Loading...
HomeMy WebLinkAbout06-4358 GOLDBECK McCAFFERTY & McKEEVER B\l: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell. TX 75019-3931 01.. - '1J~ (!, c..> ; L ~€/<..! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. P A TRlCIA A. GEORGE STEVEN A. GEORGE Mortgagors and Real Owners 236 Woods Drive Mechanicsburg, PA 17055 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendants Term CIVIL ACTI~' M0flITQAGE F~I!CLOIUfItE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A EST A 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 IMPORT ANTES. USTED DEBE LLEV AR ~STE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME POR TELBFONO LA OFICINA FIJADA AQUl ABAlO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, BSTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call Beth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of CITX-1516. Para informacion en espanol puede communicarse con Loretta al215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is TRAVELERS BANK & TRUST FSB. 1111 Northpoint Drive, Building 4, Suite 100 Coppell, TX 75019-3931. 2. The names and addresses of the Defendants are PATRICIA A. GEORGE, 236 Woods Drive, Mechanicsburg, P A 17055 and STEVEN A. GEORGE, 236 Woods Drive, Mechanicsburg, P A 17055, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On May 23,2000 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to TRAVELERS BANK & TRUST FSB, which mortgage is recorded in the Office of the Recorder of Deeds ofCurnberland County as Book 1614, Page 1. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1 019(g); which Ru1e relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for June 18, 2005 and each month thereafter and by the terms the Mortgage, upon defau1t in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance Interest from 05/18/2005 through 07/31/2006 at 6.0000% Per Diem interest rate at $31.43 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 06/18/2005 to 07/31/2006 Costs of suit and Title Search Escrow Corporate Advance $188,592.03 $13,797.77 $9,429.60 $418.50 $900.00 $5,196.97 $2,088.50 $220,423.37 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in Dersonam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants 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 "B". The Defendants have 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 Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $220,423.37, together with interest at the rate of $31.43, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: VERIFICATION !, Frankie Ward, 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 Plaintitf corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge. infonnation 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: 6l- .:1i- '0b ~hi6it ;tl ALL THAT PARCEL OF LAND IN THE TOIiNSHIP OF SILVER SPRING, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS !KlRE FULLY DESCRIBED IN DEED BOOK 101, PAGE 1070, IOU 38-20-1831-107, BEING KNOIiN AND DESIGNATED AS LOT 10, PLAN OF FINAL SUBDIVISION PLNl OF LOTS POll GBORGE N. WADE JR.. FILED IN PLAN BOOK 37, PAGE 11 AND l<<lRE PARTICULARLY DESCRIBED BY METES AND 1lOUN0S. TAX 10# 38-20-1831-107 , ~lii6it (B . ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE September 14, 2005 TO: Steven A. George 236 Woods Drive Mecbanicsburg, P A 17055 Patricia A. George 236 Woods Drive Mecbanicsburg. P A 17055 THIS FIRM IS A DEBT COLLECTOR A TIEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN A TIEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TIEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official notice that the mortRage on vour bome is in default and the lender intends to foreclosure. Specific information about the nature of the default is nrovided in the attacbed DlU!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to belo to save your bome. This Notice exolains how the or02l'am works. To see ifHEMAP can helD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS FROM THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet the CoonselinR ARencv. The name. address and ohone number of Consumer Credit CounseliM ARencies servinR vour Coonty are listed at the end of this Notice. Ifvou have anv Questions. vou mav call the pennsylvania HousinR Finance A~encv toll free at 1-800-342-2397. (Persons with iron.ired hearinR can call (717) 780-1869). This Notice contains important legal infonnation. 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 an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORT ANCIA. PUEDE AFECT A SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENJDO DE EST A NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMAR SU HIPOTECA. . STATEMENTS OF POLICY HOMEOWNER'S NAME (S): Steven A. George and Patricia A. George PROPERTY ADDRESS: 136 Woods Drive, Mechanicsburg. P A 17055 LOAN ACCT. NO.: 4425009 ORIGINAL LENDER: Citicorp Trust Bank, rsb CURRENT LENDER/SERVICER: Citicorp Trust Bank, rsb HOMEOWNER'S 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 MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECf 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 temponuy stay of foreclosure on your mortgage for thirty three (33) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) 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-Ifvou meet with one of the consumer credit counselin!! ""encies listed at the end of this notice the lender mav NOT take action lllI8inst vou for thirty three (33) davs after the date of this meetin2. The names. addresses and telenhone numbers of desilZllaled consumer credit counselin!! ""encies for the county in which the monertv is located are set forth at the end of this Notice. It is only necessllI)' to schedule one face-te-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in a default for the reasons set forth later in this Notice (see following pages for specific infonnation 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 face-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 LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDlATEL Y 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. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLWWlNG PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. If ou have roed bankru t ou can still a for Eme en Mort a e Assistance. HOW TO CURE YOUR MORTGAGE DEF AUL T (Brine it UD to date). NATURE OF THE DEF AUL T-The MORTGAGE debt held by the above lender on your property located at: 236 Woods Drive, Mechanicsburg, P A 17055 IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Start/End: 06118/05 through 08118/05 at 51,209.86 per month. Monthly Payments Plus Late Charges Accrued 53,629.58 NSF: 50.00 Inspections: 50.00 BPO: 5135.00 Speed pay: 50.00 Uncollected credit insurance: 50.00 Uncollected late charges: 5188.06 Taxes: 50.00 Late fee income: ~ Total amount to cure default $3,952.64 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use ifnot aoDlicable): N/A HOW TO CURE THE DEFAULT-You may core the default within THIRTY THREE (33) DAYS of the date of this notice BY PA YINO THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,952.64, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY THREE (33) DAY PERIOD. As of the date of this letter, you owe the amount specified above. Because ofinterest, late charges, and other charges that may vary from day to day, the amount due on the day that you pay may be greater. Hence, if you pay the amount shown above, an adjustment may be necessary after we receive your check, in which event we will infonn you before depositing the check for collection. For further infonnation, write the undersigned or call (800) 422-1498. PaVlttents must be made either bv cash. cashier's check. certified check or monev order made Davable and sent to CiticorD Trust Bank. fob. 1111 NortllDoInt Drive. CODocll. TX 75019 Attention: Loss Mitillation. You can cure any other default by taking the following action within THIRTY THREE (33) DAYS of the date of thIs letter. (Do not use if not aoDlicable.) N/A. IF YOU DO NOT CURE THE DEF AUL T-lfyou do not cure the default within THIRTY THREE (33) DAYS of the date of this Notice, the lender intends to exercise its rillhts to accelerate the mortl!ll2e debt. The 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 THREE (33) DAYS, the lender also intends to instruct its attorney to start legal action to foreclosure unoo your mort28.lle nlonertv. 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 begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to 550.00. However, iflegal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed 550.00. Any attorney's fees will be added to the amount to the lender, which may also include other reasonable costs. lfvou cure the defanlt within the THIRTY THREE (33) DAY neriod. vou will not be required to cav attomev'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 DEF AUL T PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY THREE (33) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and orevent the sale at anv time un to one hour before the Sheriff's Sale. You mav do so bv navine the total amount then cast due. olus anv late or other charees then due. reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sale as snecified in writing bv the lender and bv nerformine anv other reouirements under the mortlllll!e. Curing your defanlt 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 Sheriff's Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may fmd out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Cltieorp Trust Bank, fsb 1111 Northpolnt Drive Coppell, TX 75019 Attn: Loss Mitigation (800) 422-1498 EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the mortgaged properly 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 mayor _X_may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charge and attorney's fees and cost 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 PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEF AUL T CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEF AUL T. (HOWEVER, YOU NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS A'IT ACHED . If tbis is the first notice tbat you bave received from tbis omce. be advised tbat: You may dispute tbe validity of tbe debt or any portion thereof. If you do so in writing within thirty (30) days from the receipt of tbis letter. this firm will obtain and provide you witb written verification tbereof; otberwise the debt will be assumed to be valid. Likewise If requested in writing within thirty (30) days from receipt of this letter. the firm will send you the name and address of the original creditor ifditTerent from above. Very truly yours, Phelan Hallinan & Schmieg, LLP On Behalf of Citicorp Trust Bank, fsb By: Francis S. Hallinan FF:jrnm Cc: Citicorp Trust Bank, fsb Attn: Loss Mitigation Account No.: 4425009 Mailed by I" Class Mail and by Certified Mail No: 7005 0390 0004 07591044/1051 . . J,,'DI-ZDD5 II.ZI.. Fr... T-447 P.DD7/DID !"tIS Pennsylvania Housing Finance Agency Homeowners' Emergency Mol'tg1l88 Mei&tanc8 Program County Counseling Agency List CUMBERLAND Adams County InterflliIh Houaing Aull 40 e. HlSh SlI'88t Gettyaburg. PA 17325 {711}a34-1S1a LcweIIhill. Inc. :z320 NDIIh 5th street Harriaburg, PA 17110 (717) 232-2207 DAUPHIN CCCS ofW.tem PA 2000 LlnQlestown RaecI HIIn111lUrg. PA 17102 ~11-2227 PHFA 211 North Front SlrEt Harr!$burg, PA 17110 Bl10442-2SS7 DELAWARE Acorn Housing Corporallan 846 North Bread SlrIlet Philllilelphla, PA 19130 (2' 5} 765-1221 Ameriean Financial Counseling Servtl 175 Sl/lIfrorcl AwnU8, SIllte One Way"", PA 19087 8Q0.480-3039 Carrot! Park Communjly Counctl, Inc. 6218 t..\llsler strael Philadelphia. PA 19131 (215) Sn-1157 January 200s CCCS oIWlISI8m PA 2000 LlngleeloWn !toad Har/fabJ.ug. PA 17102 1l8a.511-2221 M....1I8lha . 43 PhII8deIp/lla Avenue ~,PA 17268 (717) 782-3285 Community AcIIon Commission of ea 1514 DtIny SIRIet Harrilbul'll, PA 17104 (717) 132-$751 American Crecllt Counullng lnstitu1e 115 Sllaffo!d "venue SuT.' Wayne, PA 19081 (610) 971-2210 AmeI1can Red CIoIlS of Chettier 1729 EdQ8lTIOI\l -"venue Chester. PA 19013 (1l10) 814-1484 CCOS of Delawwe VaJIey 280 North PrO\Iidence Road Media, PA 19O1l3 (215)583-5Sl1S Page 8 of 21 Communllv At;ljcn Comrnlulon of Ca 1514 Derry ~ HarrlsllurV. PA 17104 (717) 232...757 PHFllo 211 NorII1 FIDIlI Slteet Harrltlblllg. PA 11110 800-342-2387 ~Ip,1nc. 2320 Ncd't 511I StrHl Hwrfebur;. PA. 17110 (717) 232-221l7 Amerlcan Flnanc181 Counseling Servf, 1 AbIngton PIUa, Suibo 403 Old YorIC ROlId and Township Line JenklnlDwn. PA 1ll1l48 8000490-3039 APM 2147 Norll\ SixIh stTael Philadelphia, PA 18122 (215) 235-&788 CCCS of DeIawar8 V""y 790 e. r.wtc.t SI. Sul18 17Q, MlIn&IIaU B\IiIdinQ INeet CIteel8r. PA 1931lZ (215)5IWlSll5 7J ~ ~ tt 11 ~ r -- l'f( - l> c> ~ ~ -J ~ ~ P- r ~ ~ - . . -, - - -; C'J, -r_ _".... ~~ - GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 . BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. PATRICIA A. GEORGE and STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 No, 06-4358 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. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, David B. Fein, Esq., in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a first mortgage upon the premises 236 Woods Drive, Mechanicsburg, PA, 17055, hereinafter, the "mortgaged premises". and real owners of the mortgaged premises. 2. Defendants, PATRICIA A. GEORGE and STEVEN A. GEORGE, are the mortgagors the Complaint. 3. The last known address of Defendant, Steven A. George, is as set forth in Paragraph 2 of 4. The Sheriff has been unable to effect service of the Complaint upon Defendant, Steven A. The Defendant, Steven A. George, has not lived at the property address for four years, per Sheriff. George, at his property address, 236 Woods Drive, Mechanicsburg, P A, 17055, after numerous attempts. " - whereabouts of Defendant, Steven A. George. 5. The following investigation was conducted in a good faith attempt to ascertain the WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff regular mail to the Defendant's last known address. to serve the Complaint upon Defendant, Steven A. George, by posting the premises and certified and BY: /PF David B. Fein, Esq. " - ERSAL SERVICES . . '. Affidavit of Good Faith Investioation Client provided information: File Number: CITX-1516 A ttorney Firm: Goldbeck, McCafferty & McKeever File Name: George Subject Name: Steven A. George Property Address: Street: 236 Woods Drive City: Mechanicsburg State: PA Zip: 17055 Skip Results: Verified Street: 236 Woods Drive City: Mechanicsburg State: PA Death Records: As of 0712012006, Steven A. George. Social Security Number search completed. Employment Search: Unable to verify current employer. Creditor information: Creditors indicated the last reported address for Steven A. George as 236 Woods Drive, Mechanicsburg, PA 17055 Department of Motor Vehicle Records: The Pennsylvania Department of Motor Vehicles provided no change for Steven A. George from 236 Woods Drive, Mechanicsburg, PAl 7055 Public Licenses (Pilot, Real Estate, etc): Search performed provided no information. Voter Registration Information: The County Voters Registration Office has no listing for Steven A. George. National Postal Address Search: Has no change for Steven A. George from 236 Woods Drive, Mechanicsburg, PAl 7055 Comments: 717-732-5097: Spoke with neighbor, Marlin Engel, verified current address as 236 Woods Drive, Mechanicsburg, PA 17055 Date of Birth: None Found Universal File Number: 571 64 Dates: As of 07/2012006 Phone: Zip: J 7055 the Social Security Administration has no death record on file for On 07/20/2006, /, Patti Garrett being duly SWorn according to the law, deposes and says: I am employed by Universal Default Service. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my investigation. -Subscribed and SWofntQ before me. -------- Not~ cU~ Date: 07120/2006 -'Ii'. . . ~ . E t , 329 OAKS TRAIl PlAZA . SUITE 202. GARlAND, TEXAS 75043 OFFICE: (972) 226-8883 . FAX: (972) 226-8887 - ~Ht;lU 1<'1<' I ~ .H.t;'l'U.'"<.N - NUL' 1:<'U UNJJ - ',' CASE NO: 2006-04358 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TRAVELERS BANK & TRUST FSB VS GEORGE PATRICIA A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly SWorn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GEORGE STEVEN A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , ,GEORGE STEVEN A 236 WOODS DRIVE MECHANICSBURG, PA 17055 DEFENDANT HAS NOT LIVED AT GIVEN ADDRESS FOR 4 YEARS. Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 ,00 5.00 10.00 .00 21.00 County LDBECK MCCAFFERTY MCKEEVER '--'08/04/2006 Sworn and Subscribed to before me this day of A.D. , . GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19i06-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff TRA VELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 vs. PATRICIA A. GEORGE and STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 06-4358 VERIFICATION !, David B. .Fein, Esq., Attorney for Petitioner do hereby verify that the f"'ts set forth in the foregoing Motion for Substituted Service are true and correct to the best of rny kooWledge, information and belief. ! understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. BY: David B. Fein, ~ . t ' GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney lD.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney lD.#82628 Attorney for Plaintiff TRA VELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019.3931" vs. PATRICIA A. GEORGE and STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 06-4358 MEMOMNDlJM OF LAW IN SUPPORT OF MOTION FoR SlJBSTlTUrEn SERVICE !JNDER Pa.R.C.P. 430l!) Plaintiff has filed a Complaint in Mortgage Foreclosure agalnst Defendant, Steven A. George, which the Sheriff has been unable to personally serve upon Defendant, Steven A. George. As nO'ed in the attached Motion, Plalntiff has made a good faith attempt to ascertaln Defendant's whereabouts withoot success. ACCOrdingly, the Court may approve alternative means of service. See Pa.R.c.p.430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allOwing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendant, Steven A. George, by POSting the premises and certified mall and regular mail to the Defendant's last known address. Respectfully ~ David B. Fein, Esq. . i" GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney lD.#16132 Suite 5000 - Mellon. Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney lD.#82628 Attorney for Plaintiff TRA VELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppel1, TX 75019-3931 vs. PATRICIA A. GEORGE STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 IN THE COURT OF COMMON PLEAS Of Cumberland County No. 06-4358 CERTIFICA TE OF SERVICE David B. Fein. Esq.. does hereby certify that true and COrrect copies of the foregoing !vIotion for Substituted Service have been served upon the Defendan~ Steven A. George. this 21"day of August 2006, by first class mail, postage prepaid. {lJJr- BY: David B. ~ .....u, c.sq. o c ~ C -:- c>.... C'-'} c', o --~,' o -n '-~-n I'll f'" '=;.~')\\3 ,.' "~ I, '),0 , -<" 1-- .,--~-i ~r~ r;-? ,-.11 C) :~ 1/ ,. RECEIVED. '7 AUG 3 I 2006 GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#I6132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS OFCumoorl~dCOUNTY vs. PATRICIA A. GEORGE ~d STEVEN A. GEORGE 236 Woods Drive Mech~icsburg, PAl 7055 06-4358 ORDER AND NOW, this ~ day o~ 2006, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C-P. 430(a) ~d it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defend~t. Steven A. George, has been unsuccessful, it is, ORDERED ~d DECREED: that Plaintiffs Motion is gr~ted ~d the Sheriff ~d1or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defend~t, Steven A. George, by posting a copy of the Complaint upon the premises 236 Woods Drive. Mechanicsburg, P A, 17055, ~d Plaintiff is directed to serve the Complaint by certified ~d regular mail to the Defendant's last known address at 236 Woods Drive, Mech~icsburg, PA, 17055, ~d that all further service of legal papers, including but not limited to motions, petitions ~d rules 00 made by certified ~d regular mail to Defend~t's last known address ~d that Notice of Sheriff Sale pursuant to Pennsylv~ia Rule of Civil Procedure 3129 may 00 made upon Defend~t, Steven A. George, by sending copies of same to Defend~t' s last known --,,-.."""-"""..,"_.'"~ '" ~ ~~ BY T: c.;,.:.J.. J. ~ ~ r> ~ i~ ~i, ~\ ?' ~ l . \lINVillASNN::J,-l AlNrlCC; ,,,,..-,.,,i';Vllfi::> I I :8 !,/d S- d3S 900l AW10i\GH1C',id 3Hi :10 3CilJ:'O-{1311:l GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE PATRICIA A. GEORGE STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, PA 17055 Term No. 06-4358 Defendant( s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff (J tP -) ~_'!") ~,.,~ 1'.> l') SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04358 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TRAVELERS BANK & TRUST FSB VS GEORGE PATRICIA A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GEORGE STEVEN A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , GEORGE STEVEN A 236 WOODS DRIVE MECHANICSBURG, PA 17055 DEFENDANT HAS NOT LIVED AT GIVEN ADDRESS FOR 4 YEARS. Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 .00 5.00 10.00 .00 21. 00/ C\}1- ~O(, cr Subscribed to before County LDBECK MCCAFFERTY MCKEEVER 08/04/2006 Sworn and me this day of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-04358 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TRAVELERS BANK & TRUST FSB VS GEORGE PATRICIA A ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GEORGE PATRICIA A the DEFENDANT , at 0855:00 HOURS, on the 4th day of August 200?5 at 236 WOODS DRIVE MECHANICSBURG, PA 17055 by handing to PATRICIA A GEORGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed So Answers: 1~:~~ .~~ ~ .00 r ' ~~ 10.00 R. Thomas Kline .00 37.68/ 08/04/2006 ~ "11 ::>1c\,GOLDBECK MCCAFFERTY MCKEEVER to By' ~V~ day v Dep ty Sheriff before me this of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-04358 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TRAVELERS BANK & TRUST FSB VS GEORGE PATRICIA A ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon GEORGE STEVEN A the DEFENDANT at 0016:50 HOURS, on the 12th day of September, 2006 at 236 WOODS DRIVE MECHANICSBURG, PA 17055 by handing to POSTED PROPERTY AT ADDRESS STATED a true and attested copy of NOTICE together with COMPLAINT IN MORTGAGE FORECLOSURE and at the same time directing His attention to the contents thereof. 18.00 ~: ~~ f""'~J.t:~~ 10.00 R. Thomas Kline .00 42. 80 ~ 09/13/2006 ~ lI{H'JOt... GOLDBECK, MCCAFFERTY, MCKEEVER Sworn and Subscibed to By: Sheriff's Costs: Docketing Service POSTING Surcharge So Answers: A.D. ~J=&lN-1 D puty Snerlff " day before me this of . .. f GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF TRA VELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. CIVIL ACTION - LAW PATRICIA A. GEORGE and STEVEN A. GEORGE Mortgagor( s) 236 Woods Drive Mechanicsburg, PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant(s) Term No. 06-4358 CERTIFICATE OF SERVICE JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on S..e~/lJb.Jl-l /9, d~& he did serve upon Defendant STEVEN A. GEORGE a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated September 5,2006. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, LDBECK McCAFFERTY & McKEEVE BY: JOSEPH A. GOLDBECK, JR. ESQUIRE (') c s: -0 (0 QJfJ: ..,(.:..- ..A~ t~~~ -<. - '<c' .~~. '~ r-J = = <::r> en !:ti N N ~ ~::n -oh1 :ut? 96 --r. ;+.; ::!J ':i0 om ..::..j ~ -0 :x N .. .::;- \D In the Court of Common Pleas of Cumberland County TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 Plaintiff vs. PATRICIA A. GEORGE STEVEN A. GEORGE (Mortgagor(s) and Record Owner(s)) 236 Woods Drive Mechanicsburg, P A 17055 No. 06-4358 Defendant( s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against PATRICIA A. GEORGE and STEVEN A. GEORGE by default for want of an Answer. Assess damages as follows: $222,372.03 Debt Interest from 11/02/06 to Date of Sale 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 FR E COMPLAINT. Prothono against whom judgment prior to the date of the I certify that written notice of the intention to file this praecipe was mailed or delivered t is to be entered and to his attorney of record, if any, after the default occurred and at leas filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A. Go dbec Attorney for la" ti J.D. #16132 AND NOW ~O u <.3, f.o , I dgment is entered in favor of TRAVELERS BANK & RUST FSB and against PATRICIA A. GEORGE and STE EORGE by default for want of an Answer and damages assessed in the sum of $222,372.03 as per the above certi 1 ion. Rule of Civil Procedure No. 236 - Revised TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 PATRICIA A. GEORGE STEVEN A. GEORGE (Mortgagors and Record Owner(s)) 236 Woods Drive Mechanicsburg, P A 17055 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff No. 06-4358 vs. Defendant( s) 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 M~ By: ~ If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 CITX-1516 TillS 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: October 20, 2006 TO: STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 In the Court of Common Pleas of Cumberland County TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CIVIL ACTION - LAW Plaintiff vs. PATRICIA A. GEORGE STEVEN A. GEORGE (Mortgagor(s) and Record Owner(s)) 236 Woods Drive Mechanicsburg, P A 17055 Action of Mortgage Foreclosure Term No. 06-4358 Defendant(s) TO: STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 IMPORTANT NOTT(;F, YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGmLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 hvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 Joseph)1 qoUf6ect Jr GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 -701 Market Street. Philadelphia, PA 19106 215-825-6318 CITX-1516 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: October 20, 2006 TO: PATRICIA A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 In the Court of Common Pleas of Cumberland County TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CNIL ACTION - LAW Plaintiff vs. PATRICIA A. GEORGE STEVEN A. GEORGE (Mortgagor(s) and Record Owner(s}} 236 Woods Drive Mechanicsburg, P A 17055 Action of Mortgage Foreclosure Term No. 06-4358 Defendant(s) TO: PATRICIA A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 TMPORT A NT NOTTCR YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGmLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 hvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 JoSeph)1 qo{d6ec~ Jr GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 -701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation wi thin 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-Mili tary 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, PATRICIA A. GEORGE, is about unknown years of age, that Defendant's last known residence is 236 Woods Drive, Mechanicsburg, PA 17055, 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, STEVEN A. GEORGE, is about unknown years of age, that Defendant's last known residence is 236 Woods Drive, Mechanicsburg, PA 17055, 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, provisions of the Soldiers' and Sailors' Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627 -1322 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION LAW PATRICIA A. GEORGE STEVEN A. GEORGE (Mortgagor(s) and Record owner(s)) 236 Woods Drive Mechanicsburg, P A 17055 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 06-4358 ORDER FOR JUDGMENT Please enter Judgment in favor of TRAVELERS BANK & TRUST F , an against PATRICIA A. GEORGE and STEVEN A. GEORGE for failure to file an Answer in the abov acti within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service oft Complaint, in the sum of $222,372.03. Joseph A. Goldbec Attorney for Plainti . . ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $188,592.03 Interest from 05/18/2005 through 11/01/2006 $15,746.43 Reasonable Attorney's Fee $9,429.60 Late Charges $418.50 Costs of Suit and Title Search $900.00 Escrow Corporate Advance $75,196.97 $2.088.50 AND NOW, this ,&AA- day of ;l)DU. , 2006 damages are assessed as above. ~ ~ c~~g, '4-- \J-u ::;~?=- -Ji: ~ ~ ~ ~ ~ " ~ --c; ~ r--- \"..;) 0 o g "'Tl ~ CT' ~ - ~ :J:-n ~J: rt1 \:::: -1") CD "U '-r) "~"~~ ~'.~~,:~ ~ ~:.?: '$1\~~ (2( 'f? ~ I (..., f'.) (fl , -, PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 . Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 Plaintiff vs. PATRICIA A. GEORGE STEVEN A. GEORGE Mortgagor(s) and Record Owner(s) 236 Woods Drive Mechanicsburg, P A 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-4358 TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount Due Interest from 11/02/06 to Date of Sale at 6.0000% (Costs to be added) $222,372.03 ~ ~ ~ oo~ 11')0 ~u 51~ ~~o ~~ o u ~ ~ ~ ~ r.n \.J.< ~ ~ ~ ~ ~ ~ ~ ~ ~ S ~ >- cr.: <f:. !-- .--'- UJ"':~ r1~ ~~";! ~?t'S -<:1 (J- twc;... ~llJ U-~ ...I- I- l.1- o ,;, ;> - 3 .. "d iU II') ~~~ :s ~c:10iU~ ~ ~ ~ .~ .( o~gop.. ~c:1B~bO c:1 010"< oS .....("ao~ .....z(o:S~~ .( ~ ~ \0 '8 U?;-.::~~ >-j.....OM,o ~~~ iU ~ OIl ~ p.. ~ 6 tn N Ch (.: ::~ ~~:~.~ :~~ (~/) ~.- :a: ("') I ,:f .. J t.,l.....i ~rJ- o :::- c::> Z ....0 = = ~ g ~ u ai Q ~"C3 o iU ).< ~~ ~.... 0).< ~Q ~ o i ~ ).<'a iU iU tu ~ iU ~ ~ \0 Y'" 0 ~..g.....- ~diUO\M ca!g - M r.n.(~ ;>:> .....p..~ i,SJj cd'~ l::d~:.a", .O~P.1 u..... .....11') ..... iU- i~O~M ~Ir--:.a Yo p.. iUo :g~ 'iiU o :~ ::s r.n t~: .." .... .... '" .. .. .. ... .. ~J ... .... ... ~ ... ... .. ... - .. ... ... ~ .. ~ () <)( ~ ~ () () ~ \) c... () VJ C~ () ~ ~. ~ Va '::t . ~ ""- . . . ""1 ~ v)~ "':'o\4~~ ~ ~(V) ~=r - ~ 3 ~ ~ ~ ...J ~ Do ~ ':::)- 1:"" Or... fi -- J ~ ci , ( c=::(. (j ALL THAT CERTAIN lot or piece of ground situate in Silver Spring Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Northern side of Woods Drive said point being North and parallel to the existing center line of said Woods Drive and said point being the dividing line of Lots Nos. 9 and 10 on the hereinafter mentioned Plan of Lots; thence along said dividing line North 13 degrees 35 minutes 31 seconds West 200.00 feet to a point on lands now or formerly of George N. Wade, Jr., thence along the dividing line of Lot No. 10 and lands now or formerly of George N. Wade, Jr., South 76 degrees 24 minutes 29 seconds West 100.00 feet to a point at the northwestern comer of Lot No. 10; thence along the dividing line of Lot No. 10 and the lands now or formerly of George N. Wade, Jr., South 13 degrees 35 minutes 31 seconds East 200.00 feet to a point on the dedicated Northern side of Woods Drive; thence along the dedicated Northern side of Woods Drive North 76 degrees 24 minutes 29 seconds East 100.00 feet to a point, the place of beginning. BEING KNOWN AS 236 WOODS DRIVE, MECHANICSBURG P A 17055 TAX PARCEL NO: 38-20-1831-107 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-4358 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TRAVELERS BANK & TRUST FSB, Plaintiff (s) From PATRICIA A. GEORGE AND STEVEN A. GEORGE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 $222,372.03 L.L. $.50 Interest FROM 11/2/06 TO DATE OF SALE AT 6.0000% Arty's Comm % Atty Paid $183.48 Plaintiff Paid Date: NOVEMBER 3, 2006 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 50000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 <tIdbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW PATRICIA A. GEORGE STEVEN A. GEORGE (Mortgagor(s) and Record Owner(s)) 236 Woods Drive Mechanicsburg, P A 17055 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 06-4358 AFFIDAVIT PURSUANT TO RULE 3129 TRAVELERS BANK & TRUST FSB, 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: 236 Woods Drive Mechanicsburg, P A 17055 1.Name and address of Owner(s) or Reputed Owner(s): PATRICIA A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 2. Name and address ofDefendant(s) in the judgment: PATRICIA A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 .... Carlisle, PA 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 UNIFUND CCR PARTNERS 10625 Techwood Circle Cincinnati, OH 45242 4. Name and address of the last recorded holder of every mortgage of record: BENEFICIAL CONSUMER DISCOUNT CO. D/B/A BENEFICIAL MORTGAGE CO. OF P A. 4910 Carlisle Pike Suite 104 Mechanicsburg, P A 17050 BENEFICIAL CONSUMER DISCOUNT CO. 961 Weigel Drive Elmhurst, IL 60126 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUP ANTS 236 Woods Drive Mechanicsburg, P A 17055 (attach separate sheet if more space is needed) DATED: November 1. 2006 I verify that the statements made in this affidavit are true and correct to e best 0 my personal knowledge or information and belief. I understand that false statements herein are made subj ct to the pe alties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. o ~; ":.":'-> -(n....; ~ \~-\ ~ c;;::> cr- ..... C5 .:.. ~~!) r-- ~:...... ~.j;\t:,. ;;., c: ?~{ -" \ (...;:l ~ -\ ~..,., rnc -n fi"1 :fJy ,~~) :"") :'\~ ~~'~ \l ~~:; o --\ ~ ::<. ~ -,d'" u::> .- f"-" (Ji /J 7 J <------..-,. lRECEI\lED! AUG 3 1 2006 BY: GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627 -1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. PATRICIA A. GEORGE and STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 06-4358 ORDER AND NOW, this ~ day o~ 2006, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant, Steven A. George, has been unsuccessful. it is, ORDERED and DECREED: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendant, Steven A. George, by posting a copy of the Complaint upon the premises 236 Woods Drive, Mechanicsburg, PA, 17055, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendant's last known address at 236 Woods Drive, Mechanicsburg, PA, 17055, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Steven A. George, by sending copies of same to Defendant's last known odd"" by certified""" "gula< mail""" by p,,,ting lbe P'~ ~ ~ ~;~ TRUE COpy FROM RECOHLI BY~' c;,:.J.~, n Testimony whereof. I here unto 881 "" halO J. ,1d the _I of said Oou~ at CarlIle, Pa. S l~ dayt2_~co(, SHERIFF'S RETURN - REGULAR .. l r , , , CASE NO: 2006-04358 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TRAVELERS BANK & TRUST FSB VS GEORGE PATRICIA A ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon GEORGE STEVEN A the DEFENDANT , at 0016:50 HOURS, on the 12th day of September, 2006 at 236 WOODS DRIVE MECHANICSBURG, PA 17055 by handing to POSTED PROPERTY AT ADDRESS STATED a true and attested copy of NOTICE together with COMPLAINT IN MORTGAGE FORECLOSURE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service POSTING Surcharge So Answers: 18.00 8.80 6.00 10.00 .00 42.80 ;'"""'"~"aJlt" ~-.. R. Thomas Klin 09/13/2006 GOLDBECK, MCCAFFERTY, MCKEEVER Sworn and Subscibed to By: before me this day of A.D. GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. CIVIL ACTION - LAW PATRICIA A. GEORGE and STEVEN A. GEORGE Mortgagor( 5) 236 Woods Drive Mechanicsburg, PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant{s} Term No. 06-4358 CERTIFICATE OF SERVICE JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on t(11-tJ0 he did serve upon Defendant STEVEN A. GEORGE a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated September 5, 2006. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, tt~L LDBECK McCAFFERTY & McKEEVE BY: JOSEPH A. GOLDBECK, JR. ESQUIRE iJ 0 ~\ ~ ~ ~. >< ;:u. I ~ 0 -->- (}1' (,..) ~ }; -->- co en .... ~ ;t> :I ~ G> " (1) m c- O 2 ~ \I) ::u -< ~ G> N m 0 0 QO N (f) '=ti \I) -l (Q m (1) < m 0 - Z ~ ;J> G> m 0 ::u G> m .....-1 -'0 ll[ ~~ (1)3 <pO" ::l<P a.~ <pQ, ~" (D' fa '" ~ ;AJr) gl[ tDZ a.C: .,3 -~ ,,~ 00 la- 0:2 3l~ lil", :--J ~ u -I- - - --t u o o 3 '0 .. S' -i ~ '0 i S' :- 5' F o ... OJ !l!: ~ o :; .. ~ CD ~ " ~ ., la ~ " ~ Z ~ Q, ~ :C' ~' $ I -1-- en CD CD ." ... <" I>> ~ ~ ... en it fD 3 CD ~ .... o ~ :;0 ~ CD ~ CD ~ Jl..1 . i i I I I \ I i r "- ~?' \ \ ..' I' ::~.'\ '-:'\ ", "'r ,CJ I .'-:. ) --I ~. ;\,",c-' '/ / /;y/'. ____r-o,y ~--)y wi !'ll ~I ....."......(1)(;1 \~;~SO~ Oi"s:-lr3 5: I\) G> 9ll>)>mO(1) ct> U) m 1....0 (1ICJIll a en 0 Cl'lm;ocmi5. ::; ~ JJ \~i"^gCh> \l) 0 G> "0 m " 0. :J ::t-l ~ p' 0 m '-en CD 0- (J) (J) \ }> ~ ~ 0- m c 0 -l "0;0 S. .... .... m \ l>Rl W <0 <' ct> < -l is. -u m )> z ~ ...... )> I -...j i 0 (}'I (}1 o ::T (1) I Ji Il J IIII ~ 13' m 0 a a ~ ~ >< (1) 0 ~ (1) ~lIo! ~ ~b' ~ =.;~ "" 3 !!I- 0' ::l Q '" (1) < 0' ,(1) J $10 ~ " j Illli-il i ~~l~ ~3~a Cil;o~~ alii 0 o 12, (1) S, ~ ~ ~Q' $ ~I $' +-- I 0' ::l ~ " o l& CQ (1) g~Q,Sl!Pl;~ ---I II s: 0 0 UNtr~/) ~~; t)', ~ ~ I t~ ~ ~ ;"'llf~ ~:~ IIII ~ gUl ~ mOlO 1"Tl;AJ Iffi 0 1 ~ ;-n;o 1 1m ;AJ Form 3877 Domestic USPS Firm Mailing Book -------------------------------------------------------------------------------- Name and Address of Sender: JOSEPH A GOLDBECK JR MELLON INDEPENDENCE CENT 701 MARKET ST STE 5000 PHILADELPHIA, PA 19106 Piece ID Article # Delivery Address Addressee Name Permit Number Sequence Number 255A SS Type Fee Postage Ascent - MAC v6.80.6.90.E Value Insur./Register Sender Charges Total Due AMQ~1213 PCO 71114342363000005563 ------------------------------------------------------------- ---------------------------- ------------------- 4.62 HALL, BRENDA M. 6324 Foxhill Road Philadelphia, PA 19120 CITX~1516 PCO 71114342363000005570 AMQ~0805 10~2671114342363000005587 ERNEST B. STEWART 111 INDEPENDENCE TRAIL LONG POND, PA 18334 FN~0951 PCO 71114342363000005594 SANBOWERS, FOSTER W. 528 Pine Ridge Road Bedford, PA 15522 SPS~0512 PCO 71114342363000005600 COLLIER, FRANK A. 146 Ontario Road Eighty Four, PA 15330 CWD~6493 COMP 71114342363000005617 MIGNONE, TARA 99 Larkspur Circle Sicklerville, NJ 08081~4165 CWD~9496 COMP71114342363000005624 MIGNONE, MICHAEL 99 Larkspur Circle Sicklerville, NJ 08081~4165 WM~0824 COMP 71114342363000005631 ALMQUIST, STACI A. 66 Greenway Walk pennsauken, NJ 08109 C RRE 2.40 1.35 0.87 0.87 0.39 0.87 0.87 1.35 1.35 0.87 4.62 4.14 4.62 4.62 5.10 5.10 4.62 Page Totals: Cumulative Totals: 8 32 ------------------------------------------------------------------------------------------------- Page 4 C 2.40 RRE 1. 35 C RRE 2.40 1 .35 C RRE 2.40 1.35 C RRE 2.40 1.35 C RRE 2.40 1.35 C 2.40 1 .35 RRE C RRE 2.40 1 .35 30.00 120.00 7.44 30.00 37.44 150.00 SHERIFF'S RETURN - REGULAR ... " . , , CASE NO: 2006-04358 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TRAVELERS BANK & TRUST FSB VS GEORGE PATRICIA A ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GEORGE PATRICIA A the DEFENDANT , at 0855:00 HOURS, on the 4th day of August , 2006 at 236 WOODS DRIVE MECHANICSBURG, PA 17055 by handing to PATRICIA A GEORGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.68 .00 10.00 .00 37.68 .r"~~ . R. Thomas Kline 08/04/2006 GOLDBECK MCCAFFERTY MCKEEVER day By, ~[!b~ (. . Dep ty Sheriff Sworn and Subscibed to before me this of A.D. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA 55. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz September 29,2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 29 day of September, 2006 ~~~,#~ .~ NOTAR!AL. "E,c.t t I LOIS E. SNYDER Notary PIJ~~!ic 1 ~ Carlisle Bore, Cumberland Countv I I My Commis:3.0n Expire::. i.,~arch 5. 20?.::J S~.;.;'>>t:-~~"'.t,,"~:n.,.;;.,.....'o:'~'''~~-~~--..-,a:: CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County CMI Action-Law Term No. 06-4358 TRAVELERS BANK & TRUST FSB Plaintiff vs. PATRICIA A. GEORGE & STEVEN A. GEORGE Mortgagor and Real Owner Defendant NanCE OF ACTION IN MORTGAGE FORECLOSURE STEVEN A. GEORGE. MORT- GAGOR AND REAL OWNER. DE- FENDANT whose last known ad- dress is 236 Woods Drive. Mechanicsburg. PA 17055. TIllS FIRM IS A DEBT COLLEC~ TOR AND WE ARE ATIEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. You are hereby notified that Plain~ tiff TRAVELERS BANK & TRUST FSB. has filed a Mortgage Foreclo~ sure Complaint endorsed with a notice to defend against you in the Court of Common Pleas of Cumberland County. Pennsylvania. docketed to No. 06~4358 wherein Plaintiff seeks to foreclose on the mortgage secured on your property located. 236 Woods Drive. Me- chanicsburg. PA 17055 whereupon your property will be sold by the Sheriff of Cumberland County. 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 attor- ney 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 judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plain~ tiff. You may lose money or prop- erty or other rights important to you. YOU SHOULD TAKE THIS PA~ PER TO YOUR lAWYER AT ONCE. IF YOU DO NOT HAVE A lAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU wrm INFOR- MATION ABOUT HIRING A lAW~ YER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LE- GAL SERVICES TO ELIGIBLE PER- SONS AT A REDUCED FEE OR NO FEE. MidPenn Legal Services. Inc. 401 East Louther StreetCarlisle. PA 17013 (71 7) 243~9400 CUMBERLAND COUNTI BAR ASSOCIATION 32 South Bedford Street Carlisle. PA 17013 JOSEPH A. GOLDEBECK. JR. ESQUIRE GOLDBECK McCAFFER1Y & McKEEVER. PC 10 CUMBERLAND LAW JOURNAL Attorneys for Plaintiff Suite 5000. Mellon Independence Center 701 Market Street Philadelphia. PA 19106- 1532 (215) 825-6411 Sept. 29 11 . . PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) September 29,2006 COpy OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of ~~~~ Sworn to and subscribed before me this 04th. day of October 2006. -~{;f {V Notary ~o:t- My commission expires: q 1,1 tJ~ COMMONWEALTH OF PENNSYLVANIA Notarial Seal Christina L. WcAfe. Notary: Carlisle~. ~ 1 2008 My ())mmissIoI'l expireS . . Member. Pennsylvania Association Of Notaries l " 06-4358 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. PATRICIA A. GEORGE STEVEN A. GEORGE Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 236 Woods Drive Mechanicsburg, P A 17055 Term No. 06-4358 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: GEORGE, PATRICIA A PATRICIA A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 Your house at 236 Woods Drive, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriff's Sale on Wednesday, March 07, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $222,372.03 obtained by TRAVELERS BANK. & TRUST FSB against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to TRAVELERS BANK. & TRUST FSB, 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. ... . oW.. 06-4358 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may frod out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless 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 HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 (") ~,,; ";"_::.~ -0('. c~:-; ~. ..:-. -:-:.-- ~~~ :? c~ t. :l J;:- ~ = cro ~ Q ...G: , W ~ :;ii: \f! ~ .-1 ::r:..,., rnc -08 ~"1:] '-( ':-~:;~~?; ~-::_"".q ~2c) ;2') rn :.\ 2;'" ~ N (.J1 ( 06-4358 A GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. PATRICIA A. GEORGE STEVEN A. GEORGE Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 236 Woods Drive Mechanicsburg, P A 17055 Term No. 06-4358 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: GEORGE, STEVEN A STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 Your house at 236 Woods Drive, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 07,2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $222,372.03 obtained by TRAVELERS BANK & TRUST FSB 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, 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. ,- . fa 06-4358 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 71 7-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be fIled by the Sheriff within thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless 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 SHOUID TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 \, ( . c:~ ~ ,...., = = r:::t" .-"". C5 <: I W ;?, .-( :J:;;:n rT t r'~~ ~~1 C~J ~2~t:; ~::~~: M '-.1 .'-1 .~,. ".0 =< "T-" =!: '-R N (J1 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney IiD.#16132 S\1ite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITX-1516 CF: 07/31/2006 SD: 03/07/2007 $222,372.03 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE PATRICIA A. GEORGE STEVEN A. GEORGE Mortgagor(s) and Record Owner(s) Term No. 06-4358 236 Woods Drive Mechanicsburg, P A 17055 Defendant( s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (e) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (K) Personal Service by the Sheriffs Officele8Hll'etelit ..dull {copy of return attached). - Po.+r;ti... ~k.J . ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. (~) Premises was posted by Sheriffs Office/e6ft1l'atCftt ..duil (copy of return attached)." ~+tVfNt ~ \~ . ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ~) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Mfidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. / ub . tt!ti; ------- -. tOtO o 00 \\~\~;\ \\\~ o~ u '~OI> ~, !~~ \\ 9< ~ 4",,:;:!, "- ~ ""'Od.. ~ ..... {'l~~ <("60, 0 ~8Q31It-l(\ ., i ~ tt a "'C ~ S to en 1 ~ ~ 0. 1 $ ~ I \Iti ~ \I~ ~ "'0-8 11* ::>ji' :Z:.., \(i ~ \. is If> 'l- :.:::l t- (0 to ~ n ~ ~ X u.. t: If U Ul ~ ~ <( ill Gj t> ~ Ul ~ g <9 <i.. <( o C2 '< 0.. 8 S :z: lii ~..... 1% ~ m- \....~ ~ ct. a.~ _ '0 t;~ ~ WiNI :g~g~m~1 4. (.) 0 (t. 0 ... ~ 'M It) 4 4. d:l,\ <<I OUl~ ~Oi ~ .t- cf:) \ let> ' . iN II- Form 3877 Domestic USPS Firm Mailing Book -------------------------------------------------------------------------------- Name and Address of Sender: JOSEPH A GOLDBECK JR MELLON INDEPENDENCE CENT 701 MARKET ST STE 5000 PHILADELPHIA, PA 19106 Permit Number Sequence Number 397A Ascent - MAC v6.80.6.90.E Piece ID Article , Delivery Address 55 Fee Postage Value Sender Charges Addressee Name Type Insur./Register Due Total ---------- - ----------- -------- CITX-1516 3/7 71114342363000029781 GEORGE, STEVEN A C 2.40 0.39 4.14 236 Woods Drive RRE 1.35 Mechanicsburg, PA 17055 CWD~6477 1/5 M71114342363000029798 OFFI, MARTIN J. RD 1 BOX 69BB Cochranton, PA 16314 C 2.40 RRE 1.35 0.39 4.14 CWD-6477 1/5 S71114342363000029804 OFFI, SHERRIE A. RD 1 BOX 69BB C 2.40 RRE 1.35 0.39 4.14 Cochranton, PA 16314 CWD-6496 2/6 T71114342363000029811 MIGNONE, TARA 99 Larkspur Circle Sicklerville. NJ 08081-4165 C 2.40 RRE 1.35 0.39 4.14 CWD-6496 2/6 M71114342363000029828 MIGNONE, MICHAEL 99 Larkspur Circle Sicklerville, NJ 08081-4165 C 2.40 RRE 1.35 0.39 4.14 CITX~1516 3/7 71114342363000029835 GEORGE, PATRICIA A 236 Woods Drive Mechanicsburq, PA 17055 C 2.40 RRE 1.35 0.39 4.14 CITX~1530 2/6 71114342363000029842 COLLINS, ROBERT 3146 North 27th Street Philadelphia, PA 19132 C 2.40 0.39 4.14 RRE 1.35 CFNA-0375 2/1671114342363000029859 JONES N/K/A ANDREA A. MCCULLUM, C 2.40 1154 W. 25th Street Apt. 1 RRE 1.35 Erie, PA 16502 0.39 4.14 Page Totals: Cumulative Totals: 8 40 30.00 150.00 3.12 15.60 33.12 165.60 Page 5 ,. 0(- .. Travelers Bank & Trust FSB VS Patris;ia A. George and Steven A. George In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-4358 Civil Term Cpl. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on December 14,2006 at 1951 hours, 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: Patricia A. George, by making known unto Patricia A. George personally, at 236 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Cpl. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on December 14,2006 at 1951 hours, 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: Steven A. George, by posting the premises at 236 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania pursuant to order of court with the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 19,2007 at 2053 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Patricia A. George and Steven A. George located at 236 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Patricia A. George and Steven A. George, by regular mail to their last known address of236 Woods Drive, Mechanicsburg, P A 17055. These letters were mailed under the date of January 16, 2007 and never returned to the Sheriffs Office. So Answers: ?'~/~ "R. Thomas Kline, Sheriff B~{~ Real Estate Deputy . --.". GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. PATRICIA A. GEORGE and STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 06-4358 ORDER AND NOW, this ,!'II day o~ 2006, upon consideration of the Plaintiff's Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant, Steven A. George, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff andlor Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendant, Steven A. George, by posting a copy of the Complaint upon the premises 236 Woods Drive, Mechanicsburg, P A, 17055, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendant's last known address at 236 Woods Drive, Mechanicsburg, PA, 17055, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Steven A. George, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the pr~_ ~ ~ ~ r-;::.~Ir . BY. T: ~ I TRUE COpy FROM RECOHLJ n Testimony wber8of. I here unto III ..., haRo J. llCI the !!I' or said CouI1l at CarlIle. PI. · f~t2~~o<<, GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 ;Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-825-6320 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. PATRICIA A. GEORGE STEVEN A. GEORGE Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Term No. 06-4358 236 Woods Drive Mechanicsburg, P A 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 TRAVELERS BANK & TRUST FSB, 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: 236 Woods Drive Mechanicsburg, P A 17055 I.Name and address of Owner(s) or Reputed Owner(s): PATRICIA A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 2. Name and address ofDefendant(s) in the judgment: PATRICIA A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: .. DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 . . P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 UNIFUND CCR PARTNERS 10625 Techwood Circle Cincinnati, OH 45242 4. Name and address of the last recorded holder of every mortgage of record: BENEFICIAL CONSUMER DISCOUNT CO. D/B/A BENEFICIAL MORTGAGE CO. OF P A. 4910 Carlisle Pike Suite 104 Mechanicsburg, P A 17050 BENEFICIAL CONSUMER DISCOUNT CO. 961 Weigel Drive Elmhurst, IL 60126 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 236 Woods Drive Mechanicsburg, P A 17055 (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. DATED: February 21,2007 K McCAFFERTY & McKEEVER BY: os h A. Goldbeck, Jr., Esq. Attorney for Plaintiff C) r== l"-...) => C~.:) -...J o ." :T.!-n ["11- r:::: Iii C;; S~ i5~ --I )::~ ::::J -< -~ ~~ :'::~ ::;:; I CO -0 :'l: c..) N COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Travelers Bank & Tr FSB is the grantee the same having been sold to said grantee on the 7th day of March A.D., 2007, under and by virtue of a writ Execution issued on the 3rd day of Nov, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 4358, at the suit of Travelers Bank & Tr FSB against Patricia A George & Steven A is duly recorded in Deed Book No. 279, Page 1371. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this J-h day of ~ ,A.D. ~()1 ~ jJ IY~, oI,'f~~ ~of DIIdI. CumberIInd~, Cllllll.PA My Ctlmmllllo.. Exphs lie FIlII McIlIdayof__ Recorder of Deeds J Travelers Bank & Trust FSB VS Patricia A George and Steven A George ,. .. In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-4358 Civil Term Cp1. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on December 14,2006 at 1951 hours, he served a true copy ofthe within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant to wit: Patricia A George, by making known unto Patricia A George personal1y, at 236 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personal1y the said true and correct copy of the same. Cp1. Richard Smith, Deputy Sheriff, who being duly Sworn according to law, states that on December 14, 2006 at 1951 hours, 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: Steven A George, by posting the premises at 236 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania pursuant to order of court with the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 19,2007 at 2053 hours, he posted a true copy ofthe within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Patricia A George and Steven A George located at 236 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the fol1owing manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Patricia A George and Steven A George, by regular mail to their last known address of236 Woods Drive, Mechanicsburg, P A 17055. These letters were mailed under the date of January 16, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 07,2007 at 10:00 o'clock AM. He sold the same for the sum of$1.00 to Attorney Joseph Goldbeck, on behalf of Travelers Bank and Trust FSB. It being the highest bid and best price received for the same, Travelers Bank and Trust FSB, of, 1111 Northpoint Drive, Building Four (4), Suite 100 Coppel1, TX, 75019-3931, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$ 929.02. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy $30.00 18.22 15.00 15.00 30.00 10.00 .50 1.00 17.60 5.34 15.00 ... ) Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 30.00 355.00 305.03 16.83 25.00 39.50 $ 929.02 ./ 3/':J-?/01 C)- ;.~~~~ R. Thomas Kline, Sheriff B~ J~uL D-- J3~b~.,/ ~ 6-o~ 3{). /, ,::>0 (k. ~19~() ~Z.v, J 4D t I,t/ ., . . , Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney J.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 CoppeII, TX 75019-3931 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. PATRICIA A. GEORGE STEVEN A. GEORGE (Mortgagor(s) and Record Owner(s)) 236 Woods Drive Mechanicsburg, P A 17055 CNIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 06-4358 AFFIDAVIT PURSUANT TO RULE 3129 TRAVELERS BANK & TRUST FSB, 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: 236 Woods Drive Mechanicsburg, PAl 7055 I.Name and address ofOwner(s) or Reputed Owner(s): PATRICIA A. GEORGE 236 Woods Drive Mechanicsburg, PAl 7055 STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, PAl 7055 2. Name and address ofDefendant(s) in the judgment: PATRICIA A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 r -- , Carlisle, P A 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 UNIFUND CCR PARTNERS 10625 Techwood Circle Cincinnati, OH 45242 4. Name and address of the last recorded holder of every mortgage of record: BENEFICIAL CONSUMER DISCOUNT CO. DIB/ A BENEFICIAL MORTGAGE CO. OF P A. 4910 Carlisle Pike Suite 104 Mechanicsburg, P A 17050 BENEFICIAL CONSUMER DISCOUNT CO. 961 Weigel Drive Elmhurst, IL 60126 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 addre" of every other pernoo of whom the plaintiff has Imowledge who has aoy reeon! iotere" io the pmperty which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 236 Woods Drive Mechanicsburg, P A 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to e best 0 my personal knowledge or information and belief. I understand that false statements herein are made subj ct to the pe aIties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. cKEEVER DATED: November 1. 2006 ~ , 06-4358 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB III I Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW PATRICIA A. GEORGE STEVEN A. GEORGE Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 236 Woods Drive Mechanicsburg, P A 17055 Tenn No. 06-4358 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: GEORGE, PATRICIA A PATRICIA A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 Your house at 236 Woods Drive, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriff's Sale on Wednesday, March 07, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$222,372.03 obtained by TRAVELERS BANK & TRUST FSB against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to TRAVELERS BANK & TRUST FSB, 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. '"' , 06-4358 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 0017-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 " , 06-4358 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CNIL ACTION - LAW P A TRlCIA A. GEORGE STEVEN A. GEORGE Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 236 Woods Drive Mechanicsburg, PAl 7055 Tenn No. 06-4358 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. TO: GEORGE, STEVEN A STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, P A 17055 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Your house at 236 Woods Drive, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 07, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$222,372.03 obtained by TRAVELERS BANK & TRUST FSB against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to TRAVELERS BANK & TRUST FSB, 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. , I 06-4358 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 of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PAL 7013 . ALL THAT CERTAIN lot or piece of ground situate in Silver Spring Township, Cwnberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Northern side of Woods Drive said point being North and parallel to the existing center line of said Woods Drive and said point being the dividing line of Lots Nos. 9 and lOon the hereinafter mentioned Plan of Lots; thence along said dividing line North 13 degrees 35 minutes 31 seconds West 200.00 feet to a point on lands now or fonnerly of George N. Wade, Jr., thence along the dividing line of Lot No. 10 and lands now or formerly of George N. Wade, Jr., South 76 degrees 24 minutes 29 seconds West 100.00 feet to a point at the northwestern comer of Lot No. 10; thence along the dividing line of Lot No. 10 and the lands now or fonnerI y of George N . Wade, Jr., South 13 degrees 35 minutes 31 seconds East 200.00 feet to a point on the dedicated Northern side of Woods Drive; thence along the dedicated Northern side of Woods Drive North 76 degrees 24 minutes 29 seconds East 100.00 feet to a point, the place of beginning. BEING KNOWN AS 236 WOODS DRIVE, MECHANICSBURG P A 17055 TAX PARCEL NO: 38-20-1831-107 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 06-4358 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TRAVELERS BANK & TRUST FSB, Plaintiff (s) From PATRICIA A. GEORGE AND STEVEN A. GEORGE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $222,372.03 L.L. $.50 Interest FROM 11/2/06 TO DATE OF SALE AT 6.0000% Atty's Comm % Atty Paid $183.48 Plaintiff Paid Due Prothy $1.00 Other Costs Date: NOVEMBER 3, 2006 (Seal) By: REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 50000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Deputy Real Estate Sale # 52 On November 30,2006 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA Known and numbered as 236 Woods Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. VI e ~ ~ ~ Date: November 30, 2006 By: J 0 rI LI S'vvuJ:l, Real E~;tJ Sergeant 8 I :b V b - hON qUnZ . . "I j i ~.i :J l;' , ..L ::, ,) I ' t-"'. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever smce; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 24th and 31st day(s) of January and the 7th day(s) of February 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot~News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #52 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYL VANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: January 26, February 2 and February 9,2007 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. 52 Writ No. 2006~4358 Civil Travelers Bank & Trust FSB vs. Patricia A. George and Steven A. George Atty.: Joseph Goldbeck ALL 'IHAT CERTAIN lot or piece of ground situate in Silver Spring Township, Cumberland County. Pennsylvania, bounded and de- scribed as follows. to wit: BEGINNING at a point on the Northem side of Woods Drive said point being North and parallel to the existing center line of said Woods Drive and said point being the di- viding line of Lots Nos. 9 and 10 on the hereinafter mentioned Plan of Lots; thence along said dividing line North 13 degrees 35 minutes 31 eecon.de West 200.00 feet tQ...a.J!omt NOT AFML SEAL LOiS E. SNYDER, Notary Public Carli:;le 8ora, Cumberland County C')trrmssion Expires March 5. 2009 ,:il<,"~.),!'I.lfJr...~'::;;~'-