The URL can be used to link to this page

Home My WebLink About00-00273 ~ . f:i,', ;' . . MARK J. UDREN &: ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort worth, Tx 76116 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 : NO. 2000-273 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 840 Erford Road, Camp Hill, Pa 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address GIGI MCDADE 840 ERFORD ROAD, CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. .L , . CHASE BANK OF TEXAS, f/k/a TEXAS COMMERCE BANK, N.A., AS CUSTODIAN, ASSIGNEE OF SAXON MORTGAGE, INC. 801 W. GREENS RD., HOUSTON, TX 77067 CHASE BANKOF TEXAS N.A. ONE RIDGMAR CENTRE, 6500 W FREEWAY, STE 400, FORT WORTH, TX 76116 5. Name and address of every other person who has any record lien on 'the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address REAL ESTATE TAX DEPT. 1 COURTHOUSE SQ., CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER ST., CARLISLE, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the. property which may be affected by Address Tenants/Occupants 840 Erford Road, Camp Hill, Pa 17011 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. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: February 23, 2000 I Mark.~. Udren, ESQ. Attorpey for Plaintiff STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } ss. Robert P Ziegler I, ________________________________________ _______________ _______________________ Recorder of needs in and for said County and State do hereby certify that the Sheriffs need in which hhU______h__ Chase Bank of Texas N A fka Texas Commerce Bank N a _______n_____hu__n_____ ____hh__u___n__n n_________h___h___________n_____ is the grantee 6th the same having been sold to said grantee on the _n____h_______uh_n______________h__n____ day of Ii I t I I I Ii h____~~!'_t.':.~~~_':.__hh_________________ A. n., HE{~_Q.QQ__, under and by virtue of a WriLh_h___h__ Execution . 29th __n_____hnn____h______n_______________hU Issued on the ______un____h____h__________n___ Feb lQ<2000 . day of _n_h___nn_____________ A. n., 1:3______, out of the Court of Cornman Pleas of saId County as of _______n_~~yi_J__hnnnn___m________h_h____ __________h________U__U____h_ Term, amQO__ Nuhlbl,r ______________, at the suit of ___<::!>_'!.~~_1l_'!.'!1c_2J:_!.!'_"-'!~__~'!_J_~'<:i!!l__QQ!!J!Il_e_J::~.!'__l!<!glUL!i___ ______m_________n____h___h____ againsL________n____~~~~__~:~~_<!.~m_______________m__ is duly recorded in Sheriffs need Book No. _~~_~_______, Page _6_~~n______. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this __~~__h day . ___u_____n_ Ai" r2l!~__ ~4J. . _.&_~.;- ;-;;;0;;;. R8conIer of Deeds. Cumbertand County, Cartisle, PA My Commission Expires the first Monda, of JaIl. 2002 ~~ "~ .J ... liilllllitm: Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, N.A. Custodian One Ridgmar Centre -vs- Gigi McDade In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-273 Shawn Harrison Deputy Sheriff, who being dilly sworn according to law, says on March 28, 21100 at 4:00 o'clock P.M.EST, he posted a copy of Real Estate Writ Notice Poster aIid Description on the property of Gigi McDade located at 840 Erford Road, Camp Hill, Cumberland County, Pennsylvania according to law. Shawn Harrison Deputy Sheriff who being duly sworn according to law, says on March 28, 2000 at 4:00 o'clock P.M. ESTR, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Gigi McDade, by making known unto Gigi McDade at 840 Erford Road, Camp Hill Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the aid true and attested copies of the same. R. Thomas Kline, Sheriff, who being dilly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant Gigi McDade at he last known address 840 Erford Road, Camp Hill, Pennsylvania. This letter was mailed under the date of March 29, 2000 and neverreturned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being dilly sworn according to law, says that after due and legal notice had been given according to law, exposed the above described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania, on September 6, 2000 at 10:00 o'clock A.M. EDST, and sold the same for the sum of $ 1.00 to Attorney James Flower, Jr. for Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, N.A. as custodian. It being the highest bid and best price quoted for the same Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank. N.A. as custodian of 4708 Mercantile Drive, North, Fort Worth, IX being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of$ 753.99 it being costs. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Postpone sale Law Journal 30.00 14.80 15.00 15.00 30.00 10.00 .50 1.00 9.92 .86 15.00 20.00 20.00 270.05 Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 225.56 24.80 25.00 26.50 $753.99 Pd By arty 10/03/00 Sworn and Subscribed To Before Me This/t.!b Day of (Pe.~.u _ .. .. . ./ /.;/ q - ,O~r".~.IHllr~~~~~~: 1/~~ 2000. AID. . .0. lk, tlhJ VJr" J'!f1lJ.~ ::r r~(motary I R. Thomas Kline, Sheriff ByfiLn jJdi Real Estate Deputy '.'4&': ~ ~. 3D'oJ pi> r:Jz... J 99c;<f Ru- /0.2 'f,Jf ^-^ , '~1!I;; Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, N.A. Custodian One Ridgmar Centre -vs- Gigi McDade In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-273 Shawn Harrison Deputy Sheriff, who being dilly sworn according to law, says on March 28,2000 at 4:00 o'clock P.M.EST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Gigi McDade located at 840 Erford Road, Camp Hill, Cumberland County, Pennsylvania according to law. Shawn Harrison Deputy Sheriff who being dilly sworn according to law, says on March 28, 2000 at 4:00 o'clock P.M. ESTR, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Gigi McDade, by making known unto Gigi McDade at 840 Erford Road, Camp Hill Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the aid true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant Gigi McDade at he last known address 840 Erford Road, Camp Hill, Pennsylvania. This letter was mailed under the date of March 29,2000 and never returned to the Sheriff's Office. R. Thom~s Kline, Sheriff, who being dilly sworn according to law, says that after due and legal notice had been given according to law, exposed the above described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania, on September 6, 2000 at 10:00 o'clock A.M. EDST, and sold the same for the sum of $ 1.00 to Attorney James Flower, Jr. for Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, N .A. as custodian. It being the highest bid and best price quoted for the same Chase Bank of Texas, N.A., Vk/a Texas Commerce Bank. N.A. as custodian of 4708 Mercantile Drive, North, Fort Worth, TX being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 754.99 it being costs. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Postpone sale Law Journal 30.00 .14.80 15.00 15.00 30.00 10.00 .50 1.00 9.92 .86 15.00 20.00 20.00 270.05 Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed Sworn and Subscribed To Before Me This_Day of 2000. AID. Prothonotary -. - 226.56 24.80 25.00 26.50 $754.99 Pd By arty 10/03/00 SO~~A"t:~ R. Thomas Kline, Sheriff BY~~/<I /t7L Real Estate Deputy , .-~ ~ \l:liMID,LI /. < ~ '-. ~. " ~- '...-' . ' .' . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 . COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 : NO. 2000-273 Defendant(s) N.QTI.CE OF SliERIFF' S SAL~QE'.Jl.EAlL.EROl'ElU'.Y TO: GIGI MCDADE 840 Erford Road Camp Hill, Pa 17011 Your house (real estate) at 840 Erford Road, Camp Hill, Pa 17011 is scheduled to be sold at the Sheriff's Sale on June 7, 2000, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA, to enforce the court judgment of $69,624.29, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE O~R'S RIGHTS ruU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take ~diate a~~o~ 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (609) 48~~. mortgagee the back payment, late To find out how much you must pay I 2, You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was 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. more chance you will have of stopping the sale. to obtain an attorney,} The sooner you contact one, the {See notice on page two on how / - -----<-'- - .. YOU__.MAY_ STIL~BE ._ABLE._ TO_SAVE._YOUR_PROPERTY AND30U_..HAVE.._O.THER.. RIGHTS EYEN._IF_THE-SHERIFJ1'-'-S_SALE__DQES._TAKE._PLACE . 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 609-482-6900. 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 609-482-6900. 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid 'for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, pa 17013-3387 717-249-3166 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 ~ /'...'.. ;&0',,"_ . ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY BY ERNEST J. WALKER, PROFESSIONAL ENGINEER, DATED APRIL l, 1976, AS FOLLOwS: BEGINNING AT A POINT ON THE SOUTHWESTERN LINE OF ERFORD ROAD AT THE LINE OF DIVIDING LOTS NOS. 13 AND 13X ON THE HEREINAFTER MENTIONED PLAN OF LOTS, SAID POINT ALSO BEING 192.50 FEET IN A SOUTHEASTERLY DIRECTION FROM DAVID DRIVE; THENCE ALONG ERFORD ROAD SOUTH 46 DEGREES 50 MINUTES EAST 37.5 FEET TO THE LINE DIVIDING LOTS NO. l3X AND 14; THENCE ALONG THE SAME SOUTH 43 DEGREES 10 MINUTES WEST l05 FEET TO A POINT; THENCE NORTH 46 DEGREES 50 MINUTES WEST 37. 5 FEET TO THE LINE DIVIDING LOTS NOS. 13 AND 13X; THENCE ALONG THE SAME NORTH 43 DEGREES lO MINUTES EAST l05 FEET TO THE POINT OF BEGINNING. BEING KNOWN AS 840 ERFORD ROAD PROPERTY TAX PARCEL NO. 09-17-1044-043 TITLE TO SAID PREMISES IS VESTED IN GIGI MCDADE BY DEED FROM PIN HUI KUO AND KUEI YING KUO A/K/A YING KUEI KUO A/K/A WANG KUEI YING, DATED l2/18/l997 AND RECORDED 12/26/1997 IN DEED BOOK 169 PAGE l104 ~ /..."... . . '" '" ll'- . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 2000-273~ CIVIL fg{ Term CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Chase Bank of Texas, N.A., f/k/a Texas Cormnerce Bank, N.A., as custodian One Ridgrnar Centre PLAINTIFF(S) Gigi McDadQ, Q40 Erford Road, Camp !lill, PA 170n from DEFENDANT(S} (1) You are directed to levy upon the property of the defendant(s) and to sell See Leqa1 Description (2) You are also directed to attach the property of the defendant(s) not .Ievied l,Ipon 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/are enjoined from paying any debt to or for the account of the defE1ndant(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 nomy him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due 7~q 864 ?q from 2 47 to 6/7/00 Interest @ 21 20 - $?, 22'> 00 Atty's Comm % Atty Paid Sl09. 92 Plaintiff Paid LL $ "0 $1 on - per diem Due Prothy Other Costs Date: February 29, 2000 Curtis R. Lonq Prothonotary, Civil Division br--AO-'"Jo" ~ . P 7pcn/?~J--- Deputy REQUESTING PARTY: Name Mark J. Udren, Esq. Address: 1040 N. Kinqs Hiqhway, Suite 500 Cherry Hill, NJ 08034 Attorney for.: Plaintiff Telephone: 609-482-6900 Supreme Court ID No. 04302 ~~~~"' :-~ !lI.~~i1JIj,gj""fj\'fJlllft . 'l'r"*MiilliiiiiWl~-'~~ '[lll~J^ ' :, .""""'" ~-~I-"'-"Ii:liillilMl -)j1iJ . REAL ESTATE SALE No}O . un/Pl~ I, ~ the sheriff levied upon the dEriendaOls interest in the real property situated in ~.....f L.-- J,c~ ~u ,..;:' Cumberland County, Pa., known and numbered as:<f~oE.~ (J."",./jL'fJ and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. fJate/J1/},;,u.ll. :J..."tz) By: t-t:;,,_AL2L- ~{;.ti 4i{,J .,.... . ," ( cr"tJ CLnJI CVil ~ <it) ~ I " THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under ReI No. 587. Rooroued May 16. 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and pubiished 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 and Metro editions/issues which appeared on the 2nd, 9th and 16th day(s) of May 2000. 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 au h' in MisceOaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #30 Swor A.D, Notarial Seal Terry L, Russell, Notary pubr Harrisburg. Oaup/lifl Cou My Commission Expires June 6, 2 2 NOT Y PUBLIC Member, Pennsylvania AssootatiOnM)NlllallIlmission expires June 6, 2002 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) $ T~~ $ 224.06 1,50 225.56 " Publisher'S Receipt for Advertising Cost. 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. THE PATRIOT-NEWS CO. By.....,.,.,.......,.,.,.........,.,.,.,.......,.,..........,...,..... REAL ESTATE SALE NO. 30 Writ No. 2000-273 Chase Bank of Texas. N.A.. f/k/a Texas Commerce Bank, N.A., as custod1an One Ridgmar Centre vs. Glgi McDade Atly.: Mark J. Udren ALL THAT CERTAIN piece or par- cel ofland situate In the Townshlp of East Pennsboro, Cumberland CoW1ty, Pennsylvania, more particularly . bOW1ded and described in accordance wlth a SUlVey by Ernest J. Walker, Pro- fessional Englneer. dated April I. 1976, as follows: BEGINNING at a pOint on the Southwestern !lne of Erford Road at the !lne of dlviding lots nos. 13 and 13x on the hereinafter mentioned plan of lots. sald point also betng 192.50 feet in a Southeasterly dtrec- tlon froni David Drive: thence along Erford Road South 46 degrees 50 mlnutes East 37.5 feet to the llne dlvlding lots no. 13x and 14; thence along the same South 43 degrees 10 mlnutes West 105 feet to a point: thence North 46 degrees 50 minutes West 37.5 feet to the llne dlvlding lots nos. 13 and 13x: thence along the same North 43 degrees 10 minutes East 105 feet to the point of begln- nIng. BEING KNOWN AS 840 ERFORD ROAD. PROPERTY TAX PARCEL NO. 09- 17.1044.043. TITLE TO SAlD PREMISES IS VESTED IN GlgI McDade by deed from PIn Hul Kuo and Kuel Ymg Kuo. a/k/a Ylng Kuel Kuo, a/k/a WangKuel Ylng. dated 12/18/1997 and record- ed 12/26/1997 ill Deed Book 169 Page 1104. ,',,-, ,', "'"' ' - ~. - PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 i !" STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : , , I I' Ii !, I I Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being du1y 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 regu1arly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: APRIL 28, MAY 5,12,2000 Ii 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. SWORN TO AND SUBSCRlBED before me this 12 day of MAY. 2000 NOTAIlI q LOIS E. SNYDER, Notary.Public Ca<lisl. Bora, Cumberland County, PI< My Commilllion Expi.... March S, 2001 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 Defendant(s) : NO. 2000-273 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff I s Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest per Complaint From 01/12/00 to 02/23/00 Late charges per Complaint From 01/15/00 to 02/23/00 Escrow payment per Complaint From 02/01/00 to 02/23/00 $68,542.08 911.60 68.04 102.57 TOTAL $69.624.29 I hereby certify that (l) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.l, a copy of whiCh is attached hereto. Mark Attor SSOCIATES MARK dren, ESQUIRE for Plaintiff DAMAGES ARE HEREBY ASSESSED DATE: "):;.J.. ~~ :;;'000 ASI;~. .~ 07~)k.. PRO ROTHY _~~"~-F-"''''''''''''''' . ~w '-rnbHJUlfij.~'~l~:IiK "'".'~;'" ' >':1 .~...~--- -..""'~ CA:J(:J~ ~ fk- ~ ~ ~ -{) ~ 8 J~~~ r: ~ c) s 52E~.; '"-'6 -< c::: ,', '.s:C> 5~:: :z: -< ,~" , : Q C~,.i -,.., ,.::;; ~'0 \.D 'co.J i~, .~ t.c) ':J m , "~ ~~ . ~. 1 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 Defendant(s) NO. 2000-273 DATED: TO: USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEB IDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAI!lIED WILL BE USED FOR THAT PURPOSE. &Il~ililil.li8J~ "-"'"'!;Jllfja~ - ~,-...~, '''''Ii!II!ll\!II1:i~ H' ~~ ......., _ ,i" ,,~~~, ---,""-'- 2t?:' Z::C' ~f:~i, P,- ?E~ =J -< C) C <..~ '-' c:-:,. -'1 n"'; ct::;I r'V ~,.~) ~~ ,=> ,,- " ' . , ., """- MARX J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2000-273 v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF SS COUNTY OF THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Gigi McDade Over 18 As captioned above Unknown Sworn to and sUbscribed before me thi 23rd day of b 2000 Name: Title: Company: MARK J. WREN, EEl:;!. ATTORNEY FOR PLAINTIFF -. ., ,. , " . .,'-..1 ;',' _'--,' - , ;',NOTARb\ki1~Al< , NICOLE',M,' MENOW,iNOtary PublIC City of Ph\laderp~la.Phila County My Commission Expires Auo. 23, 2003 iIilii__GnJ ~I-"""""" 1P&l1Ul~",. ~^'~~""''''.w<.l;J_"''''~ '""' '..... "~ - (') ~-; <. ~t7~: 2:~:-~' ;Z:r:~- ~:~ ~~i ~h z :< ~~ "'" ~.' . . ~. c,::' ~'1 :~~.'\ ~," ~"0 *4'",' c.,:.' (}"j , - - ,I MARX J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 : NO. 2000-273 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: 840 Erford Road Camp Hill, PA 17011 Amount due $69.624.29 Interest From February 24. 2000 to Date of Sale June 7, 2000 Per diem @$21.20 2.226.00 (Costs to be added) $ MARK J. UDREN & ASSOCIATES dren, ESQUIRE FOR PLAINTIFF ..~'''''''~' ~. ~-'--""._~IiiilJlIiIIIiI1~""'-""'" 'L~~!;I!W~li!iI;~~.",,"""""i'" ~' -:AI -';"',.c ~~'~iI* ~J ,'~. ~~ ~'J:!l;Id.--<lA .... p(::, ""- ~ ~~ () Vv~ ~ .ltl -...) ~ ;-C ,0) ~'i . :- .(\ '" () --C c.,~6 o 0 ..0 - 0 D /0 () ~ C) \) ~ , , \ g , r-f? r~ ~ r- ~ , '""' "'- , ~ , , .., ~ ... o ~ !~~~~i_:': -.-,': 65 ~-~~: ~;~~: ~;::? ):>~; :::; -< " ,-, L ~, 'i!,J --:--1 :'.j (::;) (j1 , .- , ," '" ,~.. ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY BY ERNEST J. WALKER, PROFESSIONAL ENGINEER, DATED APRIL 1, 1976, AS FOLLOwS: BEGINNING AT A POINT ON THE SOUTHWESTERN LINE OF ERFORD ROAD AT THE LINE OF DIVIDING LOTS NOS. 13 AND 13X ON THE HEREINAFTER MENTIONED PLAN OF LOTS, SAID POINT ALSO BEING 192.50 FEET IN A SOUTHEASTERLY DIRECTION FROM DAVID DRIVE; THENCE ALONG ERFORD ROAD SOUTH 46 DEGREES 50 MINUTES EAST 37.5 FEET TO THE LINE DIVIDING LOTS NO. 13X AND 14; THENCE ALONG THE SAME SOUTH 43 DEGREES 10 MINUTES WEST 105 FEET TO A POINT; THENCE NORTH 46 DEGREES 50 MINUTES WEST 37.5 FEET TO THE LINE DIVIDING LOTS NOS. 13 AND 13X; THENCE ALONG THE SAME NORTH 43 DEGREES 10 MINUTES EAST 105 FEET TO THE POINT OF BEGINNING. BEING KNOWN AS 840 ERFORD ROAD PROPERTY TAX PARCEL NO. 09-17-1044-043 TITLE TO SAID PREMISES IS VESTED IN GIGI MCDADE BY DEED FROM PIN HUI KUO AND KUEI YING KUO A/K/A YING KUEI KUO A/K/A WANG KUEI YING, DATED 12/18/1997 AND RECORDED 12/26/1997 IN DEED BOOK 169 PAGE 1104 ~ -^. ' ~17 ~"~ , -' . .d... '""0' " MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Chase Bank of Texas, N.A., f/k/a, Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 :NO. 2000-273 Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above ~matter is based on an Action: ~. In Assumpsit (Contract) ----B. In Trespass (Accident) ~C. In Mortgage Foreclosure _D. On a Note accompanying a purchase money mortgage and th", property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: --lLA . _B. _C. _D. _E. F' -' An individual Tenants by Entireties Joint Tenants with right of survivorship A partnership Tenants in Common A corporation III. The Defendant(s) is (are): --lLA . _B. C. Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of Pennsylvania If more than one Defendant and either A or B above state which Defendant is resident of the Pennsylvania: Resident: is not applicable, Commonwealth of ESQUIRE # as above .r~' ~ ~> Jl -'~-"~M~ ",~"~ ,- '"~",&if!,I:"'i,]",,;!!liiL41l~__i. .~,.... rl^ ~ ~- u'~... , ,'." - .L... "',","""I~~" -1li:iI ;:n L ~. c -~ C:~~ ,~ .'-.. .-, ~~ -< "' !,,;' tJ..::, --"3 :::::> ~.,"",! ;~ '~ ~ i, ^ "' '.h- ~ MARK,J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 : NO. 2000-273 Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for. the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ASSOCIATES dren, ESQUIRE FOR PLAINTIFF __1lilll",~iII""'~""'."''''''"'''''''''''"~'-'"~'c..; -' -'ltM'wJ,f111I.\ii"-"m-~i:lll;illi!!l,' "'...'~ '"""'~"'" JIilulilJlinlQllll~ . , ~~~ -ofCr S2L--: 2~ (/) ;:s; ~~:.: Pc': :;:::: -i -<. C) S._:;; '.-,",-~ 0_' C~,. .~ I',) u:.) ("J ::.? .....j . ~'-! ^ , 'MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 : NO. 2000-273 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank,N.A., as custodian, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 840 Erford Road, Camp Hill, Pa 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address GIGI MCDADE 840 ERFORD ROAD, CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. ~ ...........'.....~ . , , 'CHASE BANK OF TEXAS, f/k/a TEXAS COMMERCE BANK, N.A., AS CUSTODIAN, ASSIGNEE OF SAXON MORTGAGE, INC. 801 W. ~REENS RD., HOUSTON, TX 77067 CHASE BANKOF TEXAS N.A. ONE RIDGMAR CENTRE, 6500 W FREEWAY, STE 400, FORT WORTH, TX 76116 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address REAL ESTATE TAX DEPT. 1 COURTHOUSE SQ., CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER ST., CARLISLE, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the, property which may be affected by Address Tenants/Occupants 840 Erford Road, Camp Hill, Pa 17011 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. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN & ASSOCIATES DATED: February 23, 2000 . Udren, ESQ. ey for Plaintiff Mark Atto , ~~~~ ,-.""......""~ ~~ "~,'IlU<H;!iI}.i:!kM""'I<Gi!~,.1Iw:a:.,iL_~~ - .. 1IlIl-~"-.V. ,_~_...='CM' .....~~ . ",..I 0 " C , ., -" -0 C',; :rl m '~~ j i:TJ ~ -~-:: ."J cr;~ \,D , r:' C:. -:1 :t-: C) .' :> C.I .' -, :~) C k,A,' 3 :--<j => ~o ~, ..,j -< '-, , , , . ~ ~ J _ ~:' ~ ! ;'! , , . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Chase Bank of Texas, N.A., f/k/a Texas COmmerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County , , : MORTGAGE FORECLOSURE Plaintiff v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 : NO. 2000-273 " ~ i ,I Defendant(s) NOTIClLO~ER~S SAL~~A~QURTY TO: GIGI MCDADE 840 Erford Road Camp Hill, Pa 17011 Your house (real estate) at 840 Erford Road, Camp Hill, Pa 17011 is scheduled to be sold at the Sheriff's Sale on June 7, 2000, at 10:00 AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA, to enforce the court judgment of $69,624.29, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. ROl'LClLQF OWNER'S RIGIiT.S YQU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take ~adiate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (609) 482-6900c mortgagee the back payment, late To find out how much you must pay, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was 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. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how . , . YOU--.MAY_ STIL~BE_AaLE._ TO.SAVE.YOUR, PROPERTY AND._y'QtLHA~O'I'HER_RIGHTS E'lEN._IF...THE.-8HERIF.F_'-S_SALE..DO.ES_TAKE.._PLACE . 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 609-482-6900. 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 609-482-6900. 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. S. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, pa 17013-3387 717-249-3166 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, pa 17013-3387 717-249-3166 ." . ,- "~- I I I i I I" , I i: , ii' i r I f I I I I I' , 'I l4iill~~''"'"'''~'''''~'~'lili!iiiilIIil-'~',,"-,"'~~O~" J!(!MiP'illlWlli'~~;ljfrW:1i!ilf r~"~~" '-" ""'. - "'. -0 ~t~ q;!~- ~~." -< r:: ~~~ --i -< o :::.,;:;:; . " , . f"'-.) ~_D C,) .:::> .-....J :"0 -< . ~ ~ ~ _~OO ~,~=_" ~ ,',,_~, .._ J 0[; , MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY 1.0. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 Plaintiff - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 Defendant(s) : NO. 2000-273 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.p.RULE 3129.1 Plaintiff, by itS/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was' signed for by Defendant (s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: May 24, 2000 MARK J. UDREN & ASSOCIATES BY: '-I'i\ Mark J. Udren, Esquire Attorney for Plaintiff "- " MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6.900 Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar C~ntre 6500 West Fre~way, Suite 400 Fort Worth, Tx 76116 ! Plaintiff v, Gigi McDade 840 Erford Road Camp Hill,. Pa 17011 Defendant(s) , DATE: March 3, 2000 ,j, >>' ~ ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2000-273 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE Q~AL.-12RO-EERTY OWNER(S): GIGI McDADE PROPERTY: 840 Erford Road Camp Hill, Pa 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the ~umQ~and County Sheriff's Sale on ~~e~~QQQ, at 10:00 AM, at the CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the f~ling of the schedule. EX/-"-- 1\ , '. ~' , -~ - 'I;' ~" .'. For Accountable Mail ~. . o~_ ~ ~--' . ~ '~ ~ ~ ~ '0 J1 ... '" '" ~ <D CD .... ./ ' / 'V4/~4jJ , \ , I i I , / / 1/ / (J) 01 ~ W f'V ->.. g ;6:~ (D 5tm t::? ::Jmm r: tig:::J C/ T ~ n(e \ " \'\ \ ~ 111 7J!o~gf It '6> ~ ~~ \ ... ii -1=", Jf';<;' 0+> 0 fi., ?~~ 1 ~" o 1-"7 'l>,.. 0 r 6 a T"it ;::>!'- f !?~~ ~ ~ ;: m,. ~~ '" ' ;;:: c: r rrf~~fg-h~..,~-,l~ f~ ~:.rn;:<;o~ .., ~rZL-": :;;:.,,;? ~ ,,~m. czjg.. ~~%~/' e "f, ~~~~ ~j ~~;;~ ~1 Of ("~r:r;''^ ~.? ". ~~ ~; ~~"'5, [;hI' "10,- Ii' r :pc- -:-I~!i-_ ~, c.?G)CDm "fD~l.lrp 0'" (!1~~S."':1 :t:fgttl ('5/.-& ;5~~t"~"H- il ~Q o ....e. U rt ..c .y ~ ::<~ :P {>0r:t 8 cev ;, '-I " :J'f.: 1'-1? l"" 1""- '.':f> ~ 1i m "'" ~:::. cr ~in-2" ~ ~ 1~~f ~~, ~ 1-~~~ ~ ;oQlCL- '-n ~f~:i, i 'F-~~,.J~,? ~ i~~~ ~ F ~~ ~ :) ;:;::\ ~ I~~ .:g ~r;b i;~ ~ ~~n C*, L;S: ~_ijJ ::. J,~ "t ~, t::-- '" ()' ~f-' ' , 1/ I' I / J II / .' , . . , , I. 'v -. .IFe 9D .IOr89 ;n,~: -. ;;;j;\,::::!~::H') Vw '~O,,'" 0" 8d u ! ~ ~ ~......- ~.;k': 'J,~ * .>'. .> '-1--.:.<;c ~;J..!:~-~' L L < ;) :z g ~ 9 c r , ~ L.. !. .. .,. ~" I H HUla. 00:) :05' CD OUl CD ll.> ~O@~~ \. (f) a.CD'< ~ -~ mm ~O DD D3 m3"0':Id1f: -0 ~ _... 11l ij; I@ ~:i:E: iii UI (I) ~:) ~ ~Q~ffil ~.g.a.2 o._.i:j. 'O~- !'- -n m m (')::I: DD:n 0 ::rill CD '::l" Ill:) ~ < to CD ~~~~![~ lC g -0 ~.al .... 0 CD ..... > -o!!1 o.~ :I)p. ~ =~.g ~,~ ~ 11: ~ ~. 1ii'i: ~ ~ CD __lll C:;:! 0- ~ 2 g - 2 ^ ~~ Q c~ mil. "iJ 1llC'l:;t> 2 9 2;~sr _CD .." ...._ C100 3' o'o'!!l. Olll Q) ;:!ellll '0:) ~ ~lll3 ~m :>t C'lo'O ... Q) .g-::r ~ ro'~~ :0 Q. UI _.CD ;p. t:J oS';O: CD:I)D:I ~Ui' , (i 2:Q~ 0l(J) Q. ~O'~ m 0 :0 ~.... el , " C 0l(J) ~. m~ - :0 :o~ m ~ 3 " ~ ~ ^ ' . -n m m "' , . ','~",,,:, ., :'c', / ":<'-;i,~,;:j. _. , ' . ;2"...1'" .,.~ .~.. .., O:':_'~j ...:';~: :T':h.::. '" ~~i~l+';'''';''~~-}~;J;~~~:&;:N!b': '.'"." ""'>-v' . . ~~~jU~Iii'lilil:liII~.;tIlIi"~7'f ". ~~;"~""'''''M,.~kt~@B:&!~o;;-''''''''~ ^~ ,~-, ~~ ....;, .~' , . .. ~~ () 0 Q ~ ~ 0 .1 ::II: :;:! ~! ;po -< r-'''-i~ ,,- r- ~ W "Qr'ti ~O 0 stb ~o '"0 -,,--.-, 3;. ~.::n c'?li: ~~ ~ Z' 5' ,~ U'l -< ~;- SHERIFF'S RETURN - REGULAR CASE NO: 2000-00273 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE BANK OF TEXAS NA ET AL VS MCDADE GIGI DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MCDADE GIGI the DEFENDANT , at 0017:45 HOURS, on the 18th day of January 2000 at 840 ERFORD ROAD CAMP HILL, PA 17011 by handing to GIGI MCDADE a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.92 .00 10.00 .00 37.92 ~~~~ R. Thomas Kline Sworn and Subscribed to before 01/19/2000 MARK J. UDREN By: ~~ o '/YJ""~ Deputy eriff ~ me this ,,1...-.-.( day of .J~~ ,,2bv1J A. D. 9*~th~~/~~ >=, " i. ,-, . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, Tx 76116 Plaintiff ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Gigi McDade 840 Erford Road Camp Hill, Pa 17011 Defendant(s) : NO. ~DOO - ~l3 ,CKh'[ ~ COMPLAINT IN MORTGAGE FORECLOSURE 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 ~re 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 t,he plaintiff.. You may lose money or property or other rights important to you. YOU SHOULD TAKE TH~S PAPER TO YOUR LAWYER AT ONCE. A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU DO NOT HAVE THE OFFICE SET FORTH LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 ~",,"=-, ";,.' .'1 ,I II , I I I A'lISO Le han demandado a usted en la corte. si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir dela fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos import antes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONCE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 717-249-3166 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 3.0 days after receipt of this Notice and the attached document that the validity ofthe stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against yon, and mail it to you. If you do not di~pute the debt, it is not an admission of liability on yonr part. Also, upon your written request within the 30 day period, we will provide you with the name andl address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once' we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/ Mark J. Udren, Esquire 1040 N.Kings Highway, Suite 500 Cherry Hill, NJ 08034 (609) 482-6900 ,-- ~ ~, '., -' ~; " __, I ' ," ~ ~ 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Saxon Mortgage, Inc. Assignee: Chase Bank of Texas, N.A., f/k/a Texas Commerce Bank, N.A., as custodian Recording Date: 12/2~/97 Book: 565 Page: 371 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3 . On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g) . The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 840 Erford Road MUNICIPALITY/TOWNSHIP/BOROUGH: East Pennsboro Township COUNTY: Cumberland DATE EXECUTED: 12/18/97 DATE RECORDED: 12/26/97 BOOK: 1423 PAGE: 978 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 1/11/2000: Principal of debt due and unpaid Interest at 13.75% from 5/1/99 to 1/11/2000 (the per diem interest accruing on this debt is $21.20 and that sum should be added each day after 1/11/2000) $56,266.81 Title Report 5,427.20 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $102.57 and that sum should be added on the first of each month after 1/11/2000) 191. 81 Late Charges (monthly late charge of $34.02 should be added on the fifteenth of each month after 1/11/2000) Other Fees Billed 713.42 2,599.50 Attorneys Fees (anticipated and actual to 5% of principal) TOTAL 2.813.34 $68,542.08 7. The attorney's fee 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 in accordance with the reduction provisions of Act 6, if applicable. 8. Notice of Intention to Foreclose under Act 6 of 1974 of the Commonwealth of Pennsylvania is not required as the original principal ~'~ L_. -~ '"" amount exceeds the sum of $50,000.00. The notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has been sent as required on the date appearing on the copy attached hereto as Exhibit "A", and Defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $68,542.08, plus interest, costs and attorneys fees as more fully set forth in the complaint, and for foreclosure and sale of the Mortgaged premises "' Mark dren, ESQUIRE MARK ~. UDREN & ASSOCIATES Attor ey for Plaintiff Attor ey I.D. No. 04302 - - ~ j '-;:,"'e...;:':' ... ~': , , ..,~' , , .;; I I, I I i I I I I --- .." '.,< .....' .. AU. THAT CERTAIN piece or parcel of land situate jn the Towhsh;p of East Pennsbofo, Cumberland County, Pennsylvania, more particularly bounded and described in ac~ordance with a survey by Ernest J. Walk.er, Protessio~a[ Engineer, dated April 1. 1976. as follows: . . . '. Beginning t a p~jnt o'n'the Southwestern line af E;fo~d Road at tJ;le lina at dividing Lots Nos. 13 and 13X on the hereinafter mentioned Plan of Lots; said point also being 192.50 feet in a Southeasterly direction from David Drive; thence along Erlord Road South 45 degrees 50 minutes East 37.5 feet to the line dividing Lars No. 13X and 14; thence along the same South 43 degrees 10 minutes W~st 105 feet to a point; thence North 46 degrees 50 minutes West 37.5 feet to the Iin,d"Mdfng Lots Nos. 13 and 13X; thence along the same North 43 degrees 10 minutes East 105 fee.t to the po-int of BEGINNING. ' BEING Lot No. 13X on Plan No. 18 of Ridley Par!c as recorded in {re f:umberland County Recorder's Otfice in Plan Book21,Page97. " ' HAVING THEREON ERECTED a dwelling hOlJses known as No. ~40'Eriord Road. , ' .. BEING THE SAME PREMiSeS. which Ronald A~' aOd Joann'~ T.~ Sei'lhamer by deed dated April 24, 1987 and recorded April 24, 1987 in the Recorder of Deeds.Off,icj!! in al]:i f9rCumberland COl,lnty. Pennsylvani4 in Oee,d Book. P. Volume 3Z. Page 853 conveyed unto Pin Hui Kuo and Ku:e\ Ylrv:] Kuo alk/a Ying Kuei Kuo aSkla ytang )(uai YinG'" - , . t ~ , " h--' '" ~. . '<11; ",,, " , " ..., " ~',. ,:.-...' ,." ~ -. L-._~,~ ~'. "~" ..,7:, '.... () Date: August 9, 1999 " " ACT 91 NOTICE TAKE ACTION TO SAVE Y0UR-IIOME-FROM ---- FORECLOSURE . - 1.1' ~_ " , . This is an official notice that the mortgage on your home is in default, and tne lender intends to foreclose. Specific information about the nature of the default is provided in the attached pae:es. "'. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save YOur hame. This Notice explains how the program works. To see if HEMf\P can help, you.must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TIDS NOTICE. Take this Notice with you when you meet with the Counseling Agency.' The name address and_ hoile.number of Consumer.Credit Counselina Agencies serving your County are' 'sted 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 Cop-sumer Credit Counseling Agency may be able to help explain it. You mayalso want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUlVIA IMPORTA1~CIA, PUES AFECTA SU DERECHO A CONTlNUAR VIVIENDO EN SU CASA. SI NO COlVIPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAiVIENTE LLAMA_i'WO EST A AGENCIA EXHIBIT j. EXHlBXHllalT A Page I of 6 ~~ - L T' ,SJ'?l ......;... . (PENNSYL VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO .ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Gig McDade PROPERTY ADDRESS: 840 Erford Road, Camp Hill, Pa 17011 ,-"._...., -,------ . LOAN ACCT. NO.: 010012556 . ORIGINAL LENDER: Saxon Mortgage, Inc. CURRENT LENDER/SERVICER: ,Meritech mortgage Services, Inc. ~'. . . HOMEOWNER'S EiVIERG.ENCY MORTGAGE . ASSISTANt;E PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU' COMPLY WITH TIlE 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 cmCUMSTANCES BEYOND YOUR CONTROL, .' . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE P A YMEl'ITS, AND . . .. t,. ., ...... 'f . IF YOU MEET OTHERELI4tmILITYREQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA 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 crediJ counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGEN<J:Y 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 . , cou~.scl:n;; 0:;0".0;"0 ':~,o~ c: ,1;0 end oflhis 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 COllnn' in which the propertY is located are set forth at the end of this Notice. It is only oIecessary to schedule one face-to-face meeting, Advise your lender immediately of your intentions. Page 2 0 f 6 - iI~ItliIlllF-.....~. ",....... 2\,,'), . APPLICATION FOR lVIORTGAGE 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 ,t~e Homeowner's Emergency Mortgage, Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the , designated consumer,credit counseling agencies listed at the'end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FIL:E: YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO. NOT-FOLLOW THE OTHERTIME.PERIODS SET FORTH IN THIS LETTER, FORECLOSURE J\1AY 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 crite~ia,;'stablished by the Act. The Pennsylv':nia Housing Finance Agency has sixty (60) days to make a decisipn:after it receives your application. During that time, no foreclosure proceedings will be pursued agains,t you if YOU' have met the time requirements set forth above. You will be notified directly by the Pennsy\v~nia Housing Finance Agency of its decision on your .. , application. : , iiv,,,,: 11' i0u A,~J;; CURRENTLYXROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (Iryau have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) I'. " ~. " w~.~:-;..;.;....... .....;.,..'. ';>;{. '.- ~":':::::"'Y""""'",-<"","'" . ;:.~... >-m-:: ...'. ~. .""'. ...;+:""h:.Z';....... I HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to date) NATURE OF THE DEF A UL T - The MORTGAGE debt held by the above lender on your property located at: 840 Erford Road, Camp Hill, PA 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHE. Y\MORTGAGE PAYMENTS for'the following months and the following amounts are now past du~ , 3 payments @ $783.00 (6/99 - 8/99) $2,349,00 Late Charges/Accrued Late ?harges Due Other Charges (Miscellaneous Fees) $543.32. $2,316.95 TOTAL AMOUNT PAST DUE: $5.029.27 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot applicable): N/A " HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL A"'IOUNT PAST DUE TO THE LENDER, WlilCH IS S5,029,27, l_ Pa!!c 3 or 6 , . , ~ !' ,,', " C' ~ -?:) ,'-. -.'- . . ., 'p'.. ,,,.... PLUS ANY MORTGAGE P~'YMENTS AND LATE CHARGES WHICB~'ECOME DUE DURING mE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check. certified check or money order made payable and sent to: , Louis P. Vitti, Esquire LOUIS P. VITTI & ASSOCIATES, P.C. 916 Fifth Avenue Pittsburgh, PA 15219 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: N/A (DO NOT USE IF NOT APPLICABLE) IF YOU DO NOT CURE THE DEFAULT ,'7 If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends ti! exercise its rie:hts to accelerate the morte:ae:e 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 installme,t;lts; 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 morte:ae:ed propertv.' ~" >';-:- IF-THE MORTGAGE IS FORECLOSED UPON -- The ljlortgaged 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~'O0. 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 he required to PllY attorney's fees. OTf[ER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and other sums due under thetmortgage, 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 rie:ht to cure the default and prevent the sale at anv time UP to one hour before the Sheriff's Sale. You mav do so bv pavine: the total amount Then past due. plus anv late or other chare:es then due. reasonable attornev's fees and costs connected with the foreclosure sal and an. , other costs conne 'ted with the. heriff's Sale as s ecified in writin b the lender and b erfonnina an 0 er re uirements under the mort aae. Curing your default in the manner set forth in this Notice will restore your mortgage to the sa'me position as if you had never defaulted. EARLIEST POSSffiLE 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 approxim..ately 4-5 months from tbe date oftbis Notice. A notice of the actuall:fate of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the defalllt 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: Meritech Mortgage Services, Inc. One Ridgmar Centre 6500 West Freeway, Suite 400 Fort Worth, TX 76116 Foreclosure Dept. (800)874-9516 , " \ Pane 4 of Ii - - " _ i ,j ,~ <~): , EFFECT OF SHERIFF'S S~iE - You should realize that a Sheriffs Saj~\vould 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 may not be able to 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. (Please contact the lender to find out if this option is available to you under your mortgage and note.) - "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 Al'!Y THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE TI:IE MORTGAGE RESTORJtb'TO 1'HE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE1JEFAULT. (HOWEVER, YOU Db NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE,THAN THREE TIMES IN ANY CALENDAR YEAR.) - , . . '.. . TO ASSERT THE NONEXISTENCE OF ADEF AULT IN Ai'\IY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, ;/ CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY . REMAP Counseling Agencies in Cumberland County . .. L. ~ " cccs of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PAl 71 02 (717) 541-1757 Urban League of Metropolitan Harrisburg 2107 N. 6th Street Harrisburg, PA ]7110 (717) 234-5925 FAX (717) 234-9459 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (7] 7) 762-3285 YWCA of Carlisle 301 G Street Carlisle, P A ] 70 13 (717)243-3818 FAX (717) 731-9589 ~Pasc;5or'f) - r {Bl Community Action Commission of the Capital Region 1514 Derry Street Harrisburg P A 17<104 (717) 232-9757 FAX (717) 234-2227 .-, ;.-::,"\ ':',c"~.i Adams County Honsing Authority 139-143 Carlisle Street Gettysburg, P A 17325 (717) 334-1518 FAX (717) 334-8326 ..' ," '- ;' . .. [' ~ ! Pal..!c h 0 f n - . Ii !: i. i] i! -~------~,-,,--'---~--------- [i I; , " i !i i: i I,; " -... . V E RTF ~A T ION Mark J. Udren, Esquire, hereby states that he is the ~ttorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true.and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of plaintiff's-agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Udren, ESQUIRE UDREN & ASSOCIATES ! '-~~~6iIIiil" -", _~IIIiiI"'~ft6m "'~""'Ilill!lilir.!!"~"..':l- ~"" "-~, '-' ~l:W~i. II ~ ., - - ""-...... ~" ~ l Rl ~ ~ 8 0 0 B 0 .." ~ ~~ .~ , ---I 6 ~tf3 ~:: :-i:"T) () ~ inn; ~- !11j= -7::tJ -urn 0 ~~~ -"10 .-0 "- w :--3 t ::_~Q () ........ ( I !;;::r::J ." ;,c?d ~ ?o :3: 00 ..... ~ L-m >0 ~ =0 ':? 0. CY >c: ~ ...c:: ~ ~ 0 -< 1- r~ ~ ~ _ 0