HomeMy WebLinkAbout06-5188GOLDBECK McCAFFERTY & McKEEVER
BY: JOSEPH A. GOLDBECK, JR.
ATTORNEY I.D.#16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 825-6318
W W W.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
oLp -.swp (2lf???? l
M&T MORTGAGE CORPORATION
I Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagors and Real Owners
110 E. Countryside Drive
Boiling Springs, PA 17007
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Defendants
CIVIL ACTFUN: MORTGAGE
CL6"LC
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES
NECESSARIO QUE USTED, 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 ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA 0 LLAME POR TELPEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, $STA 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, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
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 the following number: 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
MT-1070.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
Resources available for Homeowners in Foreclosure
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is M&T MORTGAGE CORPORATION, 1 Fountain Plaza, Buffalo, NY 14203.
2. The names and addresses of the Defendants are TIMOTHY C. KEANE, 110 E. Countryside Drive,
Boiling Springs, PA 17007 and NATALIE P. KEANE, 110 E. Countryside Drive, Boiling Springs, PA
17007, who are the mortgagors and real owners of the mortgaged premises hereinafter described.
On August 17, 2001 mortgagors made, executed and delivered a mortgage upon the Property hereinafter
described to M&T MORTGAGE CORPORATION, which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County as Book 1731, Page 2497. The Mortgage and assignment(s)
are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule
of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to
pleadings if those documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for April 01, 2006 and each month thereafter and by the terms the Mortgage, upon default 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 03/01/2006
through 09/30/2006 at 6.7500%
Per Diem interest rate at $43.71
Reasonable Attorney's Fee at 5% of Principal Balance as
more fully explained in the next numbered paragraph
Late Charges from 04/01/2006 to 09/30/2006
Monthly late charge amount at $106.92
Costs of suit and Title Search
Escrow
Corporate Advance
Monthly Escrow amount $348.07
$236,367.62
$9,353.94
$11,818.38
$641.52
$900.00
$2,064.07
$100.00
$261,245.53
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
Sheriffs 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 personam" 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 terris judgment in mortgage foreclosure in the sum of $261,245.53,
together with interest at the rate of $43.71, 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: a-k Q
G K McCAFFERTY & McKEEVER
JOS A. GOLDBECK, JR., ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
I, Tara Weller, as the representative of the Plaintiff corporation within named do hereby
verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and
the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein are made subject to the penalties of
18 Pa. C.S. 4904 relating to unworn falsification to authorities.
Date: O-K-66 /
JO-U??-
Tara Weller
M&T Mortgage Corporation
E?Q-hibit,g
EXHIBIT A - LEGAL DESCRI1r
110 East Countryside Drive
Boiling Springs PA 17007
ALL that certain tract of land situate in South Middleton Township, Cumberland County
Pennsylvania, bounded and described as follows:
BEGINNING at a point located on the northern right of way line of East Countryside Drive, (50 foot
right-of-way), said point beingrefereaced from the centerline intersectionof Jane Lane(50 foot right-
of-way) and East Countryside Drive by the following: from said intersection along centerline ofEast
Countryside Drive, South 87 degrees 18 minutes 49 seconds East, a distance of 163.00 feet to a
point; thence across East Countryside Drive, North 02 degrees 41 minutes it seconds East, a
distance of 25.00 feet to a point on the southern right-of-way line of East Countryside Drive at the
southeast comer of Lot# 38 and the Point of Beginning; thence along the East side of Lot No. 38,
North 02 degrees 41 minutes 11 seconds East, a distance of 121.05 feet to a point; thence along the
South side of Lot No. 33, South 87 degrees 18 minutes 49 seconds East, a distance of 134.00 feet to
a point; thence along the West side of Lot No. 40, South 02 degrees 41 minutes 11 seconds West,
a distance of 121.05 feet to a point on the northern right-of-way of East Countryside Drive; thence
along said right-of-way, North 87 degrees 18 minutes 49 seconds West, a distance of 134.00 feet to
the Point of BEGINNING.
BEING Lot No. 39 of the Plan of Lots known as Misty Meadows, Phase 1 as recorded on the Office
of Recorder of Deeds for Cumberland County, in Plan Book 77, Page 95; containing 16,220.05
square feet.
SUBJECT to building and use restrictions set forth in Miscellaneous Book 606, Page 1009
BEING the samepremiscs which Misty Meadows Partnership, A Pennsylvania General Partnership,
by Deed Dated December 20, 1999 and recorded in the Office of Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Record Book 213, Page 584, granted and conveyed unto
Lonetree, Inc.
AND BEING the same premises which Lonetree, Inc. by deed dated and recordedeven date herewith
in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, granted and
conveyed unto Timothy C. Keane and Natalie P. Keane, husband and wife, Mortgagors herein.
I Certify this to be recorded
In Cumberland County PA
- ,, 3 `.'r of i?crds
Ex,ohibit B
.. ..
M&T Mortgage Corp.
- P.O. Box 1188 ®Ma$Ca'(IO['>DQ
Buffalo, NY 14240-1288
06/12/2006
Natalie P Keane
110 E Countryside or
Boiling Springs, PA 17007
M MWMERS NAME(S): Netall• P steers
Tism,thy c Ketone
PROPERTY A00RESS: 110 Cast CatRatrYaid DO
Soiling SPwirtpa, PA 17007
MAN ACCT N0: 0072900809
CURRENT LOUR/gERWCCR: Mar NPrtplBa OWWMt/an
Certified No.: 71826389306008362149
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAy BE • 1 ® £ FOA FINAN At A4aIRT Nrr WHI H AN SA{ YO m HOA'F FROM
FOR£ iR AND .PYO 1 M Y£ FIITrm MQ 1?C' -AGE FAYMEya;T?y
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT') YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES
BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY
YOUR MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS
ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under otc Act,!
on your mortgage far thirty (30) days from the date of ails Notice.
"feco-t fm"mmmig with one of the consumer =edit cotuoelina
CONSUMER CREpPT CO tNa: LING AGENCIES
agency listed et the end ofthia mtiEm, the ]alder may NOT
untitled m a temporarystey of Suec6nure
that time you must arrange and attend a
as listed a the and of this Notice. 33M
of the coneuner ciedit counseling
ou for thirty (30) days aliar the data
one
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AI=6P0a secount hWn4UOnJW a dick away www.mwgn criampa.cmn
? y
M Mortgage Corp. ®m,
P.O. Box 1236
Buffalo,NY 14240-1288
06/122006
Timothy C Keane
110 E Comtrygide Dr
Boiling Springs, PA 17007
HOMEOWNERS MME(S): Time" 0 Knne
Matalle P Karon,
PROPERTY ADDRESS: 110 Seat CantrySldO DM
Selling Springs, PA 17001
LOIN ACCT NO: 0008 OM2
CuRREMT LENDER/SERVICER: MIT RertgRBR COrperlatim
Certified No.:
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CL1. ARSIRTAN E WIlI B N AVE YO R ROME FROM
YO Y E I I IAN, . 11 1. 1!
FORPLI ARIIRR AND NR:LP VOII MAIeF FrITI1RF MORTC?CF. P?VMENTg
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT'j YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
IF YOUR DEFAULT RAS BEEN CAUSED BY CIRCUMSTANCES
BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY
YOUR MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS
ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the AQ you e2 entitled to a Mnpomy ANY of fnrecloNAnt
m your mortgage for thirty (30) days from the data of this Notice. During to time you must arrange end attend a
"Faco-to-fae"meeting with one of the consumer aedit eolmael'mR amcies listed a the and of this Notice. THIS
me of the corDUnar credit cottoseling
Mt You for thirty (30) days after the date
one
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modpw sarongs mlomtKbn,lust a -ft away. www.msncwona pa.mn,
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IF TRF MORTGA - . IS FORECLOSED UPON - The moRgaged propertywi0 be sold by the Sheriff to payoff
the mortgage debt. If the leader refers your can to its atioraeys, but you ewe the delinquency before the lender
begins legal proceedings against you, you will still be required to pry the reasonable abomey'afees that were
actually inO ned, up to $50.00. However, iflegal proceedings are started against you, you will have to pay all
reasonable abomey's fees actually mounted by the lender even if they exceed $50.00. Any attomey'sfees will be
added to the amount you owe the leader, which may also include other reapnabie costa, if you care the dernalt
within the THIRTY (30) DAY period, you will not be required m pay attorney's fees.
OTHER LI!t4ORR REMRDTES _ The leader may also sue you personally for the unpaid principal balance and all
ndrer sums due under the mortgage.
RI .HT TO RF F DEFA LT PRIOR TO SHERRFFFO. SALE _ ifyou have not cured the default within
the THIRTY (30) DAY period end foreclosure proceedings have began, you still have the right to care the default
and prevent the sale at any time up to me hour before the Sherift'sSale. You may do so by paying the total amount
then past due, plus any late or other charges than due, reasonable aaomey'sfear and cods connected with the
foreclosure sale and my other costa connected with the Sheriffs Sale as specified in writing by the leader and by
performing my other requirements under the mortgage. Curing your default is the muuer set forth in this
notice will restore your mortgage to the same position as if you laid never defaulted.
EARLIEST POSSIBLE SHERIFFS SALE DATE - It is estimated that the earliest data that such a Sherift'sSele
of the mortgaged property could be held would be aplimdmately 10 months from the date of this Notice. A
notice of the actual date of the SberiffsSale will be seat to you before the able. Of course, the amount needed to
core the default will increase the longer you wait. You may find out at my time exactly what the required payment
or action will be by cont4co ng the leader.
HOW TOT ONTA T THE .END U
Name of Lender, M&T Mortgage Corporation
Addrann P.O. Box 840
Buffalo, NY 14340
Phone Number: (800) 734.1633
EFFECT OF SHERIFF'S SALT -You timid realize that a ShorifPBSale will end your ownership ofdre
mortgaged property and your right to occupy it. Ifyou continue to live to the property after the SbeciffsSale, a
lawsuit to remove you and your furnishings and other belongings could be started by the leader at my time.
ARSUMPTON OF MOR1'GAf.E - You _ may m.9 may am sell er transfer your home to abuyer or
moral ee who wall worse the mortgage debt, provided that all the outstanding payments, charges and attorney's
fees and costs are paid prior to or at the sale and that the other requirenats of the mortgage ate mtafied
VO AYA - A?,THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE TI IAN THREE TIMES IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
TO ASSERT ANY OTHER DEFENSE, YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
sincerely, '
??-%4 9.-Ae.
Russell M. Alessi Jr.
Collwmas Manager
Enc: Act 91 Notice
Consumer Credit Contacting Agencies Serving Your County
1 ants Ile 1633 Cwrsapwnsnca - P.O. Box 610, au8do. N1' 10240.0140 PsOnMea • P.O. Bea 82192, Batlmere, MD 212642182
kiwlpape aeeeunt kd"arcn,(uat a tick away. wew.mwManwrpspa.mm
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[F ME MOR A -R K FORFr112M UPON -The mortgaged propetywill be sold by the Sheriff to payoff
the mortgage debt. If the lend" refers your aso wits atiomeys, bw you core the delinquency before the lender
begins legal proccadmgs egamat you, you will still be required to pay the reasonable artomney'sfem that were
actually incurred, up to 550.00. However, if legal proceedings are starred against you, you will have in pay all
mawneble stn mey'sfem actually mcumd by the lender even if they exceed SS0.00. Any attmney'sfees will be
added to the amount you owe the leader, which may also include other reasonable cab. If you cure the default
within the THIRTY (30) DAY period, you will not be required to pay attoroey's fem.
.OTHER .E R EM DI S -The lender may also sue you personally for the unpaid principal balance and all
other sums due under the mortgage.
511%9 n F THE D D.T IOR TO SmFASFF'c cp .E - If you have not cm'ed the default within
(30) DAY period and foreclosum proceedings have begun, you still have the right to cure the default
and prevent the sale at soy time up m one hour before the Sheriff's Sale. You may do so by paying the total amount
than past due, plus any late or other charges than due, reasonable anomey'sfem and coats connected with &a
foreclosure wit and my other coats connected with the Sheriffs Sale m specified in writing by the lender and by
performing soy other requirements under the mortgage. Curing your default in the summer set forth In this
notice will restore your mortgage to the same position as if you had never defaulted.
F.AAI.IF. T ®7.. c RRFF'S SAL DATE - It is estimated that the earliest data that such a Sherifi'sSale
of mortgaged property ouldbe held would be approximately 10 months from the date of this Notim. A
notice of the actual date of the SheaiffsSale will be emu to you befom the sale. Of course, the ammmt needed to
cure the default will increase the longer you wait. You may find out at soy time =wily what the required payment
or action will be by contacting the leader.
HOW TOCONTACTTHE dEMM'
Nam of Lender: M&T Mortgage Corporation
Address: P.O. Box 810
Buffalo, NY 14240
Phone Number: (800) 724-1633
EFFFrT OF S?HrAIFF'S SALE -You should reagre that a SheriffsSek will and yew ownership of the
mortgaged property and yow right to occupy it If you consume to live in the property after the Sheriffs Sale, a
lawsuit to remove you and your furnishings and other belongings could be started by the leader at soy time.
ASSUMPTION OF MORTGAGE - You may" X may not Sell or transfer your home to a buy" or
transferee who will assume the mortgage debt, provided that all the outstanding psyments, charges and attorney's
fees and cats are paid prim to oat The sale and that the other requirements of the mortgage are mtisFied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE TI IAN THREE TIMES IN ANY CALENDAR YEAR.)
v 1W
Homeowners Emergency Assistance Program
Cumberland County
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ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
Thh Is v Official eti that the mode on v home . ?• ed the 4adK lataadf m faredose.
-'° i ft tien bo t tha ! cth deg M b brovidedlo the ?• aed
The HOMEO R'SMORTCA 6 ASSISTANCE PROGRAM MAPI . be able to help to sove
your hope. This Notice er_abL how the eroerem worha
This Notice coenioa important legal Information. If you bays any 4uestions6 representatives at the
Consumer Credit Coumeltag Agency may be able to help erpnla h. YOU may also want to contact ap
attorney In your arm. The kcal bar association may be able to help you And a lawyer.
LA NOTIFICACION EN ADJUNTO IS DE SUKA IMPORTANCtA. PLIES AFECTA SU DERECRO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTRNIDO DE ESTA
NOTIFICACION OATENGA UNA TRADUCCION UVMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRBA. PUEDES SER ELEGIRLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO -HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
1 B W M4103 C.onw oftd es -P.O. BM MO. Bumb, W 14240-0840 Payments, P.O. Ann 82182. Bmimam, MD 21280.2182
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pppt IrAT. HLaN FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the resaons set forth later
in this Notice (era following pages forapecige injor mon about the mature ofyour defmIL) Ifyou have tried and
art 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 an, you moat fill our. sip and file a completed
Homeowner'sEmergency Assistance Program Application with one ofthe designated commuter credit counseling
agencies listed at the and ofthis Notice. Only comumcrr 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 postmarkW within thirty (30) days ofyour face-to-fece meeting.
YOU2EM FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER FORECLOSURE MAY
PROCEED AGAINST YOUR HOME WMEDIATELY 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 yew application. Doing dust time, no foreclosure proceedings
will be pursued against you ifyoa have out the time requirements set forth above. You will be notified directly by
the Pennsylvania Housing Finance Agency ofits decision On your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES
ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(It you have flied bankruptcy you can sWl apply for Emergency Mortgage AssistamaJ
HOW TO CURE YOUR MORTGAGE DEFAULT (arise k ass W daesL
NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located a
110 east coon"itle Orl
Bailing Springer. PA 17007
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MORTGAGE PAYMENTS for the following months and the following amounts am
now past due:
angular payaarto Of x2136.38 for also nmrths Of 04/01/3008
through today's rota: 8 8784.08
Other msorges: Act: Late Charges: a U2. 04
Accrued OtMr I WVM a 37.50
TOTAL AVaUW PAST CK: 5 7124.10
HOW TOC eTHE EFA ILT-You may core the default within THIRTY (30) DAYS of the data of this
5!HY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDRR, WHICH IS $7124.20. PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must by rnado eitheir by hark certified chock gitla me& navable and jillb. gent m:
M&T Mortgage Corporation
One Fous aim Plaza / Ilk Floor
Attn: Payment Processing
Baffelo, NY 14203
You c other d_•fa .lt by t•4' the following actim within THIRTY (10) DAYS Ofthe data ofhhia lever
ft !dm, NOT CURE THE DEFAULT-If you do not cos the default within THIRTY (30) DAYS ofthe date
ofthie Notice, the tender Intends to merges no rights to acrelerau the mortgage debt. This moan, that the entire
outstanding balance of this debt will be considered due immediately and you may ban the chance mpay the
mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also inands to Instruct its attorneys to am legal action to foreclose upon your mortgaged
Property
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In the Court of Common Pleas of Cumberland County
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
(Mortgagor(s) and Record Owner(s))
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
PRAECIPE FOR JUDGMENT
No. 06-5188
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 TIMOTHY C. KEANE and NATALIE P. KEANE by default
for want of an Answer.
Assess damages as follows:
Debt
Interest from 10/17/06 to Date of Sale
Total
(Assessment of Damages attached)
$262,399.88
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivered t th p against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at leas t prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
Joseph A. 19,
Attorney for
I.D. #16132
AND NOW /V ?. 2_ ?- ment is entered in favor of M&T
MORTGAGE CORPORATION and against TIMOTHY C. KEANE and NATALIE P. KEANE by default for want of an
Answer and damages assessed in the sum of $262,399.88 as per the above certifica ' n.
Pro otary
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Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
(Mortgagors and Record Owner(s))
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
No. 06-5188
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
Curt Long
Prothon
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, PA 19106
215-627-1322
MT-1070
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 4, 2006
TO:
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
M&T MORTGAGE CORPORATION
1 Fountain Plaza.
Buffalo, NY 14203
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
(Mortgagor(s) and Record Owner(s))
110 E. Countryside Drive
Boiling Springs, PA 17007
TO: NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Plaintiff
Defendant(s)
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 06-5188
IMPORTANT NOTIC R
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
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
?OsexvFr;. Taa&c?r
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
MT-1070
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 4, 2006
TO:
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
(Mortgagor(s) and Record Owner(s))
110 E. Countryside Drive
Boiling Springs, PA 17007
TO: TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Plaintiff
Defendant(s)
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 06-5188
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
;?ase.?rhr,?, sa?clf?ec?r
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 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, TIMOTHY C. KEANE, is
about unknown years of age, that Defendant's last known
residence is 110 E. Countryside Drive, Boiling Springs, PA
17007, 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' Ci 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, NATALIE P. KEANE, is
about unknown years of age, that Defendant's last known
residence is 110 E. Countryside Drive, Boiling Springs, PA
17007, 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 Oot rwi se within the
provisions of the Soldiers' and SailorsRelief Action of
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, PA 19106
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
(Mortgagor(s) and Record owner(s))
110 E. Countryside Drive
Boiling Springs, PA 17007
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 06-5188
ORDER FOR JUDGMENT
Please enter Judgment in favor of M&T MORTGAGE CORPORATION, and against TIMOTHY C.
KEANE and NATALIE P. KEANE for failure to file an Answer in the above a within (20) days (or sixty
(60) days if defendant is the United States of America) from the date of servi a of Cj laint, in the sum of
$262,399.88.
Joseph A. G
Attorney for
I hereby certify that the above names are correct and that the pr id ce address of the judgment
creditor is M&T MORTGAGE CORPORATION 1 Fountain Plaza Buf lo, NY 1 203 and that the name(s) and
last known address(es) of the Defendant(s) is/are TIMOTHY C. KE , 110 E Countryside Drive Boiling
Springs, PA 17007 and NATALIE P. KEANE, 110 E. Countryside Driv Boil' g Sprin s, PA 17007;
GOLDBECK M AFFE Y & McKEEVER
BY: Joseph A. oldb , Jr.
Attorney for PI i0ify,
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $236,367.62
Interest from 03/01/2006 through $10,053.30
10/16/2006
Reasonable Attorney's Fee $11,818.38
Late Charges $748.44
Costs of Suit and Title Search $900.00
Escrow $2,412.14
Corporate Advance $100.00
88
GOLDBECK McC ERTi
BY: Joseph A. Gold eck, Jr.
Attorney for Plainti /
AND NOW, this Z day of / 10V, , 2006 damages are assessed as above.
Pro Prothy
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or PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-5188
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from 10/17/06
to Date of Sale at
6.7500%
(Costs to be added)
$262,399.88
GOLDBECK McC FERTY McKEEVER
BY: Joseph A. Gol beck, Jr.
Attorney for Plainti
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All that certain tract of land situate in South Middletown Township, Cumberland County, Pennsylvania,
bounded and described as follows:
Beginning at a point located on the northern right of way lien of East Countryside Drive, (50 foot right-
of-way), said point being referenced from the centerline intersection of Jane Lane (50 foot right-of-way)
and East Countryside Drive by the following: from said intersection along centerline of East
Countryside Drive, South 87 degrees 18 minutes 49 seconds East, a distance of 163.00 feet to a point;
thence across East Countryside Drive, North 02 degrees 41 minutes 11 seconds East, a distance of 25.00
feet to a point on the southern right-of-way line of East Countryside Drive at the southeast comer of Lot
#38 and the point of beginning; thence along the East side of Lot No. 38, North 02 degrees 41 minutes
11 seconds East, a distance of 121.05 feet to a point; thence along the South side of Lot No. 33, South
87 degrees 18 minutes 49 seconds East, a distance of 134.00 feet to a point; thence along the West side
of Lot No. 40, South 02 degrees 41 minutes 11 seconds West, a distance of 121.05 feet to a point on the
northern right-of-way of East Countryside Drive; thence along said right-of-way, North 87 degrees 18
minutes 49 seconds West, a distance of 134.00 feet to the point of beginning.
Being Lot No. 39 of the Plan of Lots known as Misty Meadows, Phase 1 as recorded on the Office of
Recorder of Deeds for Cumberland County, in Plan Book 77, page 95; containing 16,220.05 square feet.
Subject to building and use restrictions set forth in Miscellaneous Book 606, page 1009.
TAX PARCEL NO: 40-10-0638-063
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WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183 AND Rule 3257
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Commonwealth of Pennsylvania:
County of Cumberland
To the Sheriff of Cumberland County, Pennsylvania
In the Court of Common Pleas of
Cumberland County
No. 06-5188
WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the
following described property:
PREMISES: 110 E. Countryside Drive Boiling Springs, PA 17007
See Exhibit "A" attached
AMOUNT DUE
Interest From 10/17/06
Through Date of Sale
(Costs to be added)
$262,399.88
Dated:
Prothonotary, Common Pleas Court
of Cumberland County, Pennsylvania
Deputy
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All that certain tract of land situate in South Middletown Township, Cumberland County, Pennsylvania,
bounded and described as follows:
Beginning at a point located on the northern right of way lien of East Countryside Drive, (50 foot right-
of-way), said point being referenced from the centerline intersection of Jane Lane (50 foot right-of-way)
and East Countryside Drive by the following: from said intersection along centerline of East
Countryside Drive, South 87 degrees 18 minutes 49 seconds East, a distance of 163.00 feet to a point;
thence across East Countryside Drive, North 02 degrees 41 minutes 11 seconds East, a distance of 25.00
feet to a point on the southern right-of-way line of East Countryside Drive at the southeast corner of Lot
#38 and the point of beginning; thence along the East side of Lot No. 38, North 02 degrees 41 minutes
11 seconds East, a distance of 121.05 feet to a point; thence along the South side of Lot No. 33, South
87 degrees 18 minutes 49 seconds East, a distance of 134.00 feet to a point; thence along the West side
of Lot No. 40, South 02 degrees 41 minutes 11 seconds West, a distance of 121.05 feet to a point on the
northern right-of-way of East Countryside Drive; thence along said right-of-way, North 87 degrees 18
minutes 49 seconds West, a distance of 134.00 feet to the point of beginning.
Being Lot No. 39 of the Plan of Lots known as Misty Meadows, Phase 1 as recorded on the Office of
Recorder of Deeds for Cumberland County, in Plan Book 77, page 95; containing 16,220.05 square feet.
Subject to building and use restrictions set forth in Miscellaneous Book 606, page 1009.
TAX PARCEL NO: 40-10-0638-063
,-r,
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
I Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
(Mortgagor(s) and Record Owner(s))
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-5188
AFFIDAVIT PURSUANT TO RULE 3129
M&T MORTGAGE CORPORATION, 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:
110 E. Countryside Drive
Boiling Springs, PA 17007
1.Name and address of Owner(s) or Reputed Owner(s):
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
2. Name and address of Defendant(s) in the judgment:
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
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
4 .%
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
BENEFICIAL MORTGAGE CO. OF PA
961 Weigel Drive
Elmhurst, IL 30126
BENEFICIAL CONSUMER DISCOUNT CO. DB/A BENEFICIAL MORTGAGE CO. OF PA.
419 Village Drive
Suite 2
Carlisle, PA 17013
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
110 E. Countryside Drive
Boiling Springs, PA 17007
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the est of oral knowledge or
information and belief. I understand that false statements herein are made subject t the p ties 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: October 16, 2006
GOLDBECK McC FERTY &
BY: Joseph A. Gol beck, JAttorney for Plaintiff
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06-5188
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-5188
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: KEANE, TIMOTHY C.
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Your house at 110 E. Countryside Drive, Boiling Springs, PA 17007 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 $262,399.88 obtained by M&T MORTGAGE
CORPORATION 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 M&T MORTGAGE CORPORATION, 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.
?,. 06-5188
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
_ f} A I
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06-5188
GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff'
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-5188
Defendants
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: KEANE, NATALIE P.
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Your house at 110 E. Countryside Drive, Boiling Springs, PA 17007 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 $262,399.88 obtained by M&T MORTGAGE
CORPORATION 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 M&T MORTGAGE CORPORATION, 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.
06-5188
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
N
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Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
I Fountain Plaza
Buffalo, NY 14203
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Plaintiff
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
Defendant(s)
ACTION OF
MORTGAGE FORECLOSURE
NO. 06-5188
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney c
action, and I further certify that this property is subject to Act 91 of 1983 and the
the provisions of the Act.
Joseph A. Go
Attorney for
for the Plaintiff in this
bas complied with all
Jr.
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co
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N006-5188 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due M&T MORTGAGE CORP. Plaintiff (s)
From TIMOTHY C. AND NATALIE P. KEANE,110 E. COUNTRYSIDE DR., BOILING
SPRINGS PA 17007
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 110 E. COUNTRYSIDE DR., BOILING SPRINGS PA 17007 (SEE LEGAL
DESCRIIPTION).
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $262,399.88
Interest FROM 10/17106 TO 3/7/07 @ 6.7500%
Atty's Comm %
Atty Paid $130.40
Plaintiff Paid
Date: NOVEMBER 2, 2006
L.L. $.50
Due Prothy $1.00
Other Costs
Curti Long, onotary(Seal)
REQUESTING PARTY:
Name JOSEPH A. GOLDB ECK, JR., ESQ.
Address: SUITE 5000, MELLON INDEPENDENCE CENTER
701 MARKET ST., PHILADELPHIA PA 19106
Attorney for: PLAINTIFF
Telephone: (215) 627-1322
Supreme Court ID No. 16132
By:
Deputy
CASE NO: 2006-05188 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
M&T MORTGAGE CORPORATION
VS
KEANE TIMOTHY C ET AL
KENNETH GOSSERT
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within NOTICE was served upon
KEANE TIMOTHY C
the
DEFENDANT , at 0019:45 HOURS, on the 13th day of September, 2006
at 110 E COUNTRYSIDE DRIVE
BOILING SPRINGS, PA 17007
TIMOTHY KEANE
a true and attested copy of NOTICE
COMPLAINT IN MORTGAGE FORECLOSURE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00 So Answers: ,
4.40
.00
10.00 R. Thomas Kline
32.40,/ 09/14/2006
h+14JuL, C?- GOLDBECK, MCCAFFERTY, MCKEEVER
Sworn and Subscibed to By:
before me this day
of , A. D.
by handing to
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-05188 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
M&T MORTGAGE CORPORATION
VS
KEANE TIMOTHY C ET AL
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within NOTICE was served upon
KEANE NATALIE P the
DEFENDANT , at 0019:45 HOURS, on the 13th day of September, 2006
at 110 E COUNTRYSIDE DRIVE
BOILING SPRINGS, PA 17007 by handing to
TIMOTHY KEANE
a true and attested copy of NOTICE
COMPLAINT IN MORTGAGE FORECLOSURE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 6.00 Service .00
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
16.00 09/14/2006
GOLDBECK, MCCAFFERTY, MCKEEVER
Sworn and Subscibed to By:
before me this day r1f
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
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and
Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
MT-1070
CF: 09/06/2006
SD: 03/07/2007
$262,399.88
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 06-5188
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants of the Notice of Sheriff Sale was made by:
( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached).
Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S.
Section 4904.
Cesr t u
B Jo h A. oldbeck, Jr.
At orn r or Plaintiff
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UMITEOSTAT S
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POSTAL SERVICE,&
Date Produced: 11/20/2006
GOLDBECK MCCAFFERTY & MCKEEVER <.- (n
The following is the delivery information for Certified item number 7111 4342 3630 0003 0794.
Our records indicate that this item was delivered on 11/16/2006 at 11:27 a.m. in BOILING
SPRINGS, PA, 17007. The scanned image of the recipient information is provided below.
?b?ery soon
Signature of Recipient:
ti
Address of Recipient:
Thank you for selecting the Postal Service for your mailing needs. If you require additional
assistance, please contact your local post office or Postal Service representative.
Sincerely,
United States Postal Service
The customer reference number shown below is not validated or endorsed by the United
States Postal Service. It is solely for customer use.
Customer Reference Number: 4340453 16625576
A - /0?0
UvtrEasTATEs
rOsrnt sERVXE.
Date Produced: 11/20/2006
GOLDBECK MCCAFFERTY & MCKEEVER
The following is the delivery information for Certified item number 7111 4342 3630 0003 0985.
Our records indicate that this item was delivered on 11/16/2006 at 11:27 a.m. in BOILING
SPRINGS, PA, 17007. The scanned image of the recipient information is provided below.
?W umon
Signature of Recipient:
Address of Recipient:
Thank you for selecting the Postal Service for your mailing needs. If you require additional
assistance, please contact your local post office or Postal Service representative.
Sincerely,
United States Postal Service
The customer reference number shown below is not validated or endorsed by the United
States Postal Service. It is solely for customer use.
Customer Reference Number: 4340453 16625576
GOLDBECK MCCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129
Term
No. 06-5188
M&T MORTGAGE CORPORATION, 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:
110 E. Countryside Drive
Boiling Springs, PA 17007
1.Name and address of Owner(s) or Reputed Owner(s):
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
2. Name and address of Defendant(s) in the judgment:
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
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
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
BENEFICIAL MORTGAGE CO. OF PA
961 Weigel Drive
Elmhurst, IL 30126
BENEFICIAL CONSUMER DISCOUNT CO. DB/A BENEFICIAL MORTGAGE CO. OF PA.
419 Village Drive
Suite 2
Carlisle, PA 17013
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
110 E. Countryside Drive
Boiling Springs, PA 17007
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unworn falsification to authorities.
DATED: February 21, 2007
GO BE MCCAFFERTY McKEEVE
BY tics A. Goldbeck, Jr., Esq.
Attorney r Plaintiff
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GOLDBECK WCAFFERTY & McKEEVER
A Professional Corporation
BY: Lisa A. Lee, Esquire
Attorney I.D.#78020
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P. KEANE
Mortgagors and Record Owners
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendants
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
NO. 06-5188
MOTION TO COMPEL SHERIFF ITO SCHEDULE A SHERIFF'S SALE
Plaintiff, M&T MORTGAGE CORPORATION, by and through its attorneys, Goldbeck
McCafferty & McKeever, moves this Honorable Court for an Order to Compel the Sheriff of Cumberland
county to schedule a Sheriff's Sale and in support thereof states:
1. Plaintiff instituted an Action in Mortgage Foreclosure under the above caption with the
filing of a complaint in foreclosure on September 6,!, 2006.
2. Judgment was entered on November 2, 2006 in the amount of $262,399.88.
3. The property located at 110 E. Countryside Drive, Boiling Springs, PA 17007 (the
"Property") was scheduled to be sold at the March 2007 Cumberland County Sheriff's Sale.
4. The March 7, 2007 Cumberland Cooty Sheriff's Sale was voluntarily postponed to April
4, 2007 by Plaintiff to allow the Defendant additional time to reinstate the mortgage loan.
5. The Defendant failed to reinstate the mortgage loan before the scheduled April 4, 2007
Sheriff's Sale.
6. In an effort to amicably resolve this matter and further allow additional time for the
Defendant to reinstate the mortgage loan, Plaintiff again postponed the sale to June 13, 2007.
Plaintiff stayed the June 13, 2007 Cumberland County Sheriff s Sale to once again allow
e
the Defendant time to reinstate the mortgage loan.
8. To date, Defendant has failed to reinstate the loan despite his assurances to Plaintiff that
he would do so.
9. The Sheriff's cutoff for listing the Property for the September 5, 2007 Cumberland
County Sheriff's Sale was June 6, 2007.
10. The next available sale date is December 5, 2007.
11. Plaintiff avers that it will be harmed if it is required to wait until December to execute on it
collateral.
12. Plaintiff filed a new Writ of Execution on or about July 2, 2007.
13. It is Plaintiff's understanding that it has not missed the publishing deadline or the printing of
the handbill required for listing the Property for the September 5, 2007 Cumberland County Sheriff's
Sale.
14. Plaintiff now moves this Honorable Court for an Order directing the Sheriff to schedule
the Property for the September 5, 2007 Cumberland, County Sheriff's Sale.
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order directing the
Sheriff of Cumberland County to set the Property located at 110 E. Countryside Drive, Boiling Springs, PA
17007 for the September 5, 2007 Cumberland County Sheriff's Sale.
Respectfully submitted,
GOLDBECK McCAFFERTY & McKEEVER
By:
Lisa A. Lee Xsquire
Attorney for Plaintiff
VERIFICATION
Lisa A. Lee, Esquire, hereby states that she is the attorney for Plaintiff herein, and that all of the
facts set forth within the attached Motion to Compel Sheriff to Schedule a Sheriff's Sale true and correct
to the best of her knowledge, information and belief. The undersigned understands that the foregoing
statements are made subject to the penalties of 18 P.S. Section 4904.
GOLDBECK cCAFFERTY McKEEVER
By: Lisa A. Lee, Esquire
Attorney for Plaintiff
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GOLDBECK McCAFFERTY & McKEEVER
A Professional Corporation
BY: Lisa A. Lee, Esquire
Attorney I.D.#78020
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
vs.
IN THE COURT OF COMMON PLEAS
Plaintiff
OF Cumberland COUNTY
TIMOTHY C. KEANE and NATALIE P. KEANE
Mortgagors and Record Owners
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendants
NO. 06-5188
CERTIFICATE OF SERVICE
Lisa A. Lee, Esquire, attorney for Plaintiff herein, does hereby certify that true and correct copies
of the foregoing Motion to Compel Sheriff to Schedule a Sheriff's Sale and all supporting papers attached
hereto were served upon the following:
TIMOTHY C. KEANE R. THOMAS KIM
NATALIE P. KEANE OFFICE OF THE SHERIFF
110 E. Countryside Drive CUMBERLAND COUNTY
Boiling Springs, PA 17007 l COURTHOUSE SQUARE
CARLISLE, PA 17013
via overnight mail, postage prepaid, on July 6, 2007.
GOLDBECK McCAFFERTY & McKEEVER
By: Lisa . Lee, ire
Attorney for Plai iff
4W 4%
GOLDBECK WCAFFERTY & McKEEVER
By: Lisa A. D'Angeli, Esquire
Attorney I.D. No. 78020
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627 -1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
Plaintiff
V.
TIMOTHY C. KEANE
NATALIE P. KEANE
IN THE COURT OF
COMMON PLEAS OF
CUMBERLAND COUNTY
:NO. 06-5188
Defendants
PLAINTIFF'S AMENDMENT TO ITS MOTION TO
COMPEL SHERIFF TO SCHEDULE A SHERIFF'S SALE
Plaintiff, M&T MORTGAGE CORPORATION, by and through its attorneys, Goldbeck
McCafferty & McKeever, hereby files the instant amendment to its previously filed Motion to
Compel Sheriff to Schedule a Sheriffs Sale in accordance with Cumberland County Local Rule
2083(a)(9), and in support thereof avers as follows:
1. Upon information and belief, Plaintiff submits that no judge has ruled upon any other
issue in this or any other related matter.
2. Plaintiff's counsel did not seek the concurrence of the Defendants as they are pro se.
Plaintiff's counsel did seek the concurrence of the Office of the Sheriff. Plaintiff's
counsel left a telephone message for the Sheriffs solicitor, but has not received a
return call.
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order directing
the Sheriff of Cumberland County to set the Property located at 110 E. Countryside Drive, Boiling
Springs, PA 17007 for the September 5, 2007 Cumberland County Sheriff s Sale.
Respectfully submitted,
GOLDBECK McCAFFERTY & McKEEVER
By: BOA I
isa A. Lee, Esquire
Attorney for Plaintiff
^. .
VERIFICATION
Lisa A. Lee, Esquire, hereby states that she is the attorney for Plaintiff herein, and that all
of the facts set forth within the attached Amendment to Plaintiff s Motion to Compel Sheriff to
Schedule a Sheriff's Sale true and correct to the best of her knowledge, information and belief.
The undersigned understands that the foregoing statements are made subject to the penalties of
18 P.S. Section 4904.
i
GOLDBECK WCAFFERTY McKEEVER
By: Lisa A. Lee, Esquire
Attorney for Plaintiff
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GOLDBECK McCAFFERTY & McKEEVER
A Professional Corporation
BY: Lisa A. Lee, Esquire
Attorney I.D.#78020
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza.
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE
P. KEANE
Mortgagors and Record Owners
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendants
IN THE COURT OF COMMON
PLEAS
OF Cumberland COUNTY
CERTIFICATE OF SERVICE
NO. 06-5188
Lisa A. Lee, Esquire, attorney for Plaintiff herein, does hereby certify that true
and correct copies of the foregoing Amendment to Motion to Compel Sheriff to Schedule
a Sheriff's Sale and all supporting papers attached hereto were served upon the
following:
TIMOTHY C. KEANE
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
R. THOMAS KLINE
OFFICE OF THE SHERIFF
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
via first class mail, postage prepaid, on July 12, 2007.
GOL B McCAFFERTY & McKEEVER
By: Lisa A. Lee, Equire
Attorney for Plaintiff
W
M&T Mortgage Corporation In the Court of Common Pleas of
VS Cumberland County, Pennsylvania
Timothy C. Keane and Natalie P. Keane Writ No. 2006-5188 Civil Term
Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that
on December 14, 2006 at 2009 hours, he served a true copy of the within Real Estate
Writ, Notice and Description, in the above entitled action, upon the within named
defendants, to wit: Timothy C. Keane and Natalie P. Keane, by making known unto
Timothy C. Keane personally and husband of Natalie P. Keane, at 110 E. Countryside
Drive, Boiling Springs, Cumberland County, Pennsylvania its contents and at the same
time handing to him personally the said true and correct copy of the same.
Gerald Worthington, Deputy Sheriff, who being duly sworn according to law,
states that on January 19, 2007 at 0950 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 Timothy C. Keane and Natalie P. Keane located at 110 E. Countryside Drive,
Boiling Springs, 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: Timothy C. Keane and Natalie P. Keane, by regular mail to their last
known address of 110 E. Countryside Drive, Boiling Springs, PA 17007. These letters
were mailed under the date of January 12, 2007 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per letter of request from Attorney Joseph Goldbeck
Sheriffs Costs:
Docketing 30.00
Poundage 17.90
Advertising 15.00
Posting Bills 15.00
Law Library .50
Prothonotary 1.00
Mileage 8.80
Certified Mail 1.40
Levy 15.00
Surcharge 30.00
Postpone Sale 40.00
Law Journal 359.00
Patriot News 362.63
Share of Bills 16.83
s
1
/0
7
$913.06 .( J a
o Answers:
R. Thomas Kline, Sheriff
B ? c
Real Estate ergeant
j , Sro
dk X9639
. /9117!/
sp
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE
NATALIE P. KEANE
(Mortgagor(s) and Record Owner(s))
110 E. Countryside Drive
Boiling Springs, PA 17007
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 06-5188
AFFIDAVIT PURSUANT TO RULE 3129
M&T MORTGAGE CORPORATION, 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:
110 E. Countryside Drive
Boiling Springs, PA 17007
1.Name and address of Owner(s) or Reputed Owner(s):
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
2. Name and address of Defendant(s) in the judgment:
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
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
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
BENEFICIAL MORTGAGE CO. OF PA
961 Weigel Drive
Elmhurst, IL 30126
BENEFICIAL CONSUMER DISCOUNT CO. DB/A BENEFICIAL MORTGAGE CO. OF PA.
419 Village Drive
Suite 2
Carlisle, PA 17013
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
110 E. Countryside Drive
Boiling Springs, PA 17007
(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 onal knowledge or
information and belief. I understand that false statements herein are made subject t e palties f 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities. th ,,/ /
DATED: October 16, 2006
GOLDBECK McC ff FERTY &
BY: Joseph A. Gol beck, Jr., c
Attorney for Plaint ff
06-5188
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-5188
Defendants
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: KEANE, NATALIE P.
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Your house at 110 E. Countryside Drive, Boiling Springs, PA 17007 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 $262,399.88 obtained by M&T MORTGAGE
CORPORATION 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 M&T MORTGAGE CORPORATION, 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.
06-5188
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
06-5188
GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s' ,
Term
No. 06-5188
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: KEANE, TIMOTHY C.
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Your house at 110 E. Countryside Drive, Boiling Springs, PA 17007 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 $262,399.88 obtained by M&T MORTGAGE
CORPORATION 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 M&T MORTGAGE CORPORATION, the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
f
06-5188
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
All that certain tract of land situate in South Middletown Township, Cumberland County, Pennsylvania,
bounded and described as follows:
Beginning at a point located on the northern right of way lien of East Countryside Drive, (50 foot right-
of-way), said point being referenced from the centerline intersection of Jane Lane (50 foot right-of-way)
and East Countryside Drive by the following: from said intersection along centerline of East
Countryside Drive, South 87 degrees 18 minutes 49 seconds East, a distance of 163.00 feet to a point;
thence across East Countryside Drive, North 02 degrees 41 minutes 11 seconds East, a distance of 25.00
feet to a point on the southern right-of-way line of East Countryside Drive at the southeast corner of Lot
#38 and the point of beginning; thence along the East side of Lot No. 38, North 02 degrees 41 minutes
11 seconds East, a distance of 121.05 feet to a point; thence along the South side of Lot No. 33, South
87 degrees 18 minutes 49 seconds East, a distance of 134.00 feet to a point; thence along the West side
of Lot No. 40, South 02 degrees 41 minutes 11 seconds West, a distance of 121.05 feet to a point on the
northern right-of-way of East Countryside Drive; thence along said right-of-way, North 87 degrees 18
minutes 49 seconds West, a distance of 134.00 feet to the point of beginning.
Being Lot No. 39 of the Plan of Lots known as Misty Meadows, Phase 1 as recorded on the Office of
Recorder of Deeds for Cumberland County, in Plan Book 77, page 95; containing 16,220.05 square feet.
Subject to building and use restrictions set forth in Miscellaneous Book 606, page 1009.
TAX PARCEL NO: 40-10-0638-063
. ' WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N006-5188 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due M&T MORTGAGE CORP. Plaintiff (s)
From TIMOTHY C. AND NATALIE P. KEANE, 110 E. COUNTRYSIDE DR., BOILING
SPRINGS PA 17007
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 110 E. COUNTRYSIDE DR., BOILING SPRINGS PA 17007 (SEE LEGAL
DESCRUPTION).
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $262,399.88
Interest FROM 10/17/06 TO 3/7/07 @ 6.7500%
Atty's Comm %
Atty Paid $130.40
Plaintiff Paid
Date: NOVEMBER 2, 2006
L.L. $.50
Due Prothy $1.00
Other Costs
I oaieW4
Curtis A. Long, P ,redfo-Tiotary
(Seal)
REQUESTING PARTY:
Name JOSEPH A. GOLDB ECK, JR., ESQ.
Address: SUITE 5000, MELLON INDEPENDENCE CENTER
701 MARKET ST., PHILADELPHIA PA 19106
Attorney for: PLAINTIFF
Telephone: (215) 627-1322
Supreme Court ID No. 16132
By:
Deputy
Real Estate Sale # 27
On November 6, 2006 the Sheriff levied upon the
defendant's interest in the real property situated in
South Middleton Township, Cumberland County, PA
ft" Known and numbered as 110 E. Countryside Drive,
eD
Boiling Springs, more fully described on Exhibit "A"
P^n
UM) filed with this writ and by this reference incorporated herein.
f
Date: November 6, 2006 By:
J6C
Real Esta Sergeant
b S b d E- A0i1 995l
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
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. 27
Writ No. 2006-5188 Civil
M&T Mortgage Corporation
vs.
Timothy C. Keane and
Natalie P. Keane
Atty.: Joseph Goldbeck
All that certain tract of land situ-
ate in South Middletown Township,
Cumberland County, Pennsylvania,
bounded and described as follows:
Beginning at a point located on
the northern right of way lien of East
Countryside Drive, (50 foot right-
of-way), said point being referenced
ti
/?isa Marie Co 1)/1 Editor
SWORN TO AND SUBSCRIBED before me this
___2 _day of Februar, 2007
NOTARIAL SEAL
LOIS E. SNYDER, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires March 5, 2009
1 '%a
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday/ Metro editions which appeared in the 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
SALE#27
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............Xsuib ..................................
Sworn to an efore me this 26th day of February 2007 A.D.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Terry L. Russell, Not ublic
ity Of Harrourg, D ph' County
My Commis r ne 6, 2010
NOTA4XY PUBLIC
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
I Fountain Plaza
Buffalo, NY 14203
vs.
Plaintiff
IN THE COURT OF COMMON PLEAS
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-5188
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
10/17/2006 to Date of
Sale at 6.7500%
(Costs to be added)
$262,399.88
GOLD C McCAFFERTY & McKEEVER
BY: J A. Goldbeck, Jr.
Attorne for Plaintiff
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All that certain tract of land situate in South Middletown Township, Cumberland County, Pennsylvania,
bounded and described as follows:
Beginning at a point located on the northern right of way lien of East Countryside Drive, (50 foot right-
of-way), said point being referenced from the centerline intersection of Jane Lane (50 foot right-of-way)
and East Countryside Drive by the following: from said intersection along centerline of East
Countryside Drive, South 87 degrees 18 minutes 49 seconds East, a distance of 163.00 feet to a point;
thence across East Countryside Drive, North 02 degrees 41 minutes 11 seconds East, a distance of 25.00
feet to a point on the southern right-of-way line of East Countryside Drive at the southeast corner of Lot
#38 and the point of beginning; thence along the East side of Lot No. 38, North 02 degrees 41 minutes
11 seconds East, a distance of 121.05 feet to a point; thence along the South side of Lot No. 33, South
87 degrees 18 minutes 49 seconds East, a distance of 134.00 feet to a point; thence along the West side
of Lot No. 40, South 02 degrees 41 minutes 11 seconds West, a distance of 121.05 feet to a point on the
northern right-of-way of East Countryside Drive; thence along said right-of-way, North 87 degrees 18
minutes 49 seconds West, a distance of 134.00 feet to the point of beginning.
Being Lot No. 39 of the Plan of Lots known as Misty Meadows, Phase 1 as recorded on the Office of
Recorder of Deeds for Cumberland County, in Plan Book 77, page 95; containing 16,220.05 square feet.
Subject to building and use restrictions set forth in Miscellaneous Book 606, page 1009
IMPROVEMENTS consist of a residential dwelling.
BEINGPREMISES: 110 E. Countryside Drive
Boiling Springs, PA 17007
SOLD as the property of TIMOTHY C. KEANE and NATALIE P. KEANE
TAX PARCEL #40-10-0638-063
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-5188 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION Plaintiff (s)
From TIMOTHY C. KEANE & NATALIE P. KEANE
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $262,399.88
L.L. $.50
Interest from 10/17/06 to date of sale at 6.7500%
Atty's Comm %
Atty Paid $170.90
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: 07-03-07
(Seal)
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
jjalt4 -
Curtis R. tong, Protho
By:
Deputy
Telephone: 215-627-1322
Supreme Court ID No. 16132
?ioldbeck 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
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
(Mortgagor(s) and Record Owner(s))
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-5188
AFFIDAVIT PURSUANT TO RULE 3129
M&T MORTGAGE CORPORATION, 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:
110 E. Countryside Drive
Boiling Springs, PA 17007
1.Name and address of Owner(s) or Reputed Owner(s):
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
2. Name and address of Defendant(s) in the judgment:
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
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
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
BENEFICIAL CONSUMER DISCOUNT CO. DB/A BENEFICIAL MORTGAGE CO. OF PA.
419 Village Drive
Suite 2
Carlisle, PA 17013
BENEFICIAL MORTGAGE CO. OF PA
961 Weigel Drive
Elmhurst, IL 30126
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
110 E. Countryside Drive
Boiling Springs, PA 17007
Terrance J. McCabe
123 South Broad Street, Suite 2080
Philadelphia, PA 19107-1029
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unworn falsification to authorities.
DATED: June 29, 2007
thK McCAFFERTY & McKEEVER
A. Goldbeck, Jr., Esq.
for Plaintiff
i
06-5188
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
VS.
ACTION OF MORTGAGE
FORECLOSURE
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s
Term
No. 06-5188
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: KEANE, TIMOTHY C.
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Your house at 110 E. Countryside Drive, Boiling Springs, PA 17007 is scheduled to be sold at
Sheriffs Sale on Wednesday, December 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the court judgment of $262,399.88 obtained by M&T MORTGAGE
CORPORATION 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 M&T MORTGAGE CORPORATION, the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call
our office at 215-825-6329 or 1-866-413-2311 and
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.
06-5188
r
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
06-5188
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
5). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretentionagoldbecklaw.com.
Call Judy 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 MT-1070.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
06-5188
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Term
No. 06-5188
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: KEANE, NATALIE P.
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Your house at 110 E. Countryside Drive, Boiling Springs, PA 17007 is scheduled to be sold at
Sheriffs Sale on Wednesday, December 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the court judgment of $262,399.88 obtained by M&T MORTGAGE
CORPORATION 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 M&T MORTGAGE CORPORATION, the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call
our office at 215-825-6329 or 1-866413-2311 and
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
06-5188
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
06-5188
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
5). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention(i?goldbecklaw.com.
Call Judy 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 MT-1070.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
M&T MORTGAGE CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
TIMOTHY C. KEANE AND
NATALIE P. KEANE,
DEFENDANTS
: 06-5188 CIVIL TERM
ORDER OF COURT
AND NOW, this 144 day of July, 2007, a Rule is entered against
the Cumberland County Sheriff to show cause why the motion and amended motion for
an order directing the Sheriff to set 110 East Countryside Drive, Boiling Springs, PA
17007 for the September 5, 2007, Cumberland County Sheriff's Sale, should not be
granted. Rule returnable five (5) days after service.
By the Court,
Edgar B. Bayley, J.
Lisa A. Lee, Esquire
For Plaintiff
lTimothy C. Keane
`Natalie P. Keane
110 E. Countryside Drive
Boiling Springs, PA 17007
Cumberland County Sheriff
:sal `` `
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GOLDBECK WCAFFERTY & McKEEVER
A Professional Corporation
By: Lisa A. Lee, Esquire
Attorney I.D. #: 78020
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendants
AFFIDAVIT OF SERVICE
No. 06-5188
I hereby certify that the Rule dated July 17, 2007 in the above-captioned matter was
served pursuant to Rule 440 by first class mail on the following parties on the date listed below:
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
SHERIFF OF CUMBERLAND COUNTY
Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
I understand that false statements herein are made subject to the penalties of 18
Pa. C.S.A. §4904 relating to unworn falsifications to authorities.
GOLDBECK, McCAFFERTY & McKEEVER
Date: 7/24/2007 U Jk
Lis A. Lee, Esq ire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
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M&T MORTGAGE CORPORATION
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
TIMOTHY C. KEANE, and
NATALIE P. KEANE
Defendants
: No. 06-5188 CIVIL TERM
ANSWER OF THE OFFICE OF THE SHERIFF OF CUMBERLAND
COUNTY TO THE RULE ENTERED BY THIS COURT ON JULY 17, 2007
AND NOW, comes the Office of the Sheriff of Cumberland County, by and through its
Solicitor, Edward L. Schorpp, Esq., and answers Plaintiff's Amended Motion as follows:
Original Motion
1-3. Admitted.
4-8. Denied. After reasonable investigation, Respondent is without knowledge sufficient
to form a belief as to the truth of these averments and the same are therefore denied.
9. Admitted.
10. Admitted in part and denied in part. The next regularly scheduled sale date is
December 5, 2007, however the Office of the Sheriff has sale dates scheduled in each month of the
year for the purpose of conducting sales which have been postponed.
11. Denied. After reasonable investigation, Respondent is without knowledge sufficient
to form a belief as to the truth of these averments and the same are therefore denied.
12. Admitted.
13. Denied. The Office of the Sheriff received the Court's Order on July 25, 2007. On
that date, the September sales had already been advertised two of the three successive times required
by law.
14. Admitted in part and denied in part. It is admitted that Plaintiff seeks relief. It is
denied that it is entitled to the relief sought, which averment is a conclusion of law.
Amended Motion
Plaintiff Amended Motion contains two new paragraphs and does not include the remaining
paragraphs constituting the original Motion. Nevertheless, the Office of the Sheriff answers by
incorporating by reference Paragraphs Nos. 1-14 above and answers the new paragraphs as follows:
1. Denied. After reasonable investigation, Respondent is without knowledge or
information sufficient to prove the truth of these averments and the same are denied.
2. Admitted in part and denied in part. Respondent cannot speak to the standing of
defendants. It is admitted that Plaintiff's counsel did leave a telephone message, which did not
specify a request for concurrence, for the Sheriff's Solicitor and the call was not returned. By way
of further answer, Plaintiff's counsel made no subsequent effort to contact the Sheriff s Solicitor.
WHEREFORE, Respondent Office of the Sheriff demands that Plaintiff's motion be
dismissed.
Edward ?LSc?horpp, Esquire
Attorney I.D. No. 17495
35 South Thrush Drive
Carlisle, PA 17015-7652
Telephone: (717) 486-8386
Email: elschorpp@comcast.net
Solicitor for the Office of the Sheriff
t:,
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VERIFICATION
I verify that the statements contained herein are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn
falsification to authorities.
s' ..etl? 1
l
Dated: 4 X7 .ADD,'
M&T MORTGAGE CORPORATION
Plaintiff
vs.
TIMOTHY C. KEANE, and
NATALIE P. KEANE
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-5188 CIVIL TERM
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Answer of the Office of the Sheriff of
Cumberland County to the Rule Entered by this Court on July 17, 2007, was served this date by
depositing same in the Post Office at Carlisle, Pennsylvania, first-class mail, postage prepaid,
addressed as follows:
Lisa A. Lee, Esquire
Goldbeck, McCafferty & McKeever
Suite 5000 Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
Timothy C. Keane
Natalie P. Keane
110 E. Countryside Drive
Boiling Springs, PA 17007
Dated:?/U_u Z % -2 0 07
By: J#d b S 0r2Lkk , Sgrq-e ai4j
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M&T MORTGAGE CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
TIMOTHY C. KEANE AND
NATALIE P. KEANE,
DEFENDANTS
06-5188 CIVIL TERM
ORDER OF COURT
AND NOW, this 15f' day of August, 2007, following review of the
motion and answer, and this case having never been advertised, the motion to compel
the sheriff to schedule a sheriff sale for September 5, 2007, IS DENIED
By the 906rt,
Edgar B
Xisa A. Lee, Esquire
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
For Plaintiff
? imothy C. Keane
Natalie P. Keane
110 E. Countryside Drive
Boiling Springs, PA 17007
Cumberland County Sheriff
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GOLDBECK McCAFFERTY & MCKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
PLAINTIFF'S
PETITION TO AMEND JUDGMENT
Plaintiff, M&T MORTGAGE CORPORATION, petitions the Court to Amend its
Judgment in mortgage foreclosure for the following reasons:
1. Plaintiffs Complaint in Mortgage Foreclosure was filed on September 05,
2006 as to the property located at 110 E. Countryside Drive Boiling Springs, PA 17007
("Property").
2. On November 02, 2006, judgment in mortgage foreclosure was entered in
favor of Plaintiff and against Defendants in the amount of $262,399.88, based upon the
demand in Plaintiffs Complaint.
3. Additional sums have been incurred or expended on Defendant's behalf since
the complaint was filed.
4. Since the filing of the Complaint, interest and late charges continue to accrue
based on the rate set forth in the mortgage; and plaintiff has continued to pay taxes and hazard
insurance premiums as required under the terms of the note and mortgage or under the terms
of the mortgage contract in order to protect the interest of Defendants and Plaintiff.
5. Due to the increase in the amounts due and owing to Plaintiff, Plaintiffs
judgment amount is not sufficient to satisfy the amounts due and owing on the mortgage and
the mortgage lien on the Property.
6. A sheriffs sale is scheduled for December 05, 2007, and the amounts due and
owing on the mortgage as of the sheriff s sale will be as follows:
Principal Balance
Interest from 04/01/2006 thru 12/05/2007
at 6.7500% Per diem interest rate at $43.71
Escrow
Sub-Total
Pro Rata PMI
Unpaid NSF Charges
Property Inspections
Miscellaneous Expense Due
INSPECTIONS
09/11/06 9.00
10/03/06 9.00
11/13/06 9.00
11/29/06 9.00
01/03/07 9.00
01/30/07 9.00
03/05/07 9.00
03/29/07 9.00
05/10/07 9.00
05/31/07 9.00
06/27/07 12.00
07/27/07 12.00
08/28/07 12.00
10/02/07 12.00
Total $138
$236,367.62
$32,061.12
$8,827.55
$277,256.29
$649.76
$20.00
$26.50
$5,278.96
BPO
07/31/06 100.00
04/12/07 350.00
04/27/07 100.00
06/25/07 235.00
Total $785
Property Preservation
04/05/07 1,375.00
F/C
09/21/06 325.00
09/21/06 1,500.00
09/21/06 190.00
09/21/06 55.50
06/15/07 125.00
06/15/07 125.00
06/15/07 34.00
06/15/07 1,250.00
06/15/07 15.00
07/12/07 (638.54)
Total $2980.96
Final total = $5278.96
Sub-Total $283,231.51
Recording Fees $27.00
Inspections $36.00
Appraisal $500.00
Sub-Total $283,794.51
Attorney's Fee at 5.0000% of principal balance $11,818.38
Costs of Suit and Title Search $900.00
TOTAL $296,512.89
WHEREFORE, Plaintiff prays that the Petition be granted and Plaintiff s Judgment be
amended to $296,512.89, plus interest and costs of the action.
y submitted,
By:
GOLDBEOK McCAFYEFITY & McKEEVER
Ga E.cCa Esq.
Pho : (215) 825 302
Fax: ( 25-
Email: 2mccaffe izoldbecklaw.com
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6302
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
VERIFICATION
Gary E. McCafferty, Esq., hereby states that he is the attorney for plaintiff and that all of
the facts set forth within the attached Petition to Amend its Judgment are true and correct to the
best of his knowledge, information and belief. The undersigned understands that the foregoing
statements are made subject to the penalties 18 P.S. Section
Gary E. cCafferty sq.
Phone: (21 825-610
Fax: (215) 825-
Email: gmccafferty@goldbecklaw.com
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6302
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S
PETITION TO AMEND JUDGMENT
Plaintiff is entitled to the amounts due and owing pursuant to the terms of the mortgage
and note at the time of the Sheriff s Sale of property involved. For reasons stated in the within
motion, Plaintiff's judgment in mortgage foreclosure is insufficient to compensate Plaintiff for
the amount due and owing under the mortgage. Specifically, interest charges, late charges and
advances made by plaintiff to pay taxes, insurance, or to otherwise protect its mortgage lien and
the interests of the Defendant, have all been accruing while Plaintiff's action in mortgage
foreclosure was delayed.
CONCLUSION
For the reasons stated above and in the within petition, Plaintiff respectfully requests that
the petition be granted and Plaintiffs judgment be amended to $296,512.89, plus interest and
costs.
By:
Respectfully somitted,
GOLDBECK MWAFFEAW & McKEEVER
Gary E. afferty, q.
Phone: (2 25- 2
Fax: (215) 825-6402
Email: gmccafferty@goldbecklaw.com
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
CERTIFICATION OF SERVICE
Jaclyn Jamieson is a legal assistant with the firm of GOLDBECK McCAFFERTY &
McKEEVER and hereby certifies that a true and correct copy of Plaintiffs Petition to Amend
Judgment was mailed by first class mail, postage prepaid to Defendant(s) TIMOTHY C.
KEANE and NATALIE P. KEANE @ 110 E. Countryside Drive Boiling Springs, PA 17007
on October 19, 2007.
GOLDBECK McCAFFERTY & McKEEVER
By: \
Gol beck a rty McKeever
Jaclyn Jamieson
Judgment Department
Phone: (215) 825-6369
Fax: (215) 825-6378
Email: jjamieson@goldbecklaw.com
GOLDBECK McCAFFERTY & MCKEEVER
A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
SUITE 5000
MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
W W W.GOLDBECKLA W.COM
October 18, 2007
PROTHONOTARY OF CUMBERLAND COUNTY
Prothonotary of Cumberland County
1 Courthouse Square
Carlisle, PA 17013
RE: M&T MORTGAGE CORPORATION vs. TIMOTHY C. KEANE and NATALIE P.
KEANE
Docket Number: 06-5188
Our file Number: MT-1070
To the Prothonotary:
Kindly file Plaintiff's Petition to Amend Judgment the same of record with the Court and
return a time-stamped copy in the self-addressed stamped envelope enclosed.
Very truly yours,
Goldbeck McCafferty & McKeever
Jaclyn Jamieson
Judgment Department
Phone: (215) 825-6369
Fax: (215) 825-6378
Email: jjamieson@goldbecklaw.com
cc: TIMOTHY C. KEANE
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
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.1o 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
MT-1070
CF: 09/06/2006
SD: 12/05/2007
$262,399.88
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and
Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 06-5188
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants of the Notice of Sheriff Sale was made by:
( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached).
Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S.
Section 4904.
pectfully submitted,
Joseph A. Goldbeck, r.
A orney for Plaintiff
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?P05T,l1t SERVICE.
Date Produced: 07/16/2007
GOLDBECK MCCAFFERTY & MCKEEVER
The following is the delivery information for Certified item number 7111 4342 3630 0014 3753.
Our records indicate that this item was delivered on 07/13/2007 at 11:57 a.m. in BOILING
SPRINGS, PA, 17007. The scanned image of the recipient information is provided below.
Signature of Recipient:
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Ile
Address of Recipient:` r
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Thank you for selecting the Postal Service for your mailing needs. If you require additional
assistance, please contact your local post office or Postal Service representative.
Sincerely,
United States Postal Service
The customer reference number shown below is not validated or endorsed by the United
States Postal Service. It is solely for customer use.
Customer Reference Number: 4340453 16625576
1MO 5TISTS
POSTAL SE RVICE
Date Produced: 07/16/2007
GOLDBECK MCCAFFERTY & MCKEEVER
The following is the delivery information for Certified item number 7111 4342 3630 0014 3760.
Our records indicate that this item was delivered on 07/13/2007 at 11:57 a.m. in BOILING
SPRINGS, PA, 17007. The scanned image of the recipient information is provided below.
Signature of Recipient:
Address of Recipient:
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Thank you for selecting the Postal Service for your mailing needs. If you require additional
assistance, please contact your local post office or Postal Service representative.
Sincerely,
United States Postal Service
The customer reference number shown below is not validated or endorsed by the United
States Postal Service. It is solely for customer use.
Customer Reference Number: 4340453 16625576
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 06-5188
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
M&T MORTGAGE CORPORATION, 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:
110 E. Countryside Drive
Boiling Springs, PA 17007
1.Name and address of Owner(s) or Reputed Owner(s):
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
2. Name and address of Defendant(s) in the judgment:
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
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
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
BENEFICIAL MORTGAGE CO. OF PA
961 Weigel Drive
Elmhurst, IL 30126
BENEFICIAL CONSUMER DISCOUNT CO. DB/A BENEFICIAL MORTGAGE CO. OF PA.
419 Village Drive
Suite 2
Carlisle, PA 17013
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.
CHERIE STORK
MOSS CODILIS, LLP
20 NORTH MAIN STREET
ALBION, NY 14411
TENANTS/OCCUPANTS
110 E. Countryside Drive
Boiling Springs, PA 17007
Terrance J. McCabe
123 South Broad Street, Suite 2080
Philadelphia, PA 19107-1029
(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: October 18, 2007
ECK Mc AFFERTY & McKEEVER
B . oseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling.Springs, PA 17007
Defendant(s)
AMENDED PLAINTIFF'S
PETITION TO AMEND JUDGMENT
No. 06-5188
In reference to the above mentioned case the Honorable Judge Bayley has been assigned
to this case. He has ruled upon the Motion to Compel the Sheriff sale for September 5, 2007,
which he denied on August 1, 2007.
There is no opposing counsel listed on record for this particular matter.
Respectfully s-qbmitted,
By:
GOLDBECK WCAFFEWrY/& McKEEVER
Gary E. affe sq.
Phone: ( 15) 825-6 2
Fax: (215) 25-640
Email: jmcca ,jz Idbecklaw.com
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
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OCT 2 52Q07y
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
10/aa
- Sen tA E
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
RULE
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested
in Plaintiffs Motion to Reassess Damages should no
10-
Rule returnable the 1-5 day of Od-'i
Date: J
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GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 500 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6302
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
CERTIFICATION OF SERVICE OF RULE RETURNABLE
Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of
Plaintiffs Petition for Reassessment of Damages and Rule Returnable Dated November 15,
2007, stating the RULE is returnable FIFTEEN (15) days from the date of service was mailed
by first class mail, postage prepaid to Defendant(s) TIMOTHY C. KEANE & NATALIE P.
KEANE on November 19, 2007 @ 110 E. Countryside Drive, Boiling Springs, PA 17007.
GOLDBECK
Sworn
me th,
to
day vember, 2007
By:
PENNSYLVANIA
COMMONWF-AL7 1 -..
NOTARIAL .?-- P?
BARBARA L. HAND, Notary
City of Philadelphia, Phila. County
My Commission Irxpires June 19#2010
Gary E. Cafferty,
215-825-6
215-825-6442 ax
Email: 2mccaffertv(c
IN THE COURT OF COMMON PLEAS
El
FEY'Y & McKEEVER
ldbecklaw.com
OCT s s2om,4'
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
RULE
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested
in Plaintiffs Motion to Reassess Damages should not be granted.
Rule returnable the day of
Date: 7 /s/ •
IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
ORDER
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
AND NOW, this day of , 2007, upon consideration of the Petition
of M&T MORTGAGE CORPORATION to Amend its Judgment, it is,
ORDERED:
That the motion is granted and Plaintiff s judgment is hereby amended to
$296,512.89, plus interest at the rate set forth in the note and mortgage, and costs of this action
through and including the Sheriff's Sale of the Property or payment of the mortgage loan in full.
BY THE COURT:
J.
Distribution list:
Gary E. McCafferty, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street,
Philadelphia, PA 19106-1532
TIMOTHY C. KEANE, 110 E. Countryside Drive Boiling Springs, PA 17007
NATALIE P. KEANE, 110 E. Countryside Drive Boiling Springs, PA 17007
t
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
RULE
IN THE COURT OF COMMOU PLEAS
of Cum
CIVIL A I -
ACTION OF l
FORECLQAJ
? C
ya
-In
No. 06-5188
go<
AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested
in Plaintiffs Motion to Reassess Damages should not be granted.
Rule returnable the day of , .
Date:
J.
IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
ORDER
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
AND NOW, this day of , 2007, upon consideration of the Petition
of M&T MORTGAGE CORPORATION to Amend its Judgment, it is,
ORDERED:
That the motion is granted and Plaintiff s judgment is hereby amended to
$296,512.89, plus interest at the rate set forth in the note and mortgage, and costs of this action
through and including the Sheriff s Sale of the Property or payment of the mortgage loan in full.
BY THE COURT:
J.
Distribution list:
Gary E. McCafferty, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street,
Philadelphia, PA 19106-1532
TIMOTHY C. KEANE, 110 E. Countryside Drive Boiling Springs, PA 17007
NATALIE P. KEANE, 110 E. Countryside Drive Boiling Springs, PA 17007
GOLDBECK McCAFFERTY & McKEEVER c?
BY: Gary E. McCafferty C7
?.r
C:) -n
Attorney I.D.#42386 T C-) M'11
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532 i
215-825-6342 - -- t ``
Attorney for Plaintiff 2-1
--
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
IN THE COURT OF COMMON
PLEAS
of Cumberland County
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
PLAINTIFF'S
PETITION TO AMEND JUDGMENT
Plaintiff, M&T MORTGAGE CORPORATION, petitions the Court to Amend its
Judgment in mortgage foreclosure for the following reasons:
1. Plaintiffs Complaint in Mortgage Foreclosure was filed on September 05,
2006 as to the property located at 110 E. Countryside Drive Boiling Springs, PA 17007
("Property")
2. On November 02, 2006, judgment in mortgage foreclosure was entered in
favor of Plaintiff and against Defendants in the amount of $262,399.88, based upon the
demand in Plaintiffs Complaint.
3. Additional sums have been incurred or expended on Defendant's behalf since
the complaint was filed.
4. Since the filing of the Complaint, interest and late charges continue to accrue
based on the rate set forth in the mortgage; and plaintiff has continued to pay taxes and hazard
insurance premiums as required under the terms of the note and mortgage or under the terms
of the mortgage contract in order to protect the interest of Defendants and Plaintiff.
5. Due to the increase in the amounts due and owing to Plaintiff, Plaintiffs
judgment amount is not sufficient to satisfy the amounts due and owing on the mortgage and
the mortgage lien on the Property.
6. A sheriffs sale is scheduled for December 05, 2007, and the amounts due and
owing on the mortgage as of the sheriffs sale will be as follows:
Principal Balance
Interest from 04/01/2006 thru 12/05/2007
at 6.7500% Per diem interest rate at $43.71
Escrow
Sub-Total
Pro Rata PMI
Unpaid NSF Charges
Property Inspections
Miscellaneous Expense Due
INSPECTIONS
09/11/06 9.00
10/03/06 9.00
11/13/06 9.00
11/29/06 9.00
01/03/07 9.00
01/30/07 9.00
03/05/07 9.00
03/29/07 9.00
05/10/07 9.00
05/31/07 9.00
06/27/07 12.00
07/27/07 12.00
08/28/07 12.00
10/02/07 12.00
Total $138
$236,367.62
$32,061.12
$8,827.55
$277,256.29
$649.76
$20.00
$26.50
$5,278.96
BPO
07/31/06 100.00
04/12/07 350.00
04/27/07 100.00
06/25/07 235.00
Total $785
Property Preservation
04/05/07 1,375.00
F/C
09/21/06 325.00
09/21/06 1,500.00
09/21/06 190.00
09/21/06 55.50
06/15/07 125.00
06/15/07 125.00
06/15/07 34.00
06/15/07 1,250.00
06/15/07 15.00
07/12/07 (638.54)
Total $2980.96
Final total = $5278.96
Sub-Total $283,231.51
Recording Fees $27.00
Inspections $36.00
Appraisal $500.00
Sub-Total $283,794.51
Attorney's Fee at 5.0000% of principal balance $11,818.38
Costs of Suit and Title Search $900.00
TOTAL $296,512.89
WHEREFORE, Plaintiff prays that the Petition be granted and Plaintiffs Judgment be
amended to $296,512.89, plus interest and costs of the action.
ly submitted,
By:
GOLDBEM MCCAFYEFJTY & McKEEVER
Ga E. McA825 Esq.
Pho : (?12
Fax: (2 Email:9-mcgoldbecklaw.com
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6302
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
VERIFICATION
No. 06-5188
Gary E. McCafferty, Esq., hereby states that he is the attorney for plaintiff and that all of
the facts set forth within the attached Petition to Amend its Judgment are true and correct to the
best of his knowledge, information and belief. The undersigned understands that the foregoing
statements are made subject to the penalties 18 P. S. Section 0904.
Gary E. cCatfert}
Phone: (21 825-6
Fax: (215) 825--640
Email: mccaffertv
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
ldbecklaw.com
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6302
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
IN THE COURT OF COMMON
PLEAS
of Cumberland County
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S
PETITION TO AMEND JUDGMENT
Plaintiff is entitled to the amounts due and owing pursuant to the terms of the mortgage
and note at the time of the Sheriffs Sale of property involved. For reasons stated in the within
motion, Plaintiff's judgment in mortgage foreclosure is insufficient to compensate Plaintiff for
the amount due and owing under the mortgage. Specifically, interest charges, late charges and
advances made by plaintiff to pay taxes, insurance, or to otherwise protect its mortgage lien and
the interests of the Defendant, have all been accruing while Plaintiff s action in mortgage
foreclosure was delayed.
CONCLUSION
For the reasons stated above and in the within petition, Plaintiff respectfully requests that
the petition be granted and Plaintiffs judgment be amended to $296,512.89, plus interest and
costs.
By:
Respectfully
GOLDBECK WCAFFEP T/f & McKEEVER
Gary E. afferty, q.
Phone: (2 25- 2
Fax: (215)825 _6402
Email: gmccafferty@goldbecklaw.com
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GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
I Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
CERTIFICATION OF SERVICE
Jaclyn Jamieson is a legal assistant with the firm of GOLDBECK McCAFFERTY &
McKEEVER and hereby certifies that a true and correct copy of Plaintiffs Petition to Amend
Judgment was mailed by first class mail, postage prepaid to Defendant(s) TIMOTHY C.
KEANE and NATALIE P. KEANE rr 110 E. Countryside Drive Boiling Springs, PA 17007
on October 19, 2007.
GOLDBECK McCAFFERTY & McKEEVER
By: ?.?
Gol beck MWa rty McKeever
Jaclyn Jamieson
Judgment Department
Phone: (215) 825-6369
Fax: (215) 825-6378
Email: jjamieson@goldbecklaw.com
•? r
GOLDBECK McCAFFERTY & WKEEVER
A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
SUITE 5000
MELLON INDEPENDENCE CENTER
70 t MARKET STREET
PHILADELPHIA, PA 19106
WWW.GOLDBECKLAW.COM
October 18, 2007
PROTHONOTARY OF CUMBERLAND COUNTY
Prothonotary of Cumberland County
1 Courthouse Square
Carlisle, PA 17013
RE: M&T MORTGAGE CORPORATION vs. TIMOTHY C. KEANE and NATALIE P.
KEANE
Docket Number: 06-5188
Our file Number: MT-1070
To the Prothonotary:
Kindly file Plaintiff s Petition to Amend Judgment the same of record with the Court and
return a time-stamped copy in the self-addressed stamped envelope enclosed.
Very truly yours,
Goldbeck McCafferty & McKeever
Jaclyn Jamieson
Judgment Department
Phone: (215) 825-6369
Fax: (215) 825-6378
Email: jjamieson@goldbecklaw.com
cc: TIMOTHY C. KEANE
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
GOLDBECK MCCAFFERTV & McKEEVER
A PROFESSIONAL CORPORATION
SUITE 5000
MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
WWW.GOLDBECKLAW.COM
November 19, 2007
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
RE: M&T MORTGAGE CORPORATION v. TIMOTHY C. KEANE & NATALIE P.
KEANE
Docket Number. 06-5188
Loan Number: 0006390603
Our File Number: MT-1070
I have enclosed for service upon you Plaintiffs Petition for Reassessment of Damages
and Rule Returnable Dated November 15, 2007, stating the RULE is returnable FIFTEEN (15)
days from the date of service was mailed . Please contact your own legal counsel to discuss this
petition.
Very truly yours,
GOLDBECK McCAFFERTY & McKEEVER
By: Jaclyn Jamieson
Legal Assistant to Gary McCafferty
215-825-6369
215-825-6378 (fax)
Jiamieson@goldbeeklaw.com
GOLDBECK McCAFFERTY & McKEEVER
A PROFESSIONAL CORPORATION
SUITE 5000
MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
WWW.GOLDBECKLAW.COM
November 19, 2007
PROTHONOTARY OF CUMBERLAND COUNTY
Prothonotary of Cumberland County
1 Courthouse Square
Carlisle, PA 17013
RE: M&T MORTGAGE CORPORATION vs. TIMOTHY C. KEANE and
NATALIE P. KEANE
NO. 06-5188
Our file Number: MT-1070
To the Prothonotary:
Kindly file Plaintiffs CERTIFICATION OF SERVICE OF RULE RETURNABLE with
the Court and return a time-stamped copy in the pre-addressed and prepaid envelope provided.
Very truly yours,
GOLDBECK McCAFFERTY & McKEEVER
By: Jaclyn Jamieson
Legal Assistant to Gary McCafferty
215-825-6369
215-825-6378 (fax)
jjamieson@goldbecklaw.com
CC: TIMOTHY C. KEANE and
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
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-GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203 IN THE COURT OF COMMON PLEAS
vs.
Plaintiff
of Cumberland County
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
MOTION TO MAKE RULE ABSOLUTE
Plaintiff, M&T MORTGAGE CORPORATION, moves to make a rule absolute for the
following reasons:
1. Plaintiff filed a Petition to Amend Judgment on October 22, 2007. A true and
correct copy of Plaintiff's Motion is attached as Exhibit A.
2. A Rule was issued by the Court with a Rule Returnable dated November 15,
2007, stating the RULE is returnable FIFTEEN (15) days from the date of service. Service was
sent on November 19, 2007.. Exhibit B.
3. Plaintiff's Certificate of Service of the Rule Returnable is attached as Exhibit C.
4. Upon information and belief, no response to the Petition has been filed with the
Court or served upon Plaintiff.
WHEREFORE, Plaintiff prays that the Court make the le absolute and enter the
attached Order. n
E. McCferty, Esq.
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
AFFIDAVIT
Gary E. McCafferty, Esquire., subject to the penalties of 1 P.S. Section 4904, deposes
and says that he is the attorney for the within named Plaintiff and t at all the fa s set forth
within the attached a Motion to Make Rule Absolute are true and c ect to t best of his
knowledge, information and belief.
SWORN TO AND SUBSCRIBED:
Before me this day:
Gary E. M
Of 12007 1--i
v 'y Public
COMMONWEALTH OF PENNS1fL.VANIA
NOTARIAL SEAL
BARBARA L HAND, NOWY Pdit
Phis. CCU*
CwwnW n Eiq*w ,lime 19, 2010
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
CERTIFICATE OF SERVICE
Gary E. McCafferty, Esquire., attorney for Plaintiff, being duly sworn according to law,
hereby certifies that he did serve Defendants TIMOTHY C. KEA and NAT LIE P. KEANE,
a copy of Plaintiff's Motion to Make Rule Absolute by first class ail on tuber 4, 2007 at
110 E. Countryside Drive, Boiling Springs, PA 17007.
Gary E.
SWORN TO AND SUBSCRIBED:
Before me this rlL-1- da
Of '2007
0
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
BARBARA L. HAND, Notary Pudic
City of Philadelphia, PhNa. Cowriy
My Cww*m ion Expires Jura 19, 2010
Exhibit A
Plaintiff's Motion to Reassess Damages
IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
vs.
Plaintiff
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
ORDER
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
AND NOW, this day of , 2007, upon consideration of the Petition
of M&T MORTGAGE CORPORATION to Amend its Judgment, it is,
ORDERED:
That the motion is granted and Plaintiffs judgment is hereby amended to
$296,512.89, plus interest at the rate set forth in the note and mortgage, and costs of this action
through and including the Sheriffs Sale of the Property or payment of the mortgage loan in full.
BY THE COURT:
J.
Distribution list:
Gary E. McCafferty, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street,
Philadelphia, PA 19106-1532
TIMOTHY C. KEANE, 110 E. Countryside Drive Boiling Springs, PA 17007
NATALIE P. KEANE, 110 E. Countryside Drive Boiling Springs, PA 17007
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF CO
of Cum
CIVIL A W -
ACTION OF'
20a
FORECL(O J
No. 06-5188
PLEAS
RULE
AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested
in Plaintiffs Motion to Reassess Damages should not be granted.
Rule returnable the day of , .
Date:
J.
?• 4
IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
ORDER
AND NOW, this day of , 2007, upon consideration of the Petition
of M&T MORTGAGE CORPORATION to Amend its Judgment, it is,
ORDERED:
That the motion is granted and Plaintiffs judgment is hereby amended to
$296,512.89, plus interest at the rate set forth in the note and mortgage, and costs of this action
through and including the Sheriff's Sale of the Property or payment of the mortgage loan in full.
BY THE COURT:
J.
Distribution list:
Gary E. McCafferty, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street,
Philadelphia, PA 19106-1532
TIMOTHY C. KEANE, 110 E. Countryside Drive Boiling Springs, PA 17007
NATALIE P. KEANE, 110 E. Countryside Drive Boiling Springs, PA 17007
GOLDBECK McCAFFERTY & McKEEVER o
BY: Gary E. McCafferty =
?,..
Attorney I.D.#42386 r - m r
Suite 5000 - Mellon Independence Center v =i;
701 Market Street
PA 19106-1532
Philadelphia ag
-
,
215-825-6342
yv
-- t` `n
Attorney for Plaintiff --
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
IN THE COURT OF COMMON
PLEAS
of Cumberland County
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
PLAINTIFF'S
PETITION TO AMEND JUDGMENT
Plaintiff, M&T MORTGAGE CORPORATION, petitions the Court to Amend its
Judgment in mortgage foreclosure for the following reasons:
1. Plaintiffs Complaint in Mortgage Foreclosure was filed on September 05,
2006 as to the property located at 110 E. Countryside Drive Boiling Springs, PA 17007
("Property").
2. On November 02, 2006, judgment in mortgage foreclosure was entered in
favor of Plaintiff and against Defendants in the amount of $262,399.88, based upon the
demand in Plaintiffs Complaint.
3. Additional sums have been incurred or expended on Defendant's behalf since
the complaint was filed.
.y
4. Since the filing of the Complaint, interest and late charges continue to accrue
based on the rate set forth in the mortgage; and plaintiff has continued to pay taxes and hazard
insurance premiums as required under the terms of the note and mortgage or under the terms
of the mortgage contract in order to protect the interest of Defendants and Plaintiff.
5. Due to the increase in the amounts due and owing to Plaintiff, Plaintiffs
judgment amount is not sufficient to satisfy the amounts due and owing on the mortgage and
the mortgage lien on the Property.
6. A sheriff's sale is scheduled for December 05, 2007, and the amounts due and
owing on the mortgage as of the sheriff's sale will be as follows:
Principal Balance
Interest from 04/01/2006 thru 12/05/2007
at 6.7500% Per diem interest rate at $43.71
Escrow
Sub-Total
Pro Rata PMI
Unpaid NSF Charges
Property Inspections
Miscellaneous Expense Due
INSPECTIONS
09/11/06 9.00
10/03/06 9.00
11/13/06 9.00
11/29/06 9.00
01/03/07 9.00
01/30/07 9.00
03/05/07 9.00
03/29/07 9.00
05110107 9.00
05/31/07 9.00
06/27/07 12.00
07/27/07 12.00
08/28/07 12.00
10/02/07 12.00
Total $138
$236,367.62
$32,061.12
$8,827.55
$277,256.29
$649.76
$20.00
$26.50
$5,278.96
BPO
07/31/06 100.00
04/12/07 350.00
04/27/07 100.00
06/25/07 235.00
Total $785
Property Preservation
04/05/07 1,375.00
F/C
09/21/06 325.00
09/21/06 1,500.00
09/21/06 190.00
09/21/06 55.50
06/15/07 125.00
06/15/07 125.00
06/15/07 34.00
06/15/07 1,250.00
06/15/07 15.00
07/12/07 (638.54)
Total $2980.96
Final total = $5278.96
Sub-Total
Recording Fees
Inspections
Appraisal
Sub-Total
Attorney's Fee at 5.0000% of principal balance
Costs of Suit and Title Search
TOTAL
$283,231.51
$27.00
$36.00
$500.00
$283,794.51
$11,818.38
$900.00
$296,512.89
. I
WHEREFORE, Plaintiff prays that the Petition be granted and Plaintiffs Judgment be
amended to $296,512.89, plus interest and costs of the action.
ectfully submitted,
GOLD BE McCAF Y & McKEEVER
By:
Ga E. McCaf y, Esq.
Pho : (?15) 825 302
Fax: (2 25-
Email: gmccaffe goldbecklaw.com
a
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6302
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
VERIFICATION
Gary E. McCafferty, Esq., hereby states that he is the attorney for plaintiff and that all of
the facts set forth within the attached Petition to Amend its Judgment are true and correct to the
best of his knowledge, information and belief. The undersigned understands that the foregoing
statements are made subject to the penalties 18 P.S. Section 1904.
Gary E. cCafferty
Phone: (21 825-6a
Fax: (215) 825-6-4-0,'
Email: gmccafferty(
Idbecklaw.com
¦
go -j
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6302
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S
PETITION TO AMEND JUDGMENT
Plaintiff is entitled to the amounts due and owing pursuant to the terms of the mortgage
and note at the time of the Sheriff's Sale of property involved. For reasons stated in the within
motion, Plaintiff s judgment in mortgage foreclosure is insufficient to compensate Plaintiff for
the amount due and owing under the mortgage. Specifically, interest charges, late charges and
advances made by plaintiff to pay taxes, insurance, or to otherwise protect its mortgage lien and
the interests of the Defendant, have all been accruing while Plaintiff s action in mortgage
foreclosure was delayed.
• v -1 •
CONCLUSION
For the reasons stated above and in the within petition, Plaintiff respectfully requests that
the petition be granted and Plaintiffs judgment be amended to $296,512.89, plus interest and
costs.
Respectfully submitted,
By:
GOLDBECK MWCAFFEAW & McKEEVER
Gary E. afferty, q.
Phone: (2 25- 2
Fax: (215) 825-6402
Email: gmccafferty@goldbecklaw.com
n
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
vs.
Plaintiff
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
CERTIFICATION OF SERVICE
Jaclyn Jamieson is a legal assistant with the firm of GOLDBECK McCAFFERTY &
McKEEVER and hereby certifies that a true and correct copy of Plaintiff's Petition to Amend
Judgment was mailed by first class mail, postage prepaid to Defendant(s) TIMOTHY C.
KEANE and NATALIE P. KEANE @ 110 E. Countryside Drive Boiling Springs, PA 17007
on October 19, 2007.
GOLDBECK McCAFFERTY & McKEEVER
By: a'-)
Gol beck a rty McKeever
4Jaclyn Jamieson
Judgment Department
Phone: (215) 825-6369
Fax: (215) 825-6378
Email: jjamieson@goldbecklaw.com
.x
MXAFFERTY & McKEEVER
CORPORATION
GOLDBECK
A PROFESsIONLpw
ATTORNEYS AT SUITE 5000
MELLON LNDEPEND STET CENTER
701 MARS
PHILADELPHIA, PA 19106
VyW W.GOLDBECKLAW.COM
October 18, 2007
PROTHONOTARY OF CUMBERLAND COUNTY
Prothonotary of Cumberland County
1 Courthouse square
.
Carlisle, PA 17013
GE CORPORATION vs. TIMOTHY C. KEANE and NATALIE P
RE. M&T MORTGA
KEANE
Docket Numbee?. 0M6-5T 1 070
Our file Numb
To the prothonotary:
end Judgment the same of record with the Court an
. on to A
Kindly file Plaintiff's P het elf adds ssed stamped envelope enclosed.
stamp-
return atime-stamped copy In
Very truly yours,
Goldbeck McCafferty & McKeever
j aclyn J amieson
judgment Department
Phone: (215) 825-6369
Fax: (215) 825-6378
Email: jjamieson@goldbecklaw.com
cc: TIMOTHY C- KEANE
NATALIE P KEANE
Drive
110 E. Countryside
PA 17007
Boiling Springs,
,_
Exhibit B
Rule Returnable issued by the Court
OCT 2 b20DV4'
} _,
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203 plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
VS.
TIMOTHY C. KEANE and NATALIE P.
KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
RULE
entered u on Defendant(s) to show cause why the relief requested
AND NOW, a rule is p
in Plaintiff s Motion to Reassess Damages should not be granted.
'oh
Rule returnable the )? day of
Date:
Exhibit C
Plaintiff's Certification of Service of the Rule Returnable
GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D.#42386
Suite 500 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532 :?Mq
215-825-6302
Attorney for Plaintiff CL-Mn?
IN THE CO T AOIMON PLEAS
M&T MORTGAGE CORPORATION
Plaintiff of Crb unty
vs. C T
P?n
TIMOTHY C. KEANE and NATALIE P. ACTION OF GAGE,,;
KEANE `
FOREC
-,
110E. Countryside Drive i..
Boiling Springs, PA 17007
Defendant(s) No. 06-518
I y J1
CERTIFICATION OF SERVICE OF RULE RETURNABLE
Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of
Plaintiffs Petition for Reassessment of Damages and Rule Returnable Dated November 15,
2007, stating the RULE is returnable FIFTEEN (15) days from the date of service was mailed
by postage prepaid to Defendant(s) TIMOTHY C. KEANE & NATALIE P.
'
first class mail, KEANE on November 19, 2007 @ 110 E. Countryside Drive, Boiling Springs, PA 17007.
GOLDBECK CAFFE Y & McKEEVER
By:
Gary E. Cafferty, sq.
215-825-6
215-825-6442 ax
Email: gmccafferty oldbecklaw.com
Sworn bscri ed to
me t 9 day vember, 2007
?,VAN1A
p NN
GOM MONWEALY
NOTARIAL of pW jdeiph'p ry Public
?? L. HOD, phila CouMY
g? It 0
My commission Expires June
r '
GOLDBECK McCAFFERTY& McKEEVER
A PROFESSIONAL CORPORATION
SUITE 5000
MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
WWW.GOLDBECKLAW.COM
November 19, 2007
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Dri ve
Boiling Springs, PA 17007
TIMOTHY C. KEANE & NATALIE P.
enclosed for service upo n you Plaintiffs Petition for Reassessment of Damages
I have
able FIFTEEN (15
November 15, 2007, stating the RULE is return
and Rule Returnable Dated al counsel to discuss this
days from the date of service was mailed . Please contact your own leg
RE: M&T MORTGAGE CORPORATION v
KEANE
Docket Number. 06-5188
Loan Number: 0006390603
Our File Number: MT-1070
petition.
Very truly yours,
GOLDBECK MCCAFFERTY & McKEEVER
By: Jaclyn Jamieson McCafferty
Legal Assistant to Gary
215-825-6369
215-825-6378 (fax)
ii amieson@goldbecklaw.com
)I c1 • ?
GOLDBECK WCAFFERTY & McKEEVER
A PROFESSIONAL CORPORATION
SUITE 5000
MELLON INDEPENDFNCF. CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
N% WW.GOLDBECKLAW.COM
November 19, 2007
PROTHONOTARY OF CUMBERLAND COUNTY
Prothonotary of Cumberland County
1 Courthouse Square
Carlisle, PA 17013
RE: M&T MORTGAGE CORPORATION vs. TIMOTHY C. KEANE and
NATALIE P. KEANE
NO. 06-5188
Our file Number: MT-1070
To the Prothonotary:
Kindly file Plaintiff's CERTIFICATION OF SERVICE OF RULE RETURNABLE with
the Court and return a time-stamped copy in the pre-addressed and prepaid envelope provided.
Very truly yours,
GOLDBECK McCAFFERTY & McKEEVER
By: Jaclyn Jamieson
Legal Assistant to Gary McCafferty
215-825-6369
215-825-6378 (fax)
'Jamieson@goldbecklaw.com
CC: TIMOTHY C. KEANE and
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
GOLDBECK McCAFFERTY & MCKEEVER
A PROFESSIONAL CORPORATION
SUITE 5000 MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
VAM.GOLDBECKLAW.COM
December 4, 2007
Prothonotary of Cumberland County
1 Courthouse Square
Carlisle, PA 17013
RE:M&T MORTGAGE CORPORATION
VS.
TIMOTHY C. KEANE and NATALIE P. KEANE
NO. 06-5188
Our File Number: MT-1070
To the Prothonotary:
Kindly file Plaintiffs Motion to Make Rule Absolute with the Court and return a time-
stamped copy in the enclosed self-addressed stamped envelope.
Goldbeck McCafferty & McKeever
By: Jaclyn Jamieson
Legal Assistant to Gary McCafferty
215-825-6369
215-825-6378 (fax)
jjamieson@goldbecklaw.com
?GOLDBECK McCAFFERTY & McKEEVER
BY: Gary E. McCafferty
Attorney I.D. # 42386
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6342
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE and NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
DEC 0 61D071
for Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 06-5188
--7 ORDER
AND NOW, this 1 day of Q 007, upon consideration of the Petition
of M&T MORTGAGE CORPORATION to Reassess Damages and Motion to Make Rule
Absolute, it is,
ORDERED:
That the Rule is hereby made absolute and the petition is granted and Plaintiffs
judgment is hereby reassessed to $296,512.89, plus interest at the rate set forth in the mortgage
and note and costs of this action through the date of Sheriff's Sale or until the mortgage lien is
paid in full.
Distribution list:
Gary E. McCafferty, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street,
Philadelphia, PA 19106-1532
TIMOTHY C. KEANE, 110 E. Countryside Drive Boiling Springs, PA 17007
NATALIE P. KEANE, 110 E. Countryside Drive Boiling Springs, PA 17007
12OF rep rn.'-L t 6c
?
l 01,/7 D '-?J
t4-a
07
..w
i is t F_ 1
LL ro
M & T Mortgage Corporation In the Court of Common Pleas of
VS Cumberland County, Pennsylvania
Timothy C. Keane and Natalie P. Keane Writ No. 2006-5188 Civil Term
William Cline, Deputy Sheriff, who being duly sworn according to law, states that on
October 08, 2007 at 1350 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendants, to wit: Timothy C.
Keane and Natalie P. Keane, by making known unto Natalie P. Keane, personally and wife of
Timothy C. Keane, at 110 E. Countryside Drive, Boiling Springs, Cumberland County,
Pennsylvania its contents and at the same time handing to her personally the said true and correct
copy of the same.
William Cline, Deputy Sheriff, who being duly sworn according to law, states that on
October 08, 2007 at 1350 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 Timothy C. Keane and Natalie P.
Keane located at 110 E. Countryside Drive, Boiling Springs, 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: Timothy C.
Keane and Natalie P. Keane by regular mail to their last known address of 110 E. Countryside
Drive, Boiling Springs, PA 17007. These letters were mailed under the date of October 12, 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 December 5,
2007 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck, on
behalf of M&T Bank s/b/m M&T Mortgage Corporation. It being the highest bid and best price
received for the same, M&T Bank s/b/m M&T Mortgage Corporation of 1 Fountain Plaza, Buffalo,
NY 14203 being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,015.65.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
$30.00
19.91
15.00
15.00
48.00
10.00
.50
2.00
9.60
15.00
30.00
395.00
346.22
14.92
25.00
39.50
$ 1,015.65 ? ?//? ?a F
P
J
ua. Gi pwG
?„_ d o 3.2 /3
So Answer
R. Thomas Kline, Sheriff
BY c
Real Estate Se eant
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
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
vs.
TIMOTHY C. KEANE
NATALIE P. KEANE
(Mortgagor(s) and Record Owner(s))
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-5188
AFFIDAVIT PURSUANT TO RULE 3129
M&T MORTGAGE CORPORATION, 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:
110 E. Countryside Drive
Boiling Springs, PA 17007
1.Name and address of Owner(s) or Reputed Owner(s):
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
2. Name and address of Defendant(s) in the judgment:
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
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
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
BENEFICIAL CONSUMER DISCOUNT CO. DB/A BENEFICIAL MORTGAGE CO. OF PA.
419 Village Drive
Suite 2
Carlisle, PA 17013
BENEFICIAL MORTGAGE CO. OF PA
961 Weigel Drive
Elmhurst, IL 30126
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
110 E. Countryside Drive
Boiling Springs, PA 17007
Terrance J. McCabe
123 South Broad Street, Suite 2080
Philadelphia, PA 19107-1029
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unworn falsification to authorities.
DATED: June 29, 2007
K McCAFFERTY & McKEEVER
h A. Goldbeck, Jr., Esq.
for Plaintiff
06-5188
GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Term
No. 06-5188
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: KEANE, TIMOTHY C.
TIMOTHY C. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Your house at 110 E. Countryside Drive, Boiling Springs, PA 17007 is scheduled to be sold at
Sheriffs Sale on Wednesday, December 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the court judgment of $262,399.88 obtained by M&T MORTGAGE
CORPORATION 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 M&T MORTGAGE CORPORATION, the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call
our office at 215-825-6329 or 1-866413-2311 and
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
06-5188
3. You may also be able to stop the sale through other legal proceedings
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
06-5188
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
5). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretentionAgoldbecklaw.com.
Call Judy 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 MT-1070.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
06-5188
GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
Plaintiff
VS.
TIMOTHY C. KEANE
NATALIE P. KEANE
Mortgagor(s) and Record Owner(s)
110 E. Countryside Drive
Boiling Springs, PA 17007
Defendant(s
Term
No. 06-5188
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: KEANE, NATALIE P.
NATALIE P. KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
Your house at 110 E. Countryside Drive, Boiling Springs, PA 17007 is scheduled to be sold at
Sheriffs Sale on Wednesday, December 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the court judgment of $262,399.88 obtained by M&T MORTGAGE
CORPORATION 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 M&T MORTGAGE CORPORATION, the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call
our office at 215-825-6329 or 1-866-413-2311 and
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
06-5188
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
06-5188
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or .
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
5). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention(a-,goldbecklaw.com.
Call Judy 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 MT-1070.
Para informacion en espanol puede communicarse con Loretta at 215-825-6344.
All that certain tract of land situate in South Middletown Township, Cumberland County, Pennsylvania,
bounded and described as follows:
Beginning at a point located on the northern right of way lien of East Countryside Drive, (50 foot right-
of-way), said point being referenced from the centerline intersection of Jane Lane (50 foot right-of-way)
and East Countryside Drive by the following: from said intersection along centerline of East
Countryside Drive, South 87 degrees 18 minutes 49 seconds East, a distance of 163.00 feet to a point;
thence across East Countryside Drive, North 02 degrees 41 minutes 11 seconds East, a distance of 25.00
feet to a point on the southern right-of-way line of East Countryside Drive at the southeast corner of Lot
#38 and the point of beginning; thence along the East side of Lot No. 38, North 02 degrees 41 minutes
11 seconds East, a distance of 121.05 feet to a point; thence along the South side of Lot No. 33, South
87 degrees 18 minutes 49 seconds East, a distance of 134.00 feet to a point; thence along the West side
of Lot No. 40, South 02 degrees 41 minutes 11 seconds West, a distance of 121.05 feet to a point on the
northern right-of-way of East Countryside Drive; thence along said right-of-way, North 87 degrees 18
minutes 49 seconds West, a distance of 134.00 feet to the point of beginning.
Being Lot No. 39 of the Plan of Lots known as Misty Meadows, Phase 1 as recorded on the Office of
Recorder of Deeds for Cumberland County, in Plan Book 77, page 95; containing 16,220.05 square feet.
Subject to building and use restrictions set forth in Miscellaneous Book 606, page 1009.
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 110 E. Countryside Drive
Boiling Springs, PA 17007
SOLD as the property of TIMOTHY C. KEANE and NATALIE P. KEANE
TAX PARCEL #40-10-0638-063
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-5188 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION Plaintiff (s)
From TIMOTHY C. KEANE & NATALIE P. KEANE
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $262,399.88
Interest from 10/17/06 to date of sale at 6.7500%
Atty's Comm %
Arty Paid $170.90
Plaintiff Paid
Date: 07-03-07
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
A !l4
Cu s R. Long, P notary
By:
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Deputy
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
AAA
Real Estate Sale # 37
On August 16, 2007 the Sheriff levied upon the
defendant's interest in the real property situated in
South Middleton Township, Cumberland County, PA
Known and numbered as 110 E. Countryside Drive,
Boiling Springs, more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: August 16, 2007 By:J Q
Real Estate Sergeant
bZ .b V ?- -- r£ii' LOrN
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
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:
October 26, November 2 and November 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. 37
Lis arie Coyne, Edit 1'
Writ No. 2006-5188 Civil
M & T Mortgage Corporation
SWO TO AND SUBSCRIBED before me this
vs.
Timothy C. Keane and 9 day of November, 2007
Natalie P. Keane _
Atty.: Joseph Goldbeck
DESCRIPTION ,
All that certain tract of land situ- Notar
Notary
ate in South Middleton Township,
Cumberland County, Pennsylvania,
bounded and described as follows:
Beginning at a point located on
the northern right of way lien of East _
NOTARIAL SEAL
Countryside Drive, (50 foot right-of-
way), said point being referenced DEBORAH A COLLINS
from the centerline intersection of Notary Public
Jane Lane (50 foot right-of-way) and CARLISLE BORO, CUMBERLAND COUNTY
East Countryside Drive by the fol- My Commission Expires Apr 28, 2010
lowing: from said intersection along
centerline of East Countryside Drive,
The Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8292
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
c?he atriot-News
Now you know
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. 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 This ad ran on the date(s) shown below:
F" aft" solo "M 37 10/24/07
WON" 20"00 CNNTwm
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Assignment of Bid
NO. 06-5188 - KEANE
110 E. Countryside Drive
Boiling Springs, PA 17007
I, Joseph A. Goldbeck, Jr., Esquire, as attorney for the successful bidder, hereby
assign my bid at the Sheriff Sale dated December 05, 2007 to:
M&T BANK SB/M M&T MORTGAGE CORPORATION
1 Fountain Plaza
Buffalo, NY 14203
GOLDBECK MCCAFFERTY & MCKEEVER
Date: December 12, 2007
JOSEPH A. GOLDBECK, JR.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which M & T Bank is the grantee the same having been sold to said grantee on the
5th day of Dec A.D., 2007, under and by virtue of a writ Execution issued on the 3rd day of Jam, A.D.,
2007, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 5188, at the suit
of M & T Mtg Corp against Timothy C Keane & Natalie P is duly recorded as Instrument Number
200801487.
IN TESTIMONY WHEREOF, I have he?to set my hand
and eal of said office this day of
A.D.
Rec rder of Deeds
Records of Deals, Uun benand County. Cadisle, PA
My Corn auion Expkse ft Fket Monday of Jan.2010