintiff
DEUTCHE BANK F/KJA BANKERS TRUST
COMPANY OF CALIFORNIA ON BEHALF
OF VENDEE MORTGAGE TRUST
71 05 Corporate Drive
PTX C 35
Piano, TX 75026
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
no. 06-1914
TOD H. MUTHIG
And OCCUPANTS
318 Stumpstown Road
Mechanicsburg, P A 17055
PRAECIPE TO DlSCON'fINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of your costs only.
!fJI~-
JOSEPH A. GOLDBECK, JR., ESQUIRE
r-"I ()
c? -11
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01914 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK
VS
MUTHIG TOD H
CPL. TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT
was served upon
MUTHIG TOD H
the
DEFENDANT
, at 2029:00 HOURS, on the 12th day of April
, 2006
at 318 STUMPS TOWN ROAD
MECHANICSBURG, PA 17055
by handing to
HEATHER MUTHIG, WIFE
a true and attested copy of COMPLAINT - EJECTMENT
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
10.56
.00
10.00
.00
38.56
So Answ~ ~
.r -f~
R. Thomas Kline
3/1'I/~(.
Sworn and Subscribed to
04/13/2006
GOLDBECK MCCAFFERTY MCKEEVER
be~e By:
me this
day of
A.D.
prothonotary
I" ",,,
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01914 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK
VS
MUTHIG TOD H
CPL. TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT
was served upon
OCCUPANT
the
DEFENDANT
, at 2029:00 HOURS, on the 12th day of April
, 2006
at 318 STUMPSTOWN ROAD
MECHANICSBURG, PA 17055
by handing to
HEATHER MUTHIG
OCCUPANT
a true and attested copy of COMPLAINT - EJECTMENT
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
6'/JQ/ot +
So Answers:
.t'~?r."<~
R. Thomas Kline
04/13/2006
GOLDBECK MCCAFFERTY
Sworn and Subscribed to before By:
me this
day of
A.D.
Prothonotary
r
~
..
.
By virtue of this writ, on the _ day of , . I caused the within
named , to have possession ofthe premises described with the
appurtenances, and
WRIT OF EXECUTION RETURNED STAYED THIS DATE. ATTY GOLDBECK
FILED A PREACIPE-TO DISCONTINUE ON 6/26/06
SWOql and subscribed to before me this
Day of
SO~~~~~
ByCJQl1~ &!IJwi
.
Sheriff's Return
Dock~ting
Surcharge
Poundage
Milage
Pro thy
I 18.00
20.00
1.16
8.80
1'~ 00
58.96
Advance Costs: 150.00
Sheriff's Costs: 58.96
91. 04
Refunded to Atty on 6/29/06
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20f2
No 06-1914 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
DEUTCHE BANK F/K/A BANKERS TRUST COMPANY OF
CALIFORNIA ON BEHALF OF VENDEE MORTGAGE TRUST
VS.
TOD H. MUTHIG AND OCCUPANTS
318 STUMPSTOWN ROAD
MECHANICSBURG, P A 17055
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y
P1ff (s}
Prothy
Sheriff
$ 134.06
$
$
$
1.00
Plaintiff (s) attorney name and address:
JOSEPH A. GOLDBECK, JR., ESQUIRE
GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for Plaintiff (s )
Where papers may be served
By virtue of this writ, on the _ day of , . I caused the within
named , to have possession of the premises described with the
appurtenances, and
So Answers,
Sworn and subscribed to before me this
Day of
Sheriff
By
Prothonotary
Deputy
. ' .
,,'
toU
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DEUTCHE BANK FIKIA BANKERS
TRUST COMPANY OF CALIFORNIA
ON BEHALF OF VENDEE MORTGAGE
TRUST
VS.
No. 06-1914 Civil Term_
TOD H. MUTHIG AND OCCUPANTS
318 STUMPSTOWN ROAD
MECHANICSBURG, P A 17055
Costs
Attorney's
Plaintiff's
Prothonotary
$ 134.06
$
$ 1.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
DEUTSCHE BANK FIK/A BANKERS TRUST COMPANY OF CALIFORNIA ON BEHALF
OF VENDEE MORTGAGE TRUST
being: (Premises as follows):
SEE ATI ACHED LEGAL DESCRIPTION
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
Date MAY 16, 2006
(Seal)