HomeMy WebLinkAbout02-1837COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is TRAVELERS BANK & TRUST FSB C/O 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 CLARA E. KELLY, 70 Fairway Drive, Camp
Hill, PA 17011 and ARTHUR G. KELLY, 70 Fairway Drive, Camp Hill, PA 17011, who is/are the
mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described.
On March 01, 2000 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to TRAVELERS BANK & TRUST FSB, which mortgage is recorded in the Office
of the Recorder of Deeds of Cumberland County as Book 1598 and Page 767. 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
October 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 09/01/2001
through 04/30/2002 at 9.9500%
Per Diem interest rate at $38.65
Attorney's Fee at 5.0% of Principal Balance
Late Charges from 10/01/2001 to 04/30/2002
Monthly late charge amount at $62.63
Costs of suit and Title Search
Escrow
$141,854.94
$8,193.80
$7,092.75
$438.41
$750.00
$158,329.90
$0.00
$158,329.90
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 date of the postmark on the Notice was the same as the date of the
Notice. The Defendant(s) had the required face to face meeting within the required time and Plaintiff
has been advised that the Defendant(s) filed an application for mortgage assistance with the
Pennsylvania Housing Finance Agency, the Plaintiff has been advised by the Pennsylvania Housing
Finance Agency that the Defendant(s)' application has been rejected.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $158,329.90, together with
interest at the rate of $38.65, 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:-? "- a Ae&d " ' ?-
GOLDBECK McCAFFERTY & McII ERVER
BY: JOSEPH A. GOLDBECK, 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 unworn falsification to
authorities.
Date: V-10 --V L
.16 7177741380 ASAP
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herein desiprwted an the Grantew
rrra-otco-wAAawrT' Aoas ST-1 CawelanTWe abrAU,stATIU"SUMLrcese,
wo OR CORP.
?:b t? 3ppP? t meek at 29th day gr October 19 87 ;
lktmtem HOWARD C. GALE DEVELOPMENT CO. INC., a corporation created
under the laws of the Commonwealth of Pennsylvania of Camp Hill,
Cumberland County, Pennsylvania,
herein deatpnated at the Grentam
Anh ARTHUR G. KELLY.and CLARA E. KELLY, his wife,
9hinturt4, the! the Grualem for and in contiderud" of ONE HUNDRED TEN .THOUSAND---
----------------------(8110,000.00) DOLLARS ---------------------------
&wN money of the Vatted Stain gfdnarrica to tie Gruntore to hand wed and truly paid by the Gruntatt,
at or bcObm the ¦eaffag and de8vary gr there.presestr, the receipt whereat is hereby adlnowWgrd and the
Creature being therYndth JW4 t 04faad, do by'thaaa praaenta 9=4 bargain, te0 and cumay meta Me
Gruateeeforever;
Ali THAT CERTAIN trud or pare! of land and pmmiaea, situate, lying and Wag is the
Township of Hampden in the Coasty of
Cumberland and C ommonvad iA gf Peanaylawaio, more particularly detraibsd ar Jblia i
BEGINNING at a point on the northern line'of Fairway Drive which
point is at the dividing line between Lots Nos. 393 and 394 on
Plan of Lots hereinafter ment;ionedt ,
THENCE North 13.56' pest and along the dividing line between Lots,
Not. 393 and 394 on Plan of Lots hereinafter mentioned, a ,
distance of 103.32 feet to a point at the rear lot line of Lot
No. 128 on Plan of Lois known as Section 'Be Chestnut Billst
THENCE South 75'17'14' West and along the rear lot line of Lot No.
126 aforesaid, a distanee.of 85.01 feet to a point at the
dividing line between Lots Nos. 394 and 395 on Plan of Lots
hereinafter mentioned;
THENCE South 13.56' East and along the dividing line between'Lots
Nos. 394 and 395 on Plan of Lots hereinafter mentioned, a
distance of 102.16 feet to a point on the northern line of
Fairway Drive;
THENCE North 76.04' East and along the northern line of Fairway
Drive, a distance of 85 feet to a point, the point and place of
BEGINNING.
T, BEING Lot No. 394 on Plan of Lots known an Part of Country Club
Park which Plan is recorded in the office of the Recorder of
,
BA33 rs?? 351
PAGE 03
EXHIBIT A
ACT 91 NOTICE
s
DATE OF NOTICE: January 8, 2002
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default and the
ier intends to foreclose. Specific information about the nature of the default is provided in
attached naees.
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 Ilamanda 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
i
Date: January 8, 2002
Homeowners Name: CLARA E. KELLY and ARTHUR G. KELLY
Property Address: 70 Fairway Drive, Camp Hill, PA 17011
Loan Account No.: 5308006622878
Original Lender:
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: 70 Fairway Drive, Camp Hill, PA 17011 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 10/01/2001 thru 1/8/2002
(4 mos. at $1,252.56/month) $5,010.24
Partial payment from 9/01 $550.07
(b) Late charges from 10/01/2001 thru 1/8/2002
(4 mos. at $62.63/month) $250.52
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $5,810.83
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 $5,810.83, 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 beings 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 attorneys fees and costs connected with the foreclosure sale and any other costs connected
with the Sheriffs Sale as specified in writing by the lender and by 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
Sheriffs 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.)
* 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
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SHERIFF'S RETURN - REGULAR
CASE NO3 2002-01837 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
TRAVELERS BANK & TRUST FSB
VS
KELLY CLARA E ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
KELLY CLARA E the
DEFENDANT at 1413:00 HOURS, on the 26th day of April 2002
at 70 FAIRWAY DRIVE
CAMP HILL, PA 17011 by handing to
ARTHUR G KELLY, HUSBAND
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 10.35
Affidavit .00
Surcharge 10.00
.00
38.35
Sworn and Subscribed to before
me this /g F day of
dCra ?- A. D.
Prothonotary
So Answers:
R. Thomas Kline
04/29/2002
GOLDBECK MCCAFFERTY MCKEEVER
By: Deputy Sheri f
SHERIFF'S RETURN - REGULAR
CASE Na: 2002-01837 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
VELERS BANK & TRUST FSB
VS
KELLY CLARA E ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
KELLY ARTHUR G the
DEFENDANT
, at 1413:00 HOURS, on the 26th day of April , 2002
at 70 FAIRWAY DRIVE
CAMP HILL, PA 17011 by handing to
ARTHUR G KELLY
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this ),tk day of
?19a A.D.
. _
rothonotary
So Answers;
R. Thomas Kline
04/29/2002
GOLDBECK MCCAFFERTY MCKEEVER
By:
Deputy Sheriff
In the Court of Common Pleas of Cumberland County
TRAVELERS BANK & TRUST FSB C/O CITIFINANCIAL
SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
vs.
CLARA E. KELLY
ARTHUR G. KELLY
(Mortgagor(s) and Record Owner(s))
70 Fairway Drive
Camp Hill, PA 17011
Plaintiff
Defendant(s)
No. 02-1837 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 CLARA E. KELLY and ARTHUR G. KELLY by default for
want of an Answer.
Assess damages as follows:
Debt $159,513.38
Interest - 09/01/2001 to 05/29/2002
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 delive to the party against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred aat 1 ast to ays prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
Joseph XIdbea{(, Jr.
Attorney Plain
I.D. #161
AND NOW ??? ?O 4) Judgment is entered in favor of
TRAVELERS BANK & TRUST B C/O CITIFINANCIAL SERVICES INC. and against CLARA E. KELLY and
ARTHUR G. KELLY by default for want of an Answer and damages assessed in the sum of $159,513.38 as per the above
certification.
Prothonotary
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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
IRA V ELERS BANK & TRUST FSB C/O
CITIFINANCIAL SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
VS.
CLARA E. KELLY
ARTHUR G. KELLY
(Mortgagor(s) and Record owner(s))
70 Fairway Drive
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 02-1837 CIVIL TERM
ORDER FOR JUDGMENT
Please enter Judgment in favor of TRAVELERS BANK & TRUST FSB C/O CITIFINANCIAL
SERVICES INC., and against CLARA E. KELLY and ARTHUR G. KELLY for failure to file an Answer in the
above action within (20) days (or sixty (60) days if defendant is 7T ited States of America) from the date of
service of the Complaint, in the sum of $159,513.38.
Joseph 4. fjoldbeWJr.
I hereby certify that the above names are correct and that the precise residence address of the judgment
creditor is TRAVELERS BANK & TRUST FSB C/O 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
CLARA E. KELLY, 70 Fairway Drive Camp Hill, PA 17011 and/ RTHUR G. KELLY, 70 Fairway Drive Camp
Hill, PA 17011; / %
UULll 1V1lc¢ ERTY & McKEEVER
BY: Jo ep A. T1 beck, Jr.
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $141,854.94
Interest from 09/01/2001 through $9,314.65
05/29/2002
Attorney's Fee at 5.0000% of principal $7,092.75
balance
Late Charges $501.04
Costs of Suit and Title Search $750.00
Escrow Balance Deficit $0.00
($0.00)
$159,513.38
liuLllti VK c C FTY & McKEEVER
BY: Jose Gol ec Jr.
Attorney lain f
AND NOW, this t day of Aaq '2002 damages are assessed as above.
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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, CLARA E. KELLY, is
about unknown years of age, that Defendant's last known residence
is 70 Fairway Drive, Camp Hill , PA 17011, 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. n
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, ARTHUR G. KELLY, is
about unknown years of age, that Defendant's last known residence
is 70 Fairway Drive, Camp Hill , PA 17011, 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:
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 17, 2002
TO:
ARTHUR G. KELLY
70 Fairway Drive
Camp Hill, PA 17011
TRAVELERS BANK & TRUST FSB C/O CITIFINANCIAL
SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
vs.
CLARA E. KELLY
ARTHUR G. KELLY
(Mortgagor(s) and
Record Owner(s))
70 Fairway Drive
Camp Hill, PA 17011
Plaintiff
Defendant(s)
TO: ARTHUR G. KELLY
70 Fairway Drive
Camp Hill, PA 17011
IMPORTANT NOTICE
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 02-1837 CIVIL TERM
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD
TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN
GET LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
Lilxny Avenue
Carlisle. PA 17013
LEGAL SERVICES MC
K Irvine Raw
Cadisle, PA 17013
717-243-9400
GRO
IcCAFF
ER CEEVER
B . 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 179 2002
TO:
CLARA E. KELLY
70 Fairway Drive
Camp Hill, PA 17011
TRAVELERS BANK & TRUST FSB C/O CITIFINANCIAL
SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
vs.
CLARA E. KELLY
ARTHUR G. KELLY
(Mortgagor(s) and
Record Owner(s))
70 Fairway Drive
Camp Hill, PA 17011
TO: CLARA E. KELLY
70 Fairway Drive
Camp Hill , PA 17011
Plaintiff
Defendant(s)
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 02-1837 CIVIL TERM
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD
TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN
GET LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
? Liberty Avenue
Carlisle. PA 17013
LEGAL SERVICES INC
R Irvine Row
Carlisle. PA 17013
717-243-9400
GO C IcCAFFER CEEVER
1 aeph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
1 I 1 S. Independence Mail East
Philadelphia, PA 19106 215-627-1322
Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
TRAVELERS BANK & TRUST FSB C/O CITIFINANCIAL SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
Plaintiff
vs.
CLARA E. KELLY
ARTHUR G. KELLY
(Mortgagors and Record Owner(s))
70 Fairway Drive
Camp Hill, PA 17011
Defendant(s)
No. 02-1837 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
Prothon tary
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
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
TRAVELERS BANK & TRUST FSB C/O
CITIFINANCIAL SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
Plaintiff
VS.
CLARA E. KELLY
ARTHUR G. KELLY
Mortgagor(s) and Record Owner(s)
70 Fairway Drive
Camp Hill, PA 17011
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 02-1837 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
09/01/2001 to
05/29/2002 at
9.9500%
(Costs to be added)
$159,513.38
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WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183 AND Rule 3257
TRAVELERS BANK & TRUST FSB C/O
CITIFINANCIAL SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
vs.
CLARA E. KELLY
ARTHUR G. KELLY
70 Fairway Drive
Camp Hill, PA 17011
Commonwealth of Pennsylvania:
County of Cumberland
WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
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: 70 Fairway Drive Camp Hill, PA 17011
See Exhibit "A" attached
AMOUNT DUE
Interest From 09/01/2001
Through 05/29/2002
(Costs to be added)
Dated: Prothonotary, Common Pleas Court
of Cumberland County, Pennsylvania
In the Court of Common Pleas of
Cumberland County
No. 02-1837 CIVIL TERM
$159,513.38
Deputy
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All THAT CERTAIN frad or parcel of land and premises, situate, lying and being in the
Township of Hampden in the County of
Cumberland and Commonwealth of ,Pennsytvadia, more particularly described as jWkm*.
BEGINNING at a point on the northern line'of Fairway Drive which
point is-at the dividing line between Lots Nos. 393 and 394 on
Plan of Lots hereinafter mentioned;
THENCE North 13156' West and along the dividing line between Lots*
Nos. 393 and 394 on Plan of Lots hereinafter mentioned, a
distance of 103.32 feet to a point at the rear lot line of Lot
NO. 128 on Plan of Lots known as Section "B" Chestnut Hillsl
THENCE South 75'17114' West and along the rear lot line of Lot No.
126 aforesaid, a distance.of 85.01 feet to a point at the
dividing line between Lots Nos. 394 and 395 on Plan of Lots
hereinafter mentioned;
THENCE South 13'56' East and along the dividing line between'Lote
Nos. 394 and 395 on Plan of Lots hereinafter mentioned, a
distance of 102.16 feet to a point on the northern line of
Fairway Drive;
THENCE North 76'04' East and along the northern line of Fairway
Drive, a distance of 85 feet to a point, the point and place of
BEGINNING.
BEING Lot No. 394 on Plan of Lots known as Part of Country Club
Park which Plan is recorded in the office of the Recorder of
Deeds in and for Cumberland County in Plan Book 37, Paige 80.
HAVING THEREON ERECTED a dwelling known as and numbered 70
Fairway Drive, Camp Hill, Pennsylvania.
UNDER AND SUBJECT the following restrictions which shall be
construed as covenants running with the lands The property
herein described shall not be used at any time for a beauty
parlor or barber shop. No trailers or mobile homes are to be
permitted on the premises at any time.
rA)( PARCE
L #10-19-1596-167
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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
TRAVELERS BANK & TRUST FSB C/O
CITIFINANCIAL SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
Plaintiff
VS.
CLARA E. KELLY
ARTHUR G. KELLY
Mortgagor(s) and Record Owner(s)
70 Fairway Drive
Camp Hill, PA 17011
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 02-1837 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: KELLY, CLARA E.
CLARA E. KELLY
70 Fairway Drive
Camp Hill, PA 17011
Your house at 70 Fairway Drive, Camp Hill, PA 17011 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 $159,513.38 obtained by TRAVELERS BANK & TRUST FSB C/O
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 TRAVELERS BANK & TRUST FSB C/O
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
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
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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
TRAVELERS BANK & TRUST FSB C/O
CITIFINANCIAL SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
Plaintiff
VS.
CLARA E. KELLY
ARTHUR G. KELLY
Mortgagor(s) and Record Owner(s)
70 Fairway Drive
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 02-1837 CIVIL TERM
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: KELLY, ARTHUR G.
ARTHUR G. KELLY
70 Fairway Drive
Camp Hill, PA 17011
Your house at 70 Fairway Drive, Camp Hill, PA 17011 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 $159,513.38 obtained by TRAVELERS BANK & TRUST FSB C/O
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 TRAVELERS BANK & TRUST FSB C/O
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
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
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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
TRAVELERS BANK & TRUST FSB C/O
CITIFINANCIAL SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
Plaintiff
vs.
CLARA E. KELLY
ARTHUR G. KELLY
Mortgagor(s) and Record Owner(s)
70 Fairway Drive
Camp Hill, PA 17011
Defendant(s)
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
NO. 02-1837 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.
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'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
TRAVELERS BANK & TRUST FSB C/O
CITIFINANCIAL SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
Plaintiff
vs.
CLARA E. KELLY
ARTHUR G. KELLY
(Mortgagor(s) and Record Owner(s))
70 Fairway Drive
Camp Hill, PA 17011
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 02-1837 CIVIL TERM
TRAVELERS BANK & TRUST FSB C/O 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:
70 Fairway Drive
Camp Hill, PA 17011
1.Name and address of Owner(s) or Reputed Owner(s):
CLARA E. KELLY
70 Fairway Drive
Camp Hill, PA 17011
ARTHUR G. KELLY
70 Fairway Drive
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
CLARA E. KELLY
70 Fairway Drive
Camp Hill, PA 17011
ARTHUR G. KELLY
70 Fairway Drive
Camp Hill, PA 17011
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
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
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:
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 unworn falsification to authorities.
DATED: May 29, 2002
BY:Jos 'bf c A?Ff F RTY & McKEEVER
BY: Jose h Go c , Jr., Esq.
Attorney Plain
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Travelers Bank & Trust FSB c/o
Citifinancial Services, Inc.
VS
Clara E. Kelly and Arthur G. Kelly
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-1837 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Joseph A. Goldbeck.
Sheriff's Costs:
Docketing 30.00
Surcharge 30.00
Law Library .50
Prothonotary 1.00
Mileage 10.35
Levy 15.00
Poundage 100.00
$186.85 paidbyattorney
07/03/02
Sworn and subscribed to before me
This / L ?- day of
2002, A.D.
Prothonotary
So Answer
R. Thomas Kline, Sheriff
A BY OU1
Real Es ate Deputy
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Real Estate Sale # 42
On June 7, 2002 the sheriff levied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County,
PA known and numbered as 70 Fairway Drive,
Camp Hill, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: June 7, 2002
By: -?j cdq ShV,-?
Real E tate Deputy
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GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6312
for Plaintiff
TRAVELERS BANK & TRUST FSB CIO
CITIFINANCIAL SERVICES INC.
7467 New Ridge Road
Suite 222
Hanover, MD 21076
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 02-1837 CIVIL TERM
CLARA E. KELLY
ARTHUR G. KELLY
70 Fairway Drive
Camp Hill, PA 17011
Defendants
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs
only.
Wicha ( Mcnever
MICHAEL T. McKEEVER, ESQUIRE
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