HomeMy WebLinkAbout06-6195GOLDBECK 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
WWW.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
0 L - 1v I9,S 01 vi C AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
Plaintiff
vs.
CHERYL E. HOERNER
Mortgagor and Real Owner
10 West Circle
Camp Hill, PA 17011
Defendant
CIVIL ACVN: MORTGAGE;
ECLOSOME
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, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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 O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-
9400 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 ALS-0086.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is AURORA LOAN SERVICES, LLC, 601 5th Avenue, Scottsbluff, NE 69361.
2. The names and addresses of the Defendant is CHERYL E. HOERNER, 10 West Circle, Camp Hill, PA
17011, who is the mortgagor and real owner of the mortgaged premises hereinafter described.
3. On June 19, 2002 mortgagors made, executed and delivered a mortgage upon the Property hereinafter
described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS
A NOMINEE FOR LEHMAN BROTHERS BANK, FSB, A FEDERAL SAVINGS BANK, which
mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1763, Page
1015. The mortgage has been assigned to: AURORA LOAN SERVICES, LLC by assignment of
Mortgage which assignment is lodged for recording. The Mortgage and assignment(s) are matters of
public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil
Procedure 1019(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 July 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 ..................................................................................$227,253.96
Interest from 06/01/2006 through 10/31/2006 at 8.8500% .......................$8,548.10
Per Diem interest rate at $55.87
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph .................$11,362.70
Late Charges from 07/01/2006 to 10/31/2006 .............................................$522.08
Monthly late charge amount at $130.52
Costs of suit and Title Search ......................................................................$900.00
Escrow ....................................................................................................... $6,872.02
Mortgagor Recoverable Corporate Advance .................................................$36.00
Suspense ....................................................................................................... -$93.14
Monthly Escrow amount $747.59
$255,401.72
7. If the Mortgage is reinstated prior to a Sheriff s Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up
to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at
Sheriff s Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the
Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding,
this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that
was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law.
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendant 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 Defendant 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 Defendant
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 $255,401.72,
together with interest at the rate of $55.87, 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 Sheriffs Sale of the Property.
By: !- 0 ..0 etd.G-c<,
eSOLDBECK McCAFFERTY & McKEEVER
BY: JOSEPH A. GOLDBECK, JR., ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
I,?p,t?c?Jti??calV as the representative of
the Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
Date: AURORA OAN SERVICE
#0011792975 - CHERYL E. HOERNER
?hibit.X
ALL THAT CERTAIN lot of land situate in the Township of Hampden, County of Cumberland and Commonwealth
of Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point on the southern line of West Circle, said point being located 5.02 feet East of the
intersection of the dividing line of Lots Numbers 4 and 5 on the hereinafter mentioned Plan of Lots and West
Circle, measured along the scuthem line of West Circle; thence in a southerly direction through Lot Number 4 on
said Plan, 195.58 feet to a point on the dividing line between Lots Numbers 3 and 4 on said Ian, said point being
located 5.08 feet East of the southwest comer of Lot Number 4 measured along the dividing line of Lots 3 and 4;
thence in a westerly direction along the dividing line of Lots 3 and 4; thence in a westerly direction along the
dividing line between Lots Numbers 3 and 4 and 2 and 5, 100 feet to a point; thence in a northerly direction
through Lot Number 5,198.89 feet to a point in the southern line of West Circle, said point being located 5 feet
East of the intersection of West Circle and the line dividing Lots Numbers 5 and 6, measured along the southern
line of West Circle; thence in an easterly direction along the southern line of West Circle on a curve to the let
having a radius of 50 feet, 50.8 feet to a point; thence continuing in an easterly direction along the southern line of
West Circle 56.17 feet to the place of BEGINNING.
BEING part of Lot Number 4 and part of Lot Number 5 as shown on the Plan of Lots, Section 1, Point Ridge Farm,
,v, Pennsylvania, said Plan being recorded in the Cumberland County
Hampden Township, Cumberland Count
Recorder's Office in Plan Book 8, Page 2
HAVING THEREON ERECTED a modified 2 story stone and aluminum siding dwelling known and numbered as
10 West Circle.
SAID LOT of land shall be subject to the protective covenants and restrictions and reservations established by
Kurvin W. Lauer and Eva S. Lauer, his wife, with respect to lands shown on said Plan by an instrument in writing
dated February 6, 1956 and recorded February 17, 1956, in the Recorder's Office aforesaid in Miscellaneous
Book 118, Page 445.
UNDER AND SUBJECT, NEVERTHELESS, to easements, restrictions, reservations, conditions and rights of way
of record.
Parcel No. 10-20-1846-073
(2002050099.PF0/2002050099/70)
QY 1 7UJIb 1 03 1
E?Fcidit B
A'JR.ORA LOAN SERVICES
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ACT 91 NOTICE TSeptember 06, 2006 SAVE YOUR HOME FROM
G011792975CL07109-06-06 FORECLOSU
Chervl E Hoerner
10 West Cir
Camp Hill PA 17011
RE: Borrower(s):
Property Address
Loa: No.:
Current Lender/Servicer:
?16a 39D1 9849 615? 6990
•
Cheryl E Hoerner
10 W Cir
Camp Hill PA 17011
0011792975
Aurora Loan Services
This is an official notice that the mortgage on your home is in default,
and the lender intends to foreclose. Specific information about the
nature of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help
to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with
you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling
Agencies serving your County are listed at the end of this Notice. If
you have any questions, you may call the Pennsylvania Housing Finance
Agency toll free at 1-800-342-2397. (Persons with impaired hearing can
call (717) 780-1869).
This Notice contains important legal information. If you have any
questions, representatives at the Consumer Credit Counseling Agency
may be able to help explain it. You may also want to contact an attorney
in your area. The local bar association may be able to help you find a
lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE
ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Page 1 of 6 IMPORTANT INFORMATION ON PAGE 5
(ENDER At R();..
' ? - ..
AURORA LOAN SERVICES
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Loan Num::er 0011792975 Page 2 of
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE
FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled
to a temporary stay of foreclosure on your mortgage for thirty (30)
days from the date of this Notice. During this time you must arrange
and attend a "face-to-face" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING
MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE.
THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT",
EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the
consumer credit counseling agencies listed at the end of this notice,
the lender may NOT take action against you for thirty (30) days
after the date of this meeting. The names, addresses and telephone
numbers of designated consumer credit counseling agencies for the
county in which the property is located are set forth at the end
of this Notice. It is only necessary to schedule one face-to-face
meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-- Your mortgage is in default
for the reasons set forth later in this Notice (see following pages
for specific information about the nature of your default). If you
have tried and are unable to resolve this problem with the lender,
you have the right to apply for financial assistance from the Homeowner's
Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will
assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF
YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
L?J
TEND!
!:
A T.; RORA LOAN SERVICES
L.(--)ari Humijer 0011792975 Page 3 of 6"
AGENCY ACTION - Available funds for emergency mortgage assistance are
very limited. They will be disbursed by the Agency under the eligibilit
criteria established by the Act. The Pennsylvania Housing Finance Agenc
has sixty (60) days to make a decision after it receives your
application. During that time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing
Finance Agency of its decision on your application.
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on
your property located at: 10 W Cir, Camp Hill PA 17011
is SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the
following amounts are now past due:
Regular monthly payments of $ 2610.37 for the months of
July 01, 2006 through today, September 06, 2006.
Unpaid Late Charge Balance 279.42
NSF Fees.00
Inspection Fees.00
Corporate Advance 24.00
(Less Suspense) 93.14
TOTAL AMOUNT DUE $ 8041.39
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY
(30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT
PAST DUE TO THE LENDER, WHICH 1S $ 8041.39 PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE
THIRTY (30) DAY PERIOD. Payments must be made by cashier's
check, certified check or money order made payable and sent to:
Aurora Loan Services
Attn: Cashiering Dept.
PO Box 5180
Denver, CO 80217-5180
You can cure any other default by taking the following action within
THIRTY (30) DAYS of the date of this Notice:
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within
THIRTY (30) DAYS of the date of this Notice, the lender intends to
exercise their rights to accelerate the mortgage debt considered due
immediately, and you may lose the chance to pay the mortgage in monthly
installments. If full payment of the total amount past due is not made
within THIRTY (30) DAYS, the lender also intends to instruct their
attorneys to start legal action to foreclose upon your mortgaged
property.
Lt
AURORA LOAN SERVICES
i ?; { i; :!':. • ! ;. i". ?`; I";;L • `,( ."f'C',!ti i'11 , 1f c?i,?? :m.
Loan Number 0011792975 Page 4 of 6
IF 1HE MORTGAGE IS FORECLOSED UPON - The mortgaged property will
be sold by the Sheriff to pay off the mortgage debt. If the lender
refers your case to their attorneys, but you cure the delinquency
before the lender begins legal proceedings against you, you will still
be required to pay the reasonable attorney fees that were actually, up
to $50.00. However, if legal proceedings are started against you, you
will have to pay all reasonable attorney fees actually incurred by the
lender even if they exceed $50.00. Any attorney fees will be added to
the amount you owe the Lender, which may also include other reasonable
costs. If you cure the default within the THIRTY (30) DAY period by
paying all amounts due, you will not be required to pay attorney fees.
OTHER LENDER REMEDIES - The lender may also start legal action against
you personally for the unpaid principal balance and all other sums due
under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not
cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, you still have the right to cure the default
and prevent the sale at any time up to one hour before the Sheriff's
sale. You may do so by paying the total amount then past due, plus any
late or other charges then due, reasonable attorney fees and costs
connected with the foreclosure sale and other costs connected with the
Sheriff's sale as specified in writing by the lender and by performing
any other requirements under the mortgage. Curing your default in the
manner set forth in this notice will restore your mortgage to the same
position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the
earliest date that such a Sheriff's sale of the mortgaged property
could be held would be approximately ten (10) months from the date of
this Notice. A notice of the actual date of the Sheriff's sale will
be sent to you before the sale. Of course, the amount needed to cure
the default will increase the longer you wait. You may find out at any
time exactly what the required payment or action will be by contacting
the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: AURORA LOAN SERVICES
Address: PO BOX 2056
Scottsbluff, NE 69363-2056
Phone Number: 800-550-0509
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's sale
will end your ownership of the mortgaged property and your right
to occupy it. If you continue to live in the property after the
Sheriff's sale, a lawsuit to remove you and your furnishings and
other belongings could be initiated by the lender at any time.
IENCiEA '.?
AURORA LOAN SERVICES
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oar_ :numb cr 00117?2975 Page -5 of
ASSU7MPTIO117 OF MORTGAGE - You may or may not
sell or transfer your home to a buyer or transferee who will assume
the mortgage debt, provided that all the outstanding payments,
charges and attorney fees and costs are paid prior to or at the
sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO
PAY OFF THIS DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES
IN ANY CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
You may find out at any time exactly what the required payment
will be by calling us at the following number: (800) 550-0509.
This payment must be cashiers check, certified check or money
order, payable to Aurora Loan Services and sent to the address
above.
You should realize that a Sheriff's or other similar official's
sale will end your ownership of the mortgaged property and your
right to remain in it. If you continue to live in the property
after the Sheriff's or other similar official's sale, a lawsuit
could be initiated to evict you.
You shall have the right to assert in the foreclosure proceedings,
the non-existence of a default, or any other defense that you may
have, to acceleration or foreclosure.
You have additional rights to help protect your interest in the
property.
0
LENDER J T.
AURORA LOAN SERVICES
Loan :lumber 0011792975
Page '5 df: ;
You have the right to sell the property to obtain money to pay off
the mortgage debt, or to borrow money from another lending
insti?ution to pay off this debt.
You may have the right to sell or transfer the property, subject to
the mortgage, to a buyer or transferee who will assume the mortgage
debt, provided that all the outstanding payments, charges and
attorney fees and costs are paid prior to or at the sale, and
that the other requirements under the mortgage are satisfied.
Contact us to determine under what circumstances this right might
exist.
You have the right to have this default cured by any third party
acting on your behalf.
If you cure the default, the mortgage will be restored to the same
position as if no default had occurred. However, you are not
entitled to this right to cure your default more than THREE (3)
times in any calendar year.
This is an attempt to collect a debt and any information obtained will
be used for that purpose. However, if you have previously received
a discharge in bankruptcy, and you were a borrower on a loan with
Aurora Loan Services, or its predecessor(s), at the time of filing your
bankruptcy, this correspondence is not and should not be construed to
be an attempt to collect a debt or impose personal liability against you,
but solely an enforcement of a lien against the property.
If you have a,iy questions regarding this matter, feel free to contact
one of our Loan Counselors at the address above or by calling
800-550-0509.
Loan Counseling
Aurora Loan. Services
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APPENDIX C
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
CCCS of Western Pennsylvania, Inc. Financial Counseling Services of Franklin
2000 Linglestown Road 31 West 3rd Street
Harrisburg, PA 17102 Waynesboro, PA 17268
(717) 541-1757 (717) 762-3285
Urban League of Metropolitan Harrisburg YWCA of Carlisle
N 6`" Street 301 G Street
Harrisburg, PA 17101 Carlisle, PA 17013
(717) 234-5925 (717) 243-3818
FAX (717) 234-9459 FAX (717) 731-9589
Community Action Comm of the Capital Region Adams County Housing Authority
1514 Derry Street 139-143 Carlisle St
Harrisburg, PA 17104 Gettysburg, PA 17325
(717) 232-9757 (717) 334-1518
FAX (717) 234-2227 FAX (717) 334-8326
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In the Court of Common Pleas of Cumberland County
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
VS.
CHERYL E. HOERNER
(Mortgagor(s) and Record Owner(s))
10 West Circle
Camp Hill, PA 17011
Plaintiff
Defendant(s)
PRAECIPE FOR JUDGMENT
No. 06-6195
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 CHERYL E. HOERNER by default for want of an Answer.
Assess damages as follows:
$259,281.00
Debt
Interest from 12/09/06 to Date of Sale
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIE AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FR HE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivered the arty against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at le t to days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
Joseph A. G ck, r.
Attorney for Pl ' ' f
I.D. #16132
AND NOW £ C N ooh , Judgment is entered in favor of
AURORA LOAN SERVICES, LLC and against CHERYL E. HOERNER by default for want of an Answer and damages
assessed in the sum of $259,281.00 as per the above certification.
Protho otary
/
Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
Plaintiff
vs.
CHERYL E. HOERNER
(Mortgagors and Record Owner(s))
10 West Circle
Camp Hill, PA 17011
Defendant(s)
No. 06-6195
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
Prothono
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
ALS-0086
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: November 27, 2006
TO:
CHERYL E. HOERNER
10 West Circle
Camp Hill, PA 17011
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
VS.
CHERYL E. HOERNER
(Mortgagor(s) and Record Owner(s))
10 West Circle
Camp Hill, PA 17011
TO: CHERYL E. HOERNER
10 West Circle
Camp Hill, PA 17011
Plaintiff
Defendant(s)
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 06-6195
rupaRTANT 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.
LEGALSERVICESINC
8 hvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
;?ns?h.? Tn?rl?ecl??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, CHERYL E. HOERNER, is
about unknown years of age, that Defendant's last known
residence is 10 West Circle, Camp Hill, PA 17011, and is
engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or o rwise within the
provisions of the Soldiers' and Sailors' (vil Relief 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
AURORA LOAN SERVICES, LLC
601 5th Avenue IN THE COURT OF COMMON PLEAS
Scottsbluff, NE 69361
Plaintiff of Cumberland County
vs.
CHERYL E. HOERNER CIVIL ACTION LAW
(Mortgagor(s) and Record owner(s))
10 West Circle
Camp Hill, PA 17011 ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 06-6195
ORDER FOR JUDGMENT
Please enter Judgment in favor of AURORA LOAN SERVICES, L , a against CHERYL E.
r ty (60) days if defendant is
HOERNER for failure to file an Answer in the above action within (20) da'r
the United States of America) from the date of service of the Complaint, in t of $259,281.00.
Joseph A. Goldb ck, J
Attorney for Pla' ti
I hereby certify that the above names are correct and that the precis resi ce address of the judgment
creditor is AURORA LOAN SERVICES, LLC 601 5th Avenue Scottsbluff, 9361 and that the name(s) and
last known address(es) of the Defendant(s) is/are CHERYL E. WERNER, est C' cle Camp Hill, PA 17011;
GOLDBECK M AFFER Y & McKEEVER
BY: Joseph A. Go dbeck
Attorney for Plaint
V
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
Interest from 06/01/2006 through
12/08/2006
Reasonable Attorney's Fee
Late Charges
Costs of Suit and Title Search
Escrow
Mortgagor Recoverable Corporate
Advance
Suspense
$227,253.96
$10,671.16
$11,362.70
$783.12
$900.00
$8,367.20
$36.00
-$93.14
$259,281.00
GOLDBECK CAF RTY & McKEEVER
BY: Joseph A. oldbec Jr.
Attorney for PI intiff
AND NOW, this / 41 ' lday of , 2006 damages are assessed as above.
Pro Pro thy
44-
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
VS.
CHERYL E. HOERNER
Mortgagor(s) and Record Owner(s)
10 West Circle
Camp Hill, PA 17011
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
ACTION OF MORTGAGE FORECLOSURE
No. 06-6195
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from 12/09/06
to Date of Sale at
8.8500%
(Costs to be added)
$259,281.00
of Cumberland County
CIVIL ACTION - LAW
GOLDBECK MCCAI
BY: Joseph A. Goldb
Attorney for Plaintiff
Jr.
McKEEVER
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All that certain lot of land situate in the Township of Hampden, County of Cumberland and
Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit:
Beginning at a point on the southern line of West Circle, said point being located 5.02 feet East of the
intersection of the dividing line of Lots Number 4 and 5 on the hereinafter mentioned Plan of Lots and
West Circle, measured along the southern line of West Circle; thence in a southerly direction through
Lot Number 4 on said Plan, 195.58 feet to appoint on the dividing line between Lots Number 3 and 4 on
said Plan, said point being located 5.09 feet East of the southwest corner of Lot Number 4 measured
along the dividing line of Lots 3 and 4; thence in a westerly direction along the dividing line of Lots
Numbers 3 and 4 and 2 and 5, 100 feet to a point; thence in a northerly direction through Lot Number 5,
198.89 feet to a point in the southern line of West Circle, said point being located 5 feet East of the
intersection of West Circle and the line dividing Lots Numbers 5 and 6, measured along the southern
line of West Circle; thence in an easterly direction along the southern line of West Circle on a curve to
the left having a radius of 50 feet, 50.8 feet to a point; thence continuing in an easterly direction along
the southern line of West Circle 56.17 feet to the place of beginning.
Being part of Lot Number 4 and part of Lot Number 5 as shown on the Plan of Lots, Section 1, Point
Ridge Farm, Hampden Township, Cumberland County, Pennsylvania, said Plan being recorded in the
Cumberland County Recorder's Office in Plan Book 8, Page 2.
Having thereon erected a modified 2 story stone and aluminum siding dwelling known and numbered as
10 West Circle.
Said Lot of land shall be subject to the protective covenants and restrictions and reservations established
by Kurvin W. Lauer and Eva S. Lauer, his wife, with respect to lands shown on said Plan by an
instrument in writing dated February 6, 1956 and recorded February 17, 1956, in the Recorder's Office
aforesaid in Miscellaneous Book 118, page 445.
Under and subject, nevertheless, to easements, restrictions, reservations, conditions, and rights of way of
record.
BEING KNOWN AS 10 WEST C IRCLE, CAMP HILL PA 17011
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6195 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due AURORA LOAN SERVICES, LLC, Plaintiff (s)
From CHERYL E. HOERNER,
(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 $259,281.00
L.L. $.50
Interest FROM 12/9/06 TO DATE OF SALE AT 8.8500%
Atty's Comm % Due Prothy $1.00
Atty Paid $123.20
Plaintiff Paid
Other Costs
Date: DECEMBER 14, 2006
(Seal)
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Curt' R. Lon!, 'P onot
By:
Deputy
Telephone: 215-627-1322
Supreme Court ID No. 16132
/1
'boldbeck 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
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
VS.
CHERYL E. HOERNER
(Mortgagor(s) and Record Owner(s))
10 West Circle
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 06-6195
AFFIDAVIT PURSUANT TO RULE 3129
AURORA LOAN SERVICES, LLC, 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:
10 West Circle
Camp Hill, PA 17011
1.Name and address of Owner(s) or Reputed Owner(s):
CHERYL E. HOERNER
10 West Circle
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
CHERYL E. HOERNER
10 West Circle
Camp Hill, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
VILLAGE FINANCE CO.
P.O. BOX 3546
1771 E. Market Street
York, Pa 17402
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
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:
HOUSEHOLD REALTY CORP.
25 Gateway Drive
Gateway Square, Suite 107
Mechanicsburg, PA 17055
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
10 West Circle
Camp Hill, PA 17011
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best m personal knowledge or
information and belief. I understand that false statements herein are made subject to r enalt' s of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: December 8, 2006
GOLDBECK McC.
BY: Joseph A. Gob
Attorney for Plainti
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06-6195
GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
Plaintiff
vs.
CHERYL E. HOERNER
Mortgagor(s) and Record Owner(s)
10 West Circle
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-6195
Defendant(s,'
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: WERNER, CHERYL E.
CHERYL E. HOERNER
10 West Circle
Camp Hill, PA 17011
Your house at 10 West Circle, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $259,281.00 obtained by AURORA LOAN SERVICES, LLC 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 AURORA LOAN SERVICES, LLC, 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
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.
You may also be able to stop the sale through other legal proceedings.
r
06-6195
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
w
06-6195
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 ALS-0086.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
C"?
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-06195 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
AURORA LOAN SERVICES LLC
VS
HOERNER CHERYL E
BRIAN BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
HOERNER CHERYL E the
DEFENDANT , at 2055:00 HOURS, on the 2nd day of November , 2006
at 10 WEST CIRCLE
CAMP HILL, PA 17011
by handing to
CHERYL HOERNER
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 13.20
Affidavit: .00
Surcharge 10.00 R. Thomas Kline
.00
41.20v/ 11/06/2006
GOLD13ECK 77&/A CKEEVER
Sworn and Subscibed to By: ,.
c
before me this day Sheriff
of A. D.
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
ALS-0086
CF: 10/24/2006
SD: 06/13/2007
$259,281.00
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
Plaintiff
VS.
CHERYL E. HOERNER
Mortgagor(s) and
Record Owner(s)
10 West Circle
Camp Hill, PA 17011
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 06-6195
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/cesngeieatad"i (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.
pec,'tful% su itted )drrl
se A. o dbec , Jr.
y for Plaintiff
Aurora Loan Services, LLC In the Court of Common Pleas of
VS Aln Cumberland County, Pennsylvania
Cheryl E. Hoerner Writ No. 2006-6195 Civil Term
William Cline, Deputy Sheriff, who being duly sworn according to law, states that on
March 16, 2007 at 1700 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendant to wit: Cheryl E.
Hoerner, by making known unto Cheryl Hoerner, personally, at 10 West Circle, Camp Hill,
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 April
13, 2007 at 1252 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 Cheryl Hoerner, at 10 West Circle,
Newville, 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 defendant, to wit: Cheryl
Hoerner, by regular mail to her last known address of 10 West Circle, Camp Hill, PA 17011. 'T'his
letter was mailed under the date of April 3, 2007 and never returned to the Sheriffs Office.
So Answers:
R. Thomas Kline, Sheriff
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GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
901 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
VS.
CHERYL E. HOERNER
Mortgagor(s) and Record Owner(s)
10 West Circle
Camp Hill, PA 17011
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. 06-6195
AURORA LOAN SERVICES, LLC, 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:
10 West Circle
Camp Hill, PA 17011
1.Name and address of Owner(s) or Reputed Owner(s):
CHERYL E. HOERNER
10 West Circle
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
CHERYL E. HOERNER
10 West Circle
Camp Hill, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
VILLAGE FINANCE CO.
P.O. BOX 3546
1771 E. Market Street
York, Pa 17402
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
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:
HOUSEHOLD REALTY CORP.
25 Gateway Drive
Gateway Square, Suite 107
Mechanicsburg, PA 17055
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
10 West Circle
Camp Hill, PA 17011
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities.
DATED: May 18, 2007
ECK cCAFFERTY & McKEEVER
GVJ
A. Goldbeck, Jr., Esq.
B eph
Attorney for Plaintiff
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Aurora Loan Services, LLC In the Court of Common Pleas of
VS Cumberland County, Pennsylvania
Cheryl E. Hoerner Writ No. 2006-6195 Civil Term
William Cline, Deputy Sheriff, who being duly sworn according to law, states that on
March 16, 2007 at 1700 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendant to wit: Cheryl E.
Hoerner, by making known unto Cheryl Hoerner, personally, at 10 West Circle, Camp Hill,
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 April
13, 2007 at 1252 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 Cheryl Hoerner, at 10 West Circle,
Newville, 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 defendant, to wit: Cheryl
Hoerner, by regular mail to her last known address of 10 West Circle, Camp Hill, PA 17011. This
letter was mailed under the date of April 3, 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 4231.78
Posting Bills 15.00
Advertising 15.00
Law Library .50
Prothonotary 1.00
Mileage 24.96
Levy 15.00
Surcharge 20.00
Law Journal 467.00
Patriot News 423.98
Share of Bills 16.17
$5260.39 / C?,,- 7//-7/0 7
So Answers:
R. Thomas Kline, Sheriff
BY
Real Estate Se •geant
`.?o ,gyuo
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
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
Vs.
CHERYL E. HOERNER
(Mortgagor(s) and Record Owner(s))
10 West Circle
Camp Hill, PA 17011
Plaintiff
of Cumberland County
CIVIL ACTION - LAW
•
Defendant(s)
IN THE COURT OF COMMON PLEAS
ACTION OF MORTGAGE FORECLOSURE
No. 06-6195
AFFIDAVIT PURSUANT TO RULE 3129
AURORA LOAN SERVICES, LLC, 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:
10 West Circle
Camp Hill, PA 17011
1.Name and address of Owner(s) or Reputed Owner(s):
CHERYL E. HOERNER
10 West Circle
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
CHERYL E. HOERNER
10 West Circle
Camp Hill, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
VILLAGE FINANCE CO.
P.O. BOX 3546
1771 E. Market Street
York, Pa 17402
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
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:
HOUSEHOLD REALTY CORP.
25 Gateway Drive
Gateway Square, Suite 107
Mechanicsburg, PA 17055
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
10 West Circle
Camp Hill, PA 17011
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best pf`ffi? personal knowledge or
information and belief. I understand that false statements herein are made subject to th penaltj?es of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities. ??
DATED: December 8, 2006
GOLDBECK.
BY: Joseph A.
Attorney for P
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
06-6195
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
VS.
CHERYL E. HOERNER
Mortgagor(s) and Record Owner(s)
10 West Circle
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-6195
Defendant(s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: HOERNER, CHERYL E.
CHERYL E. HOERNER
10 West Circle
Camp Hill, PA 17011
Your house at 10 West Circle, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $259,281.00 obtained by AURORA LOAN SERVICES, LLC 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 AURORA LOAN SERVICES, LLC, 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.
You may also be able to stop the sale through other legal proceedings.
T
P
06-6195
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 fmd
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
06-6195
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 homeretentionkgoldbecklaw.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 ALS-0086.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
r
All that certain lot of land situate in the Township of Hampden, County of Cumberland and
Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit:
Beginning at a point on the southern line of West Circle, said point being located 5.02 feet East of the
intersection of the dividing line of Lots Number 4 and 5 on the hereinafter mentioned Plan of Lots and
West Circle, measured along the southern line of West Circle; thence in a southerly direction through
Lot Number 4 on said Plan, 195.58 feet to appoint on the dividing line between Lots Number 3 and 4 on
said Plan, said point being located 5.09 feet East of the southwest corner of Lot Number 4 measured
along the dividing line of Lots 3 and 4; thence in a westerly direction along the dividing line of Lots
Numbers 3 and 4 and 2 and 5, 100 feet to a point; thence in a northerly direction through Lot Number 5,
198.89 feet to a point in the southern line of West Circle, said point being located 5 feet East of the
intersection of West Circle and the line dividing Lots Numbers 5 and 6, measured along the southern
line of West Circle; thence in an easterly direction along the southern line of West Circle on a curve to
the left having a radius of 50 feet, 50.8 feet to a point; thence continuing in an easterly direction along
the southern line of West Circle 56.17 feet to the place of beginning.
Being part of Lot Number 4 and part of Lot Number 5 as shown on the Plan of Lots, Section 1, Point
Ridge Farm, Hampden Township, Cumberland County, Pennsylvania, said Plan being recorded in the
Cumberland County Recorder's Office in Plan Book 8, Page 2.
Having thereon erected a modified 2 story stone and aluminum siding dwelling known and numbered as
10 West Circle.
Said Lot of land shall be subject to the protective covenants and restrictions and reservations established
by Kurvin W. Lauer and Eva S. Lauer, his wife, with respect to lands shown on said Plan by an
instrument in writing dated February 6, 1956 and recorded February 17, 1956, in the Recorder's Office
aforesaid in Miscellaneous Book 118, page 445.
Under and subject, nevertheless, to easements, restrictions, reservations, conditions, and rights of way of
record.
BEING KNOWN AS 10 WEST C IRCLE, CAMP HILL PA 17011
WRIT OF EXECUTION and/or ATTACHMENT
I
COMMONWEALTH OF PENNSYLVANIA) NO 06-6195 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due AURORA LOAN SERVICES, LLC, Plaintiff (s)
From CHERYL E. HOERNER,
(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 $259,281.00
L.L. $.50
Interest FROM 12/9/06 TO DATE OF SALE AT 8.8500%
Atty's Comm % Due Prothy $1.00
Atty Paid $123.20
Plaintiff Paid
Other Costs
Date: DECEMBER 14, 2006
(Seal)
Curti . Long, onot
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
Real Estate Sale # 30
On February 13, 2007 the Sheriff levied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County, PA
Known and numbered as '10 VAC sS Gi rc,te, '
! C'cum p 440 more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: February 13, 2007
By:
Real Estat Sergeant
b Z .E ci S 133 9007
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
April 20, 27 & May 4, 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.
11
Coyne,
SWORN-`TO AND SUBSCRIBED before me this
4 day of May, 2007
SEAL
LOIS E. I& Iti DER, ,Notary Public
C Guz„ac-rl?rrid Coun'"y
9 , :,-s March 5, 2" P
REAL ESTATE SALE NO. 30
Writ No. 2006-6195 Civil
Aurora Loan Services, LLC
vs.
Cheryl E. Hoerner
Atty.: Joseph Goldbeck
All that certain lot of land situate
in the Township of Hampden,
County of Cumberland and Com-
monwealth of Pennsylvania, more
particularly bounded and described
as follows, to wit:
Beginning at a point on the south-
ern line of West Circle, said point
being located 5.02 feet East of the
intersection of the dividing line of
Lots Number 4 and 5 on the here-
inafter mentioned Plan of Lots and
West Circle, measured along the
southern line of West Circle; thence
in a southerly direction through Lot
Number 4 on said Plan, 195.58 feet
to appoint on the dividing line be-
tween Lots Number 3 and 4 on said
Plan, said point being located 5.09
feet East of the southwest corner
of Lot Number 4 measured along
the dividing line of Lots 3 and 4;
thence in a westerly direction along
the dividing line of Lots Numbers 3
and 4 and 2 and 5, 100 feet to a
point; thence in a northerly direc-
tion through Lot Number 5, 198.89
feet to a point in the southern line
of West Circle, said point being lo-
cated 5 feet East of the intersection
of West Circle and the line dividing
Lots Numbers 5 and 6, measured
along the southern line of West
Circle; thence in an easterly direc-
tion along the southern line of West
Circle on a curve to the left having
a radius of 50 feet, 50.8 feet to a
point; thence continuing in an east-
erly direction along the southern line
of West Circle 56.17 feet to the
place of beginning.
Being part of Lot Number 4 and
part of Lot Number 5 as shown on
the Plan of Lots, Section 1, Point
Ridge Farm, Hampden Township,
Cumberland County, Pennsylvania,
said Plan being recorded in the
Cumberland County Recorder's Of-
fice in Plan Book 8, Page 2.
Having thereon erected a modi-
fied 2 story stone and aluminum
siding dwelling known and num-
bered as 10 West Circle.
Said Lot of land shall be subject
to the protective covenants and re-
strictions and reservations estab-
lished by Kurvin W. Lauer and Eva
S. Lauer, his wife, with respect to
lands shown on said Plan by an in-
strument in writing dated February
6, 1956 and recorded February 17,
1956, in the Recorder's Office afore-
said in Miscellaneous Book 118,
page 445.
Under and subject, nevertheless,
to easements, restrictions, reserva-
tions, conditions, and rights of way
of record.
BEING KNOWN AS 10 WEST
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
Shannon D. Billhime, being duly sworn according to law, deposes and says:
That she is a Staff Accountant with 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 18th and 25th day(s) of April and the
2nd day(s) of May 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#30
Sworn to and subscribed before me this 18th day of May 2007 A.D.
Notarial Seal
Terry L. Russell, Notary ruJ;c
City Of Harrisburg, Dauphin uouaty
ommission Expires June 6, 2010
e . Pennsvlvani?. Aq, c 6ation of Notaries
N ARY PUBLIC
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6312
for Plaintiff
AURORA LOAN SERVICES, LLC
601 5th Avenue
Scottsbluff, NE 69361
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
VS.
CHERYL E. HOERNER
(Mortgagor(s) and Record owner(s))
10 West Circle
Camp Hill, PA 17011
No. 06-6195
FRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs
only.
JOSEPH A. GOLDBECK, JR., ESQUIRE
At $ . `
-1
b F