HomeMy WebLinkAbout00-00044
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Bui1ding
123 South Broad Street, Suite 2080
Philade1phia, Pennsylvania 19109
(215) 790-1010
Conseco Finance Corp.
7360 Kyrene Rd.
Tempe, AZ 85283
v.
Mark A. Hickoff
2437 Mills St
Orlando, FL 32806
Attorney for Plaintiff
Cumberland County
Court of Common Pleas
Number .;2.000 - .iff
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NOTICE
CIVIL ACTION/MORTGAGE FORECLOSURE
AVISO
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 this complaint and
notice are served, by entering a written
appearance personally or by attorney and
filing in writing with the court your
defenses or objections to the claims set
forth against you. You are warned that if
you fail to do so the case may proceed
without you and a judgment may be entered
against you by the court without further
notice for any money claimed in the complaint
or for any other claim or relief requested by
the plaintiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO Fll'ID OUT WHERE YOU CAN GET
HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
{717} 249-3166
Le han demandado a usted en la corte. si
usted quiere defenderse de estas demandas
ex-puestas en las paginas siguientes, usted
tiene veinte (20) dias de plaza al partir de
la fecha de la demanda y la notificacion.
Hace falta asentar una comparencia escrita 0
en persona 0 con un abogado y entregar a la
corte en forma escrita sus defensas 0 sus
objeciones alas demandas en contra de su
persona. Sea avisado que si usted no se
defiende, la corte tomara medidas y puede
continuar la demanda en contra suva sin
previo aviso 0 notificacion. Ade~as, la
corte puede decidir a favor del demandante y
requiere que usted cumpla con todas las
provisiones de esta demanda. Ustedpuede
perder dinero 0 sus propiedades U otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDlATAMENTE. SI NO TIENE ABOGADO 0 SINO
TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO.
VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA
OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA
ABAJO PARA A VERlGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
CUmberland County Bar Association
2 Liberty Avenue
carlisle, PA 17013
(717) 249-3166
McCABE, WEISBERG AND CONWAY, P.C.
BY, TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Attorney for Plaintiff
Conseco Finance Corp.
7360 Kyrene Rd.
Tempe, AZ 85283
Cumberland County
Court of Common Pleas
v.
Mark A. Hickoff
2437 Mills St
Orlando, FL 32806
Number .J nrV _ 'I '{ ~ --r ~
CIVIL ACTION/MORTGAGE FORECLOSURE
1. Plaintiff is Conseco Finance Corp., a corporation duly
organized and doing business at the above captioned address.
2. The Defendant is Mark A. Hickoff, who is the mortgagor
and real owner of the mortgaged property hereinafter described, and
his last-known address is 2437 Mills St, Orlando, FL 32806.
3. On July 25, 1998, mortgagor made, executed and delivered
a mortgage upon the premises hereinafter described to Green Tree
Consumer Discount Company, which mortgage is recorded in the Office
of the Recorder of Cumberland County in Mortgage Book 1470, Page
1102.
4. The aforesaid mortgage is being assigned by Green Tree
Consumer Discount Company to Conseco Finance Corp., Plaintiff
herein, by Assignment of Mortgage recorded in the Office of the
Recorder of Cumberland County.
5. The premises subject to said mortgage is described in the
mortgage attached as Exhibit "A" and is known as 30 E. Keller St.,
Mechanicsburg, PA 17055.
6. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due August, 1999 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.
7. The following amounts are due on the mortgage:
Principal Balance
Interest 7/99 through 11/8/99
(Plus $16.846667 per diem
thereafter)
Attorney's Fee
Late Charges
Penalties
Cost of Suit
Appraisal Fee
Title Search
$56,483.04
$ 2,129.80
$
$ 2,824.15
$ 384.44
$ 3,056.61
$ 225.00
$ 125.00
$ 200.00
GRAND TOTAL
$65,428.04
8. 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 Sheriff's
Sale. If the mortgage is reinstated prior to the Sale,
reasonable attorney's fees will be charged based on work actually
performed.
9. Notice of Intention to Foreclose as required by Act 6
of 1974 (41 P.S. ~403) and notice required by the Emergency
Mortgage Assistance Act of 1983 as amended under 12 PA Code
Chapter 13, et seq., commonly known as the Combined Notice of
Delinquency has been sent to Defendant by certified mail on the
date set forth in the true and correct copies of such notices
attached hereto as Exhibit "E."
WHEREFORE, Plaintiff demands Judgment against the Defendant
in the sum of $65,428.04, together with interest at the rate of
$16.846667 per diem and other costs and charges collectible under
the mortgage and for the foreclosure and sale of the mortgage
property.
VERIFICATION
I, Terrence J. McCabe, Esquire, verify that the statements
made in the foregoing Complaint are true and correct to the best
of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 PA C.S.
&4904, relating to unsworn falsification to authorities.
DATE: .L-4?1/17
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Commonwealth or Pennsylvania Space Abo,.e This Line For R<<ording Data
OPEN.END MORTGAGE Appliaa\.~~ ## ....007,'loo~N7
This Mortgage secures future adV31lCeS
1. DATE AND PARTIES. The date of this Mortgage (Security Instrument) is ....-!.~~r...~.~.~...~~~.~...........~.... and the
parties, their addresses and tax identification numbers, if required, are as follows:
MORTGAGOR:
Mark A Hickoff
o If checked, refer 10 the attaChed Addendum incmporated heretn, for additional Mortgagors, their signatures and
acknc>wledgments.
LENDER:
Green Tree Consumer Discount Company
3401 Hartzdale Drive Suite 118
camp Hill, pennsylvania 17011
z. CONVEYANCE. For good and valuable consideration, the receipt and sufficiency of which is acknowledged, and 10 secure
the Secured Debt (defined below) 31ld Mortgagor's performance under this Security Instroment, Mortgagor grants, bargains,
conveys and mortgages to Lender the following described property:
See Exhibit A
PARCEL I.D.# 17-24-0787-051
. . CUmberland
The property 15 located ID .......................... ..... ........................................ at .............................. ..................
> (County)
. . . . .' ." PI' 17055
.. ............ ............ .................. ..... ....... ....., ...... .... ..... .... .... ........... ............. ......, ennsy vaDl3 ......... ........ ... ......
(Adcress) (City) (ZIP Code)
:
Together With all rights, easements, appurtenances, royalties, mineral rights, oil and gas rights, all water and riparian rjghts,
ditches, and water stock and all existing and furore improvements, strUCrores, fixtures, and replacements thai may now, or at
any time in the future, be part of the real estate descnDed above (all referred to as 'Property').
3. MAXIMUM OBLI~f!lHn ~T. The total principal amount secured by this Security Instrument at anyone time shall not
exceed $ .............:...~........:......................... . This limitation of amount does not include interest and other fees and
charges validly made pursuant to this Security Instrument. Also, this limitation does rot apply to advances made under the
terms of this Security Instrument to protect Lender's security and to perform any of the covenants contained in this Security
Instrument.
4. SECURED DEBT AND FUTURE ADVANCES. The term 'Secured Debt" is defined as follows:
A. Debt incurred under the terms of all promissory note{s), contract(s), guaranly(s) Or other evidence of debt described
below and all their extensions, renewals, modifications or substitutions. (MIen referencing the debts below it is
suggested that you include items such as borrowers' names. note amolUlts. interest rates. maturity dates, etc.)
Note dated July 25, 1998, between Green T~ee Consumer Discount Company and Mark A
Hickoff. ,f for $57,000.00, maturing August 1, 2023.
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PENNSYLVANlA . MORTGAGE [NOT FOR:e
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B. All future advances from Lender to Morlgagor or o~;r fu~;:"'~Ji'gati~f Mortgagor 10 Lender under any promissory
note, contract, guaranty. or other evidence of debt executed by Mortgagor in favor of Lender executed after rhis Security
Instrument whether or not this Security Instnnnent is specifically referenced. If more than one person signs this Security
Instrument, each Mortgagor agrees that this Security Instrument will secure all future advances aod future obligations
that are given 10 or incurred by any oue or more Mottgagor, or anyone or more Mortgagor and others. All future
advances and other future obligations are secured by this Security lnstrument even though all or pan may not yel be
advanced. All future advances and other future obligations are secured as if made on the date of this Security Instrument.
Nothing in this Security Instrument shall constitute a commitmenl to make additional or future loans or advances in any
amounl. Any such commitment musl be agreed 10 in a separate writing.
C. All obligations Mortgagor owes to Lender, which may later arise, to the extenl not prohibited by law, including, but not
limited to, liabilities for overdrafts relating to any deposit account agreement between Mortgagor and Lender.
.D. All additional sums advanced and expenses incurred by Lender for insuring, preserving or otherwise protecting the
Property and its value and any other sums advanced and expenses incurred by Lender under the tellIlS of this Security
lnstrunlent.
ThIs Security Instrunlent will not secure any other debt if Lender fails to give any required notice of the right of rescission.
5. PAYMENTS. Mortgagor agrees that all payments under the Secured Debt W111 be paid when due and in accordance with rhe
terms of the Secured Debt and this Sec:urity Instrument.
6. WARRANTY OF TITLE. Mortgagor warrants that Mortgagor is or will be lawfully sel2ed of the estate conveyed by this
Security lnstrument and has the right to grant, bargain, convey, sell, and mortgage the Property. Mortgagor also warrants that
the Property is unencumbered. except for encumbrances of record.
7. PRIOR SEctJRITY INTERESTS. With regard to any other mortgage, deed of trust, security agreement or other lien
document that created a prior securilY interest or encumbrance on the Property, Mortgagor agrees:
A. To make all payments when due and 10 perform or comply with all covenants.
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B. To promplly deliver 10 Lender any notices thaI Mortgagor receives from the holder.
C. Not to allow any modification or extension of, nor to requesl any future advances under any note or agreement secured
by the lien documem witham Lender's prior written cons":,,t.
8. CLAIMS -AGAINST TITLE. Mortgagor will pay all taxes, assessments. liens, encumbrances, lease payments, ground rents,
milities, and other charges relating 10 the Property when due. Lender may require Mortgagor to provide to Lender copies of all
notices that"'SIlch amounts are due and the receipts evidencing Mortgagor's payment. Mortgagor will defend title to the
Property against any claims that would impair the lien of this Security InslnUllenl. Mortgagor agrees to assign to Lender, as
requested by Lender, any rights, claims or aefenses Mortgagor may have against parties who supply Jabor or materials to
maintain or improve the Property.
9, DUE ON SALE OR ENCUMBRANCE. Lender may, at its option, declare the entire balance of the Secured Debt 10 be
immediately due and.payable upon the creation of, or contraCt for the creation of, any lien, encumbrance, transfer or sale of the
Property. This right is subject 10 the restrictions imposed by fedetallaw (12 C.P.R. 591), as applicable. This covenant shall
run with the Property and shall remain in effect until the Secured Debt is paid in full and this Security Instrument is released.
10. PROPERTY CONDITION, ALTERATIONS AND INSPECTION, Mortgagor will keep the Property in good condition and
make all repairs that are reasonably necessary. Mottgagor shall not commit or allow any waste, impairment, or deterioration of
the Property. Mortgagor will keep the Property free of noxious weeds and grasses. Mortgagor agrees that the nature of the
occupancy and use will not substantially change without Lender's prior written consent. Mortgagor will not permit any change
in any license, restrictive covenant or easement without Lender's prior written consent. Mortgagor will notify Lender of all
demands, proceedings, claims and actions against Mortgagor, and of any loss or damage to the Property.
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Lender or Lender's agents may, at Lender's option, enter the Property at any reasonable time for lite purpose of inspecting the
Property. Lender shall give Mortgagor notice at the time of or before an inspection specifying a r.....onable purpose for the
inspe<:tion. Any inspection of the Property shall be entirely for Lender's benefit and Mortgagor will in no way rely on
Lender.s irua-pection.
n, AUTHORITY TO PERFORM, If Mortgagor fails to perform any duty or any of the covenants contained in this Security
Instrument, Lender may, without notice, perform or cause them to be performed. Mortgagor appoints Lender as attorney in
fact to sign Mortgagor's name or pay any amount necessary for performance. Lender's right to perform for Mortgagor shall
not create an obligation to perform, and Lender's failure to perform will not preclude Lender from exercising any of Lender's
other rights under the law or this Security Instrument. If any construction on the Property is discontinued or not carried on io a
reasonable manner, Lender may take all steps necessary to protect Lender's security interest in the Property, including
completion of the construction.
12, ASSIGNMENT OF LEASES AND RENTS. Mortgagor irrevocably grants, bargains, conveys and mongages to Lender as
additional security all the right, tide and interest in and to any and all existing or future leases, subleases, and any other written
or verbal agreements for the use and occupancy of any portion of the Property, including any extensions, renewals,
modifications or substitutions of such agreements (all referred to as "Leases") and rents, issues and profits (all referred to as
"Rents"). Mortgagor will promptly provide Lender with true and correct copies of aU existing and future Leases. Mongagor
may collect, receive, enjoy and use the Rents so long as Mortgagor is not in default under the terms of this Security
Instrument,
Mortgagor agrees that this assignment is immediately effective between the parties to this Security Instrument and effective as
to third parties on the recording of this Security Instrument, and this assignmem will remain effective until the Obligations are
satisfied. Mortgagor agrees that Lender is entitled to notify Mortgagor or Mortgagor's teDants to make payments of Rents due
or to become due directly to Lender after such recording, however Lender agrees not to notify .Mortgagor's tenants until
Mortgagor defaults and Lender notifies Mortgagor of the default and demands that Mortgagor and Mortgagor's rerumts pay all
Rents due or to become due directly to Lender. On receiving notice of default, Mortgagor will endorse and deliver to Lender
any payment of Rents in Mortgagor's possession and will receive any Rents in trust for Lender and will not commingle the
Rents with any other funds. Any amounts collected will be applied as provided in this Security InslIUlllent. Mortgagor warrants
that no default exists under the Leases or any applicable landlord/tenant law. Mortgagor also agrees to maintain and require
any teDant to comply with the terms of the Leases and applicable law.
13. LEASEHOLDS; CONDOMINIUMS; PLANNED UNIT DEVELOPMENTS. Mortgagor agrees to comply with the
provisions of any lease if this Security Insuument is on a leasehold. If the Property inclndes a unit in a condominium or a
planned unit development, Mortgagor will perform all of Mortgagor's duties under the covenants, by-laws, or regulations of
the condominium or planned unit development.
14. DEFAULT. Mongagor will be in default if any party obligated on the Secured Debt fails to make payment when. due.
Mortgagor will be in default if a breach occurs under the terms of this Security Instrument or any other document executed for
the purpose of creating, securing or guarantying the Secured Debt. A good faith belief by Lender that Lender at any time is
insecure with respect to any person or entity obligated on the Secured Debt or that the prospect of any payxncnt or the value of
the Property is impaired shall also consnolle an event of default.
15. REMEDmS ON DEFAULT. In some instanCeS, federal and Slate law will require Lender to provide Mortgagor with notice
of the right to cure or other notices and may establish time schedules for foreclosure actions. Subject to these limitations, if
any, Lender may accelerate the Secured Debt and foreclose this Security Instrument in a manner provided by law if Mortgagor
is in default.
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At the option of Lender, all or any part of the agreed fees and charges, accrued interest and principal shall become immediately
due and payable, after giviug notice if required by law, upon the occurrence of a default or anytime thereafter. In addition,
Lender shall be entitled to all the remedies provided by law, the terms of the Secured Debt, this Security Instrument and any
related documents. All remedies are distinct, cumulative and not exclusive. and the Lender is entilled to all remedies provided
at law or equity, whether or not expressly set forth. The acceptance by Lender of any sum in payment or partial payment. on
the Secured Debt after the balance is due or is accelerated or after foreclosure proceedings are filed shall not constitute a waiver
of Lender's right to require complete cure of any existing default. By not exercising any remedy on Mortgagor's default,
Lender does not waive Lender's right to later consider the event a default if it continues or happens again.
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16. EXPENSES; APVANCES ON COVENANTS; ATTORNEYS' FEES; COLLECTION COSTS. Except when prohibited
by law, Mortgagor agrees to pay all of Lender's expenses if Mortgagor breaches any covenant in this Security Instrument.
Mortgagor will also pay on demand any amount incurred by Lender for insuring. inspecting, preserving or otherwise
protecting the Property and Lender's security interest. Th= expenses win bear interest froll1the date of the payment until paid
in full at the highest interest rate in effect as provided in the terms or the Secured Debt. Mortgagor agrees to pay all costs and
expenses incurred by Lender in collecting, enforcing or protecting Lender's rights and remedies under this Security Instrument.
This amount may include, but is not limited to, attorneys' fees, court COSts, and other legal eoq>enses. This Security Instrument
shall remain in effect until released. Mortgagor agrees to pay for any recordation <;asts of such release.
17. ENVIRONMENTAL LAWS AND HAZARDOUS SUBSTANCES. As used in this section. (1) Environmental Law means,
without limitation, the Comprehensive Environmenta1 Response, Compensation and Liability Act (CERCLA, 42 U .S.C. 96(H
et seq.), and all other federal, state and local laws, regulations, ordinances, court orders, attorney general opinions or
inteIpretive letters concerning the public health, safety. welfare, environment or a hazardous substance; and (2) Hazardous
Substance means aoy toxic, radioactive or hazardous material, waste, pollutant or conlalllinant which has characteristics which
render the substance dangerous or potentially dangerous to the public health, safety, welfare or environment. The term
includes, without limitation, any substances defined as "hazardous material," "toxic substances," "hazardous waste" or
"hazardous substance" under any Environmental Law.
Mortgagor represents, warrants and agrees that:
A. Except as previously disclosed and acknowledged in writing to Lender, no Hazardous Substance is or will be located,
stored or released on or in the Property. This restriction does not apply to small quantities of Hazardous Substances that
are genemlly recognized to be appropriate for the nonnaJ use and maintenance of the Property.
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B. Except as previously disclosed and aCknowledged in writing to Lender, Mongagor and every tenant have been, are, and
shall remain in full compUance with any applicable Environmental Law.
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C. Mortgagor shall immediately notify Lender if a release or threatened release of a Hazardous Substance occurs on, under
or about the Propeny or there is a violation of any Environmental Law conceming the Property. In such an event,
Mortgagor shall take all necessary remedial action in accordance with any Environmental Law.
D. Mortgagor shall immediately notify Lender in writing as soon as Mortgagor has reason to believe there is any pending or
threatened investigation, claim, or proceeding relating to the release or threatened release of any Hazardous Substance or
the violation of any Enviro=ntal Law.
18. CONDEMNATION. Mortgagor wm give Lender prompt notice of any pending or threatened action, by private or public
entities to purchase or take any or all of the Property through condemnation. eminent domain, or any other means. Mortgagor
authorizes Lender to intervene in Mortgagor's name in any of the above described actions or claims. Mongagor assigns to
Lender the proceeds of any award or claim for damages connected with a condemnation or other taking of all or any part of the
Property. Such proceeds shall be considered payments and will be applied as provided in this Security Instrument. This
assignmeoi of proceeds is subject to the tetms 'of any prior mortgage, deed of rrust. security agreement or other lien document.
19. INSURANCE. Mortgagor shall keep Property insured against loss by fire, flood. theft and other hazards and risks reasonably
associated witb the Property due to its lJIpe and location. This insurance shall be maintained in the amounts and for the periods
that Lender requiles. 'The insurance carrier providing the insurance shall be chosen by Mortgagor subject [0 Lender's approval,
which shall not be unreasonably withheld. If Mortgagor fails to maintain the coverage described above, Lender may, at
Lender's option, obtain covemge to protect Lender's rights in the Property according to tbe terms of this Security Instrument.
AU insurance policies and renewals sball be acceprable to Lender and shall inclnde a standard "mortgage clause" and, where
applicable, "loss payee clause." Mortgagor shall immediately notify Lender of cancellation or termination of the insurance.
Lender shall have the right to hold the policies and renewals. If Lender requires, Mongagor shall immediately give to Lender
all receipts of paid premiums and renewal notices. Upon loss, Mortgagor shall give immediate notice to the insurance carrier
and Lender. Lender may malre proof of loss if not made immediately by Mortgagor. ,
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Unless otherwise agreed in writing, all insurance prnceeds shall be applied to the restoration or repair of the Property or to the
Secured Debt, whether or not then due, at lender's option. Any application of proceeds to principal shall not extend or
postpone the due date of the scheduled payment nor change the amount of any payment. Any excess will be paid to the
Mortgagor. If the Property is acquired by Lender, Mortgagor's right ro auy insurance policies and proceeds resulting from
damage to the Property before the acquisition shall pass to Lender to the extent of the Secured Debt immediately before the
acquisition.
2(). ESCROW FOR TAXES AND INSURANCE. Unless otherwise provided in a separate agreement, MOrtgagor will not be
required to pay to Lender funds for taxes and insurance in escrow.
21. FINANCIAL REPORTS AND ADDITIONAL DOCUMENTS. Mortgagor will provide to Lender upon request, any
fimncial statement or iufonoation Lender may deem reasonably necessary. MOrtgagor agrees to sign, deliver, and file any
additional documents or certifications that Lender may consider necessary to perfect, continue, and preserve Mortgagor's
obligations under this Security InstrUment and Lender's lien status on the Property.
22. JOINT AND INDIVIDUAL UABILITY; CO-5IGNERS; SUCCESSORS AND ASSIGNS BOUND. All duties under this
Security Instrument are joint and individual. [f Mortgagor signs this Security Instrument but does not sign an evidence of debt,
Mortgagor does so only to mortgage Mortgagor's interest in the Property to secure payment of the Secured Debt and
Mortgagor does not agree to be personally [iable on the Secured Debt. [f this Security Instrument secures a guaranty between
lender and Mortgagor, Mortgagor agrees to waive any rights that may prevent Lender from bringing any action or claim
against Mortgagor or any party indebted under the obligation. These rights may include, but are not limited to, any
anti-deficiency or one-action laws. Mongagor agrees that lender and any party to this Security Instrument may extend, modify
or make any change in the terms of this Security Instrument or any evidence of debt without Mortgagor's consent. Such a
change will not release Mortgagor from the terms of this Security Instrument. The duties and benefits of this Security
Instrument shall bind and benefit the successors and assigns of Mortgagor aqcI l1fnder. '.
23. APPLICABLE LAW; SEVERABILITY; INTERPRETATION. Thi~ Security Instrument is governed by the laws of the
jurisdiction in which Lender is located, except to the extent otherwise required by' the laws of the jurisdiction where the
Property is located, This Security Instrument is complete and fully integrated. This Security Instrument may not be amended or
modified by oral agreement. Any section in this Security InstIUIllent, attachments: or any agreement related to the Secured
Debt that conflicts with applicable law will not be effective, unless that law expressly or impliedly permits the variations by
written agreement. If any section of this Security Instrument cannot be enforced according to its terms, that section will be
severed and will not affecr the enfurceability of the remainder of lbis Security IustrUment. Whenever used, the singular shall
include the plural and the plU1<ll the singular. The captions and headings of lbe sections of this Security Instrument are for
convenience only and are DOt to be used to interpret or define the tenos of this Security Instrument. Tune is of the essence in
this Security Instrument.
24. NOTICE. Unless otherwise required by law, any notice shaH be given by delivering it or by mailing it by first class mail to
the appropriOle party's address on page I of this Security Instrument, or to any other address designated in writing. Notice to
one mOrt~gor will be deemed to be notice to all mortgagors. .
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25. .W~R5..J?gept to the extent prohibited by law. Mortgagor waives any right to appraisement relating to lbe Property.
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26. OTHER TERMS. if checked. the following are applicable to this Security instrument:
D Line of Credit. The Secured Debt includes a revolving line of credit provision. Although the Secured Debt may be
reduced to a zero balance. this Security Instrument will remain in effect until released.
D Construction Loan. This Security instrument secures an obligation incurred for the construction of an improvement on
the Property.
D Fixture Filing. Mortgagor grants to Lender a security interest in all goods that Mortgagor owns now or in the future
and that are or will become fixmres related to the Property. This Security Instrument suffices as a financing statement
and any carbon, photographic or other reproduction may be filed of record for purposes of Article 9 of the Uniform
Commercial Code. .
o Purchase Money. This Security Instrument secures advances by Lender used in whole or in part to acquire the
Property. Accordingly, this Security Instrument. and the lien hereunder, is and shall be construed as a purchase money
mongage with all nf the rights, priorities and benefits thereof under the laws of the Commonwealth of Pennsylvania.
D NOTICE TO BORROWER: THIS DOCUMENT CONTAINS PROVISIONS FOR A VARIABLE
_ INTEREST RATE.
D Riders. The covenants and agreements of each of the riders checked below are incOIJlOrated into and supplement and
amend the terms of this Security Instrument. [Check all applicable boxes]
o COndominium Rider 0 Planned Utrlt Development Rider 0 Other ................................................... .
o Additional Terms.
SIGNATURES: By signing below, Mortgagor. intending to be leglllly bound hereby, agrees to me tenns and covenants contained
in this Security Instrument and in any anachments. Mongagor also acknowledges receipt of a copy of this Security instrument on
the date stated on page 1.
(Sig;~~~;;f.f.................~)..~t-~ (sii~~;j....,.:.~:.................::..........:.:......_......_......(D;t~j..
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(Witness)
ACKNO~g~~~ALTH OF ...~:7~~.:Y.~:;~!!:~.~............. COUNTY OF ....C!-l.w.l.~.Itr""'-{...........o..} ss.
,........., On this, the ....2.5.t.h.......... day of ........J.ULY..l.!1.Sl.e.................... beforemeU:o/.r;;(.,.f:T:..:Z...f.";~.,
. Mark A Hickoff.' . . '~. '~._':
the underSlgned officer, personally appeared ........................................................ ............ ......................
........................................................................................., known to rue (or satisfactorily proven) to be
me person{s) whose name(s) is subscribed to the within instrument, and acknowledged that helshe executed the same
for the purposes therein con<alned.
In. witness whereof. I here~o set my. hand and official seal. /' ) /J
My commission expires: ........L/..~...f.W.{2'f;~?!.:/::.,.
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t IS here y certi t e ress 0 e en er WI n name IS: ......................u..........................u...~;;-.....1r...............":-_",7".~""
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~:lOUBIT A
Lecral Description,
ALL THAT CERTAIN PROPERTY SITUATED IN SECOND WARD OP THE BOROUGH OP MECHANICSBURG,
CUMBERLAND COUNTY AND COMMONWEALTH OP PENNSYLVANIA BEING MORE FULLY DESCRIBED IN DEED
DATED 08/15/95, RECORDED 08/18/95, APPEARING AMONG THE LAND RECORD OF THE COUNTY AND
STATE SET FORTH ABOVE IN DEED BOOK VOLUME 126, PAGE 1035.
Parcel ID: 17-24-0787-051
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November 19,1999
Occupant( s)
30 E. Keller St.
Mechanicsburg, P A 17055
ACT 91 NOTICE
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. SDecific information about the
nature of the default is provided in the attached Dacres.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to
save YOllr home.
This Notice eXDlains how the Dr09ram 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
vou when you meet with the Counseling Acrencv.
The name. address and Dhone number of Consumer Credit Counseling Agencies
servina vour County are listed at the end of this Notice. If you have any
auestions. you mav call the Pennsylvania HousinG Finance Aaencv toll free
at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869.
This Notice contains important legal information. If you have any
questions, representatives at the Consumer Credit Counseling Agency may be
able.to help explain it. You may also want to contact an attorney in your
area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACIO EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASE. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA
(PENNSYLVANIA HOUSING-FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO paR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR
SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCOUNT NUMBER:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Mark A. Hickoff
30 E. Keller St..
6901400157
Conseco Finance
Conseco Finance
Mechanicsbura. PA 17055
EXHIBIT UB"
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE:
- IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a
temporary stay of foreclosure on your mortgage for thirty (30) days from the
date of this Notice. During that time you must arrange and attend a "face-
to-face" meeting with one of the consumer credit counseling agencies listed
at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (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 aoencies for the countv in which the p'roperty 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 immediatelv 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 the applications for the program and they
will assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. Your application MUST be filed or postmarked within
thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE
MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION--Available funds for emergency mortgage assistance are
very limited. They will be disbursed by the Agency under the eligibility
criteria established by the Act. The Pennsylvania Housing Finance Agency has
sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if
you have met the time requirements set forth above. You will be notified
directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A
PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS
FOR INFORMATION PURPOSES ONLY A.~D SHOULD NOT BE CONSIDERED AS
AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency
Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brina it un to date) .
NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your
property located at 30 E. Keller St.. Mechanicsbura. PA 17055 IS SERIOUSLY
IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the following
amounts are now past due: 5549.21 for the months of August 1999 throuah
November 1999
Other charges:
TOTAL AMOUNT PAST DUE: 52.582.70
HOW TO CURE THE DEFAULT--You may cure this default within THIRTY (30) DAYS'
of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER,
WHICH~IS 52.582.70. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash.
cashrer's check. certified check or monev order made payable and sent to:
Harold.Williams
Conseco Finance
7360 Kyrene Rd.
Tempe, AZ 85283
IF YOU DO NOT CURE THE DEFAllliT--If you do not cure the default within THIRTY
(30) DAYS of the date of this Notice, the lender intends to exercise its
riahts to accelerate the mortgaae 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 mortaaged property.
IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by
the Sheriff to payoff the mortgage debt. If the lender refers your case to
its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to $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 vou cure the default within the
THIRTY (30) DAY neriod. you will not be reouired to nav attornev'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 riaht to cure the default and nrevent the sale at
any time up to one hour before the Sheriff's Sale. You may do so by paying
the total amount then past due. nlus any late or other charges then due.
reasonable attornev'sfees and costs connected with the foreclosure sale and
any other costs connected with the Sheriff's Sale as snecified in writina bv
the lender and bv performina any other reouirements under the mortaage.
Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date
that such a Sheriff's Sale of the mortgaged property could be held would be
approximately five months from the date of this Notice. A notice of the
actual date of the Sheriff's Sale will be sent to you before the sale. Of
course, the amount needed to cure the default will increase the longer you
wait. You may find out at any time exactly what the required payment or
action will be by contacting-the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Conseco Finance
Address: 7360 Kyrene Rd.. Tempe. AZ 85283
Phone Number: 1 888 315 8733. Ext. 36239
Fax Number: 1 480 333 6457
Contact Person: Harold Williams
EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff's Sale will end
your ownership of the mortgaged property and your right to occupy it. If you
continue. to live in the property after the Sheriff's Sale, a lawsuit to
remove you and your furnishings and other belongings could be started by the
lender at any time.
ASSUMPTION OF MORTGAGE--You mayor X may not sell
or transfer your home to a buyer or transferee who will assume the mortgage
debt, provided that all the outstanding payments, charges and attorney'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.
FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE
THE ATTACHED LIST.
NOTE: Unless you notify this office within thirty (30) days after
receiving this notice, that you dispute the validity of this debt or any
portion thereof, this office will assume that the debt is valid. If you
notify this office in writing within thirty (30) days from receiving this
notice, this office will: obtain verification of the debt or obtain a copy
of judgment and mail you a copy of such judgment or verification. You are
also advised that any information which you supply to this office may be used
by us in the collection of the debt. If you request this office in writing
within thirty (30) days after receiving this, this office will provide you
with the name and address of the original creditor.
THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE.
SENT VIA REGULAR MAIL AND
CERTIFIED MAIL NUMBER Z 215 731 912
RETURN RECEIPT REQUESTED
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNERS' EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
Consumer Credit Counseling Service of Western
pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, Pa 17102
(717) 541-1757
Financial Services Unlimited
117 West 3rd Street
Waynesboro, Pa 17268
(717) 762-3285
Urban League of Metropolitan Harrisburg
25 N. Front Street
Harrisburg, Pa 17101
(717) 234-5925
FAX # (717) 232-4985
YWCA of Carlisle
301 G Street
Carlisle, Pa 17013
(717) 243-3818
FAX # (717) 243-3948
November 19, 1999
Mark A. Hickoff
2437 Mills St
Orlando, FL 32806
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on vour 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 (HEAP) mav be able to help to save vour
home.
This Notice explains how the Program works.
To see if HEAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the
Counseling Agencv.
The name. address and phone number of Consumer Credit Counseling Agencies serving vour County are listed
at the end of this Notice. lfvou have anv <;iuestions. you mav call the Pennsvlvania Housing Finance Agencv
toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869.
This Notice contains important legal information. If you have any questions, representatives at the Consumer
Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your
area. The local bar association may be able to help you fmd a lawyer.
LA NOTIFICATION EN ADJUNTO ES DE SUMA II\1PORT ANCIA, PUES AFECT A SU DERECHO A
CONTINUAR VNIENDO EN SU CASE. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA
(pENNS1'L VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR
SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCOUNT NUMBER:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Mark A. Hickoff
30 E. Keller SI.. Mechanicsburg. P A 17055
6901400157
Conseco Finance
Conseco Finance
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--Ifyou have not cured the default within the
TBIRTY (30) DAY period and foreclosure proceedings have begun, vou 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 bvpaving 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 Sheriff's Sale as specified in writing by the lender and bv performing
any other requirements under the mortgage. Curing your default in the manner set forth iu 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 from the date of this Notice. A notice of the
actual date ofthe Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default
will increase the longer you walt. You may fmd out at any time exactly what the required payment or action will
be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Conseco Finance
Address: 7360 Kvrene Rd.. Tempe. AZ 85283
Phone Number: 1 888 315 8733. Ext. 36239
Fax Number: I 480 333 6457
Contact Person: Harold Williams
EFFECT OF SHERIFF'S SALE--Y ou should realize that a Sheriff's Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the 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 mayor X may not sell or transfer your home to a buyer
or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney'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 Ai'N 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 BELlEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER.
- TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
FDR CDNSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE
THE ATTACHED LIST.
NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the
validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in
writing within thirty (30) days from receiving this notice, this office will: obtain verification ofthe debt or obtain
a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any
information which you supply to this office may be used by us in the collection of the debt. If you request this office
in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the
original creditor.
THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT ADEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THIS PURPOSE.
SENT VIA REGULAR MAIL AND
CERTIFIED MATI.. NUMBER Z 215 731 911
RETURl'f RECEIPT REQUESTED
','
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNERS' EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
Consumer Credit Counseling Service of Western
pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, Pa 17102
(717) 541-1757
Financial Services Unlimited
117 West 3rd Street
Waynesboro, Pa 17268
(717) 762-3285
Urban League of Metropolitan Harrisburg
25 N. Front Street
Harrisburg, Pa 17101
(717) 234-5925
FAX # (717) 232-4985
YWCA of Carlisle
301 G Street
Carlisle, Pa 17013
(717) 243-3818
FAX # (717) 243-3948
Z 215 731 911
us Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Do not us. lor International Mall See reverse
Benito k
Post OfflC6, State, & ZIP Code
Postage
$
Certlffed Fee
Spe,d'al Delivery Fee
"Restricted DellvelY Fee
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No Insurance Coverage Provided.
Do not use lor Internationel Mail (See revers&.
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Street & Number u
Pool Office, Slate, & ZIP Code
Postage $
Certified Fee
Special Delivery Fee
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SHE)'-! FF 'S RETURN - REGULAR
CASE NO: 2000-00044 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CONSECO FINANCE CORP
VS
HICKOFF MARK A
CHRISTOPHER EVANS Slieriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT c_MORT FORE
was.served upon
HICKOFF MARK A
the
DEFENQAl1T .
, a't 0018_:47 HOURS, on. the 5th day of January , 2000
at 30E KELLER ST
MECHANICSBURG, PA 17055
MARK HICKOFF
by handing to
a:rrue and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
anD at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit'
Surcharge
So Answer,,:
18.00
6.20
.00
10.00
.00
34.20
~._~:~.c~<!
R. Thomas Kline
,
Sworn and Subscribed to before
01/06/2000
MCCABE, aG &_ CONWAY
. By: ~~
. ., Deputy Sheriff
me this .J ,,1..A day of
.1.'-''''''-1 -2lT1JV .' A.D. .
..q, 'ft. - O. 7h,N, ...-iJirili
rothonotary
",_ T
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Bui1ding
123 South Broad Street, Suite 2080
Phi1ade1phia, PA 19109
(21S) 790-1010
Attorney for P1aintiff
CONSECO FINANCE CONSUMER
DISCOUNT COMPANY
V.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
MARK A. HICKOFF
NUMBER CV-00-44
Defendant
ORDER TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above-captioned matter discontinued and
ended upon payment of your costs only.
~
~
TERRENCE J. Me ABE, ESQ IRE
Attorney for P :"a-intiff
Fii FD--0ffiCE
O'f TI ,~-,r.;.^"\lun".!.^"\T^'RY
, \..1.:.1 "'.J'\')f'\J
03 OCT 2 3 PH 2: 14
CUM8ErilJND COUNT),
PENNSYLVANIA