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Home My WebLink About00-00337 ?" ""' , ~ ,_":O~-' ",_/.0:', ,/ ;",,,' :_"., "', k;~,~,;,.,,;,_ ~ '," ""'I ., FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO"'<O~"<- .337 CU;J T~ VB. JASON M. RUDA AND TANYA A. RUPA CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE Defendants THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOT ICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money 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 FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Carlisle, PA 17013 717-240-6200 Legal Services, Inc. 8 Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANPADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANPA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA PEMANPA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTEP CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS PERECHOS IMPORTANTES. LLEVE ESTA PEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. cumberland County Bar Association Carlisle, PA 17013 717-240-6200 Legal Services, Inc. 8 Irvine Row, Carlisle, PA 17013 717-243-9400 , - <,,-' ~, -,.- C~ __ ',__,_ -;c- ,- ~---_,,-,- "-,_ -d, _.." 1,J ", '~ , . \ FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING.FINANCE AGENCY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. JASON M. RUDA AND TANYA A. RUDA CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE Defendants THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for plaintiff ,.---~- ~~, 't.__,. '..z;, ..;.,;.",",./" ',r- 1-.,"_ .,""t.' -"-"'- ,: G-"~j FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2ovo- 35'7 ~ '1b- vs. JASON M. RUDA AND TANYA A. RUDA CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE Defendants COM P L A I N T 1. Plaintiff, FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust indenture dated as of April 1, 1982 ("Trust"), is a National Association with a servicing agent of Pennsylvania Housing Finance Agency, with an address of 2101 North Front Street, Harrisburg, Pennsylvania 17105. 2. Defendant, JASON M. RUDA, is an adult individual whose last known address is 139 BRIDGE STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. Defendant, TANYA A. RUDA, is an adult individual whose last known address is 139 BRIDGE STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. 3. On or about March 25, 1997, the said Defendants executed and delivered a Promissory Note ("Note") in favor of BROADVIEW MORTGAGE COMPANY ("Original Mortgagee") in the principal amount of $48,854.00, the proceeds of which were used to purchase a residential property located at 139 BRIDGE STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. A copy of the note is attached and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in _ .'-~.- _ ",.. " J'- ~ ',' ",_"_<",_,,,'.M~,~~_.,,- ,,,-,.,,,, ".:.'''''''1 the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1470, Page 9 conveying to original Mortgagee the subject premises. The Mortgage was re-recorded in the aforesaid County in Mortgage Book 1371, Page 607 on July 23, 1998 to include addendum. The Mortgage was subsequently assigned to MELLON BANK, N.A. and recorded in the aforesaid County in Mortgage Book 583, Page 450. The Mortgage was subsequently aS$igned to PENNSYLVANIA HOUSING FINANCE AGENCY and recorded in the aforesaid County in Mortgage Book 618, Page 606. The Mortgage was subsequently assigned to FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording. Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 139 BRIDGE STREET, NEW CUMBERLAND, PENNSYLVANIA 17070 and is more particularly de$cribed in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on September 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 47,575.80 (b) Interest at $8.99 per day from 8/1/99 to 2/1/00 (based on contract rate of 6.800~) 1,654.16 (c) Accumulated Late Charges 38.22 (d) Late charges at $12.74 per month for 6 months (e) Escrow Credit 76.44 335.79 ." "'-0'_ ,__ ," '-'~~'~",~-_."",,-,, e_ -, """"'"T'-~'''''"~' ' U -';'i ~ (f) 5% Attorney's Commission 2,378.79 $ 51,387.62 *Together with interest at the per diem rate noted in (b) above after February 1, 2000 and other charges and costs to date of Sheriff's Sale. 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 that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to Foreclose has been sent to Defendants by Certified Mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania, on the date set forth in the true and correct copies of such notices attached hereto as Exhibit "CII. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. ~ ~ ' - ~ -,"-, ~ "_H ~ 1 ,- ~, .. -'.' 'y.' ~'I'~.",-,~, -......:." -', .- WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 6.800% ($8.99 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. BYP~~~ HALLER Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 .~ c_ ~ '<'^' """'-~""_"c=<-__I"""'""~'--"""'~ ~,,--^ "--"'^i NOTE FHA CASE NO. ~ FR-44I-5360586-70:~J MARCH 251 1997 [Date 139 BRIDGE STREET, NEW CUMBERLAND, PA 17070 [Property Address) 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lelader" means BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD, WORTHINGTON, OH 43085 and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises \0 pay the principal sum of FORTY - EIGHT THOUSAND EIGHT HUNDRED FI FTY ~ FOUR AND NO/ 1 OO********************************************Dollars (U.S. $ 48,854.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of SIX AND EIGHT - TENTHS****** ********************************************************************************~.*** percent ( 6. SOO %) per year until the full amount of principal has been paid. 3.' PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and caIled the "Security Instrument" The Security Instrument protects the Lender from losses which might result if Borrower defanIts under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shaIl .make a payment of principal and interest, \0 Lender on the first day of each month beginnmg on MAY 1, 1997 . Any principal and interest remaining on the first day of APRIL 1, 2027 will be due on that date, which is caIled the "Maturity Date." (B) Place Payment shaIl be made at BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD, WORTHINGTON, OH 43085 or at such other place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 318.49 This amount will be part of a larger monthly payment required by the Security Instrument, that shaIl be applied to principal, interest and other items in the order described in the Security Instrument ." Exhlb'lt"f\ 6/96 GREATLAND. 10 Order Call: 1-aOO-530-00000 Fu61S-l9-H131 ACCT# 838824 MULTlSTATE FHA FIXED RATE NOTE . ITEM 643211 (9606) Oocld 0000000763 (Page 1 of 3 pages) .' , ,~"~,~.,<,, "-< ,n , .0'" ~'- ""~I ,+_,.' .,.-- , (D) Allonge to this Note for Payment Adjustments If an allonge providing for pavment adjusttnents is exe,euted by Borrower together with this Note, the covenant~ of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. (Check applicable box.) o Growing Equity Allonge 0 Graduated Payment Allonge o Other [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the frrst day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the re1Jiainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) ", Late Charge for Overdue Payments If Lt;nder has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of ftfteen calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR****************************** percent ( 4.000 %) of the overdue amount of each payment. (B) 'Default If Bclrrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretiuy in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in' the event of any subsequent default Ii) many circumstances regulations issued by the Secretary wi11limit Lender's rights ,to require immediate paYffi<~nt in full in the' case of payment defaults. This Note does not authorize acceleration when not permitted by HOD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C)Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law, Such fees and costs shall bear interest from the date of disbursement at the same rate as die principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under ibis Note waive the rights of presenttnent and nolice of dishonor. "Presenttnent" means the right to require Lender to demand payment of ainounts due. "Notice of dishonor" means the right to require Lender to, give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different addr,~ss if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address 813ted in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER TIDS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individnally or against all signatories together. Anyone person signing this Note may be required to pay all of the amounts owed under this Note. ITEM 6432L2 (9606) Docld 0000000763 (Page 2 of 3 pages) GREATUIND. To Order Call: ,.aOO-530-&39'30 Fax 6'6-1~\1-'131 ACCT# 838824 I < - '~"C" w _ '.0' . -,.,< < ~ . ,." ,,_, I . ,,' '.. ," -, , tli~j BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in pages I through 3 of this Note. , ~ ~ ~~~ , N M RUDA ' UNDER A TRUST INDENTURE .W~~~OD~ RECOURSE, ?AY TO THE CRDER OF: ERCADV::;;'l )1:)RTGAGE -:'::JHP.;;'\f':{ (Seal) -Borrower (Seal) .Borrower (Seal) .Borrower / 1 i (Seal) -Bon:ower (Seal) .Bon'ower (Seal) -Borrower [Sign Original Only] THE MELLON BANK, N.A., AS SUCCESSOR TRUSTEE OF THE PENNSYLVANIA HOUSING FINANCE AGENCY DATED AS OF APRIL 1, 1982 'fit}; 1t2 {; ij F!ctt)) 2 cl J J:,ORRAINE !<RV,'EL "-. '" Vice prs:W,j;;:nt SY: ITEM 6432L3 (9606) Oocld 0000000763 (Page 3 of 3 pages) GREATLAND. To Order Call: 1-800-530-9393Dfax616-79'.1131 ACCT# 838824 "" ~, c.'; -"0' Ce' ,-, , : ", -, I " ' ; . ",,,-, ~ ',-,-,' ,.',-', ",.' ~". .ij". ;c" -."' _ '. , \, '. ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point. Bridge Street, said point being 13,2 feet in a southeasterly direction from the southeast corner of Second and Bridge Streets, at corner of land conveyed to Edith R Singleton; thence in a northeasterly direction on a line parallel with Second Street and through thf> center of the partition wall of a t'1ree sto;y frame and stucco dweiling house and beyond 150 feet to Maple Alley; thence southeasterly along said alley 13,8 feet to a point; thence in a southwesterly direction on a line parallel with Second Street and through the center ,of the partition wall of a three story frame and stucco dwelling house 150 feet to Bridge Street; thence in a northwesterly direction along Bridge Street 13,8 feet to the place of BEGINNING, HAVING thereon erected a frame and stucco dwelling house known and numbered as 139 Bridge Street --..---_h___ .... .,.,. -- '-'-'~~_.'-"'_.. ..' ..' ,.... . . .' h:. : ..- ", :, ~ . h h. }..y."..'.,..~~,.,.';.,., 'i~,-,:..~'.:,. -,~.,'/,.{.'i",:~(,.~..~~.?,:~c~.e.~I-.~,~t.:,-.~;,~:,,::,;,2,.- '_i~:J:~~,~" ~.t,f.i:.... ~i"..':~...::~,.,~.~,.,~,~",:~::,!,,~:_[,...'~,.!.: ',.'.:;: . ':::,' ~.:';{~'/:::::~.:;:.:!x::;;;:(:':,:~:~~~;;;-r;;;:r:~':':~:'c./:<;C~ ~:;~':' _.". ,,- nv~1=U u, t'io]rl\ ~ MAY 1 ~ ,f~q7 ..._~""~t, -": ',.--. ....,:....~'i4l~..,.(~"'t: ... :;::.: ..~ j J t~-':~. _' r - !;,l I RJ,),b', ,....,,~...;;..~_ -' v .;,-".. .~~, ;.;:. ...~. !"''-''.~r1er<~~r?~~~~~.'.:~:i j:.~<<:;~:T'~;i.~~(~~~..',' .. . """'(.~Nl.~~~ ".0,"," ,. ,." r'1;~~[p'~'t~'" ".' ";:f' ~'5 " .',,'j'f.'\ . ',,,.ii;.... ~~ .s ~:~..~ t;, . :~:~~. ~ ~,..---:.:t ..~;: '{ ".;;" ..:-,...~'~'!...~I~-'~>..;- ;(:0>~..;,_~<;:.'~. f \ ?.~_. ;~. I...." \('.:(:4'~'W " .,.- ';"..'~~\~~I'(~-~' ""'.... ~ -,;, :....~..'\i'*-,...-.; BooK1371rAGE 614 SIN.GLE FAi\t;il( <:'" '."\"~IO.' CROGRAf'.,,1v UIVl~'-.'l' '" "',,;f1SYIVania} .55 , " ,1oerland . . . f D as It. bJFr:,~:;::':7i:ilg.<I l' . '.' -:. '~",l of 0, f b Cl . , '.." day f! +1~_ , , R ord ,-~,-, , 'Il\.-:~,!' CUiib ( .'- BooK1470fAGE .. 17 uL r ,_ ' _'" E. _o~__. .>""'~',-" '",,"',..,',~,,' " - ,~CW "M PENNSYLVANIA HOUSING FINANCE AGENCY Single Family Programs Division 2101 North Front Street P.O. Box 8028 Harrisburg, Pennsylvania 17105-8028 (717) 780-3870 TDD For The Hearing Impaired Only -(717)780-1869 CERTIFIED MAIL - RETURN RECEIPT REQUESTED September 8,1999 RE: Account NO: 663294 JASON M RUDA TANYA A RUDA 139 BRIDGE ST NEW CUMBERLAND PA 170702124 RE: 139 BRIDGE STREET NEW CUMBERL PA 17070 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by CORESTATES BANK, NA, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter we, us or ours) on your property located at 139 BRIDGE STREET NEW CUMBERL PA 17070 IS IN SERIOUS DEFAULT because you have not made the monthly payments of 444.00 for June 01, 1999 through September 01, 1999 for a total of $1,776.00, plus late charges and other charges that have accrued to this date in the amount. a of $38.22 and $15.00 respectively. 'The total listed below includes any fees (inspections or securing) that needed to be completed. The total amount now required to cure this default, or in other words, get caught up in your payments, as of .the date of this letter is $1,572.48. You may cure this default within thirty (30) DAYS of the date of this letter, by paying to us the total amount of $1,572.48, plus any additional monthly payments, expenses and late charges which may fall due during this perlod. Such payment must be, made either by cash, cashier's cheek, certified check or money order and made at PENNSYLVANIA HOUSING FINANCE AGENCY 2101 NORTH FRONT STREET/p.o. BOX 8028 HARRISBURG, PA 17105-8028 (717) 780-3870/3871 or 1-800-822-7375 or TDD# For Hearing Impaired (800) 346-3597 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY" (30) DAYS, , we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. \(1' Ei. hi I;; 1+ 0' ,~.~~- , - ,-" -,_',' ." .r ~,.;; ',. ",'. ~" ~ ,~.- -__,(.'_'l"'d__'_~_ M',,""- " ",-'C'--F'J , If the mortqaqe is foreclosed, your mort4dqed property will be sold by the Sheriff to payoff the mortqaqe debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees, even if they are over $50.00. Any attorney's fee will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay at- torney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the riqht to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by payinq the total amount of the unpaid month- ly payments and any late or other charqes then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any'other requirements under the mortqaqe. It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately five months from the date of this Notice. A notice of the date of the Sheriff 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 will be by calling us at the following number: 717-780-3870. This payment must be made payable in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your of the mortgaged property and your right to remain in it. continue to live in the property after the Sheriff's sale, could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WKl\..T CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ownership If Y(lU a lawsuit If you cure the default, the mortqaqe same position as if no default had occured. entitled to this right to cure your default any calendar year. You have the right to assert in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents, the nonexistence of a default or any other defense you believe you m~y have to any such action. will be restored to the However, you are not more than three times in If you maintain credit, life or disability insurance in connection with your mortgage loan, your failure to pay premiums with your payments may have already resulted or may result in the future in the lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply ~~- .,-."-,.-,, '-...."",~ ~,- ." '" ',~,.,.,- _d" " ,~..-_ ,;,;:.-':~ to the insurance company and qualify for replacement insurance if you wish to retain it. If you make partial payments on account of the delinquencies, we may accept them and apply them to the delinquencies. However, su.ch partial payments will not cure your default or reinstate your loa.n. The loan will not be reinstated unless we receive the entire amou.nt required to cure the default. TLG/jrd Sincerely, Mr.~f~k~ Mortgage Foreclosure Officer PENNSYLVANIA HOUSING FINANCE AGENCY 2~01 North Front Street/ P.O. Box 8028 Harrisburg, PA 17105-8028 "'- "H ",,". j' . ;,.~--' "'. ,;., PENNSYLVANIA HOUSING FINANCE AGENCY Single Family Programs Division ' 2101 North Front Street P.O. Eox 8028 Harrisburg, Pennsylvania 17105-8028 (717) 780-3870 TDD For The Hearing Impaired Only -(717)780-1869 NOTICE Septerober 8, ~999 JASON M RUDA 'TI\NYA A RmA l39 BRJI:GE S'IREEI' NEW. aJMBE:RL PA 17070 RE: Account#: 663294 TO: JASON M RUDA 'TI\NYA A RmA l39 BRJI:GE ST NEW aJMBERLAND PENNSYLVANIA 170702124 FRCM: PENNSYLVANIA HOUS:rn:; FINANCE AGENCY The Federal Housing and Develop:rent Act of 1987 (as amended) directs creditors to notify hareowners who are delinquent in their Il'Ortgage obligation of the availability of hCI!'eQWIlership counseling provided by nonprofit organizatiOnS approved by the Secretary of the Depart.rrent of Housing and Urban Develop:rent ("HOD") and experienced in the provision of hareownership counseling. Attached is a =rent'list of HOD-approved counseling agencies for Pennsylvania. Enclosure Ho\.ISing Counseling List '-" -'C'-:"P2i,'-d,,"';;;_."_;,,; .--.'-,- "'T ,c '" ." ~. -.;0".[, ""V ,--'.."- "N;E 2 OF 2 *Please be sure the agency of your choice services your county. Urban League of Harrisburg, Inc. 25 North Second Street Harrisburg, PA 17101 (717) 234-3253 Housing Council of York 116 North George' Street York, PA 17401 (717) 854-1541 Tabor Calmmity Services 439 E. King Street Lancaster, PA 17602 (717) 397-5182 _ .'J ':_.. ""_."C.,l,c''''-;'''--''.'< ".;'.' '-~ ".- .." P 971 898937 TO: JASON M RUDA 139 BRIDGE ST NEW CUMBERLAND, PA 17070 SENDER: KI REFERENCE: 663294 PS FORM "' 00 SEPTEMBER 1995 o-:sS---- .....,. CertilledFee I. RETURN Relum Receipt Fee ----DS-- RECEIPT -a-- SERVICE RestrlclooDeliYefY u .. .,3.20 Total Postoge and Fe8s - ';< ~-" '-' .., US Postal Service POSTMA,:!KoRD~E: '_' ..~~f : ('." ,.~~: . ' Receipt for ,C ,,"'-,~. ,,- Certified Mail , '--- , .. ~:' , - - -.... .. No Insurance Coverage Provided Do not use l<lr'~ernlltiona'~~l" ... ....... P 971 898 945 TO: TANYAA_RUDA 139 BRIDGE ST NEW CUMBERLAND P A 17070 , SENDER: KI REFERENCE: 663294 PS FORM 3809 SEPTEMBER 1995 ....... - 0.55 c:ertllledFee .--.---...-.....-..-.--.-. RET(JR~ 1 ,-,--,-",_...!."..,.._..,_....,.. fletum Receipt Fee 1.25 RECEIPT --_. SERVICE 0 Reslrlctad Delivery ---"---"----"0"'---"-'" TptalP<:l8!ag:l'llnclFeas 3.20 US Poslal Service " '1.9~~!,'RK OR DATE ,.- .,o!',6-,.~. . Receipt for,~~~ Certified MaU! . '. f; No Insurance Coverage P~ict9d Do not use for Inlernalionai Mail , <_i ~,-}.~-, /~"".'. ,k,,;, -,'. '-&-.-;;il';"~,;, ;:'-i' Y~i ~~~ f" III :II ~ m !!' Z ci' C i5' m 0\ n~> ~ ;!l 0\ c. ~ ,W i~~ m !oJ \0 ~ .j>. <II tr:ICI'l6 c. R ?='""'> .~ "C > - -.J 0 -.J 0 o o 3 (1) !Il. o' :II ~ c ~ ::J :II (1) (') (1) "5' - !" (') m ~ J! m C "tI ..... ..D _--.I ==.... - =11:I ..... ..... ..D -11:I ,.- ..D _.s:: -In """ .... ~ ~ ~ !t g "~ !! ~&- <II 0 ~ .. 3~ 10 Q' if 'urn Receiot co Cl' 5' :;- S'&!. "'l'l lfl:; s.ur 0:> <11- ...0 !il~ ~ ~. \1~ Alii ! i l, ..--.------.. r '\ ~ ) ~ f t :%I m ::lJ z ill o m ~ ::lJ m Cl c: m ~ m C -- I g::~C ~ I hiJ ! C1Cl co::r t i ~ g f 1 r ~ f _. , ~ ~,. I ~ ~ S i "1J .JI '", '"" Do ..JI Do ..JI l.lJ '" IJ /(~ff/ /~rn r-...~ " ""'~ 0' c......, I~ '0 ;;; :!:-~ #" ~ ~ Q~~1i ~ '"'" ~ ;;:;BI1}~~f~' \::- ~ ~ ;e' IJ:.:l t.,., ~ \) - e. 8; !j::..~~~~ I; ~ I'U /6 N Iii .. "I ... 0 'I' · lli I'" III I' fm l.; ~.........".ltlt.. , , , i r - .-,. .",. . "'-,'."';;"'I::;,~,' _". '-.a~ "';--"-'. .."- '_;.0.0'._'''->'''''''__"'''"''''_ ,T' ."'H"'-"-~~', II. 'W'-i " _. _~ ,~, ..y'C, r. .,,_-c,-_," ','_ .:,~I"_',_-, 'r;",>' . . VERIFICATION Donald 1. Plunkett hereby states that he is the Assistant Executive Director for Single Family Programs of the Pennsylvania Housing Finance Agency, mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: Jcnmy 13, 2000 DonID~ Assistant Executive Director for Single Family Programs I'E'NSYLWINlA 1D13IN:; F'JNIN:E JGN:Y, SERJICJN:i lGNI' FeR F.IR3I' lNKN ~ H\NK N3 s; I I ~,,'" t( 'IREIEE FeR 'mE I'E'NSYL\~\NIA H:IEIN:; F'JNIN:E JGN:Y ,. ~ , . , , , -, 6715/~~.~;~~i~"t.~Il;~P:;~~~:;~~~.~ . ~ I ~ II ~ ~llZ ~IZ , ;<: t1 i ~ /" L[ ~ ::: ~ . ~.~ ~ :::! ~ ~f > IZ ~ ~I ,h ~ f;j i ~ 1- ~ . 0 0 ~ > z ~ . -; ::!:! S! ~ ~ ~ E ~ ~ ~ " r !~ I~ 0 ,~ " 1 I ~ ~ ~i ij ~ ~ (2)1 jf (") c:> 0 ,e ~, 0 "'r1 s.: t..... .._.1 ....( .c -Of V ;r:--:tl" .-y' mn :z ~+1~d '" ~ G Z::o -c-h'l . ZC - ;::~t \,:;J ~ 2: cz ~Z m a ,",..._(~. ~G -<) ~~,=H ~ ~o :JI; ':4(:"') ~Q r;- orn '- ;;;! r ~ - Xl a'> ~ A"Ii!lIIlll!$i-'~ - j .- , SHERIFF'S RETURN - REGULAR CASE NO: 2000-00337 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK VS RUDA JASON M CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RUDA JASON M the DEFENDANT , at 0018:50 HOURS, on the 2nd day of February 2000 at 1133 RANA VILLA CAMP HILL, PA 17011 by handing to JASON RUDA a true 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 18.00 8.68 .00 10.00 .00 36.68 So Answers': * ~l5~e~~ f R. Thomas Kline 02/04/2000 PURCELL, KRUG & HALLER Sworn and Subscribed to before By: '~d- c;;: Deputy S~eriff me this dl.S~ day of 14....,. r d-07rQ A.D. Q'7/U-rJ. 7h'~~f" '~~' Prothonotary , - ill ". .. SHERIFF'S RETURN - REGULAR CASE NO: 2000-00337 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK VS RUDA JASON M 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 RUDA TANYA A the DEFENDANT , at 0013:00 HOURS, on the 2nd day of February, 2000 at 139 BRIDGE ST NEW CUMBERLAND, PA 17070 by handing to TANYA RUDA a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 10.54 .00 10.00 .00 26.54 So Answer,~:, " ,~~.. .' ' ..y,~ '_ 1ft , R. Thomas Kline , .,/~ me th:LS 0("'- day of 02/04/2000 PURCELL, KRUG & HALLER By: RtJVIr0 !JIll" Deputy' S~ Sworn and Subscribed to before d-J.~" A__, ~ A.D. 9-r1 Ci /v..'P€,_, i~n1'f Prothonotary I ^ ^ ~- , ~ ~^ .~ ~"'~.-, ~~ - "' 4' FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS CIVIL ACTION - LAW NO. 2000 337 IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants JASON M. RUDA AND TANYA A. RUDA for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $8.99 from 8/1/99 to 2/1/00) Accumulated late charges Late charges ($12.74 per month to 2/00) Escrow Credit 5% Attorney's Commission $47,575.80 $ 1,654.16 TOTAL $ 38.22 $ 76.44 $ 335.79 $ 2,378.79 $51,387.62** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. By Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 I:\HOME\MKF\DOCS\CUMBERLA\RUDA.P ............ - o c: 'TJlfj mr" z-!..-! 2F ;:sCIJ Jo, ""-. r <:." ~c) ".,,- ..",- ""0 -p ~c5 :J;;: c: N ~ c:; W f \ -K"". ~. r ^ f" (;.> , d r~ ,~ ." <" ~ 'J "Il '~ "\ ~ o o ~ ~ o -71 :7i .',-0;----;-' .-~~~~; ~i ?1~ 2l""'5 Orn c-I J> :rJ -< i.' , ~ ~ if .. ';'I) ~ ._.~~ p, ". ~---_ x__";;~" ", ., ^ . 1 FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS CIVIL ACTION - LAW NO. 2000 337 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on MAY 31, 2000 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 ~ . " o , [,- ~^ -'-j, .,q>".--. ,. .d." .> FIRST UNION NATIONAL BANK AS TRUSTEE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-337 Vs. JASON M. RUDA AND TANYA A. RUDA CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE Defendants DATE OF THIS NOTICE: May 31, 2000 TO: JASON M. RUDA 1133 RANA VILLA CAMP HILL, PA 17011 TANYA A. RUDA 139 BRIDGE STREET NEW CUMBERLAND, PA 17070 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION . OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717-249-3166 By Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 717-234-4178 ,,- .""""''''''' .. """" -. ..."",,~ , ~......~ ""'--^ ~~" .. -:;J Ii I w , . 0 0 C) c: a -,., s: (- ':l vcc: ~ i.-.---, 9!rn I ;'IO~:. :1:' -')8 :Zc (/)J;' w -<2.: ~"-) ,.!.., [<C) -n ~~ ~o :J::: 7D 5>8 t;y C)' " ~ w );! :;u w -< < - .'- ." '" ~-. ~_.~ .='.'_-,"~,-, ". . . " FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS CIVIL ACTION - LAW NO. 2000 337 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant(s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed befU:,/~h~S /l? day: of ~.____ 20 <2-0 : ~~~ Not uolic LEON P. HALLER, ESQUIRE NOTARIAL SEAL MARYLAND K. FERRETTI, Notlry Public LOWER PAXTONTWP., DAUPHIN County My Commission ExplrasAUGUST 8, 2002 f2 Jif!; ~:rf ~r' 0' rs~~ :EO .2:('"' :sO ~ -; '"" C:l Q ~ c: ~ o ....,/ :i:t ~ i/ f':? 6[;1 lfJ -< -:..> ..::-w . ",." -, , '1..<-,_,__ .; :,' " FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA / VS. JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS CIVIL ACTION - LAW NO. 2000 337 IN MORTGAGE FORECLOSURE , , NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You following captioned are hereby notified that judgment has been entered matter: on ~ /3,..2 o-v-tJ against you in the the above- $51,387.62 and for the sale and foreclosure of your property located at: 139 Bridge Street, New Cumberland, PA 17070 Dated: ~Ja.JJ..: ;2ff1J ~, R. ~ l,_~ PROTHONOT RY/ Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Jason M. Ruda 1133 Rana Villa Camp Hill, PA 17011 Tanya A. Ruda 139 Bridge Street New Cumberland, PA 17070 . --, ~ -~- ';"_0" '~.b-": ~=_, . FIRST UNION NATIONAL BANK IN THE COURT OF COMMON PLEAS AS TRUSTEE FOR PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF CIVIL ACTION - LAW VS. NO. 2000 337 JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS IN MORTGAGE FORECLOSURE Relief from Stay . , ~ M" '~ ~--"' {)li ~ . UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: TANYA ANN RUDA Debtor BANKRUPTCY NO. 1-00-01176 CHAPTER 7 \ FIRST UNION NATIONAL BANK AS SUCCESSOR TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY I L"" D' Harri3burg, P." F. t:,l T'~..;E ,Uk - P.M. \ MAY 1 5 lIllO, \ ~irk, u.s. Bankruptcy Court f\::' . Deputy Clerk Movant vs. TANYA ANN RUDA and LAWRENCE G. FRANK, Trustee Respondents default, DEFAULT ORDER ON MOTION FOR RELIEF FROM STAY .~ ~~ \~ day of "\\~ , 2000, upon no response or objection t~the Motion having been timely This filed by an interested party, it is ORDERED that the above captioned Motion is granted insofar as it requests relief from the automatic stay imposed by 11 U.S.C. ~362. BY THE COURT: aUoner! J, WllGd@liil Robert J. Woodside United States Bankruptcy Judge iIiIil.~;;'~"." ,-"'". .....,"-".j"-~"~-' ""lIiOIiIII!lliii:lI "(id,Mi .- I I . . 0 <::> 0 c <:;) >1 s: L. -., Ur;o c:: -"" rnQJ 2: :'-l'iiIJ 2~.J."': ~rjEj Zc:: W (f)d..:.-_, ~~1(~) ~t,> '" -' " ;t=Fj ~C; :2; ~~~ C Pc ~ ......r.' ;z: W ;i2! -< ~ -< -.J ~-- "-- ~-~ I, _, ~ ,_, .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ( J ) Confessed Judgment (XX) Other IN MORI'GAGE FOREClffiURE FIRST UNICN NATICNAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. JASCN M. RUDA AND ,TANYA A. RUDA, DEFENDANTS File No. 2000 337 Amount Due /Judqment \ Interest $8.99fram 2/1/00 to 9/6/00 Late charges $1? 74 EscrON' Deficit Costs $51,387.62 $ 1,959.82 $ ~n 'If; $ 2,000.00 TO THE PROTHONOTARY OF THE SAID COURT: WRIT $55,398.40 The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CUMBERLIIND for debt, interest and costs, upon the following described property of the defendant(s) Real Estate: 139 Bridge Street, New Clmiberland, PA County, IN MORl'GAGE FORECLCSURE PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) REAL ESTATE: As indicated above REAL cmNER: Jason M. Ruda and Tanya A. Rqda and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). o (Indicate) Index this writ against the garnishee(s) as a lis pendens against re defendant(s) described in the attached exhibit. Date 6/10/00 Signature: Print Name: Address: leon P. Haller, Esquire Purcell, Krug & Haller 1719 Nortb ~~t S~Qt Harrisburg, PA 17102 Attorney for: Telephone: Supreme Court 10 No.: PIAINTIFF 717-234-4178 U5700 (over) iill .,-" ~ ~ J!i~l> 1 il' ~. r~ --. <J2..., '0.\ 11', ~ "......'..' - ,..' G a 0 C CJ --tl :;;; ;.-.. ., "'Om _,.1 S2m ~ ,-'ilp! :1::'1 ~ Z:C' :;~ 123 03.;::;: G) ~L- '~2() ~D -0 "Tl ~o ~.. ,;-2:..:0 ~ ~~~?;1 -'('." );>c r:- '..... z: :;;! =< tv ::1J -< -- l." w-+: Lrr?\ d'17:~ "" - V' .. " .. '2 2 ?v ;r~ . w;;; i' I ,! r~ I ~ ] '" ...... ..J;\ "\ ~ ~ , . I" ~.' ,-.;;,_,,"b', ._, i< - t.;,~", . LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point Bridge Street, sajp point being 13.2 feet in a southeasterly direction from the southeast corner of Second and Bridge Streets, at corner of land conveyed to Edith R. Singleton; thence in a northeasterly direction on a line parallel with Second Street and through the center of the partition wall of a three story frame and stucco dwelling house and beyond 150 feet to Maple Alley; thence southeasterly along said alley 13.8 feet to a point; thence in a southwesterly direction on a line parallel with Second Street and through the center of the partition wall of a three story frame and stucco dwelling house 150 feet to Bridge Street; thence in a northwesterly direction along Bridge Street 13.8 feet to the place of BEGINNING. HAVING thereon erected a frame and stucco dwelling house known and numbered as 139 Bridge Street. BEING THE SAME PREMISES WHICH James Lutz and Mary Y. Lutz by deed dated 3/25/97 and recorded in Cumberland County Deed Book 154 Page 1059 granted and conveyed unto Jason M. Ruda and Tanya A. Ruda. TO BE SOLD AS THE PROPERTY OF JASON M. RUDA AND TANYA A. RUDA ON JUDGMENT NO. 2000 337. TAX PARCEL: 25-25-0006-340. . _ _' _,_' ,_,_ f'~ _ "';'" "'-U,-,~__,_ __ _'~ ~ FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS CIVIL ACTION - LAW NO. 2000 337 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 139 BRIDGE STREET, NEW CUMBERLAND, PA: 1. Name and address of the Owner(s) or Reputed Owner(s): Jason M. Ruda 1133 Rana Villa Camp Hill, PA 17011 Tanya A. Ruda 139 Bridge Street New Cumberland, PA 17070 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17110 5. Name and address of every other person who has any record I:\HOME\MKF\DOCS\CUMBERLA\RUDA.PTF f - ~ '. ',.,,,-'-- ,1 , '. lien on the property: UNKNOWN 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7 . Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Matthew J. Eshelman, Esquire 2108 Market Street Camp Hill, PA 17011 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relatin to unsworn falsification to authorities. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: June 13, 2000 IiliIl ~. '.~'"-~'.~'"i_ !::rJlI!I .H" ~,,;...., .'-'~l>'IIl!ill&I" "'"' .~~--<" '" .~., I I I .. () <::> f; a 0 -h --of;'?; <- ~:;j !;p If, c:: ::tJ <: 7,;U <t-- - C/).:r-c. .-r}1Tl ~6~ <:0 ;81 ,:::;:c -0 <: j ~ :;;:0 ~ c: <: :c;! =< W \.0 ::1.7 -< ,-, '<- l _ ~ ~' .C-'. .,- .. '~,. -, , ; ... FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS CIVIL ACTION - LAW NO: 2000 337 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT 'TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, September 6, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 139 Bridge Street New Cumberland CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2000 337 THE NAME (S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: Jason M. Ruda and Tanya A. Ruda "~ . '" "to.'^' A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. S Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This - - , ~- .'"' petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situiite in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point Bridge Street, saW point being 13.2 feet in a southeasterly direction from the southeast corner of Second and Bridge Streets, at CClrner of land conveyed to Edith R. Singleton; thence in a northeasterly direction on a line parallel with Second Street and through the center of the partition wall of a three story frame and stucco dwelling house and beyond 150 feet to Maple Alley; thence southeasterly along said alley 13.8 feet to a point; thence in a southwesterly direction on a line parallel with Second Street and through the center of the partition wall of a three story frame and stucco dwelling house 150 feet to Bridge Street; thence in a northwesterly direction along Bridge Street 13.8 feet to the place of BEGINNING. HAVING thereon erected a frame and stucco dwelling house known and numbered as 139 Bridge Street. BEING THE SAME PREMISES WHICH James Lutz and Mary Y. Lutz by deed dated 3/25/97 and recorded in Cumberland County Deed Book 154 Page 1059 granted and conveyed unto Jason M. Ruda and Tanya A. Ruda. TO BE SOLD AS THE PROPERTY OF JASON M. RUDA AND TANYA A. RUDA ON JUDGMENT NO. 2000 337. TAX PARCEL: 25-25-0006-340. iIiII .=.L- Wi'-I ,J '" ~--"" .,.,," -. -'<. ,," "-~ ,--'" ,- ''> 0 C:::> ~ c:: C) ?' C. ri1 fii c:: :,_~,-i n-- ::~ , ," 2:1:,' '1"''-.;0 Zr;:: - ~::-j'E9 ~;:~;- w ~-~) -L, ----::,,---' ~.........- '"0 -;-' ''',', .s:o ~ :;!f€ ~C) f'.) (:) f'r} c:: Z :..> ~ ::< 5:, '.0 -.; m ;,f"'- -- " ^'. "'J -,'.. --h.'- - .'''-_'' -0, ,-.... ,_ '"h "",~ ';",",' ". ~ FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS CIVIL ACTION - LAW NO. 2000 337 IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the u.S. Mails at Harrisburg , pennsylvania on 1.g.1~~:,1 M , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.,8. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail. Service addresses are as follows: Jason M. Ruda 1133 Rana Villa Camp Hill, PA 17011 New Cumberland Bomugh 1120 Market Street New Cumberland, PA 17070 Tanya A. Ruda 139 Bridge Street New Cumberland, PA 17070 pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17110 Andrew c. Sheely 127 S. Market Street PO Box 95 Mechanicsburg, PA 17055 Domestic Relations Office Cumberland County Courthouse Hanover & High streets Carlisle, PA 17013 Matthew J. Eshelman, Esquire 2108 Market Street Camp Hill, PA 17011 By PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 - ."., . "~, h,_ , JOHN W. PURCELL HOWARD B. KRUG LEON p, HALLER JOHN W, PURCELL JR BRiAN J, TYLER .IILL M, WINEKA LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FORECLOSURE DEPT. FAX (717) 234-1206 JOSEPH NISSLEY (1910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD (717) 533-3836 NOTICE TO: Jason M. Ruda 1133 Rana Villa Camp Hill, PA 17011 New OJmberland Bomugh 1120 Marlret Street New OJmberland. PA 17070 Tanya A. Ruda 139 Bridge Street New Cumberland, PA 17070 Andrew C. Sheely 127 S. Marlret Street ro :Box 95 Mechanicsburg, PA 17055 Pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17110 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Matthew J. Eshelman, Esquire 2108 Market Street Camp Hill, PA 17011 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. By: hold against the said th you have an being notified of YOU ARE FURTHER NOTIFIED that the lien real estate will be divested by the sale opportunity to protect your interest, if said Sheriff's Sale. Leon P. Haller PA I.D.15700 Attorney for Plaintiff j)-;" FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS CIVIL ACTION - LAW NO. 2000 337 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, September 6, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 139 Bridge Street New CUIIlberland CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2000 337 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: Jason M. Ruda and Tanya A. Ruda " _ ,,-, _____..E'-__- .1 ~., A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale recei ved and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This ~ -- " petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 " Ole LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point Bridge Street, sa~ point being 13.2 feet in a , southeasterly direction from the southeast corner of Second and Bridge Streets, at corner of land conveyed to Edith R. Singleton; thence in a northeasterly direction on a line parallel with Second Street and through the center of the partition wall of a three story frame and stucco dwelling house and beyond 150 feet to Maple Alley; thence southeasterly along said alley 13.8 feet to a point; thence in a southwesterly direction on a line parallel with Second Street and through the center of the partition wall of a three story frame and stucco dwelling house 150 feet to Bridge Street; thence in a northwesterly direction along Bridge Street 13.8 feet to the place of BEGINNING. HAVING thereon erected a frame and stucco dwelling house known and numbered as 139 Bridge Street. BEING THE SAME PREMISES WHICH James Lutz and Mary Y. Lutz by deed dated 3/25/97 and recorded in Cumberland County Deed Book 154 Page 1059 granted and conveyed unto Jason M. Ruda and Tanya A. Ruda. TO BE SOLD AS THE PROPERTY OF JASON M. RUDA AND TANYA A. RUDA ON JUDGMENT NO. 2000 337. TAX PARCEL: 25-25-0006-340. i/ <- ""', l. , . _", 'J~"'" -, -h "'. , .J Re: First Union v.Ruda Cumberland Sales 9/6/00 u. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Jason M. Ruda 1133 Rana Villa Camp Hill, PA 17011 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Tanya A. Ruda 139 Bridge Street New Cumberland, PA 17070 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17110 postz1R~~" ~:S's,\ rer~, ,...:, '8:; ~ (fl' U-'>~iGl ~'",,; , -- ~-..::= - << ~_ 1 ),___......'""" .. "it" ~~ ~ __.,~ " .~,.t' l.... I' ? .r; "/:.;;i ,~ ..-. :J: .UN.3 ,0 IV , j',,~ 0 7 5 '0, . ~..;.. '. ~:. :: : P!\ '>6M~TER 4t ,..,. 67635t>51 -to -" - ~ ",.- '^~ ' > -'<' " ' '" '.'- -" -'-f_",,' ,,4,,_, _~' - , " , ,. . U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service For.m 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Domestic Relations Office Cumberland county Courthouse Hanover & High Streets Carlisle, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service For.m 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Matthew J. Eshelman, Esquire 2108 Market Street Camp Hill, PA 17011 lit.. ~" -~.;...,," ~....._..."'""". . , /&II/Iidr,...... .~ . " ." '~".,".., .. , .. ,.",,,- -. .,., (") c $: '"1JCO mrn Z:fJ Zr- co~:~ ~~ r;:.CJ ~(') 60 )>C ~ ... o o "" fT1 "'0 N <.J'J o -, ---I ;~:: ::1 "'f- ~{;jE9 ~~;~~: C~ ;~~ ~".- '--" Uin ~'~i 55 -< "1') :1<; r:- (n i ... ~ ~-~... ~ .-. n_ - ,- .J. " " ~ '-j" '-'1 ,. .- '~, '~ . STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, ________________________________________ _____________n________nh_____hn__ Recorder of Deeds in and for said County and State do hereby cenify that the Sheriff's Deed in which ______h________ Secretary of Housing and Urban Dev of Washington DC. ------------------------------------------------______-_____________________________ ~ the grantee the same having been sold to said grantee on the ____Jl.tb_h_h_h_____hn___________h_____h_ day of _____nh___?_<:.e!:~.!"cl?~E__________n_n__ A. D., ~~Q9.9n_' under and by virtue of a wriL____h____n_ Execution . d th 13th ____________~___________________________________~ue on e_____________________________________ June =2000 . day of __________________________ A. D., l~______, out of the Court of Cornman Pleas of saId County as of ____________.P-::hyj,J________h __. .__________ ___ h __ h ______h __ __ ____nn n n _______ Term, W&2Diill_ Number _m_~X!...__m, at the suit of _~_iE~!:__l!.'!~9.!l._r:!~!:LI!!<__~~_%.?L!'~_'!.'!~_.!!.'?':!~j._'!.g_E)-'!-!).l\..<:.'!~y . Jason M Ruda & Tanya A :. ____________________~--------------ag8Jnst---------------_____________________________________ ~ duly reeorded in Sheriffs Deed Book No. ___~~~_h___' Page ____~~~_____. IN TESTIMONY WHEREOF, I have hereunto --.L set my baud and seal of said office this _~Q_______ day of- . D., lS_",zf!Qfl_ .d1_J!J rder of Deeds IlIaInIer oIllee1Ia: CambeIfInf CoIndr. 01_ M My QImnIiaiDn E" tile fint",Il__ :l' First Union National Bank as Trustee In the Court of Common Pleas of For Pennsylvania Housing Finance Agency Cumberland County, Pennsylvania -vs- No. 2000-337 Civil Jason M. Ruda and Tanya A. Ruda Harold J. Weary Deputy Sheriff who being duly sworn according to law, says on July 19,2000 at 6:19 o'clock P.M. EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Jason M. Ruda, by making known unto Margaret Cook, Grandmother at 1133 Rana Villa, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. Timothy Reitz Deputy Sheriff, who being duly sworn according to law, says on July 11,2000 at 2:25 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Jason M. Ruda and Tanya A. Ruda located at 139 Bridge Street, New Cumberland, Cumb.erland County, Pennsylvania, according to law. R. Thomas Kline, Sheriff who being duly sworn according to law, says he made diligent search and inquiry for one of the within named defendants to wit: Tanya A. Ruda, but was unab.le to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, to served the within Real Estate Writ Notice Poster and Description according to law. Dauphin County Return: I Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Tanya A. Ruda the defendant named in the within Notice of Sheriffs Sale and that I am unable to fmd her in the County of Dauphin, and therefore return same Not Found, September 1, 2000. So answers: J.R. Lotwick, Sheriff Dauphin County, PA. 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 by regular mail to one of the within defendants to wit: Jason M. Ruda to his last known address 1133 Rana Villa, Camp Hill, Pennsylvania. This letter was mailed under the date of July 20, 2000 and never returned to the Sheriff's Office. 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 by regular mail to one of the within named defendants to wit: Tanya A. Ruda to he last known address 139 Bridge Street, New Cumberland, Pennsylvania. This letter was mailed under the date of August 6, 2000 and returned to the Sheriff's Office on August 11, 2000 with reason forwarding time expired. R. Thomas Kline, Sheriff, who being duly 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, 20000 at 10:00 o'clock A.M. EDST, and sold the same for the sum of $ 1.00 to Attorney Leon P. Haller for The Secretary Of Housing and Urban Development Of Washington, D.C., his successors and/or assigns. It being the highest bid and best price received for the same The Secretary of Housing and Urban Development of Washington D.C., his successors and assigns of One Sentry Place 475 Sentry Parkway, ~ ~ ~._- '. . ~ . Suite 5000, Blue Bell being the buyer in this execution paid to SheriffR. Thomas Kline, the sum of $ 931.06 it being costs. Sheriff s Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified mail Levy Surcharge Out of County Dauphin County Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 30.00 18.26 15.00 15.00 30.00 10.00 .50 1.00 19.84 .78 15.00 30.00 9.00 29.25 307.25 324.15 23.43 25.00 27.50 $931.06 Pd By Arty 9/21/00 Sworn and Subscribed To Before Me This ,5''1:: Day of ~ ,.. J 2001 A.D. ~o D 7h.d..;,--<~ Pro notary So ~.e~#"r" ~" ;:" ~~~~ R. Thomas Kline, She f By!a~ J!"Ir Real Estate Deputy ,y^ r/' ,00 ';IJ /Q \-" CJc aon~7 ~ /tI.)~9.27 -., , "'-."-,'. , .... ,- FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS CIVIL ACTION - LAW NO: 2000 337 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 \. The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 139 BRIDGE STREET, NEW CUMBERLAND, PA. 1. Name and address of the Owner(s) or Reputed Owner(s): Jason M. Ruda 1133 Rana Villa Camp Hill, PA 17011 Tanya A. Ruda 139 Bridge Street New Cumberland, PA 17070 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17110 5. Name and address of every other person who has any record I:\HOME\MKRDOCS\CUMBERLA\RUDA.PTF ~ ~~~~ ",-, c.,!.-, 0.- , - lien on the property: UN'KNOWN 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UN'KNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Matthew J. Eshelman, Esquire 2108 Market Street Camp Hill, PA 17011 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relatin to unsworn falsification to authorities. .--' ~ Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: June 13, 2000 f-- -_1-:". .,"- FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JASON M. RUDA AND TANYA A. RUDA,: DEFENDANTS CIVIL ACTION - LAW NO: 2000 337 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT 'To PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, September 6, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 139 Bridge Street New Cumberland CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2000 337 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: Jason M. Ruda and Tanya A. Ruda C'.. I ^~.-- ;"- .; A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale' and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing e~ceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. S Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the sheriff's Sale you may file a petition with the Court of Common pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This , -"" .L',' ~ "',,,_ . .,-. ~"1 petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto.' PURCELL, KRUG & HALLER Attorneys for plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 '" LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land. sitl.liite in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point Bridge Street, sa4:J point being 13.2 feet in a , southeasterly direction from the southeast corner of Second and Bridge Streets, at corner of land conveyed to Edith R. Singleton; thence in a northeasterly direction on a line parallel with Second Street and through the center of the partition wall of a three story frame and stucco dwelling house and beyond 150 feet to Maple Alley; thence southeasterly along said alley 13.8 feet to a point; thence in a southwesterly direction on a line parallel with Second Street and through the center of the partition wall of a three story frame and stucco dwelling house 150 feet to Bridge Street; thence in a northwesterly direction along Bridge Street 13.8 feet to the place of BEGINNING. ' HAVING thereon erected a frame and stucco dwelling house known and numbered as 139 Bridge Street. BEING THE SAME PREMISES WHICH James Lutz and Mary Y. Lutz by deed dated 3/25/97 and recorded in Cumberland County Deed Book 154 Page 1059 granted and conveyed unto Jason M. Ruda and Tanya A. Ruda. TO BE SOI,D AS THE PROPERTY OF JASON M. RDDA AND TANYA A. RDDA ON JUDGMENT NO. 2000 337. TAX PARCEL: 25-25-0006-340. ~"*- ,1-, ' ~ ~-, ". .. , '0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO~000-337 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: First Union National Bank as Trustee for TQ satisfy the debt, interest and CQsts duf. Pennsylvania Housing Finance Agency frQm Jason M. Ruda, 1133 Rana Villa, 139 Bridge St., New Cumberland PA Camp Hill 17070. PLAINTIFF(S) PA 17011 and Tanya A. Ruda, DEFENDANT(S) (1) YQU are directed tQ levy uPQn the prQperty Qf the defendant(s) and tQ sell Real estate located at 139 Bridqe St., New Cumberland PA 17070. (See attached legal decription. ) (2) YQU are also direC!El,~"I!!l:,~tt~,~.o,: th'rr prQPEt~y Qf the defendant(s) nQt levied uPon in the PQssessiQn Qf .. -,-,~, .,...",~".....",.....~~- ,,,. ~ ..~!C . ~/ GARNISHEE(S) as fQllQws: ,./\j tfi\-"'i' and tQ nQtny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjQined frQm paying any debt tQ Qr fQr the account Qf the defendant(s) ~~~ from delivering any prQperty Qf the defendant(s) or,Qtherwise disposing thereQf; , .. ., '., (3) If property Q1Ihe defendant(s) nQt levied upon an subjecttQ attachment is fQund in the possession Qf anYQne Qther than a named garnishee, YQuaredireetedto'nQtily'him/herthat he/she has been' added as..a..gafJlishee,apdjs enjoined as above stated. Amount Due $51,387.62 $8.99 from 2/1/00 to Interest 9/6/00 $1,959.82 Due PrQthy $.50 $1. 00 L.L. Atty's CQmm Atty Paid $135.22 Plaintiff Paid % Other Costs Late charges $12.74/= $50.96 Escrow Defifcit $2,000.00 Dale: June 13, 2000 CURTIS R. LONG Prothonotary, Civil Division by: 0,~ 0., 11",p~ Deputy REQUESTING PARTY: Name Leon P. Haller, Esq. Address: 1719 N. Front St. Harrisburg PA 17102 AttQrney for: Plaintiff TelephQne: (717) 234-4178 Supreme CQurt ID NQ. 15700 !ll/lilf~;~".-":" ",J-"-, iiltiiif ,~ -~III-' II ..~ . ~ u ~ ,< ~ ~ ~ ,- '- ~-""'-'~ ~JlJ ' REAL ESTATE SALE Nc5!J Or. ~ 17- ';>eI'ri:> the sheriff levied upon the defirKlams interest in the real property situated in~c-~./ 4t?~) IJ__.J.. J.~ Cumberland County, Pa., know' ':H1 numbered as: /J<J 4~-J' ~ff J 4/....,) ~'qJL/J...,bnd more ;1 ';e-d on Exhibit "A" filed with this writ and by this reference incorporated herein. 'latII9~d t';:w?V ~~~ ,~ , / :"-' ~-/ " '/1 '1 , , l . " ! ,', ',~ -' I " ,) /,\./ '1 'I ' ,~'':J d j." "/ , .:d1it!;i;'" "C Ii I Nfl[ I , 7,~ '; > "'/!J . .:J,)J...-1.to I . . ~ ~ ~ ~ o ,~" ""' c"'",; ( .. "'--. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication . UnderHct No. 587. Hooroued Mau 16.1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Accounts Receivables Manager of THE PATRIOT-NEWS CO., a corporation organized and existing under the iaws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT- NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday and Metro editions/issues which appeared on the 1 st, 8th and 15th day(s) of August 2000. That neither he nor said Company is interested in the subject matter ot 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 stlltement 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 tor the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book oM", VO;::~4;;:~I:: ____________________~K-~------------------- COpy Sworn to and subs . is 30th d of Au 2000 A.D. S ALE #53 Nota~al Seal Terry L. Russell, Notaoy pu Harrisburg, Dauphin coon My Commission Expires June 6, 2002 TARY PUBLIC Member, Pennsylvania Associat;oncM\rotllllll1llmission expires June 6, 2002 .0 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COUR1HOUSE CARLISLE, PA. 17013 . Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 322.65 1.50 324.15 Publisher's Receipt for Advertising Cost ,THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general circuiation, 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. 53 Wrtt No. 2000-337 Civil FIrst Union National Bank As Trustee For Pennsylvania Housing Ftnance Agency vs. Jason M. Ruda and Tanya A. Ruda Atty.: Leon P. Haller LEGAL DESCRIPTION ALL TIJAT CERTAIN lot or tract of land sttuate in the Borough of New Cumberland. County of Cumberland. and State of Pennsylvania, more par- ticularly bounded and described as follows, to wit: BEGINNING at a point Brtdge Street. saldpolntbeing 13.2feetll1la ~utheasterly dtrecttonfrom the soulh- east comer of Second and Bridge Streets. at comer ofland conveyed to Edith R. Singleton; thence in a north- easterly direction on a line parallel with Second Street and through the center of the partition wall of a three story frame and stucco dwelling house and beyond 150 feet to Maple Alley; thence southeasterly along said alley 13.8 feet to a point; thence in a southwesterly direction on a line parallel with Second Street and through the center of the partition wall of a three story frame and stucco , dwelling house 150 feet to Brtdge Street; thence in a northwesterly di- rection along Brtdge Street 13.8 feet to the piace of BEGINNING. HAVING thereon erected a frame andsru~od~~ho~emo~ and numbered as 139 Brtdge Street. BEING THE SAME PREMISES WHICH James Lutz and MaryY. Lutz by deed dated 3/25/97 and recorded In Cumberland County Deed Book 154 Page 1059 granted and conveyed unto Jason M. Ruda and Tanya A. Ruda. TO BE SOLD AS TIlE PROPERlY OF JASON M. RUDA AND TANYA A. RUDA ON JUDGMENT NO. 2000- 337. TAX PARCEL: 25-25-0006-340. ""''''"^- .'~ _,1 "-- .. > PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929),f. L.1784 STATE OF PENNSYLVANIA : sS. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues ofthe said Cumberland Law Journal on the following dates, VIZ: JULY 28, AUGUST 4, 11, 2000 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. / Roge! M. Morgenthal, Editor - -- SWORN TO AND SUBSCRIBED before me this 11 day of AUGUST. 2000 NOTA lID' LotS E. SNYDER, 'Noia.y PvbIic Corlitl. Boro, Cumberland County. PA My Commisoion Expi.... Morch 5, 2001