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Home My WebLink About02-1629GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff vs. AMANDA I. YOUNG WESLEY J. YOUNG Mortgagor(s) and Real Owner(s) 597 Walnut Bottom Road Shippensburg,PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term ?o n No. Uo2 -??oc / l . l U L CIVIL ACTION: MORTGAGE i=A-nl FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 ajudgment 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 POPER 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 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SO 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 rMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. Sl NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is CITIFINANCIAL SERVICES INC., 7467 New Ridge Road, Suite 222 Hanover, MD 21076. 2. The name(s) and address(es) of the Defendant(s) is/are AMANDA I. YOUNG, 315 Pinedale Road, Carlisle, PA 17013 and WESLEY J. YOUNG, 315 Pinedale Road, Carlisle, PA 17013, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On May 16, 2001 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to CITIFINANCIAL SERVICES, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1706 and Page 1055. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due September 01, 2001, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 07/16/2001 through 03/31/2002 at 9.4000% Per Diem interest rate at $21.23 Attorney's Fee at 5.0% of Principal Balance Costs of suit and Title Search Escrow $82,430.86 $5,477.34 $4,121.54 $750.00 $92,779.74 $0.00 $92,779.74 The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) hasihave not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $92,779.74, together with interest at the rate of $21.23, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: L U' , ujwj 'J ?4 GO . BE { McCA ?FERTY & McKEEV BY: JOSEPH A. GOLD PECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION 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: - LJJ?- 08:27A Tracy Watts 717-838-2625 P.10 a?937 PARCEL NO. 39 - 12 - 0324 - 0086 DEED r MADE THE day of January In the year one thousand nine hundred ninety- nine (1999), BETWEEN DONALD L. STINE and FLORENCE A. STINE. his wife, of 355 Strohm Road, Shippensburg, Cumberland County, Pennsylvania 17257, hereinafter called Grantors, AND WESLEY J. YOUNG and AMANDA I. YOUNG, his wife, of 597 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania, hereinafter called Grantees: WITNESSETH, that in consideration of the sum of Sixty Thousand and no/100 ($60,000.00) Dollars, the receipt whereof is hereby acknowledged, the Grantors hereby grant and convey unto the Grantees, their heirs and assigns, as tenants by the entireffes: ALL that certain tract of land with the improvements thereon situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike in the intersection of Pennsylvania Route 174 and Legislative Route 21006; thence along Pennsylvania Route 174, South 79 degrees 23 minutes 42 seconds West, a distance of 208.55 feet to a point; thence North 11 degrees 40 minutes 56 seconds West, a distance of 150.00 feet to a point; thence North 79 degrees 23 minutes 42 seconds East, a distance of 208.55 feet to a point in the centerline of said Legislative Route 21006; thence along the latter, South 11 degrees 40 minutes 56 seconds East a distance of 150.00 feel to the center of the intersection, the Place of BEGINNING. ?, X93 iaw 290 :18A Tracy Watts 717-838-2625 P.11 CONTAINING 0.718 acres, more or less, according to a survey of Arrowood, Incorporated, made July 20, 1972. The above deacriptbn Includes 84)). . a 14 foot driveway (See Cumberland County Dead Book "B', Volume 14, Page 2 BEING improved with a dwelling known and numbered as 597 Walnut Bottom Road, Shlppensburg, Pennsylvania 17257. BEING the same property which was awarded to DONALD L. STINE and FLORENCE A. STINE, his wife, grantors herein, by Decree Awarding Real Estate, dated November 27, 1973 and recorded In the Cumberland County Recorder of Deeds Office In Deed Book -L', Volume 25, Page 89. (See also Estate of C. ROY FUNK, Cumberland County Register of Wills Office, Estate No. 21 - 73 -108.) BEING also part of the same property which SAMUEL H. COHICK and ETHEL E. COHICK, his wife, granted and conveyed to C. ROY FUNK and THELMA B. FUNK, his wife, by deed,dated April 12, 1951, and recorded In the Office of the Recorder of Deeds for Cumberland County, Pennsylvania, in Deed Book "R*, Volume 14, Page 284. AND the said grantors hereby covenant and agree that they WID warrant specially the property hereby conveyed. IN WITNESS WHEREOF, said grantors have hereunto set their hands and seals the day, month and year first above written. Signed, Sealed and Delivered In the presence of BOOK 193 Pue 29..L % (SEAL) FLORENCE A. STINE COW EXtj'BjT A ACT 91 NOTIC DATE OF NOTICE: February 21, 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. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number 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 Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes 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. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Fax (215) 627-7734 1 Date: February 21, 2002 Homeowners Name: AMANDA I. YOUNG and WESLEY J. YOUNG Property Address: 597 Walnut Bottom Road, Shippensburg, PA 17257 Loan Account No.: 3800410201350 Original Lender: Citifinancial Services Inc. Current Lender/Servicer: Citifinancial Services Inc. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS 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 foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE 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 (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property 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 immediately 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 from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this 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 filed or postmarked within thirty (30) days of your fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 597 Walnut Bottom Road, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 09/01/2001 thru 2/21/2002 (6 mos. at $767.42/month) $4,604.52 (b) Other charges; Escrow, Inspec., NSF Checks (c) Other provisions of the mortgage obligation, if any (d) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $4,604.52 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $4,604.52, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) 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. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney'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 incurred 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. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid 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 (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff 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 Sheriff s Sale as specified in writing by the lender and by performing 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 mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs 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 by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CITIFINANCIAL SERVICES INC. Address: 7467 New Ridge Road Suite 222 Hanover, MD 21076 Phone Number: 800-446-7876 x1604 Fax Number: 410-689-1610 Contact Person: Meryl Kessler EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings 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 who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage 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 IN ANY CALENDAR YEAR.) 5 * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. x TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. x TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact Person: Meryl Kessler Phone Number: 800-446-7876 x1604 6 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INC. 2000 Linglestown Road Harrisburg, PA 17102 (717)541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 m A fi m L" m 0 Mm .°a M1 94 U U L" m tSp T A M1 ACT 91 NOTICE DATE OF NOTICE: February 22, 2002 EXHIBIT A 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. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. r - M A . The name, address and phone number of Consumer Credit Counseling Agencies serving r your County are listed at the end of this Notice. If you have any questions you may call the A Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869.) .o o- A This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. cW You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al j; numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado G "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la Zn perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. A 111 S. Independence Mall East 52 M Philadelphia, PA 19106 rn Fax (215) 627-7734 M1 1 Date: February 22, 2002 Homeowners Name: AMANDA I. YOUNG and WESLEY J. YOUNG Property Address: 597 Walnut Bottom Road, Shippensburg, PA 17257 Loan Account No.: 3800410201350 Original Lender: CITIFINANCIAL SERVICES, INC. Current Lender/Servicer: CITIFINANCIAL SERVICES, INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS 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 foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE 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 (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property 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 immediately 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 from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this 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 filed or postmarked within thirty (30) days of your fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 597 Walnut Bottom Road, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 09/01/2001 thru 2/22/2002 (6 mos. at $767.42/month) $4,604.52 (b) Other charges; Escrow, Inspec., NSF Checks (c) Other provisions of the mortgage obligation, if any (d) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $4,604.52 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $4,604.52, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check, certified check or money order made payable and sent to: CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) 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. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney'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 incurred 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. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid 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 (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs 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 Sheriff s Sale as specified in writing by the lender and by performing any 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. 4 EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs 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 by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CITIFINANCIAL SERVICES INC. Address: 7467 New Ridge Road Suite 222 Hanover, MD 21076 Phone Number: 800-446-7876 x1604 Fax Number: 410-689-1610 Contact Person: Meryl Kessler EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings 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 who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage 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 IN ANY CALENDAR YEAR.) 5 x 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 BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact Person: Meryl Kessler Phone Number: 800-446-7876 x1604 6 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INC. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 W W p f V n -na3 i7 C 0 rv 17•v - Gil "*J w 0 ?fl CF ? ?n SHERIFF'S RETURN - REGULAR CASE NO: 2002-01629 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL SERVICES INC VS YOUNG AMANDA I ET AL CPL. MICHAEL BARRICK , sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE VnTTNh AMANDA I was served upon the DEFENDANT , at 1813:00 HOURS, on the 11th day of April , 2002 at 315 PINEDALE ROAD CARLISLE, PA 17013 AMANDA I YOUNG by handing to 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 18.00 Service 4.83 Affidavit .00 Surcharge 10.00 .00 32.83 So Answers: R. Thomas Kline 04/12/20 GOLDBECK Sworn and Subscribed to before me this 1- 761 day of ()n oZ?ij 2J A. D. ,'Prothonotary By: SHERIFF'S RETURN - REGULAR `CASE NO: 2002-01629 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL SERVICES INC VS YOUNG AMANDA I ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE YOUNG WESLEY J the DEFENDANT , at 1813:00 HOURS, on the 11th day of April 2002 at 315 PINEDALE ROAD CARLISLE, PA 17013 AMANDA I YOUNG was served upon by handing to 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 .00 Affidavit .00 Surcharge 10.00 nn Sworn and Subscribed to before me this o ? day of P 7&0 A. D. fPi-othonotary I So Answers: R. Thomas Kline 04/12/2002 GOLDBECK MCCAFFERTY By: ty Sherif In the Court of Common Pleas of Cumberland County CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. AMANDA I. YOUNG WESLEY J. YOUNG (Mortgagor(s) and Record Owner(s)) 597 Walnut Bottom Road Shippensburg, PA 17257 Defendant(s) Plaintiff PRAECIPE FOR JUDGMENT No. 02-1629 civil term THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against AMANDA I. YOUNG and WESLEY J. YOUNG by default for want of an Answer. Assess damages as follows: Debt Interest - 07/16/2001 to 05/29/2001 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment ays prior to the date of the is to be entered and to his attorney of record, if any, after the default occurred andetfl>;ast t71 filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 ? ? Joseph AIdbeV4 Jr. Attorney RV Plaintiff I.D. #16132 AND NOW Judgment is entered in favor of CITIFINANCIAL SERVICES IN . nd against AMANDA I. YOUNG and WESLEY J. YOUNG by default for want of an Answer and damages assessed in the sum of $94,032.31 as per the above ce cation. ® Prothonotary r? ?-a : ; ?v -?: cr - ._ : ? _ fir. ?- ?Lt G'? ;?? i?''? ? f' GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. AMANDA I. YOUNG WESLEY J. YOUNG (Mortgagor(s) and Record owner(s)) 597 Walnut Bottom Road Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 02-1629 civil term Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of CITIFINANCIAL SERVICES INC., and against AMANDA I. YOUNG and WESLEY J. YOUNG for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of serving of the Complaint, in the sum of $94,032.31. J Jr. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 and that the name(s) and last known address(es) of the Defendant(s) is/are AMANDA I. YOUNG, 315 Pinedale Road Carlisle, PA 17013 and WESLEY J. YOUNG, 315 Pinedale Roa ar le, PAAZ013; GOLD K/McC?F RTY & McKEEVER BY: JoJe1h G ot e , Jr. AttornPlaintif ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $82,430.86 Interest from 07/16/2001 through $6,729.91 05/29/2001 Attorney's Fee at 5.0000% of principal $4,121.54 balance Late Charges $0.00 Costs of Suit and Title Search $750.00 Escrow Balance Deficit $0.00 ($0.00) GOLDBECK BY: Joseph A Attorney for I $94,032.31 AND NOW, this ? ( day of " , 2002 damages are assessed as above. O Pro Prothy c-, -- s7 C: , CIO C_i . VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, AMANDA I. YOUNG, is about unknown years of age, that Defendant's last known residence is 315 Pinedale Road, Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, WESLEY J. YOUNG, is about unknown years of age, that Defendant's last known residence is 315 Pinedale Road, Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendment*e--\ .. Date: 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 2, 2002 TO WESLEY J. YOUNG 315 Pinedale Road Carlisle, PA 17013 CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 vs. AMANDA I. YOUNG WESLEY J. YOUNG (Mortgagor(s) and Record Owner(s)) 597 Walnut Bottom Road Shippensburg, PA 17257 TO: WESLEY J. YOUNG 315 Pinedale Road Carlisle, PA 17013 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-1629 civil term IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARAN( PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES ( OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DA 7 FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOUI TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANN( AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU C? GET LEGAL HELP: ?t1 YPAND OUN7Y BAR ASSOCIATION . rs e, ?V,GAe,$ERVICES iNC ?i?j7A_$$DD&7013 <dtous& G C [cCAFFER CEEVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 1 l I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 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 2, 2002! TO: AMANDA I. YOUNG 315 Pinedale Road Carlisle, PA 17013 CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff vs. AMANDA I. YOUNG WESLEY J. YOUNG (Mortgagor(s) and Record Owner(s)) 597 Walnut Bottom Road Shippensburg, PA 17257 TO: AMANDA I. YOUNG 315 Pinedale Road Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-1629 civil term Defendant(s) IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARAN( PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES ( OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DX FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOUI TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANN( AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU C? GET LEGAL HELP: ??,E ,A?NaD73OUNTY BAR ASSOCIATION c„ i eY GAL ERVICES INC Ails 7013 44 GG0jJC C JcCAFFER FEVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 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 2, 2002'. TO: WESLEY J. YOUNG 597 Walnut Bottom Road Shippensburg, PA 17257 CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff vs. AMANDA L YOUNG WESLEY J. YOUNG (Mortgagor(s) and Record Owner(s)) 597 Walnut Bottom Road Shippensburg,PA 17257 Defendant(s) TO: WESLEY J. YOUNG 597 Walnut Bottom Road Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-1629 civil term IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANI PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES ( OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DX FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOUI TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANN( AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU C7 GET LEGAL HELP: 17 ?'?tyl_BERJ..A?ND OUNTY BAR ASSOCIATION pAv Car is e, ,GAL ERVICESINC rjRd3 b7ei3 ?cCAFFER CEEVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-132 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 2, 2002'' TO: AMANDA I. YOUNG 597 Walnut Bottom Road Shippensburg, PA 17257 CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff vs. AMANDA I. YOUNG WESLEY J. YOUNG (Mortgagor(s) and Record Owner(s)) 597 Walnut Bottom Road Shippensburg,PA 17257 Defendant(s) TO: AMANDA I. YOUNG 597 Walnut Bottom Road Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-1629 civil term IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARAN( PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES ( OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DA7 FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOUI TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANN( AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU C7 GET LEGAL HELP: ?K,BE AND ryRJ_ ??f3 COUNTY BAR ASSOCIATION se X, GAL ERVICES INC _ _%&7013 ?g? GO Gd ECIC ICCAFFER SEVER Bph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-132 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff vs. AMANDA I. YOUNG WESLEY J. YOUNG (Mortgagors and Record Owner(s)) 597 Walnut Bottom Road Shippensburg, PA 17257 Defendant(s) No. 02-1629 civil term 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. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: Deputy If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 w V ` n V? < ?\ 1 0 +' 1 _7 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 vs. AMANDA I. YOUNG WESLEY J. YOUNG Mortgagor(s) and Record Owner(s) 597 Walnut Bottom Road Shippensburg, PA 17257 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 02-1629 civil term PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 07/16/2001 to 05/29/2001 at 9.4000% (Costs to be added) $94,032.31 & McKEEVER BY: Joseph Attorney for /a U 11 ?o \w E?-'?O d N? z 0 zo z W F., F U z 0 p V C) l? o0 - I - P. _ .b dw c? a w u Y ti b ~ O ? a M L' ? C7 a. c1 =y N : ?p R Q T u N . u tA ? o a ? N a ? `ji ° d C7 1 C e? ? t WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 AND Rule 3257 CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. AMANDA L YOUNG WESLEY J. YOUNG 597 Walnut Bottom Road Shippensburg, PA 17257 In the Court of Common Pleas of Cumberland County No. 02-1629 civil term WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of Cumberland To the Sheriff of Cumberland County,-Pennsylvania To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: PREMISES: 597 Walnut Bottom Road Shippensburg, PA 17257 See Exhibit "A" attached AMOUNT DUE Interest From 07/16/2001 Through 05/29/2001 (Costs to be added) Dated: Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania Deputy r N r fn ^ V z 0. N a .o ? c z? F o ? '?' W '? '. ff3 b9 69 69 69 14 } " i F ? w0 .a ¢ ? .a > W o o W G o ¢ L w o a = O z ¢ ° ¢3 °r r z 7 ° ¢ 31 a w m x a Fes- F U c },w?F? z ? e H?F?? 3 o O w¢ a 7 Q W Ln ? Q 0 ? a: `? F w F ¢ F fn V1 U OA azo o V 7 x 0° w a X N C7 w w c cq d U a? = G y 0 ALL that certain tract of land with the Improvements thereon situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows; BEGINNING al a railroad spike in the intersection of Pennsylvania Route 174 and Legislative Route 21006; thence along Pennsylvania Route 174, South 79 -> degrees 23 minutes 42 seconds West, a distance o(208.55 feet to a point thence North 11 degrees 40 minutes 56 seconds West, a distance of 150.00 feel to a point; thence North 79 degrees 23 minutes 42 seconds East, a distance of 208.55 feel to a point in the centedine of said Legislative Route 21006; thence along the latter, South 11 degrees 40 minutes 56 seconds East, a distance of 150,00 feet to the center of the Intersection, the Place of BEGINNING. CONTAINING 0.718 acres, more or less, according to a survey of Arrowood. Incorporated, made July 20, 1972, The above description Includes a 14 foot driveway (See Cumberland County Deed Book'B', Volume 14, Page 284). BEING Improved with a dwelling known and numbered as 597 Walnut Bottom Road. Shippensburg, Pennsylvania 17257. TAX PARCEL #39-12-0324-0088 S (/7A nip ".Y ? ?` , ` V_ V r77 t v •< . ? 6 _ ? ^ ` r V ci2 MV W Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 vs. AMANDA I. YOUNG WESLEY J. YOUNG CIVIL ACTION - LAW (Mortgagor(s) and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE 597 Walnut Bottom Road Shippensburg, PA 17257 Defendant(s) No. 02-1629 civil term AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL SERVICES 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: 597 Walnut Bottom Road Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): AMANDA I. YOUNG 315 Pinedale Road Carlisle, PA 17013 WESLEY J. YOUNG 315 Pinedale Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: AMANDA I. YOUNG 315 Pinedale Road Carlisle, PA 17013 WESLEY J. YOUNG 315 Pinedale Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS I of Cumberland County Plaintiff PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: DONALD L. STINE 355 Strohm Road Shippensburg, PA 17267 FLORENCE STINE 355 Strohm Road Shippensburg, PA 17267 CITIFINANCIAL INC. 1752 Lincoln Way East, Ste. 7 Chambersburg, PA 17201 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. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. /l DATED: May 29, 2002 GOLDBECK Me BY: Joseph A. Go dbIRTi Jr., Attorney for Plaintiff "3'-' ? mr , 77 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS. AMANDA I. YOUNG WESLEY J. YOUNG Mortgagor(s) and Record Owner(s) 597 Walnut Bottom Road Shippensburg, PA 17257 Defendant(s) Term No. 02-1629 civil term 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: YOUNG, AMANDA I. AMANDA I. YOUNG 315 Pinedale Road Carlisle, PA 17013 Your house at 597 Walnut Bottom Road, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 04, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $94,032.31 obtained by CITIFINANCIAL SERVICES 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 CITIFINANCIAL SERVICES 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 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 .- y 10 G G) GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS. AMANDA I. YOUNG WESLEY J. YOUNG Mortgagor(s) and Record Owner(s) 597 Walnut Bottom Road Shippensburg,PA 17257 Defendant(s) Term No. 02-1629 civil term 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: YOUNG, WESLEY J. WESLEY J. YOUNG 315 Pinedale Road Carlisle, PA 17013 Your house at 597 Walnut Bottom Road, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 04, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $94,032.31 obtained by CITIFINANCIAL SERVICES 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 CITIFINANCIAL SERVICES 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 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 Jospeh A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 vs. AMANDA I. YOUNG WESLEY J. YOUNG Mortgagor(s) and Record Owner(s) 597 Walnut Bottom Road Shippensburg,PA 17257 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) NO. 02-1629 civil term CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. ?? t Rm ?=? v ai COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Citifinancial Services Inc is the grantee the same having been sold to said grantee on the 4th day of Sept A.D., 2002, under and by virtue of a writ Execution issued on the 31 st day of May, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Tenn, 2002 Number 1629, at the suit of Citifinancial Services Inc against Amanda I Young & Wesley J is duly recorded in Sheriff's Deed Book No. 254, Page 432. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this / ~/ day of ?' 'aoMOe I, A.D. 2002 Citifinancial Services, Inc. In the Court of Common Pleas Vs of Cumberland County, Pennsylvania Amanda I. Young and Writ No. 2002-1629 Civil Term Wesley J. Young Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2002 at 8:14 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: Amanda I. Young, by making known unto Wesley J. Young, adult in charge, at 315 Pinedale Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2002 at 8:14 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: Wesley J. Young, by making known unto Wesley J. Young, personally, at 315 Pinedale Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on July 10, 2002 at 11:18 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Amanda I. Young and Wesley J. Young, at 597 Walnut Bottom Road, Shippensburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Amanda 1. Young, by regular mail to her last known address of 315 Pinedale Road, Carlisle, PA 17013. This letter was mailed under the date of July 16, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Wesley J. Young, by regular mail to his last known address of 315 Pinedale Road, Carlisle, PA 17013. This letter was mailed under the date of July 16, 2002 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 Court House, Carlisle, Cumberland County, Pennsylvania, on September 4, 2002 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for Citifinancial Services Inc. It being the highest bid and best price received for the same, Citifinancial Services Inc. of 7476 New Ridge Road, Suite 222, Hanover, MD 21076, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of $758.30, it being costs. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $ 30.00 14.87 15.00 15.00 30.00 10.00 .50 1.00 17.94 6.99 15.00 30.00 279.35 212.95 25.20 25.00 29.50 $ 758.30 paid by atty. 10/02/02 Sworn and subscribed to before me S This dJ Mayof Ocr? R. Thomas Kline, Sheriff 2002, A.D. BYJ641 r r thonotary Real Estat Deputy s) CIIIJ411 p ? 30 '/ q .48Yti'1 i2t,,. /368 Y3 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1629 Civil CIVIL ACTION- LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL SERVICES, INC. PLANTIFF(S) From AMANDA I. YOUNG, 315 PINEDALE RD., CARLISLE PA 17013 and WESLEY J. YOUNG, 597 WALNUT BOTTOM RD., SHIPPENSBURG PA 17257. (1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE LOCATED AT 597 WALNUT BOTTOM ROAD, SHIPPENSBURG PA 17257 (SEE ATTACHED 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/are 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 $94,032.31 Interest 7/16/01 - 5/29/02 @ 9.4000% Arty's Comm % Arty Paid $120.83 Plaintiff Paid L.L. $.50 Due Prothy $1.00 Other Costs Date: MAY 31, 2002 REQUESTING PARTY: Name JOSEPEH A. GOLDBECK, JR., ESQUIRE Address: STE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court ID No. 16132 CURTIS R. LONG Prothonotary, Civil Division By: ??V Real Estate Sale # 39 On June 7, 2002 the sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA known and numbered as 597 Walnut Bottom Road, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 7, 2002 By: Jo d I Svc Real state Deputy d L 1I i NflF 0 Cv 0 Vim, Ait A.4I _ a 0 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 11 I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 vs. AMANDA I. YOUNG WESLEY J. YOUNG Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW (Mortgagor(s) and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE 597 Walnut Bottom Road Shippensburg, PA 17257 Defendant(s) No. 02-1629 civil term AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL SERVICES 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: 597 Walnut Bottom Road Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): AMANDA I. YOUNG 315 Pinedale Road Carlisle, PA 17013 WESLEY J. YOUNG 315 Pinedale Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: AMANDA I. YOUNG 315 Pinedale Road Carlisle, PA 17013 WESLEY J. YOUNG 315 Pinedale Road Carlisle, PA 17013 3. Name and last known address of everyjudgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: DONALD L. STINE 355 Strohm Road Shippensburg,PA 17267 FLORENCE STINE 355 Strohm Road Shippensburg,PA 17267 CITIFINANCIAL INC. 1752 Lincoln Way East, Ste. 7 Chambersburg, PA 17201 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. (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 enalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 29 2002 BY: Joseph A. GoYdb#, Jr., Attorney for Plaintiff 06/06/2002 THU 19:11 FAX COLDBECK McCAFFERTY & MCICEEVER BY: Joseph A. Goldbeck, Jr. Anomcy T.D.11101.32 SuiTe 500 - The Bourse Bldg.' 111 5. Independence Mall ]Jost Philadelphia. PA 19106 215-(.i27-1.122 Arrorney for Plaotriff CITIFINANCIAL SERVICES INC. 7467 Ncw Ridge Road Sufte 222 Hanover, MD 21076 Plaintiff vs. AMANDA 1. YOUNU WESLEY J. YOUNG Mortgagor(s) and Record Owner(s) 597 Walnut linuuro Road Shippensburk. PA 17257 Dofcndant(s) Tani No. 02-1629 civil Term 'I'll IS LAW FIRM 1S A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE TS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY TNFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OT.SIIERIFF'S SALE OF REAL PROPERTY TO: YUUNU. WL1'LLY J. WESLEY J. YOUNG 315 Pinedale Road Cm9is1c, PA 17013 Your house at 597 walnut Bottom Road, Shippeasburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 04, 2002, al 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the courtjudgineur of $94,032.37 obtained by CIIIFINANCIAL SERVICES INC. against ymn. NO;(.ICE OF OWNER'S RTC.HTS YOU MAY BE ABLE TO PREVENT THIS SITERIFF'S SALE '1'0 prevent this Sheriff s Salc ymi most rake immediate action: 1. The sale will be cancelled if you pay to CTTTFTNANCIAL SERVICES INC., the back payments, late charges, costs and reasonable allomcy's fees due. To find out how much you must pay cull: 215-627-1322 IN THE COURT OF COMMON PLEAS of Cumberland Comity CTVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE U004/019 2. You may be able ro stop the sale by filing a petition asking the Court to strike or open jud6.ment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 06/08/2002 THU 19:11 FAX 0 005/019 3. You may also be able to slop the sale through other legal proceedings. You may need an attorney to assert your rights. '!he sooner you contact one, the snore chance you will have of smpping the sale. (See notice below on how to obtain an attorney). YOU r4AY STILL 1. If the Sheriffs Sale is not ampped, your prnperty will be sold To The highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6370. 2. You may be able ht petition the Court to set aside the sale if the bid price was grossly inadequulc c01111,12rcrl to the value of your property, '11c sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find nor if rhis has happened, you may call die Sheriff of 717.240_6390. 4. If the amount due from the Buyer is not paid to the Shcriff, you will remain the owner of the property as if the sale never happened. 5. You have a right To reinain in the property until the full amount due is paid To the Shcriff and the Sheriff gives a decd 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 mancy which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sherilrs Sulu.'Mis schedule will state who will be receiving that money. The money will be paid our is accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days alter thc 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 alter the salr. YOU SIiOULD TAKE TIIIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT IMVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIC OFFICE LISTED BELOW TO FIND 011T WHERE YOU CAN GET LEGAL HELP. CUMBFRLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 h-vine Row Carlisle, PA 17013 06/06/2002 THU 10:11 FAX GOLDBECKMcCAFFERTY & McKEEVER BY: Joseph A. GnldbwL-, Tr. Attorney 1.D416132 Suite 500 - The Bourse Bldg. 111 S.1uJependcnceMail E115L Philadelphia. PA 19106 215-627-1322 Attorney for Phuttiff R002/019 CITTFTNANCTAT. SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plainti Il' vs, AMANDA 1.YOUNO WESLEY I. YOUNG Martgagor(s) and Record Owner(s) 597 Walnut Bottom Road Shippensburg.i'A 17257 Defendant(s) Term No. 02-1629 civil teen THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE. ATTEMPTING TU ('01 A.EC1• 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: Y(n1N(i, AMANDA I. AMANDA I. YOUNG 315 Pinedale Road Carlisle, PA 17013 Your house at 597 Walnut Bottom Road, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 04, 2002, at 10:00 AM. in Commissioners Hearing Rm 2nd FL Counhouse 1v cnfurce the cowl judgment of $94,032.31 obtained by CT URNANCIAL SERVICES INC. against you. NOTICE OF OWNER'S RIGHTS Y011 MAY BF ABLE T'O PREVENT THIS SHERIFF'S SALE To pre.veot This Sheriffs Sale you must take immediate. action: 1. The sale will be cancelled if you pay to C111FINANCIAL SERvTCES INC., the back payments, late clm(•gcs, ousts and rcasonahle attorney's fees due. To find out how much you must pay call: 215-627-1322 IN TAE, COURT Of COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 2. You may be able to slop the sale by filing, a petition asking the Court to strike or open judgment, if dte judgment wus improperly entered. You may also ask the Court to postpone the sale for good cause. 06/06/2002 THU 19:11 F&X .. You may also be able to stop the sale through other legal proceedings You way need an attorney to asscri your rights. The sooner you contact one, du more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY SPILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN iF THE SHERIFF'S SALF, DOES NOT TAKE PLACE. 1. II'thc Shcrill's Sale is not stopped, your property will be sold To the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You nray 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. '111c sale will go through only if the buyer pays the Sheriff the full amount due in thc sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due front the Buyer is not paid to the Sheriff, you will remain the owner of the property ns 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 decd to the buyer. At that time, the buyer may bring legal proceedings To evict you. G. You imy be enTiTled to a share of the nwnry which was paid for your house. A schedule of distribution of The money bid for your house will be filed by the Sheriff thirty (30) days from the date of the ShcrifPa Sale. This scbeduls will state who will be receiving that m cy. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong)'are filed with the Shcrilf within ten (10) days after the schedule of distribution is filed. 7. )'on may also have other rights and defenses, or ways of getting your house back, if you act inwtcdiately tiller the sale. YOU SHOULLt TAKE THIS PAPER TO YOUR LAWYER AT ONCE- IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO -1-0 OR TELEPHONE THE OFFICE LISTED DELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUNWRLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue ' Carlisle, PA 17013 Z003/019 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 ALL that certain tract of land with the Improvements thereon situate in Southampton Township, Cumbedand County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike In the Intersection of Pennsylvania Route 174 and Legislative Route 21006; thence along Pennsylvania Route 174, South 79 -- degrees 23 minutes 42 seconds West, a distance of 206.55 feel to a point; thence North 1I degrees 40 minutes 56 seconds West, a distance of 150.00 feet to a point; [hence North 79 degrees 23 minutes 42 seconds East, a distance of 208.55 feel to a Point in the centerline of said Legislative Route 21006; thence along the taller, South 11 degrees 40 minutes 56 seconds East, a distance of 150.00 feet 10 the center of the Intersection, the Place of BEGINNING. CONTAINING 0.718 acres, more or less, according to a survey of ArroWOed. Incorporated, made July 20, 1972. The above description Includes a 14 fool driveway (See Cumberland County Deed Book 'B'. Volume 14, Page 284). BEING improved with a dwelling known and numbered as 597 Walnut Bottom Road, Shippensburg, Pennsylvania 17257. TAX PARCEL #39-12-0324-0086 ALL that certain tract of land With the improvements thereon situate in Southampton Township, Cumbedand County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike In the Intersection of Pennsylvania Route 174 and Legislative Route 21006; thence along Pennsylvania Route 174, South 79 degrees 23 minulas 42 seconds West, a distance of 208,55 feet to a point; thence North 1 t degrees 40 minutes 56 seconds West, a distance of 150.00 feet to a point; [hence North 79 degrees 23 minutes 42 seconds East, a distance of 208.55 feel to a point in the centerline of said Legislative Route 21006; thence along the taller, South 1 I degrees 40 minutes 56 seconds East, a distance of 150.00 feet 10 the center of the Intersection, the Place of BEGINNING. CONTAINING 0.718 acres, more or less, according to a survey of Arrowood, Incorporated, made July 20, 1972. The above description Includes a 14 foot driveway (See Cumberland County Deed Book "B", Volume 14, Page 284). BEING Improved with a dwelling known and numbered as 597 Walnut Bottom Road, Shlppensburg, Pennsylvania 17257. TAX PARCEL #39-12-0324-0086 t N_ 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 Frank J. Epler being duly sworn according to law, deposes and says: That he is the 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 on the 23rd and 30th day(s) of July and the 6th day(s) of August 2002. 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. PU BLICATION ,... COPY S A L E #39 L Sw rn to and su4s6tdbo9eblefore met Terry L. Russell, Notary Public 1 th day of gust A. D. REAL ESTATE SALE No. 39 Writ No. 2('02-1629 City Of Harrisburg, Dauphin Co My Commission Expires June CIvi4Term Member Pennsylvania Association Of Notaries NOTA Y PUBLIC Citifinanclal Services, Inc. vs My commission expires June 6 2006 Amanda I. Young and , Wesley J. Young CUMBERLAND COUNTY SHERIFFS OFFICE DESCRIPT ON Joseph A. Goldbeck, Jr. CUMBERLAND COUNTY COURTHOUSE ALL that certain tract of land with the CARLISLE, PA. 17013 improvements thereon situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING il Statement of Advertising Cysts at a ra road spike in the intersection of Pennsylvania Route 174 and Legislative Route To THE PATRIOT-NEWS CO. Dr 21006; thence along Pennsylvania Route 174, South 79 degrees 23 minutes 42 seconds West, a , . For publishing the notice or ublication attached p distance of 208.55 feet to a point;, thence North II hereto on the above stated dates $ 21 1 20 degrees 40 minutes 56 seconds West, a distance of 150.00 feet to a point; thence North 79 degrees 23 . Probating same Notar Fee(s) Y $ 1 , 75 minutes 42 seconds east, a distance of 208.55 feet Total $ 212 95 to a point in the centerline of said Legislative . Route 21006; thence along the latter, South II degrees 40 minutes 56 seconds East, a distance of Publisher's Receipt for Advertising Cost The Patriot News Co ., publisher of The Patriot-News and The Sunday Patriot-News , newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that th been duly paid. e same have 150.00 feet to the center of the intersection die , Place of BEGINNING. CONTAINING 0.718 acres, more or less, according to a survey of Arrowood,Incorporated , made July 20, 1972. The above description By"""' includes a 14 foot driveway (See Cumberland County Deed Book "B", Volume 14, Page 284). BEING improved with a dwelling known and numbered as 597 Walnut Bottom Road, Shippensburg, Pennsylvania 17257. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 597 Walnut Bottom Road . Shippensburg, PA 17257. SOLD as the property of Amanda 1. Young and Wesley J. Young. TAX PARCEL #39-12-0324-008B. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, 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 26, AUGUST 2, 9, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE No. 39 Writ No. 2002-1629 Civil Citifmancial Services Inc. vs . Amanda 1. Young and Roger M. Morgenthal, Editor Wesley J. Young Atty.: Joseph A. Goldbeck. Jr. ALL th SWORN TO AND SUBSCRIBED befo thi at certain tract of land with re me s the improvements thereon situate 9 day of AUGUST. 2002 in Southampton Township, Cumber- land County, Pennsylvania, bound- ed and described as follows: BEGINNING at a railroad spike in the intersection of Pennsylvania Route 174 and Legislative Route NOT 21006; thence along Pennsylvania Route 174 S th b LOBS E. SNYDER, Nobly N* Y , ou 79 degrees 2,3 min- utes 42 seconds West, a distance of 208 of 5 Cale A C?.?. County COFiiS1 Ulai E*ift M" 55. 2W m7 . 5 feet to a point; thence North 11 degrees 40 minutes 56 seconds West, a distance of 150.00 feet to a point; thence North 79 de- grees 23 minutes 42 seconds East, a distance of 208.55 feet to a point in the centerline of said Legislative Route 21006; thence along the lat- --- - ter, South 11 degrees 40 minutes 56 seconds East, a distance of 150- .00 feet to the center of the inter- section, the Place of BEGINNING. CONTAINING 0.718 acres, more or less, according to a survey of Arrowood, Incorporated, made July 20. 1972. The above description includes a 14 foot driveway (Sce Cumberland County Deed Book "B", Volume 14, Page 284). BEING improved with a dwelling known and numbered as 597 Wal- nut Bottom Road, Shippensburg, Pennsylvania 17257. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 597 Walnut Bottom Road. Shippensburg, PA 17257. SOLD as the property of AMAN- DA I. YOUNG and WESLEY J. YOUNG. TAX PARCEL #39-12-0324-008B.