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HomeMy WebLinkAbout00-00758 -, ..,j,I.~ - LAW OFFICE OF SAMUEL B. HORNSTEIN, P.C. A Professional Corporation By: SAMUEL B. HORNSTEIN, ESQUIRE Attorney J.D. 19445 18 East Court Street P.O. Box 1129 Doylestown, PA 18901 (215) 348-5380 Attorney for Plaintiff THE CIT GROUP/CONSUMER FINANCE, INC. 600 W. GERMANTOWN PIKE, SUITE 161 PLYMOUTH MEETING, PA. 19462 COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION LAW vs. LARRY R. REIDELL and GLORIA J. REIDELL 604 ERFORD ROAD CAMP HILL, PA. 17011 NO. "<000- 7S P Cr"u,,( '70 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following page, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE,PA.17013 717 240-6200 II !! jl II II ~'I--*'I ~ . ";,-[ r~~ LAW OFFICE OF SAMUEL B. HORNSTEIN, P.C. A Professional Corporation BY: SAMUEL B. HORNSTEIN, ESQUIRE ATTORNEY FOR PLAINTIFF Attorney LD. #19445 18 East Court Street P.O. Box 1129 Doylestown, Pennsylvania 18901 (215) 348-5380 THE CIT GROUP/CONSUMER FINANCE, INC. 600 W. GERMANTOWN PIKE, SUITE 161 PLYMOUTH MEETING, PA. 19462 COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION LAW vs. LARRY R. REIDELL and GLORIA J. REIDELL NO. 604 ERFORD ROAD CAMP HILL, PA. 17011 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is The CIT Group/Consumer Finance, Inc., which is a Pennsylvania corporation duly organized and existing pursuant to the laws of the Commonwealth of Pennsylvania, having its principal place of business at 600 W. Germantown Pike, Suite 161, Plymouth Meeting, Pa. 19462. 2. Defendants are Larry R. Reidell and Gloria 1. Reidell, who are adult individuals presently residing at 604 Erford Road, Camp HilI, Pa. 17011. 3. On or about February 23, 1996 said Defendants made, executed and delivered a mortgage upon the premises 604 Erford Road, Camp HilI, Pa., to The CIT Group/Consumer Finance, Inc., hereinafter called "Mortgagee", which mortgage is recorded in the Department of Records for the County of Cumberland, in Mortgage Book No. 1304, Page 564, and the terms of which are incorporated by reference herein as though fully set forth at length. ,- , , '~l ,- , l'~: 4. A description of the land and premises subject to the said mortgage is set forth in Exhibit "A" attached hereto and incorporated by reference herein as though fully set forth at length. 5. The said mortgage is in default because of the monthly payment on account of amortization of the principal of the note. secured by said mortgage, interest on the note secured by said mortgage due on July 1, 1999 and on the 1st of each month thereafter are due and have not been paid as a result of which the entire principal of said note and all interest due thereon together with attorney's commission for collection and other items as set forth in said mortgage and note are now due and payable. A true and correct copy of said note is attached hereto as Exhibit "B" and the terms of which are incorporated by reference herein as though fully set forth at length. 6. On or about November 18, 1999, notice under the Homeowners Emergency Mortgage Assistance Act, Act 91 of 1983, was given to Defendants, which included notice of Plaintiff's inu~ntion to foreclose within thirty (30) days pursuant to 41 P .S. Section 403. A true and correct copy is set forth as Exhibit "C". 8. The following amounts are now due and payable: Principal of Mortgage Debt Due and Unpaid Interest from 6/1/99 @ $16.90/diem Attorney's Commission for Collection Information Search $61,732.16 4,647.50 3,250.00 250.00 Amount due $69,879.66 ,-I, ;-1 ~: WHEREFORE, Plaintiff demands judgment for the amount due of $69,879.66, plus per diem interest at $16.90, costs plus foreclosure and sale of the subject premises. -"- SA EL B. HORNSTEIN, ESQUIRE Attorney for Plaintiff "- - "' I ~.1.~~ VERIFICATION Samuel B. Hornstein, Esquire, states that he is the attorney for the Plaintiff, and that the said party is out of the jurisdiction of the court, and/or that his verification would not be available within the time permitted to file this pleading, and verifies to the best of his knowledge, information and belief that the statements made in this pleading are true and correct. He understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~- SAMUEL B. HORNSTEIN, ESQUIRE Attorney for Plaintiff Exhibit "A" . , . , ...~ . "'.,,. .~ o .EXHIBIT A .............. .,. ,'_........-..... ,_ l'~' ","''''''l-!:..I'"i';::wr'l.:.~~t:.{!t",...",\,.;" ~"_1i.<:,>,.": '':'''. '-'0" .'..,','.... '.' '. ,.._,~,',..t 'i"j\ .............,,- ~. -- I'~..'.,_.,. .... ."__.'M_' ...~_. . , '"11 TMT CBll'tAIN IDe or .~r.~' of lalld .U..on J.. Bait '_obore To.... '''i" COUMY Df Cu"b.r1...d ...d StUD .1 '.M.,.,.,...la, Mr. ,artle"',,r bDWD.d...d des.db.. .. fOUDV.. in oeeDrd...e. vlth .U'I'V.,. Df D.'. Raff'<<,""""'.", Relict.Tee!' SU1'VeIyal', d.'ted .lay ..'. 1'6'. .s folIo",. tD ..I tI BEGIIINING n a 1HIlnt Dn ch. ...terly 111\. .1 Rdo'" !lo.., ..hich poll'. i. l13.91 foo' IIor.h Df ."0 norchu.torl)' ~omer of Edor. !lo8.ll .... . -. 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'Dlnt. tit. Place of RaGINIIIIIG. :i HAVING nlSRIlON BHCTBD a '''0 atory Iorick .... fr.... ..........clo.. . dwolling -Ilou'. t....wn e.1 110. 604 hlord Ro.'. ,.. . "~....~".~=.__._,, .- . l~a ,..;, 7S9 . . i i ~ ~ I .\iI'iiG 1H8 SAJ.II 'URISES vhicll Roa..U 1:. '....in.... .... Juaa. M. aaft. iwill.r. hil ..U., lor .... cl...cl Nov...ber 6, 1971 .... recordod. in the C...."nl..... tounty Rocorder'. Office la Dad BDak "ll", '101_ Z4, Pa.., . . , tzs, 'r....t.4 and eoa~oyed unto Jo~.plt DoMuro, Jr, ...d Md... DeMuro, . Illa ..U. " .rutors heroia, I ,I' '"" ~~~ Exhibit "B" ..1 I ., ""1lJ!; (]I ~. C) PROMISSORY NOTE ~ TheClTG,eupl ~ Consumer Finance. I"'. NAMES OF All BORROWERS: LlUlRY R. REIDELL GLORIA. J. REIDELL ""''''''' Add""" 604 ERFORD RD. CAMP HILL, PA 17011 lOAN NUMBER DATE INTEREST RAlE 02/23/96 09.99 AMOUNT OF OTHER PAYMENTS $ 710.71 LENDER: TIlE CIT GROUP/CONSllMER FINANCE, INC. 600 W. GERMAN'l'OWN PIKE BUI'l'E 161 PLYMOUTH MEETING, PA 19462 Dale Finance Charge Begins To AcCIW NUMBER OF DATE FIRST PAYMENT DUI: PAYMENTS .. 02/28/96 DATE FINAl PAVMENT DUE 180 03/28/96 PRINCIPAl BAlANCE 02/28/11 $ 710.71 $ 66,174.54 The words "I," "me." "my," and "us" refer to all Borrowers signing this Note. The words "you" and "your" refer to Lender or Lender's transferee if this Note is transferred. 1. BORROWER'S PROMISE TO PAY In retllm for a loan that I have received" I promise to pay the Principal Balance stated above to the order of trn: Lender shown above. 1 understand !bat !he Lendermay transfer tbls Note. 2.INTEREST I will pay interest at the Yearly Interest Rate shown above. Interest will be charged on the unpaid principal until th~ full amount of principal bas been paid. Interest will be charged beginning on the date shown above in the "'Date Finance Charge 8e,gins to Accrue" box and will continue untillhe Principal Balance has been paid in full even if you have obtained ajudgment against me,. 3. PAYMENTS (A) TIme and PI..e or hymen" 1 will pay !he principal and interest by making payments every month. 1 will make my monthly payments on the ,,,me day or each month beg;inning on the date shown above in the "Date First Payment Due" box. I will make these payments evety mCliO.th until lhave paid aU or !he PIinclpal Balance and interest and any other cbarges described below that 1 may owe under tbls Note. If on !he "Date FmaI Payment Due" sbDwn above, 1,Iill owe amounts under tbls Note, 1 will pay those amounts in full on that date. which is called the "maturity date." 1 will make my monthly payments at the address shown above under your name or at a different place if reqnired by yon. (B) Amount of My Monthly Payments Each of my monthly payments will be in the amount shown above in the "Amount of Other Payments" box 'except my fIrst: payment will be in the ammmt shown above in Ihe "Amount of rll'St PaymentN box. 4. MY FAILURE TO PAY AS REQVlRED (A) Deranlt I will be in derault if. (1) I do not pay the full amount of any monthly payment on time; (2) I default under the Mortgage as defined in Section 10 which secures this Note or under any other mortgage on the real properly ",bject to !he Mnrtgage; (3) 1 make an assignment for !he benefit of creditots; (4) I violate or fail to abide by any term or condition of this Note or any other agreement I have with you; (5) I have made any statement or representation to you in connection with this loan which is false or incorrect; (6) I begin (or if someone else begins against me) a case in bankruptcy, receivership.reorganization,rebabllitation, insolvency or any other tnatter whether or not similar to them; or if a receiver. sequestrator, liquidator, truStee, guardian. cOJIlSetVator or other judicial representative is appointed for me or any of my property; or (7) my property becomes subject to a proceeding in eminent domain or other similar governmental action. Ifl am in deCaul~ yon may require me to pay the full unpaid principal balance plos accrued and unpaid interel. and any other amounts I ,then owe to you under this loan. after the delivery of, and the expiration of any time period provided in. an~' notice required by law and applicable to tbls loan. (H) Check Colleetion Charge Ifl make a payment by check, negotiable order of withdrawal. share draft or other negotiable insttument and tbat instrument is returned or dishOnored for any reason, I will pay you a check collection charge. The amount of the cha:rge will be an,r amount passed on to you by any financial institution in connection with such instrument not to exceed $20. SEE OTHER SIDE FOR ADDITIONAL IMPORTANT TERMS. I hereby acknowledge receipt of a completed and signed COI'Y orthis Note. ~ :1.J/<- :f.;&-.ff- ~,.L,,, GLORIA. REIDELL (Botrower) 02/23/96 (Date) 02/23/96 (Date) (Date) (Borrower) #960221525110/ACAPS 202:nJA(S/9S) PelIlIS)'lvaIliaOvc:r $So.OOO(PrepaymClltJ>euallJ) .......T'l"... ........n'U' _ '1!r^m 'Il.'Il.T n'DTr.<_T"-T1I.T. .. I. \:1:,,' ~ (C) Payment of Note Holder's Costs and ExperlSeS If I default and you require me to pay in full as described above, I promise to pay all reasonable cosls and expense:; you actually incur in foreclosing on any Mortgage or collecting this loan, including your reasonable outside attorney's fees. S. MY lUGHT TO MAKE PREPAYMENTS/PREPAYMENT PENALTY I have the right to make payments of principal before they are due. Any payment made before it is due is known as a . "prepayment." A prepayment of only part oithe onpaid principal is known as a "partial prepayment" H I make a partial prepaymenL there will be no changes in the amounts of my monthly payments unless you agree to Ihose changes. Except as provided below. I will not be required by you to pay any interest not yet earned. If 1 prepay this loan in full during the firlit 5 yeatS of the ('oan, you may charge me a prepayment penalty in an amount equal to 5% of the unpaid principal balance if prepayment occurs during the first year, 4% of the unpaid principal balance if prepayment OCCOIS during the second year, 3 % of the onpaid principal balance ti: prepayment OCCOIS during the third year, 2% of the unpaid principal balance if prepayment OCCOIS during the fourth year. and 1 % (If the unpaid principal balance if prepayment OCCOIS during the fifth year. This prepayment penalty will not be charged if the prepayment in full is as a result of your refinancing of this .loan. You earn any prepaid finance charge at the time the loan is made and no parl~ of it will be refunded ifl pay in full aheadof schedule. 6. PROPERTY INSURANCE Properly insurance is required to be maintained by me to protect you against loss of or damage to the real estate cc:JiVered by the Mortgage discussed in Section 10 below for Ihe entire term of this loan. I may choose the person.:reasonably satisfactory to you through whom such insunmce is to be obtained or may, utilize existing covemge, but must obtain insurance again:n such risJrs and casualty and in such amounts of coverage as you require, with loss payable clause(s) satisfactory to you. 7. MY WAlVERS . I waive my rights to requite you to do certain things. Those lhings are: (A) to demand payment of amounts due (known as "presentm.ent"); (8) to give notice that amounts due have not been paid (known as "notice of dishonor")j (C) to obtain an official certification of nonpayment (known as a "protest"). Anyooe else (I) who agrees to keep the promises made in this NO!<', or (d) who agrees to make payments to you if I fail to keep my promises under Ibis Note, or (ill) who signs IbisNote to ttansfer it to ~lOID.eone else (known as "guarantors, sureties, and endorsers"), ~ waives these rights. 8. CHANGES/DELAY IN ENFORCEMENT No change or cancellali9I1 of this Note sbaIl be effective unless the change or cancellalion is in wriring and has been signed by you and me. You can delay enforcing, or fail to enforce, any or aU of your remedies under this Note without losing dtose or other remedies or rights. ,. GIVING OF NOTICES Any notice that must be given to me under this Note will be given by delivering it or by mailing it addressed to me at the Property Address above, except if applicable law.requires some other method of delivery. A notice will be delivered to me at a diffi=ntaddress if I give you a notice of my different address. Any notice that must be given to you under this Note will be given by mailing it to you at the address stated above, except if applicable law requires another method of delivery. A notice will be mailed to you at a different addre:ss if I am given a n.otice of that different address. 10. THIS NOTE COVERED BY A MORTGAGE A Mortgage of the same date containing a desCription of my real property protects you from. possible losses which alight result if 1 do not keep the promises which 1 make in this Note. This Note is secured by that Mortgage. That Mortgage describes hnw and andor what conditions I may be required to make immediate payment in full of all amounts that I owe under Ibis Note. 11. RESI'ONSmILITY OF PERSONS UNDER TIDS NOTE If more than one person signs Ibis Note, each of us is fully and personally obligated to pay the full amount owed plus the charges as described in Section 4(C) above and to keep all of the pro~ made in this Note. Any guarantor, surety, or endorser of Ihe Note (as described in Section 7 above) is also obligated to do these-things. You may enforce your rights under this Note agaullst each of us individually or against aD of us together. This means !bat any one of us may be required to_pay aU of the amounts 0Wlld under this Note. Any person who takes over my rights or obligations under this Note will have aU of my rights and must keep aU of my promises made in this Note. Any person who takes over the rights or obligations of a guarantor, surety, or endorser of Ibis Note (atll described in Section 7 above) is a1so obligated to keep all of the promises made in this Note. 12. APPLICATION OF PAYMENTS All payments received by you shall be applied to accmed and unpaid interest to the date of payment and then to the unpaid Principal Balance. 13. WAN CHARGES If a law, which applies to this loan and which sets maxinium loan charges, is finally interpreted so 'that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (i) any such loan. cbarge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (Ii) any sums already colleCIted, from me which exceeded pennitted limits will be refunded to me. You may choose to make this refund by reducing the principWl I owe utuIer this Note or by making a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial preJ:tayment 14. APPLICABLE LAW Pennsylvania taw and any appliCable Federa11aw governs Ibis Note. In the event of a conflict between any provisiOll of this Note and any Federal or Pennsylvania statute, law or regulation in effect as of the date of this Note, the statute, law or rw::gu1ation win control to the extent of such conflict and the provision contained in this Note will be without effect. All other provisiOD:5 of this Note win remain fully effective and enforceable. SEE OTHER SIDE FOR ADDITIONAL IMPORTANT TERMS 2-2221B - i, 01/31/00 09:13 FAX 9 405 553 4702 C. I.T .. .~~:-. :....\ ..,.... '. , <::......';J II - "~,,,.'\i .1 '., , . .~ . :1 . ." -\{-:.,~~":: -:;::;~':~:l ! ~ \; '~i;l . ;:Q...;,,1 . ,; . .E~ ..... ~ '2 0- < g :; NOTICE OF INTENTION TO FORECLOSE ! '" The Mortgage held or serviced by the CIT Group/Consume "- us or ours) on your property located at 604 ERFORD RD..' CAIIiI IN SERIOUS DEFAULT because you have not made the monthly payments since 8/31/1999 through today. The total amount required to bring your mortgage current is . calculated below: -, ... ::- The C1T Group/COnsumer Finance, Inc. National Customer Service Center P.O. Box 24510 Oklahoma City. OK 73137-0555 Tel: a0lJ.621.1437 Fax: 405.553-4702 November 18,1999 LARRY R. REIDELL GLORIA J. REIDELL 604 ERFORD RD CAMP HILL. PA 17011 RE CIT Group Reference Number: 27139039 Property Location: 604 ERFORD RD. CAMP HILL, PA 17011 Payment of$ 710.71 per month due on 01st of each month to the date of this letter and each month thereafter. Late charges of $ 0.00 per month due after the fifteenth day of the month from 8/31/1999 to the date of this letter and each month thereafter. TOTAL AMOUNT DUE ,-~.l -; I4i 005 , Z .261 037 415 us Postal Service . Receipt for Certified III/ail No Insurance Coverage ProVided Do no! use for InternatlonaJ Ma . .. Sontto if 1&'8 I'eVersBj street & Number Post Office, S1ate. &. ZIP Code PoSlage $ Certtffed Fee Spada! !lelivwy Fe. i Restrfcted Oe8very Fee Row", Reco/pl "'-og 10 Whom & Dale DellYElfBd RoOm/lo:e;llShowilg . Da.'~~-'I lOTA1.poelag.,,,,, 1$ -""''''Dale t"HILL.r_. ........ $ 3,545.65 $ 0.00 $ 3545.65 You may cure this default within THIRTY (30) DAYS of the date of this letter by paying us the sum of: $ 3,545.65 PLUS any additional monthly payments and late charges which may fall due during this period. Any additional monthly payments and late charges will accrue at the amounts set forth above. Such payment must be made either by case, cashier's check, certified check or money order, and made payable to: THE CIT Group 715 South Metropolitan Avenue Suite 150 Oklahoma City, OK 73108 Attn: Rick Lewellen Exhibit "C" CF316 ,.' 01/31/00 09:14 FAX 9 405 553 4702 C.l.T 141006 " ~ 't!b.:; '" ED . , ::- f If you do not cure the default within THIRTY (30) DAYS. we intend to exercise the lender's right to accelerate the mortgage payments. This means that whatever is owed 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, the lender also intends to instruct our finn to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed. your mortgaged property will be sold by the Sheriff or other similar official to payoff the mortgage debt. If you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe the lender, which may also include our reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you woe the lender which may also include our reasonable costs. If you cure the default within the thirty-day period you will not be required to pay attorney fees. The lender may also sure 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 (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's or other similar official foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attomey's fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriff's or other similar official's sale could be held would be approximately seven months from today. A notice of the date ofthe Sheriff's or similar official 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: 1-80lHl21-1437 This payment must be cash, cashier's check, certified check or money order and made to The elT Group/Consumer Finance Inc, at the address stated above. You should realize that a Sheriff's or other similar official sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's or other similar official sale, a lawsuit could be started to evict you. You shall have the right to assert in the foreclosure proceedings, the non-existence of a default or any other defense that you may have to acceleration or foreclosure. YOU HAVE THE RIGHT OT 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. CF316 . 01/31/00 09:15 FAX 9 405 553 4702 C.LT e . '" . . .. ::- YOU MAY HAVE THE RIGHT 'f0 SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTRGAGE 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 WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default. the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cljre your default more than three times in any calendar year. THE CIT GROUP/CONSUMER FINANCE. INC. CF316 ....... ~007 _ ~l lilt: 01/3weo 09:11 ~ f f/. .. .' ~ :" . ~ ~~ FAX 9 405 553 4702 C.I.T I4i 002 ----- ......Z 21. r--. 1 ~U:j7445 US POoIaIS Receipt i""ce . No Ins."'n"" Coor Certified .. Do nOI Use ! ""'age Provicl .v.all Sent 10 Or In(ema~ ~. Ma,l Sss reI "'roe Srreet&Nllmber POSt Offiii Qo~ , _e, & ZIP Code """"ll8 The CIT GrouplConsumer Anance. Inc. National Customer Service Center P.O. Box 24610 Oklahoma City. OK 73137.0655 Tel: 800-621~1437 Fax: 405-553-4702 November 18, 1999 :...1 i,,"WJ .!-.. ~f~~ '~:g] ACT 91 NOTICE IMPORTANT: NOTICE OF HOI CertfftecfFee SpaQ'a/ De/ive,y Fee on Rostdcted 00i1,"? I'e. ~ RslumR_s ';; !\Iulm.OaleOollhovdiiplo ... Il&o.ii""""" ..... "" &~~.~ g' ~..,~,-. :g rorAlPoet"ll8&..... 8 PoiiiiiB;;(orllaie Ii: ff! $ i .~ ~ , ~ LARRY R. REIDELL GLORIA J. REIDELL 604 ERFORD RD CAMP HILL, PA 17011 RE: CIT Account Number: 27139039 $ EMERGENCY MORTGAGE ASSISTANCE ACT OF 1911;j PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS. :<" ~i ..! -, Your mortgage is in serious default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $ 3545.65, which includes the following payments: JULY 99, AUGUST 99, SEPTEMBER 99, OCTOBER 99, NOVEMBER 99. i j ....~1 \~;~l ~ ~ :>-.~.~I :~~~~~~ '.:-;..1 Your mortgage is also in default for the following reason: LACK OF FUNDS. You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control. and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. 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 have the right to arrange a "face-ta-face" meeting with a representative of this lender. or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan. or to otherwise settle your delinquency. That meeting must occur in the next thirty- (30) days. I. ~.t ::-.'1 -;.., CF316 ."'," . . 01/31/00 09:12 FAX 9 405 553 4702 C. I.T -, @;""'. 'd. o.' .. V '. < If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name. address and telephone number of our representative is: LAVONNE DAVIS 715 South Metropolitan Suite 150 Oklahoma ~ity, OK 73118 Telephone Number: 1-800-621-1437 The names and addresses of designated consumer credit counseling agencies are/is: Urban League of Harrisburg 28 North 2nd Street Harrisburg, PA 17101 1-717-234-5925 Action Housing, Inc. Number Two Gateway Center 10th Floor Pittsburgh, PA 15222 1-412-281-2102 It is only necessary to schedule one face-tp-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve! this problem at or after your face-to-face meeting, you have right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In:order to do this,you must fill out, sign and file a completed Homeowners' Emergency As;;istance Application with the Pennsylvania Housing Finance Agency. The consumer predit counseling agency will assist you in filling out your application. It must be filed 'or postmarked within thirty (30) days of your face-to-face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency. or you must file it at the office of one of the designated consumer credit counseling agencies listed above. The Pennsylvania Housing Finance Agenl?Y is located at 2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105. Telephone No. (717) 780-3800 or 1-80D-342-2397 (toll free number). An application for assistance may be obtained from a consumer credit counseling agency or directly from the Pennsylvania Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage lilssistance are very limited. They will be dispersed by the Agency under the eligibility of criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The counseling agency will help you to fill out the application. The Pennsylvania CF316 "'"M'iil; ~003 - " " 01/31/00 09:13 FAX 9 405 553 4702 C. I.T :! ~ ~ ,!,,.,' . ~ , Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During the additional time, no foreclosure proceedings will be pursued against you If you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. In addition you will receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose". You must read both notices, since both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you received financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. Sincerely, The CIT Group/Consumer Finance, Inc. Collections Department 1-800-621-1437 This is an attempt to collect a debt and any infonnation obtained will be used for that purpose. CF316 " 't, 141 004 iMlIiIIMmlI~"'~''''''''-~~'''~1 "~~~,.~" --'~:.,..,w"""-~., , ~-" "~ ""~'" -.........., "," p~ !i g If:. ~ () !r\. gc --0 c8 I ::::.: -..t ~t? ~ -Jt "" '"", ' o ~ "l:'J['-: O)C' ~; ~ -1.-:;.-.. ~~~ L~; )>(- Z --, -< ,_. .0. C:~ C) "1 "'1 (JJ , '-.0 ~G '1'- V) ';6 ":- "'"j ~~~~ );: -'J -< :('". '?? :::> OJ