HomeMy WebLinkAbout06-1949GOL'DBECK 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
W W W.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
Plaintiff
vs.
DARIS ANN. CARTER
Mortgagor and Real Owner
1400 Warwick Road
Camp Hill, PA 17011
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term 04. -l9g7 l.: tc„ C
CIVIL ACTIOWMORTGAGE
FOOMCLO"F
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO 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 LISTED 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, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEER$
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
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 either of the following numbers: 717-243-
9400 or.
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) at 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
CWD-5865.
Para informacion en espanol puede communicarse con Loretta at 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX C-35 Plano, TX
75024-3632.
2. The name and address of the Defendant is DARIS ANN. CARTER, 2 Robin Court, Mechanicsburg, PA
17055-4339, who is the mortgagor and real owner of the mortgaged premises hereinafter described.
3. On February 21, 2003 mortgagor made, executed and delivered a mortgage upon the premises
hereinafter described to SIB MORTGAGE CORP., A NEW JERSEY CORPORATION, which
mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1798, Page
4062. The mortgage has been assigned to: COUNTRYWIDE HOME LOANS, INC. by assignment of
Mortgage, which has been 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
1019(8); 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 August 01, 2005, and each month thereafter and by the terms of the Mortgage, upon default in such
payments for a period of one month, the entire principal balance and all interest due and other charges
are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance
Interest from 07/01/2005
through 04/30/2006 at 6.2500%
Per Diem interest rate at $19.18
Reasonable Attorney's Fee at 5% of Principal Balance as
more fully explained in the next numbered paragraph
Late Charges from 08/01/2005 to 04/30/2006
Monthly late charge amount at $39.32
Costs of suit and Title Search
Monthly Escrow amount $221.19
$110,495.09
$5,236.14
$5,524.75
$353.88
$900.00
$122,509.86
If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above maybe less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff reserves its right to collect Attorney's
fees of up to 5% 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 and "in nersonam" judgment) against the
Defendant in this Action but reserves it's right to bring a separate Action to establish that right, if such
right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding,
this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that
was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law.
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 $122,509.86,
together with interest at the rate of $19.18, 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 Sheriff's Sale of the Property.
By:
K McCAFFERTY & McKEEVER
A. GOLDBECK, JR., ESQUIRE
FOR PLAINTIFF
VERIFICATION
I, --Jati4 Sv f-L7 , 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 unworn falsification to authorities.
Date: Y-.-"? "-?
CO IDE HOME LOANS INC.
E.)Qhi*biot,g
Loss P 06-6-129619A
Boreowafs),CARTER,DA?Jj ,ANN:_. . .
Ezhibit'A'
ALL THAT CERTAIN TRACT OR PARCEL OF GROUND SITUATE IN THE TOWNSHIP
OF LOWER ALLEN, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF
PENNSYLVANIA, MOREiPARTICULARLY BOUNDED AND DESCRIBED-ACCORDING
TO SURVEY OF D. F. RAFFENSPERGER, REGISTERED SURVEYOR., DATED JUNE 21,
1956, AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE SOUTHWEST CORNER OF THE INTERSECTION OF
WARWICK ROAD AND MANCHESTER ROAD, THENCE SOUTHWARDLY ALONG THE
WESTERN SIDE OF WARWICK ROAD, ONE HUNDRED THIRTY-EIGHT AND SIXTEEN
ONE-HUNDREDTHS (13&.16) FEET TO A POINT AT THE DIVIDING LINE BETWEEN
LOTS NOS. 17 AND 18, BLOCK It, ON HEREINAFTER MENTIONED PLAN OF LOTS;
THENCE WESTWARDLY ALONG THE SAME FIFTY-SIX AND FORTY-THREE ONE
HUNDREDTHS (56.43) FEET TO A POINT AT THE DIMING LINE BETWEEN LOTS
NOS. 16 AND 17, BLOCK R ON SAID PLAN; THENCE NORTHWARDLY ALONG THE
SAME AT RIGHT ANGLES TO MANCHESTER ROAD ONE HUNDRED FIVE (105) FEET
TO A POINT ON TIME SOUTHERN SIDE OF MANCHESTER ROAD, THENCE
EASTWARDLY ALONG THE SAME ONE HUNDRED EIGHTEEN AND FORTY-NINE
ONE HUNDREDTHS (119.49) FEET TO A POINT, THE PLACE OF BEGINNING.
BEING LOT NO. 17, ON PLAN OF HIGHLAND PARK RECORDED IN PLAN BOOK 5,
PAGE 24, CUMBERLAND COUNTY RECORDS.
(J -6y.
In the Court of Common Pleas of Cumberland
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
VS.
DARIS ANN CARTER
(Mortgagor(s) and Record Owner(s))
1400 Warwick Road
Camp Hill, PA 17011
Plaintiff
Defendant(s)
County
No. 06-1949
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMP ING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU W LL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
Enter the Judgment in favor of Plaintiff and against DARIS ANN CARTER y default for want of an Answer.
Assess damages as follows:
$123,077.25
Debt
Interest - 07/01/2005 to 05/16/2006
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 1{ OM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivered o the party against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at le t ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
I.D. 1613
AND NOW Judgment is entered in favor of
COUNTRYWIDE HOME LOA INC. and against DARIS ANN CARTER by defau for want of an Answer and damages
assessed in the sum of $123,077.25 as per the above certification. n
Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
Plaintiff
No. Q6-1949
VS.
DARIS ANN CARTER
(Mortgagors and Record Owner(s))
1400 Warwick Road
Camp Hill, PA 17011
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMP ING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM tOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned r against you.
urt ong
Proth
Ey:
If you have any questions concerning the above, please contact:
Joseph A. Goldbeck, Jr.
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Centejr
701 Market Street
Philadelphia, PA 19106
215-627-1322
CWD-5865
THIS LAW FIRM IS A DEBT COLLECTOR AND WE 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: May 4, 2006
TO:
DARTS ANN. CARTER
1400 Warwick Road
Camp Hill, PA 17011
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
Plaintiff
VS.
DARIS ANN. CARTER
(Mortgagor(s) and Record Owner(s))
1400 Warwick Road
Camp Hill, PA 17011
Defendant(s)
TO: DARIS ANN. CARTER
1400 Warwick Road
Camp Hill, PA 17011
IMPORTANT NOTICF,
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-1949
fTER A WRITTEN APPEARANCE
YOUR DEFENSES OR OBJECTIONS
3N (10) DAYS FROM THE DATE OF
A HEARING AND YOU MAY LOSE
HIS PAPER TO YOUR LAWYER AT
)FFICE SET FORTH BELOW. THIS
ER IF YOU CANNOT AFFORD TO
INFORMATION ABOUT AGENCIES
FEE OR NO FEE.
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN I
THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT
YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE'
ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAW
HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE
LEGAL SERVICES INC
8 kvina Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Attorney for Plaini
Suite 5000-Me16
701 Market Street
Philadelphia, PA 1
Independence Center
215.627-1322
CWD-5865
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: May 4, 2006
TO:
DARIS ANN. CARTER
2 Robin Court
Mechanicsburg, PA 17055-4339
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
VS.
DARIS ANN. CARTER
(Mortgagor(s) and Record Owner(s))
1400 Warwick Road
Camp Hill, PA 17011
TO: DARIS ANN. CARTER
2 Robin Court
Mechanicsburg, PA 170554339
In the Court of Common Pleas
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
Term
No. 06-1949
Defendant(s)
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFEN
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS F
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELO
WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFOi
MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 hvine Row
Carlisle, PA 17013
717-243.9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
BY: Joseph A.
Attorney for P
Suite 5000 - 7
Philadelphia, I
TTEN APPEARANCE PERSONALLY
3 OR OBJECTIONS TO THE CLAIMS
M THE DATE OF THIS NOTICE, A
U MAY LOSE YOUR PROPERTY OR
WYER AT ONCE. IF YOU DO NOT
THIS OFFICE CAN PROVIDE YOU
TO HIRE A LAWYER, THIS OFFICE
IAT MAY OFFER LEGAL SERVICES
:RTY & McIEEVER
Jr., Esq.
Market Street.
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 forego?ng verification of
Non-Military Service are true and correct ito the best of my
knowledge, information and belief. I understand that false
statements therein are made subject to penal ies of 18 Pa. C.S.
4904 relating to unsworn falsification to aut orities.
1. That the above named Defendant, D RIS ANN CARTER, is
about unknown years of age, that DefenI4ant's last known
residence is 2 Robin Court, Mechanicsburg, PA 1'7055-4339, and
is engaged in the unknown business located atiunknown address.
2. That Defendant is not in the Militalry or Naval Service
of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Action of
i
Congress of 1940 and its Amendments.
Date: V,
h
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
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
VS.
Plaintiff
IN THE COURT OF COMMON PLEAS
?f Cumberland County
I
CIVIL ACTION LAW
DARIS ANN CARTER
(Mortgagor(s) and Record owner(s))
1400 Warwick Road ACTION Of MORTGAGE FORECLOSURE
Camp Hill, PA 17011
Defendant(s)
No. 06-149
ORDER FOR JUDGMENT
Please enter Judgment in favor of COUNTRYWIDE HOME LOAN INC., and against DARIS ANN
CARTER for failure to file an Answer in the above action within (20) days (o sixty (60) days if defendant is the
United States of America) from the date of service of the Complaint, in the su of $123,077.25.
I hereby certify that the above names are correct and thprecise r stdence address of the judgment
creditor is COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PT C-35 Plano, TX 75024-3632 and
that the name(s) and last known address(es) of the Defendant(s) is/are DARIS?ANN CARTER, 2 Robin Court
Mechanicsburg, PA 17055-4339;
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
Interest from 07/01/2005 through
05/16/2006
Attorney's Fee at 5.0000% of principal
balance
Late Charges
Costs of Suit and Title Search
Escrow Balance Deficit
BY: Joseph A.
AND NO W, this 194~ day of / & ? 201
$110,495.09
$5,543.02
$5,524.75
$393.20
$221.19
($0.00)
.25
LTY & McKEEVER
Jr.
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.. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAdE FORECLOSURE)
P.R.C.P 3180-3183
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
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
Vs.
DARIS ANN CARTER
Mortgagor(s) and Record Owner(s)
1400 Warwick Road
Camp Hill, PA 17011
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-1049
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
07/01/2005 to
05/16/2006 at
6.2500%
(Costs to be added)
$123,077.25
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All that certain tract or parcel of ground situate in the Township of Lower Allen, County of Cumberland,
and Commonwealth of Pennsylvania, more particularly bounded and described according to survey of
D.F. Raffensperger, Registered Surveyor, dated June 21, 1956, as follows, to wit:
Beginning at a point on the southwest corner of the intersection of Warwick Road and Manchester Road,
thence southwardly along the western side of Warwick Road, one hundred thirty-eight and sixteen one-
hundredths (138.16) feet to a point at the dividing line between Lots Nos. 17 and 18, Block R, on
hereinafter mentioned Plan of Lots; thence westwardly along the same fifty-six and forty-three one
hundredths (56.43) feet to a point at the dividing line between Lots Nos. 16 and 17, Block R on said
plan; thence northwardly along the same at right angles to Manchester Road one hundred five (105) feet
to a point on the southern side of Manchester Road, thence eastwardly along the same one hundred
eighteen and forty-nine one hundredths (118.49) feet to a point, the place of beginning.
Being Lot No. 17, on Plan of Highland Park recorded in Plan Book 5, page 24, Cumberland County
Records.
MUNICIPALITY: TOWNSHIP OF LOWER ALLEN
TAX PARCEL #: 13-23-0545-372
PROPERTY ADDRESS: 1400 WARWICK ROAD, CAMP HILL, PA 17011
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06+1949 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS INC., Plaintiff (s)
From DARIS ANN CARTER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the g mishee(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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $123,077.25
Interest FROM 7/1/05 TO 5/16/06 AT 6.2500%
L.L. $.50
Arty's Comm %
Arty Paid $154.76
Plaintiff Paid
Due Prothy $1.00
Other Costs
Date: MAY 19, 2006
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000-MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Or Attorney I.D. 416132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
VS.
DARIS ANN CARTER
(Mortgagor(s) and Record Owner(s))
1400 Warwick Road
Camp Hill, PA 17011
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-1949
AFFIDAVIT PURSUANT TO RULE 3129
COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action, by its ttorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real
property located at:
1400 Warwick Road
Camp Hill, PA 17011
I.Name and address of Owner(s) or Reputed Owner(s):
DARIS ANN CARTER
2 Robin Court
Mechanicsburg, PA 17055-4339
2. Name and address of Defendant(s) in the judgment:
DARIS ANN CARTER
2 Robin Court
Mechanicsburg, PA 17055-4339
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
SUSQUEHANNA VALLEY FEDERAL CREDIT UNION
3850 Hartzdale Drive
Camp Hill, PA 17011
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
r P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lion 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.
I
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
1400 Warwick Road
Camp Hill, PA 17011
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the bet 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 unswom falsification to authorities.
DATED: May 16.2006
I
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06-1949
GOLDBECK MCCAMRTY & 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
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
VS.
Plaintiff
DARIS ANN CARTER
Mortgagor(s) and Record Owner(s)
1400 Warwick Road
Camp Hill, PA 17011
Term
No. 06-1949
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATEMPTING 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.
i
NOTICE OF SHERIFF'S SALE OF REAL PRO?PERT
Y
TO: CARTER, DAMS ANN
DARTS ANN CARTER
1400 Warwick Road
Camp Hill, PA 17011
Your house at 1400 Warwick Road, Camp Hill, PA 17011 is schedule to be sold at Sheriffs Sale
on Wednesday, September 06, 2006, at 10:00 AM, in Commissioners Hearing 2nd FL Courthouse to
enforce the court judgment of $123,077.25 obtained by COUNTRYWIDE HOME LOANS INC. against
you.
NOTICE OF OWNER'S RIGHTS
To prevent this Sheriffs Sale you must take immediate action:
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL!, ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
1. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS INC., the back
payments, late charges, costs and reasonable attorney's fees due. To find out ho much you must pay call:
215-627.1322
06-1949
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).
EVEN IF THE SHERIFFS SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid 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 find
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 #emain 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 i? paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proc edings 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 ney. 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 dis ibution is filed.
(
T You may also have other rights and defenses, or ways of getting your louse back, if you act
immediately after the sale. I
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 O FICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIA
2 Liberty Avenue
Carlisle, PA 17013
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All that certain tract or parcel of ground situate in the Township of Lower Allen, County of Cumberland,
and Commonwealth of Pennsylvania, more particularly bounded and described according to survey of
D.F. Raffensperger, Registered Surveyor, dated June 21, 1956, as follows, to wit:
Beginning at a point on the southwest corner of the intersection of Warwick Road and Manchester Road,
thence southwardly along the western side of Warwick Road, one hundred thirty-eight and sixteen one-
hundredths (138.16) feet to a point at the dividing line between Lots Nos. 17 and 18, Block R, on
hereinafter mentioned Plan of Lots; thence westwardly along the same nifty-six and forty-three one
hundredths (56.43) feet to a point at the dividing line between Lots Nosj 16 and 17, Block R on said
plan; thence northwardly along the same at right angles to Manchester oad one hundred five (105) feet
to a point on the southern side of Manchester Road, thence eastwazdly ong the same one hundred
eighteen and forty-nine one hundredths (118.49) feet to a point, the plac of beginning.
Being Lot No. 17, on Plan of Highland Park recorded in Plan Book 5, pge 24, Cumberland County
Records.
MUNICIPALITY: TOWNSHIP OF LOWER ALLEN
TAX PARCEL #: 13-23-0545-372
PROPERTY ADDRESS: 1400 WARWICK ROAD, CAMP HILL, PA
e SHERIFF'S RETURN - REGULAR
t
CASE NO: 2006-01949 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
CARTER DARIS ANN
VALERIE WEARY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
CARTER DARIS ANN the
DEFENDANT , at 1807:00 HOURS, on the 13th day of April 2006
at 2 ROBIN COURT
MECHANICSBURG, PA 17055 by handing to
DARIS ANN CARTER
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 6.00
Service 10.56
Affidavit .00
Surcharge 10.00
.00
26.56
Sworn and Subscribed to before
me this day of
A. D.
So Answers:
R. Thomas Kline
04/17/2006
GOLDBECK MCCAFFERTY MCKEEVER
By.
Deputy Sheriff f
Prothonotary
i
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-01949 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
CARTER DARIS ANN
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
CARTER DARIS ANN but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE ,
1400 WARWICK ROAD
CAMP HILL, PA 17011
WARWICK ROAD IS VACANT.
NOT FOUND , as to
Sheriff's Costs: So answer,--
Docketing , ---
Docketing 18.00
Service 13.20 /
Not Found 5.00 -' R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
46.20 GOLDBECK MCCAFFERTY MCKEEVER
04/17/2006
Sworn and subscribed to before me
the within named DEFENDANT , CARTER DARIS ANN
this
A. D.
day of
Prothonotary
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
CWD-5865
CF: 04/05/2006
SD: 09/06/2006
$123,077.25
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
Plaintiff
VS.
DARIS ANN CARTER
Mortgagor(s) and
Record Owner(s)
1400 Warwick Road
Camp Hill, PA 17011
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Tenn
No. 06-1949
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (e) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants of the Notice of Sheriff Sale was made by:
( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached).
>0 Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S.
Section 4904.
Res ct at ' 9
B : J eph A. o d eck Jr.
o for Plaintiff
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
VS.
DARIS ANN CARTER
Mortgagor(s) and Record Owner(s)
1400 Warwick Road
Camp Hill, PA 17011
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
Term
No. 06-1949
COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real
property located at:
1400 Warwick Road
Camp Hill, PA 17011
1.Name and address of Owner(s) or Reputed Owner(s):
DARIS ANN CARTER
2 Robin Court
Mechanicsburg, PA 17055-4339
2. Name and address of Defendant(s) in the judgment:
DARIS ANN CARTER
2 Robin Court
Mechanicsburg, PA 17055-4339
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
SUSQUEHANNA VALLEY FEDERAL CREDIT UNION
3850 Hartzdale Drive
Camp Hill, PA 17011
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
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
1400 Warwick Road
Camp Hill, PA 17011
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities.
DATED: August 14, 2006
Ph A. Goldbeck, Jr., Esq.
for Plaintiff
'4 0+
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Secretary of Housing & Urban Development is the grantee the same having
been sold to said grantee on the 6th day of Sept A.D., 2006, under and by virtue of a writ Execution
issued on the 19th day of May, A.D., 2006, out of the Court of Common Pleas of said County as of Civil
Term, 2006 Number 1949, at the suit of Countrywide Home Loans Inc against Daris Ann Carter is duly
recorded in Deed Book No. 278, Page 3056.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this 31 day of
A.D. 02-00 `7
of Deeds
ROOM & of Dude, Wnoet and CAM, Ca&b. PA
MY ft"*Aulm E*h" #0 Ffret Monday 01 JW 2010
Countrywide Home Loans, Inc.
VS
Daris Ann Carter
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2006-1949 Civil Term
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on July 20, 2006 at 5:47 o'clock PM, he served a true copy of the within Real Estate
Writ, Notice and Description, in the above entitled action, upon the within named
defendant, to wit: Daris Ann Carter by making known to Daris Ann Carter, personally, at
2 Robin Court, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at
the same time handing to her personally the said true and correct copy of the same.
Jessica Hermansen, Deputy Sheriff, who being duly sworn according to law,
states that on July 6, 2006 at 1:30 o'clock P.M., she posted a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Daris Ann Carter located at 1400 Warwick Road, Camp Hill, Pennsylvania
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
defendant, to wit: Daris Ann Carter, by regular mail to her last known address of 2 Robin
Court, Mechanicsburg, Pennsylvania 17055. This letter was mailed under the date of
July 26, 2006 and never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on September 06, 2006 at 10:00 o'clock A.M. He sold the same
for the sum of $1.00 to Attorney Joseph Goldbeck on behalf of the Secretary of Housing
and Urban Development, His Successors and Assigns. It being the highest bid and best
price received for the same, the Secretary of Housing and Urban Development, His
Successors and Assigns, of, 100 Penn Square East, Tenth Floor, Wanamaker Building,
Philadelphia, PA 19106, being the buyer in this execution, paid to Sheriff R. Thomas
Kline the sum of $828.35.
Sheriffs Costs:
Docketing 30.00
Poundage 16.24
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 19.60
Levy 15.00
Surcharge 20.00
Law Journal 305.00
Patriot News 267.20
Share of Bills 19.31
Distribution of Proceeds 25.00
Sheriffs Deed 39.50
$ 828.35
p}I. ? p1
So Answe
R. Thomas Kline, Sheriff
BYd W-,J-A` er
a?
p0
w
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
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-3 5
Plano, TX 75024-3632
IN THE COURT OF COMMON PLEAS
Plaintiff
VS.
DARIS ANN CARTER
(Mortgagor(s) and Record Owner(s))
1400 Warwick Road
Camp Hill, PA 17011
Defendant(s)
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-1949
AFFIDAVIT PURSUANT TO RULE 3129
COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real
property located at:
1400 Warwick Road
Camp Hill, PA 17011
1.Name and address of Owner(s) or Reputed Owner(s):
DARIS ANN CARTER
2 Robin Court
Mechanicsburg, PA 17055-4339
2. Name and address of Defendant(s) in the judgment:
DARIS ANN CARTER
2 Robin Court
Mechanicsburg, PA 17055-4339
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
SUSQUEHANNA VALLEY FEDERAL CREDIT UNION
3850 Hartzdale Drive
Camp Hill, PA 17011
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
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
1400 Warwick Road
Camp Hill, PA 17011
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities.
DATED: May 16, 2006
GOL B$C cCAFFERTY & McKEEVER
BY: J eph Goldbeck, Jr., Esq.
Attorn for lamtiff
r
Plaintiff
Defendant(s;
Term
No. 06-1949
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
06-1949
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
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024-3632
vs.
DARIS ANN CARTER
Mortgagor(s) and Record Owner(s)
1400 Warwick Road
Camp Hill, PA 17011
TO: CARTER, DARIS
DARIS ANN CARTER
2 Robin Court
Mechanicsburg, PA 17055-4339
Your house at 1400 Warwick Road, Camp Hill, PA 17011 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 $123,077.25 obtained by COUNTRYWIDE HOME LOANS INC. against
you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS INC., the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
IN THE COURT OF COMMON PLEAS
of Cumberland County
'CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
I
06-1949
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs 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 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 find
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 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 SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
06-1949
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Piano, TX 75024-3632
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
VS.
DARIS ANN CARTER
Mortgagor(s) and Record Owner(s)
1400 Warwick Road
Camp Hill, PA 17011
ACTION OF MORTGAGE
FORECLOSURE
Defendants;
Term
No. 06-1949
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: CARTER, DARIS ANN
DARTS ANN CARTER
1400 Warwick Road
Camp Hill, PA 17011
Your house at 1400 Warwick Road, Camp Hill, PA 17011 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 courtjudgment of $123,077.25 obtained by COUNTRYWIDE HOME LOANS INC. against
you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS INC., the back
payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call:
215-627-1322
06-1949
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs 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 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 find
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 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 SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
SHORT DESCRIPTION
IMPROVEMENTS consist of a residential dwelling.
BEINGPREMISES: 1400 Warwick Road
Camp Hill, PA 17011 1400 Warwick Road
Camp Hill, PA 17011
SOLD as the property of DARIS ANN CARTER
TAX PARCEL #13-23-0545-372
• WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 06-1949 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS INC., Plaintiff (s)
From DARIS ANN CARTER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $123,077.25
Interest FROM 7/1/05 TO 5/16/06 AT 6.2500%
Atty's Comm %
Atty Paid $154.76
Plaintiff Paid
Date: MAY 19, 2006
L.L. $.50
Due Prothy $1.00
Other Costs
A 5L O G
Prothonotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
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 # 66
On June 02, 2006 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA
Known and numbered as 1400 Warwick Rd.,
Camp Hill, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: June 02, 2006 By: j sV?
Real Estate Sergeant
U:01b CZ IN 9001
jjI?3NS ?Hi A 3OJJJO
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF CUMBERLAND
ss.
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.
Marie Covn6. Editor
SWORN TO AND SUBSCRIBED before me this
4day of August. 2006 _
??'2 W 112/?
.....s N07ARlAt. SEAL
LOIS E. SNYDER, Notary Pub"ic
Carlisle Boro> Curnberland Countv
My Com nisSiOn Expires March 5, 2009
REAL MTATE aA1X NO. 66
Writ No. 2006-1949 Civil
Countrywide Home Loans Inc.
VS.
Daris Ann Carter
Atty.: Joseph A. Goldbeck, Jr.
All that certain tract or parcel of
ground situate in the Township of
Lower Allen, County of Cumberland.
and Commonwealth of Pennsylva-
nia, more particularly bounded and
described according to survey of
D.F. Raffensperger, Registered Sur-
veyor, dated June 21, 1956, as fol-
lows, to wit:
Beginning at a point on the south-
west corner of the intersection of
Warwick Road and Manchester
Road, thence southwardly along the
western side of Warwick Road, one
hundred thirty-eight and sixteen
one-hundredths (138.16) feet to a
point at the dividing line between
Lots Nos. 17 and 18, Block R, on
hereinafter mentioned Plan of Lots;
thence westwardly along the same
fifty-six and forty-three one hun-
dredths (56.43) feet to a point at
the dividing line between Lots Nos.
16 and 17, Block R on said plan;
thence northwardly along the same
at right angles to Manchester Road
one hundred five (105) feet to a
point on the southern side of
Manchester Road, thence east-
wardly along the same one hundred
eighteen and forty-nine one hun-
dredths (118.49) feet to a point, the
place of beginning.
Being Lot No. 17, on Plan of High-
land Park recorded in Plan Book 5,
page 24, Cumberland County
Records.
MUNICIPALITY: Township of
Lower Allen
TAX PARCEL #: 13-23-0545-372
PROPERTY ADDRESS: 1400
Warwick Road, Camp Hill, PA 17011
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
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 N.J. ...>?6I ., .........................
COPY Sworn to and subsc ' ed fo me tb0A"*1 4"F9WW9Vl 1A
S A L E 466 Notarial Seal
Terry L. Russell, Notary Pubkc
city Of Har : rg, Dauphi
My com n 6,2010
Expn
"-K., Pen %Ivsttia s ration of Notaries
Y PUBLIC
4
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
4
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
COUNTRYWIDE HOME LOANS INC.
Plaintiff
vs.
DARIS ANN CARTER
Defendant
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
No. 06-1949
IN MORTGAGE FORECLOSURE
MOTION TO STRIKE SHERIFF'S DEED
AND NOW, comes Plaintiff, by its attorney, Kristina G. Murtha, of GOLDBECK
McCAFFERTY & McKEEVER, and represents as follows:
1. The above case had been brought in mortgage foreclosure.
2. The mortgage foreclosure action was based on a default on the residential
mortgage forming the subject of the action.
3. Judgment was entered on or about May 19, 2006.
4. A Sheriff's Sale of the property was held on September 6, 2006
5. The Sheriffs Deed was recorded on January 31, 2007 prior to Plaintiff's Counsel
receiving proper instructions from its client. A true and correct copy of the
recorded deed is attached hereto as Exhibit A.
6. Plaintiff now moves this honorable Court for an Order striking this deed and
approve a corrective deed at plaintiffs expense, so that the records of the Recorder
of Cumberland County reflect the true ownership of the property.
IN THE COURT OF COMMON PLEAS
WHEREFORE, Plaintiff requests that the Sheriff s Deed recorded January 31,
2007 be stricken.
GOLDWC&I4cAFF TY McKEEVER
By:
Pt! 1u?tlra, Esquire
for Plaintiff
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
COUNTRYWIDE HOME LOANS INC.
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
VS.
DARIS ANN CARTER
Defendant(s)
CIVIL ACTION LAW
No. 06-1949
IN MORTGAGE FORECLOSURE
BRIEF IN SUPPORT OF MOTION
TO STRIKE SHERIFF'S DEED
1. FACTS
This case is an action in mortgage foreclosure, based upon a default on the residential
mortgage forming the subject of the action. Judgment was entered on or about May 19, 2006, a
writ of execution issued and a Sheriffs sale of the property was held on September 6, 2006. The
Sheriffs Deed was recorded on January 31, 2007 prior to Plaintiff's Counsel receiving proper
instructions from its client.
Plaintiff now moves this honorable Court for an Order striking this deed, so that the
records of the Recorder of Cumberland County reflect the true ownership of the property.
II. LEGAL ARGUMENT
This honorable Court is empowered to grant the requested relief by the Pennsylvania
Rules of Court, which permits this Court to act in a manner calculated to effect a speedy and just
result. Pa.R.C.P. 126 provides this honorable Court with the power to "disregard an error or
defect of procedure which does not affect the substantial rights of the parties." As the court
stated in First Eastern Bank v. Campstead, 637 A.2d 1364 (Pa.Super. 1994):
This approach does not countenance the wholesale derogation of our procedural
rules, but does allow us to bend them just a little where the interests of justice demand. I
would not surrender this flexibility in favor of a uniform policy of super-strict
compliance with procedural rules, when such compliance would only be pointless and
burdensome.
Plaintiff notes that, in the instant matter, the county land records, held in the Office of the
Recorder of Deeds of Cumberland County, reflect an incorrect state of title for the subject
premises. Moreover, the Sheriff's Deed is void and should be stricken from the records of the
Recorder of Deeds.
III. CONCLUSION
For these and the foregoing reasons, Plaintiff respectfully requests that the Sheriff's Deed
recorded January 31, 2007 be stricken and a Corrective Sheriff's Deed issued at the
Plaintiff's expense.
submitted,
GOLDMEWWWFEITY McKEEVER
By:
Attorney
Tax Parcel No. 13-23-0545-372
Know all Men by these Presents
ADO? AN 31 flN n 0o
That 1, R. Thomas Kline, Sheriff of the County of Cumberland, In the State of
Pennsylvania, for and in consideration of the sum of $1.00. (One Dollar), to me in hand
paid, do hereby grant and convey to Secretary of Housing and Urban Development,
His Successors and Assigns.
REAL ESTATE SALE NO. 66
Writ No. 2006-1949 Civil Term
Countrywide Home Loans Inc.
Vs
Danis Ann Carter
Atty: Joseph A. Goldbeck, Jr.
DESCRIPTION
ALL THAT CERTAIN tract or parcel of ground situate in the Township of Lower
Allen, County of Cumberland, and Commonwealth of Pennsylvania, more particularly
bounded and described according to survey of D.F. Raffensperger, Registered Surveyor,
dated June 21, 1956, as follows, to wit:
BEGINNING to a point on the southwest corner of the intersection of Warwick
Road and Manchester Road, thence southwardly along the western side of Warwick
Road, one hundred thirty-eight and sixteen one-hundredths (138.16) feet to a point at the
dividing line between Lots Nos. 17 and 18, Block R, on hereinafter mentioned Plan of
Lots; thence westwardly along the same fifty-six and forty-three one hundredths (56.43)
feet to a point at the dividing line between Lots Nos. 16 and 17, Block R on said plan;
thence northwardly along the same at right angles to Manchester Road one hundred five
(105) feet to a point on the southern side of Manchester Road, thence eastwardly along
the same one hundred eighteen and forty-nine one hundredths (118.49) feet to a point, the
place of beginning. Being Lot No. 17, on Plan of Highland Park recorded in Plan Book 5,
page 24, Cumberland County Records. Municipality: Township of Lower Allen.
TAX PARCEL #: 13-23-0545-372
Property Address: 1400 Warwick Road, Camp Hill, PA 17011
278 RGF30 %
v.';v
The same having been sold by me to the said grantee on the 6th day of September Anno
Dommi Two Thousand and Six 200 after due advertisement according to law,
under and by Virtue of a Writ of Execution issued on the 19th day of May Anno
Domini 2006 out of the Court.of Common Pleas of Cumberland County, Pennsylvania, as
of Civil Term, Two Thousand and Six 2( 006) Number 1949 at the suit of Countrywide
Home Loans Inc. against Daris Ann Carter.
9OOX 278 PACE3057
V"
In Witness Whereof, I have hereunto affixed my signature this-11 qt- day of Jarary
Anno Domini Two Thousand and Seven (2007)
Thomas Klin , Sheriff
Commonwealth of Pennsylvania, ss.
County of Cumberland
Before the undersigned, Curtis R. Long, Prothonotary of the Court of Common
Pleas of Cumberland County, Pennsylvania, personally appeared R. Thomas Kline,
Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts
Set forth in the foregoing Deed are true, and that he acknowledged the same in order that
Said deed might be recorded.
Witness my hand. and seal of said Court, this 31 stday of Jan. Anno Domini
Two Thousand and Seven (2007)
:" ??;`?????;? ' -:-'rj? i
ij •
''fir '?._ ••••,•• ? -?
I Certify this to be recorded
In Cumberland County PA
.
Recorder of Deeds
CARLISLE CUMBERLAND COM COURTHOUSE
W COMMISSION EWES JANUARY 4, 2010
I hereby certify that the residence
And Post Office address of the
Within Grantee is
100 Penn Square East
Tenth Floor
Wannamaker Building
Philadelphia, PA 19106
Solicitor
BGaK 278 P,; 3oM
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
COUNTRYWIDE HOME LOANS INC.
Plaintiff
VS.
DARIS ANN CARTER
Defendant(s)
No. 06-1949
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
Kristina G. Murtha, Esquire, hereby certifies that on this day of
, 2007, he did serve true and correct copies of Plaintiffs Motion
to Strike Sheriff s Deed and all supporting papers attached hereto upon:
DARIS ANN CARTER SHERIFF OF CUMBERLAND COUNTY
1400 Warwick Road Sheriffs Office
Camp Hill, PA 17011 1 Courthouse Square
Carlisle, PA 170W
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION LAW
GOLDBECK ?FERTY McKEEVER
By: Kristina G. urtha, Esquire
Attorney for Plaintiff
VERIFICATION
I, Kristina G. Murtha, Esquire, hereby swear and affirm that the facts contained in the
foregoing Motion to Strike Sheriff's Deed are true and correct to the best of my knowledge, in
formation and belief, based upon information provided by Plaintiff, COUNTRYWIDE HOME
LOANS INC. and that said facts contained herein are made subject to the penalties of 18 Pa.C.S.
§ 4904 relating to unsworn falsification to authorities.
Date:
GOLDBEC c ERTY McKEEVER
By: Kristina G. Murtha, Esquire
Attorney for Plaintiff
C71
?S
JAN 0 3 2008 le
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
COUNTRYWIDE HOME LOANS INC.
Plaintiff
vs.
DARIS ANN CARTER
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 06-1949
MOTION TO STRIKE DEED AND
APPROVE CORRECTIVE SHERIFF'S
DEED
ORDER OF COURT
AND NOW, this 7th day of 3 evowel , 200* upon consideration
16
of the within Motion to Strike Sheriff's Deed and Approve Corrective Sheriffs Deed,
It is HEREBY ORDERED AND DECREED that the Wednesday, September 06, 2006
Sheriff's Sale of the subject property, located at 1400 Warwick Road Camp Hill, PA, 17011, is
hereby CONFIRMED, and it is further ORDERED AND DECREED that the Sheriffs Deed
recorded January 31, 2007 in Deed Book 278, page 3056, et seq., be and is hereby STRICKEN.
It is further ORDERED that the Sheriff of Cumberland County shall prepare and deliver
forthwith to Plaintiff a Corrective Sheriffs Deed at Plaintiffs expense.
It is further ORDERED that the Recorder of Deeds of Cumberland County shall record a
copy of this Order.
. BY THE COURT:
4w Ado 1. //
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