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Home My WebLink About02-2823GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. LISA L. COOPER BARRY M. COOPER Mortgagor(s) and Real Owner(s) 443 Sioux Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 0,2 CIVIL ACTION: MORTGAGE --r FORECLOSURE Defendant(s) THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and actice 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 POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LF HAN DEMANDA DO A USTED EN LA CORTE, SI DESEA DEFENDERSE CONTRA LAS QUE/AS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTED DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SO ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE LISTED Y CUALQUIER OBIECCION CONTRA LAS QUEIAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SO PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECID] R 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. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 twice Row Carlisle, PA 17013 717-243-9400 COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632. 2. The name(s) and address(es) of the Defendant(s) is/are LISA L. COOPER., 443 Sioux Drive, Mechanicsburg, PA 17055 and BARRY M. COOPER, 443 Sioux Drive, Mechanicsburg, PA 17055, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On December 23, 1998 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to AMRESCO RESIDENTIAL MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1513 Page 287. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned mortgage was assigned to: THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. by Assignment of Mortgage, which assignment is lodged for recording. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due March 01, 2001, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 02/01/2001 through 04/30/2002 at 11.7500% Per Diem interest rate at $39.38 Attorney's Fee at 5.0% of Principal Balance Late Charges from 03/01/2001 to 04/30/2002 Monthly late charge amount at $62.27 Costs of suit and Title Search Escrow $122,341.28 $17,878.52 $6,117.06 $871.78 $750.00 $147,958.64 $0.00 $147,958.64 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sherif:f's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/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(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $147,958.64, together with interest at the rate of $39.38, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: GOLDBE K cCAFF TY & McKEEVER BY: JOSEPH A. GOLDBECK, , ESQUIRE ATTORNEY`MIZ PfAINTIFF VERIFICATION I, Michael Vestal, 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: 6' 2-0 1 'X?4u/) Michael Vestal Countrywide Home Loans U61 19 14 ADAMS ABSTRACT ASSOC TEL 111+534+5108 QLS FtEGOB0:0 OF MOS ',J:IG[1,L'.•73COUnTY41' W%°"n"" '95 DE1114 AM 9 S4 10-19-3600-019 ?• ?p PAR= NO., h!z TJY882?l;masadn ?? dye/ er?t?•!l• 1995 seffoaen AWITA QCINONESt widow hertaA dcnry, ?aM et fhe Qraarora. 31tta BARRY R. COOPER and LISA L. COOPER, Husband 6 Wife lerdo dtnagered to dt Orsaw, Wllxessslh. tam rho Granars. for and in rood"des of F 00? ORE NONDRSD TEN TBODSAND AND 00/100 DOLLARS (5110.000.00( &, fal mkma qr Ad United trwre 4rA. co. m th, Grenror, In heed rdl and m 4 peld Or the Gnoten, el er ' &Can the taoltgd old ddt,eryC/d m papooz. the rraefpr eh&*Lr her aladamwbda d and the Crewmen Was thwer"th fufytot dW. do by then pacete saner, borp1%tell std romp care Me Granlaularaxf. All TEAT CLRS'AIN. *egtt er porc l of fond god p.sattrt, tanete. b4fitt grl Acted In the Tatmohip of Eamtpdsn Am the Cgr.py Cumberland MWCwegrogmegru dPow"3wnle. eere perdenlndy drse+lhed Wavott* In Aoeordanoe with a Plan of Property pools by etiehael C. D'Angala, Registered Surveyor of Nov Cumberland, Pennsylvania, dated August 17, 1979, as fellows, to Witt ADOINNINO at a point the Southweot Lutaraeetion of 91oun and Cherokee Dra.veal thence along the want oido of aiouk Drivf south 7 degrees 2 minutes East, 153.09 feet to a point at Lot 421 thence along said lot South 82 degrees S0 minutes last 106.13 feat to a point at Lot No. 45, thence along Lot 43t North 10 degrees 19 toioUten 13 laCdnd6 Vent, 184.76 feet to the south oido of eheeekee DaLOei thence along the south side of Cherokee Drive, by curve to the right having a radius of 600 feet, an arc length at 34.42 feat to a pointj thence along sane worth 92 degrees 38 minutes East, 80.58 feet to the point of BNOTI 216. BEING known as 443 Sioux Drive. BEING Lot 11. Block 'R•, on Plan 13 of Indian Creek as recorded in Plan Book 16, Page 85. sslwG the aaeo premiass which Frank L. rloto, Jr. and Roranan L. Yloto, his wife, by Dead dated June 25, 1090 and recorded July 2, 1990 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Beck Q-34, Page 641, granted and conveyed unto Manuel J. Quinones and Anita Quinones, his wife. TEE said Manuel J. Oaxnenes having passed away on march 10 1992 tharob vesting mole title unto Anita Quinones, his wife, by opera ion of law. 1 115 R 1 IX WIN e sc ? - son 132 ?W 590 ® kW HOME LOANS 8WM 0 012 MSmaIm Payments to: fiend , P.O. exw891918 P.O. axBe0494 B P10% TX 73120-1319 aeft 7X 75286-CM Certified Meg No. November 9, 2001 Return Receipt Requested Regular Mail LM L Cooper 443 Sioux Drive MecttankebU, PA 67 %? I Bex9fa qi A _ Aceowd 1b.: 23084% P A V roperty ddress: 443 Sioux Drive MOCIUMMU, PA 17055-OM Curma Servicer: COuttxywlde Hams Loans, inc. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thle Modo ooeralns Impotpm lapel InMmreaon. N YOU have arty xWmnOns, mprmwmmvn at the Consumer Craft Counseling Apsocy maybe able to help answer Slam. You a" alsowsMto contact an attorney in your area. The local bersseocistlon maybe able to help you find a lawyer. LA NO111PICAC16N EN ADJUNTO ES DE SUMA IMPORTANCW, PLIES AFECTA SU OERECHO A CONTINUAR VWEN00 EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIMAC16N 013TENGA UNA IRADUCC16N Ri3EDIATAMENTE LLAMAIDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SW CARGOS AL NOMERO MENCIONADO ARR83A. PUEDE SER ELEGBBLE PARA UN PRLSTAMO POR EL PROGRAMA LLAMADO 'HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALYAR SU CASA DE LA PERDIDA DEL DERECHO A REOIM9b SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY 13E EUMILE FOR FIN_aM I ASSISTANCE MUCH CAN SAVE YO 1R NONE FROM FCREGLOB x F AHD HELP YOtI Y e F mnoe e_ ±ne?s e?J IF YOU COMPLY WITH THE PROWSIONB OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (ME "ACT"? YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, M 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 FWANCE AGENCY. Plea" wftYour aeeato mnaber0 all theft aM xwr@VmdMW. BCBRPA W511I100 LMLCw 23064553 Maebaa,M 2001 ?vOY W W aeWFn)iYlryYb W ti„tl?enrlsgreeue„ryMy, BCaeVA $12,37051 AS OF December 6, NOME LOIe1a P.O. Box 660884 Dallas, IX 76288-0884 Ilus?rlr?Ux?x)x??nx)lu?lUU)?a?,?nx?r??,le,lulu?x?? 230645530012370511237051 arrr star OF FORECL?r F - Under the Adt, you are entitled to a temporary achy of foreClOaere on your a 10r ilk Y (3O) deye hao the data of this Notice. During that Urns you must arrange and attend a •face•to•faca° with one of the consumer creak ooummong agencies listed at the end of ime Notice. TAPS MEETING MUST - If YOU meet With one of the Consumer credit counse8ng agencies IT lake action against YOU for thirty (30) days after the date of this APPLICATION FOR MORTGAGE gr MUFF - Your mortgage is In detaut for the reasons set forte later In this Notre (see Mowing pages for specific kdormaton about the nature of your deteull) a you have tried and are unable to MO0WG this Problem With file lerMer, you have the light to apply for financial assistance from the Homeowners Emergency Mintage Asststance PNgram. To do eq You must fig out, sign and file a completed Homeowners Emergency Assistance Program Application With one of the designated consumer credit counseling agencies toted at the and of this Notice. Only consumer credtcouneeeng agencies have appoostione for the program and they wE assist you N submitting a complete apploafion to the Pennsylvania Housing Finance Agency. Your appaca*n MUST 6e Bed orpopmerked within thirty (30) days of your f wto trice meeting. YOU li{lB.L FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS 8ET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINtTT YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. Avallable funds for emergency ororlglige assistance are very Imam. They wB be disbursed by (GM e gAgency UlKlOr MO oQgIbW criteria ene to make a ? after it receives your by the Act. The Penns"Is Housing Ron" Agency has obcN M your epptlmeaon. Dudng that tine, no foreclosure proceedings wgl be pursued against you If you have met the tine requirements set forth above. You wit be ratlged dkadlly by the Peotsylvarda Housing Finance Agency of is declown on your application. NOTE: F YOU ARE CURRENTLY PROTECTED BY THE FILM OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE 18 FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONNXRED AS AN ATTEMPT TO COLLECT THE DEBT. (M you have Ned benlauploY you can sMl apply for EmergwW Mortgage Assistance.) NATUPa OFTHE DEFAULT. Ceunhvwlde Noma UM. Ins.. (herelneaer'La ntni ~services your hone foan. Your hone tern is In serous dereut because you have not made your required payments. The totan amount now mquiea for reinstate your hone loon as of the date of this later Is as follows: iorthiL2m?OM: $1,215.54 $6,227.70 $1,154.86 $4,618.60 Late $6228 $91 t.4o $57.73 $173.19 Olliercha Uncollected Lffie Chsrpes: $1,098.62 Uncoaecled Coats: TOTAL DUE: $1$870$1 PAYMENTINSTpUMNS vMase • MeaeWerahertpgaliemcarenaeafiaretoera • Wasleenberambrm7avaaedcarmatsyaur • Wselr aytlteomlenaslGywwindudnp le m W b oars he LMa0. Aaw sans aiaam aao.I • danerdryanaadcrosereFneisaaam • darrss4Wmaeporraans • Oomwgeri AYebnMe AMplymenbNebeaiaMeblle longer aM4MghmtMMdb.utlepalhasaeaiPemlyPMaVedkYUs. w arawawn HOW TO CM THE D?FF?„ T - YOU may Cute this default Within THIRTY (30) DAYS of the date of this letter, by Paying 10 us the above amount Of $12,370.61, blue spry additional monthly payments, late Charges, fees and other applicable drergas which may fell due during this period. Such Payment must be In me tone of denmw check, CBehlers check of money cater, and mode payable b Countrywide at P.O. Boo 6506114, Dallas, TX 75266-0894. If your check or other payment Is returned to us for insufficient funds or far any other reeeou, you wlu not have cured your default. No extension of time to an will be granted due to a returned payment. IF THE MOR7GAOE IS PDPEC' SEED le - 0 the manage Is foreclosed, the mortgaged Property wul be sold by the Sheriff to pay Off the nafigege debt. N the defaults cured before we begin legal proceedings, Countrywide will be entitled to collect the reasonable attorney's fees actually Incurred up to $50.00. However, I lapel proceetlinge are settled, Countrywide will be entered to collect the reasonable aflomeys fees even I they are over $50.00. Any attomeyc fees will be added to the secured debt, which may also include our reasonable costs. I you cure the del" within the THIRTY (30) DAY Period you will not be required to pay attorneys toes. OTHER LENDER REMEDIES - The leader may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RWHT TO CURE THE DEFA?a T PM TO FORECLOSURE SALE _ If you hews not cured the dafauft within the THIRTY (SO) DAY period and foreclosure Proceedings have begun, you still have the right to cure the default and prevent the sale at any ante up to one hour before the foreclosure sets. You may do so by paying the total amount then past due, On any We or other charges then du% reasonable attorneys fees and coats connected with the foreclosure sale amt any other costs connected with the foreclosure ante W specified In writing by the lender end by pedorming any omet requirements under the mortgage, Curing your default in the manner set forth In Ohre notice will restore your mortgage to fire same position as 6 you had now defeuMed. EARLIEST MBIB E FORECLr'SLEaE gsr DATE . I Is eSltrlretetl that the eeriest dote that a 10r0010atmre sere could be held would be approdam ey sled (6) months Iran the date of this "or. A Dallas of the data of the foredosure eels will be sent to you before the sere. You may find cut at any lime exactly what the "hod payment will be by calling us at the following number. I @0MOD-SIM4. This payment must be In the form of a cashiers check, cedHled check or money order and made payable to tie es the address elated above. If the default Is cured the mortgage will be restored to the same position as ff no default had occurred However, the defauh may riot be cured more then three (3) flame In any calendar year. NOW TO C.ONrACy THE LENDER, Name of Lender: Oolmbyalab Home Loans, Inc, Address, P. O. BOX 10221 Van Nuys, CA 914104M Phoos.NMpg4P 7-6004894M EOKNmahm• 1-805877e7{3T Contact PAIMM' Bpnlvuplcy, MB SV-34 Ata salon. Loan Counselor EFFECT OF a Harr &4L E _ You should mature that a foreclosure sale will and your ownership of the mortgaged property and your fight to remain In B It you continue to five in the property after the Shent1s eels, a lawsuit to remove you and your fumisMrW and other belongings could be slanted by CawtrywW at any tine. A89UMPTON OF MORTGAGE - Correct Countrywide HOme Loans for Information an the possible assumablHy of your ben. YOU MAY ALSO HAVE THERIGHT, TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTRUTION 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 E NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU 00 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. Pufensm to your home ban documents, and boom" the home ben Is In del" Countrywide may, at Its option, enter upon and conduct can reWp of the pmpery. The purpoes of this Inepediol is to observe the physical condition of the property, to property Is occupied and/or to determine me Memly of the occupant. The cost of any Such Inspection will be added to and become pert of the secured debt as provided under me terms of the home ben documents. N you are unable to cure your default on or before December 8, 211of, Countrywide wants you to be ewers of various aWlbrre that may be available to you through Countrywide to prevent a toreolosore sole of your property. For example: • Repayment : N is passible last you may be eligible for some form of payment assistance through Countrywide. basic Wan requi'se Met Countrywide raoeiva, up front, at MW % at the anroum necessary to bring the account current, and Mat the balance of the overdue arrant be Palo, along with the regular monthly payment over a defined period of Mire. Other repayment plans also are available. • Lpan Modification : Allemrefbefy, N Is PoeMbie that the regular monthly payments can be kiwared through a rrodkbatlon of the ban by reWamg the interest rise and then adding the delinquent payments to the curent loan balance. This foreclosure atiemaft however, Is WMted to certain loan types. • Sala of Your PnnerM Alterfulth y, N you are wiping to sell your home in order to avoid foreclosure, It Is possible that the sale of your tame can be approved through Oountrywbe even Nyour home Is worth less than what Is owed on N. • ) : Alternatively, N your property is free from other lien or eroumbrenores, and N the default is due to a serious fln&WM hardship which Is beyond your control, you may be eligble to deed your property deadly to the Notelnober and avoid Me foreclosure sale. N you are Interested N discussing bredaeure alternatives with Countywide, you must oomect us Immediately. N you request assistance. CounkinAde wW oleternlne, In ft ado oleicrWon, whether such assistance wilt be extended to you. In the meantime, CoMSrywbe will pursue all of No rights and femedles under the tome hone loan documents and se permitted by law, unless it agrees otherwise In wmmg. Please be advised that failure to bring the home home ban current Or to enter also a written agreement se outlined above win result In the aooelerallon of the debt. Time Is of the essence. Should you have any questions concerning this notice, please contact Countrywide's office WwwdW* at 150NOSM4, euenelat . AfA[ I Bankruptcy Loan Counselor 15066885224, adimaion Please be s"Od that Mle Communication Is tram a debt oosactor. EXHk'jok 'I kl-k Certified Article Number ACT 91 NOTICE A S ND1 9M4 % O 8976 DATE OF NOTICE: May 3, 2002 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. I I 1 S. Independence Mall East Philadelphia, PA 19106 Fax (215) 627-7734 Date: May 3, 2002 TO: BARRY M. COOPER Homeowners Name: LISA L. COOPER and BARRY M. COOPER Property Address: 443 Sioux Drive, Mechanicsburg, PA 17055 Loan Account No.: 2306455 Original Lender: AMRESCO RESIDENTIAL MORTGAGE CORP. Current Lender/Servicer: THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 443 Sioux Drive, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 03/01/2001 thru 5/3/2002 (15 mos. at $1,245.54/month) $18,683.10 (b) Late charges from 03/01/2001 thru 5/3/2002 (15 mos. at $62.27/month) $934.05 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE: $19,617.15 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $19,617.15, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check, certified check or money order made payable and sent to: COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paving the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing b the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: COUNTRYWIDE HOME LOANS INC. Address: 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Phone Number: 972-608-6476 Fax Number: 972-608-1133 Contact Person: Warren Tucker EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact Person: Warren Tucker Phone Number: 972-608-6476 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INC. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE' 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Q c- iv mr Z,z c _ ?? ?rn ro N SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-02823 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BANK OF NEW YORK THE VS COOPER LISA L ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT COOPER BARRY M but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT COOPER BARRY M 443 SIOUX DRIVE IS VACANT. PER POST OFFICE, MAIL IS STILL BEING DELIVERED TO SIOUX DRIVE ADDRESS. Sheriff's Costs: So answer : - Docketing 6.00 Not Found 5.00 Affidavit .00 R.' Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 21.00 GOLDBECK MCCAFFERTY MCKEEVER 06/13/2002 Sworn and subscribed to before me TT7"""? this ./?t day of 2OV.2, A. D. Pr onotary SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-02823 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BANK OF NEW YORK THE VS COOPER LISA L ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT COOPER LISA L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT COOPER LISA L 440 SIOUX DRIVE IS VACANT. PER POST OFFICE, MAIL IS STILL BEING DELIVERED TO SIOUX DRIVE ADDRESS. Sheriff's Costs: So answe.;?-s• , - Docketing 18.00 Service 6.90 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 39.90 GOLDBECK MCCAFFERTY MCKEEVER 06/13/2002 Sworn and subscribed to before me this /7 day of C? a&0.2 A.D. 777???? Pr onotary GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE : IN THE COURT OF COMMON PLEAS C/O COUNTRYWIDE HOME LOANS INC. . 7105 Corporate Drive OF CUMBERLAND COUNTY PTX B-35 Plano. TX 75024-3632 VS. LISA L. COOPER BARRY M. COOPER (Mortgagors and Real Owners) 443 Sioux Drive Mechanicsburg, PA 17055 No. 02-2823 Civil Term THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA R C P. 430(a) Plaintiff, by and through its attorney, Michael T. McKeever, Esquire, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a first mortgage upon the premises 443 Sioux Drive, Mechanicsburg, PA 17055, hereinafter, the "mortgaged premises". 2. Defendants, LISA L. COOPER AND BARRY M. COOPER, are the mortgagors and real owners of the mortgaged premises. 3. The last known address of Defendants' is 443 Sioux Drive, Mechanicsburg, PA 17055 as set forth in Paragraph 2 of the Complaint. 4. The Sheriff has been unable to effect service of the Complaint upon Defendants at their last known address after numerous attempts. 5. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendants. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendants by posting the premises and certified and regular mail to the Defendants' last known address. oe?? BY: 14ICHAEL T. MCKEEVER, ESQUIRE GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE IN THE COURT OF COMMON PLEAS C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive OF CUMBERLAND COUNTY PTX B-35 Plano, TX 75024-3632 VS. LISA L. COOPER BARRY M. COOPER (Mortgagors and Real owners) 443 Sioux Drive Mechanicsburg, PA 17055 No. 02-2823 Civil Term VERIFICATION I. MICHAEL T. MCKEEVER, ESQUIRE, Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service 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. BY: MICHAEL T. MCKEEVER, ESQUIRE GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE: C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 02-2823 Civil Term LISA L. COOPER BARRY M. COOPER (Mortgagors and Real Owners) 443 Sioux Drive Mechanicsburg, PA 17055 Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendants which the Sheriff has been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendants' whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). MNCIUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendants by posting the premises and certified mail and regular mail to the Defendants' last known address. Respectfully submitted, MICHAEL 6MCKEES PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: CWD-1872 Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Case Number: Subject: BARRY M & LISA L COOPER A.K.A.: None Property Address: 443 SIOUX DRIVE MECHANICSBURG, PA 17050 Last Known Address: MECHAN CSBURG, PA 17050 Last Known Number: ( ) - Michael K Gross, being duly sworn according to law, deposes and says: 1. 1 am employed in the capacity of President for Players National Locator. 2. On 0411612002, 1 conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER: - - B. EMPLOYMENT SEARCH: Unable to locate a good employer for Barry and Lisa. C. INQUIRY OF CREDITORS: The creditors indicated that Barry and Lisa are living at 443 Sioux Drive, Mechanicsburg, Pa. Cnumber. ase 2001x1705 and Lisa filed with no release chapter date given bankruptcy in March 17050 with no valid home 2001 with attorney James phone INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: The directory assistance has no listing for Barry and Lisa Cooper. We contacted 717-761-5037 and spoke with a relative who stated Barry and Lisa Cooper are both living at 443 Sioux Drive, Mechanicsburg, Pa. 17050. INQUIRY OF NEIGHBORS - NIA INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of April 16, 2002 the National Change of Address (NCOA) has no change for Barry and Lisa from 443 Sioux Drive, Mechanicsburg, Pa. 17050. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Barry and Lisa listed at 443 Sioux Drive, Mechanicsburg, Pa. 17050. OTINER INQUIRIES A. DEATH RECORDS: As of April 16, 2002 the Social Security Administration has no death records on file for Barry and Lisa L Cooper under their social security numbers. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC. ): None Found C. COUNTY VOTER REGISTRATION: The Cumberland County Voters Registration office has Barry and Lisa listed at 443 Sioux Drive, Mechanicsburg, Pa. 17050. OTHER SEARCHES - Social security numbers provided were verified. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: Barry 10157 Lisa 05161 AFFIANT Michael K Gross Players National Locator !NOTARY L Kristine M. It Notary Public St. Louis County, Mate of Missouri My Commission Expires 9/2/2002 113 Old State Road, Suite 104 St. Louis, MO 63021 Fax: (636) 230-0558 Phone: (636) 230-9922 SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-02823 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BANK OF NEW YORK THE VS COOPER LISA L ET AL R Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT but was COOPER BARRY M unable to locate Him in his bailiwick. COMPLAINT - MORT FORE , He therefore returns the NOT FOUND , as to the within named DEFENDANT , COOPER BARRY M 443 SIOUX DRIVE IS VACANT. PER POST OFFICE, MAIL IS STILL BEING DELIVERED TO SIOUX DRIVE ADDRESS. Sheriff's Costs: So answers-: Docketing 6.00 ?..-- Not Found 5.00 Affidavit .00 R." Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 21.00 GOLDBECK MCCAFFERTY MCKEEVER 06/13/2002 Sworn and subscribed to before me this A. D. day of Prothonotary SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-02823 P .COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BANK OF NEW YORK THE VS COOPER LISA L ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT but was COOPER LISA _L unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , , NOT FOUND , as to the within named DEFENDANT COOPER LISA L 440 SIOUX DRIVE IS VACANT. ' PER POST OFFICE, MAIL IS STILL BEING DELIVERED TO SIOUX DRIVE ADDRESS. Sheriff's Costs: So answers: Docketing 18.00 Service 6.90 - ?. Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 39.90 GOLDBECK MCCAFFERTY MCKEEVER 06/13/2002 Sworn and subscribed to before me this day of A. D. Prothonotary GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE IN THE COURT OF COMMON PLEAS C/0 COUNTRYWIDE HOME LOANS INC. OF CUMBERLAND COUNTY 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 No. 02-2823 Civil Term VS. LISA L. COOPER BARRY M. COOPER (Mortgagors and Real owners) 443 Sioux Drive Mechanicsburg, PA 17055 CFRTTMQ TE OF SFRVICF MICHAEL T. MCKEEVER, Esquire, do hereby certify that true and correct copies of the the foregoing Motion for Substituted Service have been served upon the Defendants this 5* day of July, 2002, by first class mail, postage prepaid. BY: MICHAEL T. MCK EVER, ESQUIRE--J- GOLDBECK WCAFFERTY & MCKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D.#16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF THE BANK OF NEW YORK AS TRUSTEE C/0 COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE VS. LISA L. COOPER BARRY M. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 Defendant(s) Term No. 02-2823 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER -PPA46- By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff } r' - L!_! ' C) `- - i i ? v ? JUL 11 2002 N GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE IN THE COURT OF COMMON PLEAS C/O COUNTRYWIDE HOME LOANS INC. OF CUMBERLAND COUNTY 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 No 02-2823 Civil Term VS. LISA L. COOPER BARRY M. COOPER (Mortgagors and Real owners) 443 Sioux Drive Mechanicsburg, PA 17055 ORDER AND NOW, this 16*4^ day of 2002, upon consideration of the Plaintiff's Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendants has been unsuccessful, it is, ORDERED and DECREED: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendants by posting a copy of the Complaint upon the premises 443 Sioux Drive, Mechanicsburg, PA 17055, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 443 Sioux Drive, Mechanicsburg, PA 17055, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises. BY THE I, J. ?.le N NVA7i\SN;N3d R n r o4 N no c •8 ,,' illf GO GOLDBECK McCAFFERTY & MCKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. LISA L. COOPER and BARRY M. COOPER Mortgagor(s) 443 Sioux Drive Mechanicsburg, PA 17055 Defendant(s) CERTIFICATE OF SERVICE IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2823 CIVIL TERM JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on 71oYod he did serve upon Defendant(s) LISA L. COOPER and BARRY M. COOPER a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated JULY 16, 2002 . The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, C** GOLDBECK McCAFFER cKEEVER BY: JOSEPH A. GO BECK, JR. ESQUIRE SHERIFF'S RETURN - REGULAR CASE NO: 2002-02823 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK THE VS COOPER LISA L ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LISA L the DEFENDANT , at 2049:00 HOURS, on the 24th day of July 2002 at 443 SIOUX DRIVE MECHANICSBURG, PA 17055 by handing to POSTED PROPERTY AT 443 SIOUX ROAD MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8,28 Posting 6.00 Surcharge 10.00 .00 42.28 Sworn and Subscribed to before me this 2,,,e_ day of 200 A.D. othonotary So Answers: R. Thomas Kline 07/25/2002 GOLDBECK MCCAFFERTY MCKEEVER By: L Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-02823 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK THE VS COOPER LISA L ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BARRY the DEFENDANT , at 2049:00 HOURS, on the 24th day of July , 2002 at 443 SIOUX DRIVE MECHANICSBURG, PA 17055 by handing to POSTED PROPERTY AT 443 SIOUX ROAD MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Posting 6.00 Surcharge 10.00 .00 22.00 Sworn and Subscribed to before me this ?.. day of -2ao-L A. D. "Prothonotary So Answers: R. Thomas Kline 07/25/2002 GOLDBECK MCCAFFERTY MCKEEVER By: Deputy Sheriff - 'D - rC 1 i G1 In the Court of Common Pleas of Cumberland County THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. LISA L. COOPER No. 02-2823 CIVIL TERM BARRY M. COOPER (Mortgagor(s) and Record Owner(s)) 443 Sioux Drive Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against LISA L. COOPER and BARRY M. COOPER by default for want of an Answer. Assess damages as follows: Debt Interest- 02/01/2001 to 08/26/2002 Total (Assessment of Damages attached) $152,854.56 1 CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at leysi`ten dayeprior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 /? Joseph A. or Go" P i gi 'I Attorney for P i iff I.D. 416132 AND NOW 4(A-Q 1, , Judgment is entered in favor of THE BANK OF NEW YORK AS TR STEE C/O COUNTRYWIDE HOME LOANS INC. and against LISA L. COOPER and BARRY M. COOPER by default for want of an Answer and damages assessed in the sum of $152,854.56 as the above certification. Prothonotary GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. LISA L. COOPER BARRY M. COOPER (Mortgagor(s) and Record owner(s)) 443 Sioux Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 02-2823 CIVIL TERM ORDER FOR JUDGMENT Please enter Judgment in favor of THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC., and against LISA L. COOPER and BARRY M. COOPER for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $152,854.56. Joseph A. Goldbe , Jr. Attorney for Plai ff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 and that the name(s) and last known address(es) of the Defendant(s) is/are LISA L. COOPER, 443 Sioux Drive Mechanicsburg, PA 17055 and BARRY M. COOPER, 443 Sioux Drive Mechanicsburg, PA 17055; GOLDBECV RTY & McKEEVER BY: Joseph c , Jr. Attorney fo ASSESSMENT OF DAMAGES 'TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $122,341.28 Interest from 02/01/2001 through $22,525.36 08/26/2002 Attorney's Fee at 5.0000% of principal $6,117.06 balance bate Charges $1,120.86 Costs of Suit and Title Search $750.00 Escrow Balance Deficit $0.00 ($0.00) $152,854.56 GOLDBECK McCd FIk p1? & McKEEVER BY: Joseph oseph A. ld eckVJIfrLF. II Attorney for Pla n f AND NOW, this , (''day of 2002 damages are assessed as above. Pro Prothy 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, LISA L. COOPER, is about unknown years of age, that Defendant's last known residence is 443 Sioux Drive, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown.address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendment_ 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, BARRY M. COOPER, is about unknown years of age, that Defendant's last known residence is 443 Sioux Drive, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and ir.G AmAn?mcntc Date: THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: BARRY M. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. LISA L. COOPER BARRY M. COOPER (Mortgagor(s) and Record Owner(s)) 443 Sioux Drive Mechanicsburg, PA 17055 Defendant(s) TO BARRY M. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 DATE OF THIS NOTICE: August 14, 2002 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 02-2823 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: (11M61 'R LAND COUNTY BAR ASSOCIATION "i Ole, PA 17013 I 'AL 1m.S1- ICES INC Irvine Curl 1 PA 17013 0 ] , A41 'I - ] 1 14110 GO C 1CCAFFER EEVER 13seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. I I I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 'THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 14, 2002 TO: LISA L. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE. HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. LISA L. COOPER BARRY M. COOPER (Mortgagor(s) and Record Owner(s)) 443 Sioux Drive Mechanicsburg, PA 17055 TO: LISA L. COOPER 443 Sioux Drive Mechanicsburg PA 17055 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 02-2823 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CU Mn I[RLAN DCOUNTV BAR ASSOCIATION "I"I" Avenue r1111d .PA I7 06 I. IarALSERVICES INC rvine Row tad?zie. PA non 'I)-r4}_9400 GO C ICCAFFER EVER B seph A. Goldbeck,.lr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. I I I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THE BANK OF NEW YORK AS TRUSTEE CIO COUNTRYWIDE H6ME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. No. 02-2823 CIVIL TERM LISA L. COOPER BARRY M. COOPER (Mortgagors and Record Owner(s)) 443 Sioux Drive Mechanicsburg, PA 17055 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in'the above-captioned matter has been entered against you. Curt Long Prothonotar Deputy If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 3 N N 4Q C', N `?7 y?_ G7 1'11T ?' N r 0 ;' JUL 1 1 2001 V GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff TTORNEY COPY THE BANK OF NEW YORK AS TRUSTEE: IN THE COURT OF COMMON PLEAS C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive OF CUMBERLAND COUNTY PTX B-35 Plano, TX 75024-3632 VS. LISA L. COOPER BARRY M. COOPER (Mortgagors and Real Owners) 443 Sioux Drive Mechanicsburg, PA 17055 No. 02-2823 Civil Term ORDER AND NOW, this /(c to day of 2002, upon consideration of the Plaintiff's Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendants has been unsuccessful, it is, ORDERED and DECREED: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendants by posting a copy of the Complaint upon the premiseV-41E?443 Sioux Drive, Mechanicsburg, PA 17055, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at*443 Sioux Drive, Mechanicsburg, PA 17055, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises. BY THE COURT: J. SHERIFF'S RETURN - REGULAR CASE NO: 2002-02823 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK THE VS COOPER LISA L ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE COOPER BARRY M was served upon the DEFENDANT , at 2049:00 HOURS, on the 24th day of July , 2002 at 443 SIOUX DRIVE MECHANICSBURG, PA 17055 POSTED PROPERTY AT 443 SIOUX by handing to MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Posting 6.00 Surcharge 10.00 .00 22.00 Sworn and Subscribed to before me this day of A. D. So Answers: R. Thomas Kline 07/25/2002 GOLDBECK MCCAFFERTY MCKEEVER By: Deputy Sheriff Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2002-02823 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK THE VS COOPER LISA L ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE COOPER LISA L was served upon DEFENDANT the , at 2049:00 HOURS, on the 24th day of July , 2002 at 443 SIOUX DRIVE MECHANICSBURG, PA 17055 by handing to POSTED PROPERTY AT 443 SIOUX ROAD MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.28 Posting 6.00 Surcharge 10.00 .00 42.28 Sworn and Subscribed to before me this day of A. D. So Answers: R. Thomas Kline 07/25/2002 GOLDBECK MCCAFFERTY MCKEEVER By: Deputy S eriff (?- Prothonotary PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, it. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. of Cumberland County CIVIL ACTION - LAW LISA L. COOPER ACTION OF MORTGAGE FORECLOSURE BARRY M. COOPER Mortgagor(s) and Record Owner(s) 443 Sioux Drive No. 02-2823 CIVIL TERM Mechanicsburg, PA 17055 . Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from $152,854.56 02/01/2001 to 08/26/2002 at 11.7500% (Costs to be added) IN THE COURT OF COMMON PLEAS GOLDBECK] BY: Joseph A. Attorney for P. Jr. McKEEVER r, `1 T t ? sj 9-) w D ' -rtJ 1 cs o v , - tT U7 '? (U C- a r cn 0 d ? w v c H 3 w? ?o ?w o ° w So ?w p o.0 0 °Qa U LT. ? ° 0 > O? x en NG W m ri?A z ryO x¢ 0 7 U 0 m z? F ?o ? ? U x a F- x N C7 d d N r"?b WW, ?o Qa b W "" 0 ? ? N I oanl D_ e? 5????? THE LAND REFERRED TO IN THIS COMMITMENT IS DESCRIBED AS FOLLOWS: ALL THAT CTAIN TCT OF PARCEL OF LAND AND TOWNSHIP OF HAMPDEN N THE COUNTY OF CUMBERLAND AND PREMISES, TH OF PEN SYLVANIA{ MORE PARTICULARLY DESCRIBED AS FOLLOWS; IN ACC SURVEYOR OF NEW CUMBERLAIND, PENNSYLVANIPDATED AUGUST MICHAEL C. WANGELO, REGISTERED 17, 1979, AS FOLLOWS, TO WIT; BEGINNING AT A POINT THE ALONG THE WEST SIDE OF SIOUX UDR DRIVE SOUTH 7 INTERSECTION DEGREES 2 MINUTES EAST, 155.09 FEET TOEA POINT A4 LOT N2; THENCE ALONG SAID LOT NO.. 43; THENCE ALONG LOT 3, NORTH I10 82 DEGREES 58 DEGREES 19 MINUTES 13 SECONDS WEST, 1504.36 FEET TO TH SOUTH SIDE Of THE RIGHT HAVING AORADIUS IOF 800 FEET, AN ARC LENGTH OF 4. 2 FEET TO CHEROKEE POINT THENCE A LOIN SAME NORTH 82 DEGREES 58 MINUTES EAST, 80.58 FEET TO THE POINT OF BEGINNING. BEING KNOWN AS 443 SIOUX DRIVE. BEING LOT #I, BOCK "K", ON PLAN #3 OF INDIAN CREEK A RECORDED IN PLAN BOOK 16, PAGE 85. TAX PARCEL #10-19-1600-019 o t l_ ? ? :+ vl 72 T s1 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 -'The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE IIOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW LISA L. COOPER BARRY M. COOPER ACTION OF MORTGAGE FORECLOSURE (Mortgagor(s) and Record Owner(s)) 443 Sioux Drive Mechanicsburg, PA 17055 Defendant(s) No. 02-2823 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 443 Sioux Drive Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): LISA L. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 BARRY M. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LISA L. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 BARRY M. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL INC 6520 Carlisle Pike, Suite 155 Mechanicsburg,,PA 17055 CITIFINANCIAL MORTGAGE CO. INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. 1 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: August 22, M02 " 1'Y & McKEEVER BY: Insep ff BY: Joseph olJr., Esq. Attorney for 1 inti C ? O vSL fI LJ l7' + Yf ' - T ;?n ? x J C [J "t Jospeh A. Goldbeck Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE CIO COUNTRYWIDE IIOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. LISA L. COOPER BARRY M. COOPER Mortgagor(s) and Record Owner(s) 443 Sioux Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 02-2823 CIVIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Joseph A. G( Attorney for N Z75 v "' E r 1t..1 - tJ T I\Ti `0 ? "l^• fw Do 02-2823 CIVIL TERM GOLDBECK MCCAFFERTY & McKEEVER BY: Joseph A. ( ioldbeck, Jr. Attorney 1. 1) 'U 161 12 Suite 500 - I hr Bourse Bldg. I I I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff THE BANK OFNEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. LISA L. COOPER BARRY M. COOPER Mortgagor(s) and Record Owner(s) 443 Sioux Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2823 CIVIL TERM THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: (UUI'1R. LISA L. LISA L. COOPER 443, Sioux Drive Mechanicsburg, PA 17055 Your house at 443 Sioux Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday. December 04, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $152,854.56 obtained by THE BANK OF NEW YORK AS TRUSTEE C/O COUN"FRY\VIDE HOME LOANS INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE li, prevent this Sheriffs Sale you must take immediate action: I . The sale will be cancelled if you pay to THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 02-2823 CIVIL TERM 2. You nay be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment Neas improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE 1.. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. )'Oil 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. 1 f the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 O T IV "O W T. N fT? acv: :.J Ci r A [J G 02-2823 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney ID.416132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff LISA L. COOPER vs. BARRY M. COOPER Mortgagor(s) and Record Owner(s) 443 Sioux Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2823 CIVIL TERM THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ( 00P1 R, BARRY M. BARRY M. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 Your house at 443 Sioux Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday. December 04, 2002, at 10:00 AM, in Commissioners Hearing Rim 2nd FL Courthouse to enforce thr court judgment of $152,854.56 obtained by THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYIVIDf? HOME LOANS INC, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE I u prevent this Sheriffs Sale you must take immediate action- I The sale will be cancelled if you pay to THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC., the back payments, late charges, costs and reasonable attorney's fees due- l (I I ind out how much you must pay call: 215-627-1322 02-2823 CIVIL TERM 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. 7. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 <J 2 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-2823 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC., Plaintiff (s) From LISA L. COOPER AND BARRY M. COOPER, 443 SIOUX DRIVE, MECHANICSBURG, PA 17055 (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 $152,854.56 L.L. $.50 Interest FROM 2/1/01 TO 8/26/02 AT 11.7500% Atty's Comm % Due Prothy $1.00 Atty Paid $188.18 Other Costs Plaintiff Paid Date: AUGUST 27, 2002 CURTIS R. LONG Prothon t n ? (Seal) a y) By Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR. ESQUIRE Address: SUITE 500-THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 11 I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE LISA L. COOPER BARRY M. COOPER Mortgagors and Record Owners 443 Sioux Drive Mechanicsburg, PA 17055 Defendants No. 02-2823 CIVIL TERM 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. 9O Premises was posted by Sheriffs Office/ooff pelent-mi4 (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriff s 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. Respectfully submitted, C-7 Wx': os ph A Goldbeck, Jr. Att rney for Plaintiff CO) T i co ?yLQ y y D V 7't, (o r> t oQ Q 0 Nit U5 P-6 v n c 3 a s s ° : E R- . y Y e .?, ns a O - 3Q S a?` •° a2m3 3°=ROj Oy 3; s w •C o'o•oc ' ? • g o n • • n Y O (•, n v Q ? Q O o O'o p?i - y O J a? ?;-wa3 m ' m 3°:5 o• ?°1 3 ? ? O V p V Q8V r G c ' c m a n? °c (n ? 0 0 n ° e m? o ? n3 m o ? m o° n s„ O m v ° 3 0 ?' jlwlNl,l?l?l?l 1 cc-n ;N? nvpp =pmc o `- - -? o ti K O p O ?° n kit cn z D .moo a (i O O W O z= z >, ; 3 m to ? m ? N O 8 _ z > m y X '? m ?_ C r s ^' '? O n cr D C1 DG b ?--? 50 c':r, ,c-', ^ b O UQ N O t- ;m a O a 9 w r . m z > J r O m J LA YA ° C m ? C ti ` a 0 ? V v % a O 04 ;, ?9?0$1 -t At/I N d ab. C M h b N ,N V ?1 of n v V Q ? m i O rj h Ch N m N S ? T p o O I I r ° D oZ CL a3 ? N N N N n c " v? • ? ? ~ C to 0.=M m ?Cnx ° o 0 n n ° LL. ` N I MR a. R m z M ? f0 y a o- 00 m ? C A? m - ? m ana1R? tTj n o ° ° e °5- mHF Y o ,p N_ W V ° ° N V h n_ r ° 3 v h -_ o , n s ? o a h n o ^ o J 0 0 n p ° n - m a C7? ° m? n m Z T10 o a Q N c 57 c ° £ m a CL ° d I golly N Q O ? K d ^ N_ n °r a?3 d m o 0 m ? In d d ;D m dH ? j N C J ? p o ? n o AMENDED RETURN The Bank of New York as Trustee c/o Countrywide Home Loans Inc. VS Lisa L. Cooper and Barry M. Cooper In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-2823 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on October 25, 2002 at 7:12 o'clock PM, she 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: Lisa L. Cooper and Barry M. Cooper, by posting the premises located at 443 Sioux Drive, Mechanicsburg, Cumberland County, Pennsylvania pursuant to court order dated July 16, 2002 by Judge Edward Guido. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 2, 2002 at 11:16 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Lisa L. Cooper and Barry M. Cooper located at 443 Sioux Drive, Mechanicsburg, Pennsylvania, according to law. Sworn and Subscribed to Before Me So Answers: This Day of R. Thomas Kline, Sheriff 2002, A.D. Prothonotary B`?'` Real Estate eputy Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE CIO COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. LISA L. COOPER BARRY M. COOPER Mortgagors and Record Owners 443 Sioux Drive Mechanicsburg, PA 17055 Defendants AFFIDAVIT PURSUANT TO RULE 3129 No. 02-2823 CIVIL TERM THE BANK OF NEW YORK AS TRUSTEE CIO COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praccipe for the writ of execution was filed the following information concerning the real property located at: 443 Sioux Drive Mechanicsburg, PA 17055 1.Name and address of Owners or Reputed Owners: LISA L. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 BARRY M. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 2. Name and address of Defendants in the judgment: LISA L. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE BARRY M. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL INC 6520 Carlisle Pike, Suite 155 Mechanicsburg, PA 17055 CITIFINANCIAL MORTGAGE CO. INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 15, 2002 J4 O DBEC McC,AFFERTY & McKEEVER Joseph A. Goldbeck, Jr., Esq. ttomey for Plaintiff 0 s-? ? n o 0 ?-' xs ? ? --± ? r - P _. C ??? ? n o ? ,:, -= -:: ? ? ,, ??-: -? 7160 3401 4844 0451 5048 TO: COOPER, BAR 3Y M. BARRY M. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER August 22, 2002 REFERENCE: COOPER, LISA. L. / CWD-1872 12/04/02 - Cumberland RETURN RECEIPT SERVICE Return Receipt Fee Total Postage & Fees ;?, -? - US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International mail C +.. 4 t^? i AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- ing left to right across ped. Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits. Otherwise affix to back of mailpiece. 2. If you do not want the receipt postmarked, stick the article # label to the right of the return address, date receipt and retain the receipt. 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mailcenter, or post office service window. (SEE ILLUSTRATION) A L.LL.LM..JIY..I np Yenpe, Le'.18.Y l SIND-. 1'331 Bou,n Ylr'wn.e!'une 110 Vw ltl,n llSnM `/? 19 Wn8Y66L 61YM L77777 DerIU D. Doe N9e15e0menl Merke,I lncMene0.1 Welz Poe,el Salutlnne, 1668 Sou11, Mleelnn no. Sul,. 110 Fe 11brook, CA 92028-4112 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt. 5. Save this receipt and present it if you make an inquiry. MO 3901 9844 0951 5031 TO: COOPER, Ll$A L. LISA L. COOPER 443 Sioux Drive Mechanicsburg, PA 17055 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER August 22, 2002 REFERENCE: COOPER 1LISAL.ICWD-1872 12/04/02 - Cumberland RETURN rO°`°b° RECEIPT Certified Fee SERVICE Return Receipt Fee Total Postage '& Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail -i N AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST'CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1• Detach the form 3811, Domestic return receipt by fear- ing left to right across pert. Attach to back the adhesive strips and affxing to fromailpiece nt of by peeling mailpiece if space permits. Otherwise affx to back of mailpiece. 2. If you do not want the receipt postmarked, stick the article # label to the right of the return address, and retain the receipt. date receipt 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mailcenter, or post Office service window. (SEE ILLUSTRATION) (Form san g , ,., ...... A o.n. o. o.. ?•vi u.n,.nr.en.n,,. er •..x. neee ne n.rm. n. e • . .num e •..•. a eeoee.ml . YweBm ll,ny Luel.Lee....ply - o.,m o. on. Weli'pesa.l8 lM.'k.'I, M•'.'.' 1688 8ou1M1 Ml..l.n 10 8 F.112.F, CA 81848-1112u h. 118 4. Enter fees for the services requested in t-+ spaces on the front of this receipt. appropriate 5. Save this receipt and present it if you make an inquiry. 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 Bank of New Yoark tr c/o Countrywide Home Loans Inc is the grantee the same having been sold to said grantee on the 4th day of Dec A.D., 2002, under and by virtue of a writ Execution issued on the 27th day of AA g sc, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 2823, at the suit of Bank of New York Tr c/o Countrywide Home Loans Inc against Lisa L Cooper & Barry M is duly recorded in Sheriff's Deed Book No. 255, Page 333. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this c13 iJ day of , A.D. 2002 of Deeds necade? of Deese, Cwtenna caexy, cue, PA My cw m*sion E)q*n ft PM Mw"y of JWL Woe AMENDED RETURN The Bank of New York as Trustee c/o Countrywide Home Loans Inc. VS Lisa L. Cooper and Barry M. Cooper In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-2823 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on October 25, 2002 at 7:12 o'clock PM, she 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: Lisa L. Cooper and Barry M. Cooper, by posting the premises located at 443 Sioux Drive, Mechanicsburg, Cumberland County, Pennsylvania pursuant to court order dated July 16, 2002 by Judge Edward Guido. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 2, 2002 at 11:16 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Lisa L. Cooper and Barry M. Cooper located at 443 Sioux Drive, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for The Bank of New York as Trustee c/o Countrywide Home Loans Inc. It being the highest bid and best price received for the same, The Bank of New York as Trustee c/o Countrywide Home Loans Inc. of 7105 Corporate Drive, PTX B-35, Plano, TX 75024-3632, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $806.20, it being costs. Sheriffs Costs: Docketing 30.00 Poundage 15.81 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 16.56 Certified Mail 1.53 Levy 15.00 Surcharge 30.00 Posting 6.00 Law Journal 297.95 Patriot News 232.15 Share of Bills 25.20 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $806.20 Sworn and Subscribed to Before Me This Day of 200 A.D.pp Pf othonotary / l So Answers: R. Thomas Kline, Sheriff BY ?JOC? Real Esta eputy 03 -30; 3 3.730 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-28231 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK AS TRUSTEE C/O COUNTRYWIDE HOME LOANS INC., Plaintiff (s) From LISA L. COOPER AND BARRY M. COOPER, 443 SIOUX DRIVE, MECHANICSBURG, PA 17055 (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 $152,854.56 L.L. $.50 . Interest FROM 2/1/01 TO 8/26/02 AT 11.7500% Atty's Comm % Due Prothy $1.00 Atty Paid $188.18 Other Costs Plaintiff Paid Date: AUGUST 27, 2002 CURTIS R. LONG Prothonota ? J (Seal) Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR. ESQUIRE Address: SUITE 500-THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale # 16 On August 29, 2002 the sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA known and numbered as 443 Sioux Drive, Mechanicsburg more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 29, 2002 ByLlp&4rv Real Estate Deputy 0 Ca =n1 rt Wr , THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 8'12 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 22nd and 29th day(s) of October and the 5th day(s) of November 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION'?,? ................................................... COPY ?-Sworn to and su scribed befaL" his 14th da f No a er 2002 A.D. S A L E #16 Notarial Seal REAL ESTATE SALE No. 16 Terry L. Russell, Notary Public Writ No. 2002-2823 aty Of Harrisburg, Dauphin LA 0411 yl Civil Term My Commission Expires June 6, 2006 NC TARY PUBLIC The Bank of New York, as Member, Pennsylvania Association Of NtNarles M commission ex ires June 6 2006 Trustee C/o Countrywide Y P Home Loans, Inc. vs Lisa L. Cooper and Barry M. Cooper Atty: Joseph Goldbeck LEGAL DESCRIPTION THE LAND REFERRED TO in this commitment is described as follows: ALL THAT CERTAIN tract of parcel of land and premises, situate, lying and being in the Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows; in accordance with a plan of property made by Michael C. D'Angelo, registered surveyor of New Cumberland, Pennsylvania dated August 17, 1979, as follows, to wit: CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total Publisher's Receipt for Advertising Cost $ 230.40 $ 1.75 $ 232.15 The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. BEGINNING at a point the southwest intersection of Sioux and Cherokee Drives; thence along the west side of Sioux Drive South 7 degrees 2 minutes East, 155.09 feet to a point at Lot #2; thence along said lot South 82 degrees 58 minut By ..... ............................................................... es West 106.13 feet to a point at Lot No. 43; thence along Lot 43, North 10 degrees 19 minutes 13 BEGINNING. BEING known as 443 Sioux Drive. Being Lot #1 " " seconds West, 154.36 feet to the South side of Cherokee Drive; thence along the South id f , Block K , on Plan #3 of Indian Creek as recorded in Plan Book 16, Page 85. SOLD as the property of Lisa L. Cooper and s e o Cherokee Drive, by curve to the right having a di IMPROVEMENTS consist of a residential dwelling Barry M. Cooper. TAX AX PARCEL #10 19 1600 ra us of 800 feet, an arc length of 3.42 feet to a i . BEING PREMISES - -019. po nt thence along same North 82 degrees 58 mi t E : 443 Sioux Drive, Mechanicsburg PA 17055 nu es ast, 80.58 feet to the point of , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 25, NOVEMBER 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 16 Writ No. 2002-2823 Civil O The Bank of New York, as Trustee, coo Countrywide R ger M. Morgenthal, Editor Home Loans, Inc. vs. Lisa L. Cooper and Barry M. Cooper Atty.: Joseph Goldbeck LEGAL DESCRIPTION: The land referred to in this Com- mitment is described as follows: ALL THAT CERTAIN TRACT of parcel of land and premises, situ- ate, lying and being in the Town- ship of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more particularly de- scribed as follows, in accordance with a Plan of Property made by Michael C. IYAngelo, Registered Sur- veyor of New Cumberland, Pennsyl- vania dated August 17, 1979, as fol- lows, to wit: SWORN TO AND SUBSCRIBED before me this 8 day of NOVEMBER, 2002 NCYTARM SEAL L/ LOIS E. Public caftle Bari, ( opn My CiOlon l :Ies Mamh .i, BEGINNING at a point the south- west intersection of Sioux and Chero- kee Drives; thence along the west side of Sioux Drive South 7 degrees 2 minutes East, 155.09 feet to a point at Lot #2; thence along said Lot South 82 degrees 58 minutes West 106.13 feet to a point at Lot No. 43; thence along Lot 43, North 10 degrees 19 minutes 13 seconds West, 154.36 feet to the South Side of Cherokee Drive; thence along the South side of Cherokee Dive, bo curve to the nigh length of 34.42 feet 800 feet, an arc to a point thence along same North 82 degrees 58 minutes East, 80.58 feet to the point of Beginning. BEING known as 443 Sioux Drive. Being Lot # 1, Block "K7, on Plan #3 of Indian Creek 8a5 recorded in Plan Book 16, Page IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 443 Sioux Drive, Mechanicsburg, PA 17055. LISA L. SOLD as the property of COOPER and BARRY M COOPER. TAX PARCEL #10-19-1600-019- ?s