The URL can be used to link to this page

Home My WebLink About96-01559 1 1 i ~. ~ J f ~ ': ~ '-", I , /i / ! , I J J ~ '-lJ '..I) -... -> '. " ~ -, ,-) <~,! ,/"'\ .,--:~ --~ . <1'- "- , .' '. ~~ , ;~ 1-, ,,~.:,.. ,'''', l '..... ,~ '--, , '~ r',. I "'::"-J 'J. " ~~:J .:.L ~ ' ',-,- ~--- -.- ~ z :5 UI '~~ o.:t tf_ 0:'01 Cl ~- ;z (1_ .q: 2;'~ 2 ~,"" :$ uci .-.!o~.c .0 r:: a.O ffiCI1I:J"iUO O 1!)Q. t.J 0 ~JJS~j UU.Q ~~ :.~ ,:a ~ '-'j '.~ ""1",".I'.I~"".,,'J.~~f:::n' ''''II' H7J:;'/.: . 1, plaintiff is OCI MORTGAGE CORPORATION 816 CONGRESS, SUITE 2000 AUSTIN, TX 78701 2. The name(s) and last known address(es) of the Defendant(s) are JAMES B. CONNOLLY LINDA A. CONNOLLY 2306 BUCKINGHAM AVENUE MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3, On 8/30/85 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FIRST UNITED FEDERAL which mortgage is recor(~d in the Office of the Recorder of CUMBERLAND county, in Mortgage Book No. 788, Page 575, By Assignment of Mortgage dated 11/10/92 the mortgage was assigned to FAIRFIELD AFFILIATES, A General partnership which Assignment is recorded in Assignment of Mortgage Book No, 442, Page 964, By Assignment of Mortgage dated 1/20/95 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No, 500, Page 683. 4, The premises subject to said mortgage is described as attached, 5, The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/1/92 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A," ~i ~. , t; ~. :s; h: ~'j n 1>' 6. The following amounts are due on the mortgage: principal Balance Int.erest 9/1/92 through 1/1/96 (Per Diem $14.70) Attorney's Fees cumulative Late Charges 8/30/85 to 1/1/96 Cost of suit and Title Search Subtotal $66,168.03 17,889.90 3,308.00 1,758,75 550.00 89,674,68 Escrow Credit DeHcit Subtotal 0.00 2,832,66 2,832.66 TOTAL en, 507. H 7. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000,00, 8, Notice of Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, is not required as the mortgagor is more than thirty-six months in arrears on the mcrtgage, 9, Pursuant to the Fair Debt Collection practices Act, 15 U.S,C. S 1692 et seq, (1977), Defendant(s) may dispute the validity of the debt or any portion thereof, If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid, Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands Judgment against the Defendant(s) in the sum of $92,507.34, together with interest from 1/1/96 at the rate of $14,70 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~-<<-vl- r~ Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff n.U'l1t F!DlllLlriIAN LAWU!'KIl T PKlLAH MAROLD!'t. 1Uft.AH- lOAN p, 1I0DSKY. .m. C. otlD UIIICCA t. WOODSIDI USLlI . PUlD"- PJ,ANOS S. HAU.JHAN- DAHIlL Q. SCKMlIO ntOMAJ A. SAAOL. T1fOMAS W. nDIIMAH- MIOmLI W. llAMORD aOSIMAlUI DlAMOHDl DAHIBUI CASC.WIlO' -.tlWtTTIDIN'.. .."".'4/ - NPf JUJU kfN.tQ/NQ ,.tJtf,..~ L-.W omns FEDERMAN AND PHELAN Sl;rT1! 900 TWO PP.SN C1!!'O'!R PUL\ IIHIL.\OP.lJ'tfl.\. II,' 191C;:.: ~99 mmoj.~ p''''(I:m!6).UH TF.1..fCOIIIUftJI"'OJ.UH MEOl' OVfIC1l 604) ~IUlf telD.I.QH M!DIA. 11-\ 1906) 1:1S~"1..1M NllWI!UIlY.)ma SUm! J03 SlHTJ.Y O"ICI PLALA 116 HADDON "V!JfU1l W1U"1lotOHT. f'fIW IUSIY 01101 T!I..BCOPtIt'1l10') UI.t461 nns NOT1C1lS SINT TO YOU rJr( AH "nBMPT TO caLUler nil ttmllmOHlSS unuaD TO HUI[H AND AHY 1H10lMAnQHOI'TAiHID nON you wtLL II USID '01 THAT PVUOSI. ADMlNtSTUroIl DONALD .. QOODN.AH PlLUIl UPL Y TO nil PHtt..ADIUKlA oma December 26, 1995 James B. Connolly 2306 Buckingham Ave Mechanicsburg, PA 17055 Linda A. Connolly 2306 Buckingham Ave Mechanicsburg, PA 17055 Re: Premises: Loan No.: 2306 Buckingham Ave, Mechanicsburg, PA 17055 50810119 NOTICE OF INTENTION TO FORECLOSE We represent OCI Mortgage Corporation, the holder ot the Mortgage on the above-reterenced premises, who hereby advises that it will accelerate your Mortgage (demand payment in tull) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured as provided below. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. You may dispute the validity of the debt or any portion thereot. It you do so in writing within thirty (30) days ot receipt of this letter, this firm will obtain and provide you with written verification thereof: otherwise, the debt will be assumed to be valid. Likewise, you may request the name and address ot the original creditor it different from above. The total delinquency, including late and other charges is $27,888.75 tor the months of 10/1/92 through 12/1/95. Your tailure to pay the delinquent amount, plus any additional monthly payment and late and other charges (inCluding any accrued interest) that may come due within the next thirty (30) days, will result in the acceleration of all sums due under your Mortgage. After acceleration occurs, a foreclosure action or any other remedy permitted by your mortgage may be instituted. EXHIBIT "A" ...' '.' "\... \ \ '. \ --.-". ------ - 3300001600 xar0230-004-0052 EXHIBIT A (Legal DescriptiOn) BEGINNING at a point on the western line of Buckinqh~m Avenue. at the north- east corner of Lot NuMber BO. as shown on the hereInafter mentioned Plan of Lots; thence by tne dividing line between Lot No. 101 and Lots BO and 79. North 81 degreeS 51 ~inutes 41 s.conds West. 216.45 feet to a point; thence by the dividing line between Lots Numbers 101 arod 78. North 1 degree 5 minuteS East. B2.13 feet to a point; thence North 10 deqreeS 53 minutes 9 seconds East. 36.42 feet to \ point; thence North 43 degreeS 21 minutes 11 seconds East. 63.4g f.et to a point; thence by the dividing \Ine between Lots Numbers 10\ and 100. South 62 degrees 1 minute 41 seconds East. 183.81 feet to a point on the western line of Buckingham Avenue; thence by the western line of Buckinqham Avenue In a southerly direction by an arc on a curve to the left with a radius of 260 feet. an arc distance of 90 feet to the point and place of BEGINNING. BEING Lot ~o, 101 on the Plan of Lots of Center Square Manor, Estenslon "A". Plan Number 1, which Plan Is recorded in the C~berland County Recorder of aeeds Office In Plin Book 31. Page 36A, BEING kr.~wn and numbered as premises 2306 Bucklngha~ Avenue, MechanlcSbur9. Pennsylvania.