HomeMy WebLinkAbout00-02422
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Beneficial Consumer Discount
Company d/b/a Beneficial Mortgage
Co. of Pennsylvania
961 Weigel Drive, P,O. Box 8604
Elmhurst, IL 60126
v.
Ellen J. Deschenes
1600 Orrsbridge Road
Enola, PA 17025
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Attorney for Plaintiff
Cumberland County
Court of Common Pleas
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Number
CIVIL ACTION/MORTGAGE FORECLOSURE
NOTICE
You have been sued in court. If you wish to defend
against the claims set forth in the foL Lowing
pages, you must take action within twenty (20) days
after this compLaint and notice are served, by
entering a written appearance personaL Ly 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 HELP.
CumberLand County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
AVISO
Le han demandado a usted en la corte. Si usted
qui ere defenderse de estas demandas ex-puestas en
las paginas siguientes, usted tiene veinte (20)
dias de pLaza aL partir de La fecha de La demanda y
la notificacion. Hace faLta asentar una
comparencia escrita 0 en persona 0 con un abagado y
entregar a La corte en forma escrita sus defensas 0
sus objeciones a Las demandas en contra de su
persona. Sea avisado que S1 usted no se defiende,
la corte tomara medidas y puede continuar la
demanda en contra suya sin previ 0 avi so 0
notificacion. Ademas, La corte puede decidir a
favor deL demandante y requi ere que usted cumpla
con todas las provisiones de esta demanda. Usted
puede perder dinero 0 sus propiedades u otros
derechos import antes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIA TAMENTE. SI NO TIENE ABOGADO 0
SI NO TIENE EL DINERO SUFICIENTE DE P AGAR
TAL SERVICO, VAYA EN PERSONA 0 LLAME
POR TELEFONO A LA OFlCINA CUY A
DIRECCION SE ENCUENTRA ESCRITA ABAJO
PARA A VERIGUAR DONDE SE PUEDE
CONSEGUlR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
CarLisLe, PA 17013
(717) 249-3166
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, pennsylvania 19109
(215) 790-1010
Attorney for Plaintiff
Beneficial Consumer Discount
Company d/b/a Beneficial Mortgage
Co. of pennsylvania
961 Weigel Drive, P.O. Box 8604
Elmhurst, IL 60126
Cumberland County
Court of Common Pleas
v.
Ellen J. Deschenes
1600 Orrsbridge Road
Enola, PA 17025
Number
CIVIL ACTION/MORTGAGE FORECLOSURE
1. Plaintiff is Beneficial Consumer Discount Company d/b/a
Beneficial Mortgage Co. of Pennsylvania, a corporation duly
organized under the laws of Pennsylvania and doing business at the
above captioned address.
2. The Defendant is Ellen J. Deschenes, who is the mortgagor
and real owner of the mortgaged property hereinafter described, and
her last-known address is 1600 Orrsbridge Road, Enola, PA 17025.
3. On June 23, 1999, mortgagor made, executed and delivered
a mortgage upon the premises hereinafter described to Plaintiff
which mortgage is recorded in the Office of the Recorder of
Cumberland County in Mortgage Book 1552, Page 582.
4. The premises subject to said mortgage is described in the
mortgage attached as Exhibit "A" and is known as 1600 Orrsbridge
Road, Enola, PA 17025.
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5. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due November, 1999 and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest 11/99 through 3/3/00
(Plus $31.33 per diem thereafter)
Attorney's Fee
Cost of Suit
Appraisal Fee
Title Search
$78,868.44
$ 7,513.35
$
$
$
:3
3,943.42
225.00
125.00
200.00
GRAND TOTAL
$90,875.21
7. The attorney's fees set forth above are in conformity
with the mortgage documents and Pennsylvania Law and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the mortgage is reinstated prior to the Sale, reasonable
attorney's fees will be charged based on work actually performed.
8. Notice of Intention to Foreclose as required by Act 6 of
1974 (41 P.S. ~403) and notice required by the Emergency Mortgage
Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et
seq., commonly known as the Combined Notice of Delinquency has been
sent to Defendant by certified mail on the date set forth in the
true and correct copies of such notices attached hereto as Exhibit
liB. II
WHEREFORE, Plaintiff demands Judgment against the Defendant in
the sum of $90,875.21, together with interest at the rate of $31.33
per diem and other costs and charges collectible under the mortgage
and for the foreclosure and sale of the mortgage property.
,-'10A.M-'V'\.LL~ . f/lAv~
TERRENCE J. CABE, ESQUIRE
Attorney for Plaintiff
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VERIFJ:CATJ:ON
The undersigned, Kevin Marshall, hereby certifies that he is
the Foreclosure Specialist of the Plaintiff in the within action,
Beneficial Consumer Discount Co. d/b/a Beneficial Mtge. Co. of PA , and that
he is authori~ed to make this verification and that the foregoing
facts are true and correct to the best of his knowledge,
information and belief and further states that false statements
herein are ma.de subject to the penalties of 18 PA.C.S. !'?4904
relating to unsworn falsification to authorities.
KEVIN MARSHALL
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I MORTGAGE I
IS CHll<;:KBO. nns MO'R.TGAGE IS AN OI'BN-BNlI MOlllGAGE A.ND S1lCVllB$ F1JTVllB
D If' BOX
Ar>VANCJ<ls
'Tlils MORTGAGE is made this day
ELLEN DESCHENES, SINGLE
23RD
of
.lUN~
19...22..., between Ih.o Mortgagot",
(herein "Borrower") and Mortgagee BEN~FICIAL CONSlNER DISCOUNT COMPANY D/B/A
BENEFICIAL MORTGAGE CO OF PENNSYLVANIA
a corporatIon ot"ganize.i and eltsting und.,. the laws of P~NNSYLVANIA
4g10 CARLISLE PIKE/Sl04, MECHANICSBURG, PA 17055
(herein "Lender").
,
, whose address is
The lonowing paragraph pr~ceded by a checked bOI is applicable.
G:J WHBREAS, Bo!'l'O"er i. indebted 10 l.ender in the prindpal sum of S 62. a~(l. 60 ,
evidenced by llorrower'. Loan Repayment llII<l Security Agreement or Secondary M()J"\g.ge Lolln Agreement <lated
JUNE 2:3. 1 B9B and any extensions or renewals thereof (herein "Note"), providing f<>r monthly
inslallments of pnnoJpllJ llIId inlCtest, ,noludingan,y adjustmenlS to the amount of payments or the contracl rate if that
rate i. variable, with the balance nf the indebtedness. 1f not sooner paid. due and payable on JUNE 28, ZOZg
D WHEREAS, Borrower i. indebted 10 Le'lCler in the prinoipal sum of $ , or so much
thereof JlS may be advanced pursuant to Borrow",,', Revolvh)g Loan Agreement datod
and extensions and renewals Ihereof (herein "Nole"). providing for monlhly inst.ellments, and intetest at the nile and
undu the terms specified in the Nolo, incluclin,g ony adjustments in the interesl rate if th,t rate i, VlIriable, and
providing ror a credit limit stated in the prineipal SlIm above and an initial advllllCCl 01 $
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TO SECURB to LenclOr .he repayment of (I) the indebtedness evldcncod by the Note, with interest thereon,
inoludinlr any incr....... if the conll'aCt rate is variable; (2) future advan<:es under any Revolvinll Loan Agreement; (3)
the payment of all other SUMs. witb ;0_ thereon, advanced in .._rdanee herewith 10 prole'" the security of this
Mortgage; Illld (4) the perform...... of the covenants and agreements of Borrower herein contained. Borrower does
hereby mortgage, grant and convey. 10 Lendor and Lender's suecessors and assigns the following described propettY
lo'cated in the Comlty'of, ClNBERLAND Cammonw(lllltb of Pennsylvania:
ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF
HAMPDEN IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF
PENNSYLVANIA, BEING MORE FULLY DESCRIBED IN A FEE SIMPLE
DEeD DATED 07"611B84 AND RECORCED 07/17/84. AMONG THE LAND
RECORDS OF THE COUNTY AND STATEE~RTH ABOYE, IN VOLUME
U-30 PAGE 408" .- LlZB'IT
TAX PARCR 10: 10-15-1285-006 I7J
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T0GETHER with all the improvementS now or hereafler orcclcocl on the property. and all _moots, rights,
appurtenances and s1mW. all of which shall be deeme<l to be and remain a part of the property ClOV...ed by thi.
Mortgage; lUld all or the f01'tlgolng. together wilh said property (or the leasehold estate if thIs Mortgege i. On a
l~hold) ate herein\.fter referred to Illl the "Property: .. '
Botrower cove~ants that Borrower is lawtully ..Ised ot th. estate. bei'eby conveyed and b8s' the right to
mOTtpge. grant and convey the ~y, and that the pI<lpertf is urlencuinbet"ed, e1<Cept tor' OIlcumbranoes of
r~l'd. Borrower CO~18 \hat llorrowcr II'alTllnts and will detMd gMerllly the title to the Property agaJllSt all
claims and demands. subjeCt to encumbtancC1l of record. '
UNIFORM CO~ENAN1'S. B01'1'OwOl" and Lencler covenant and agree as follows:
t. Payment of, Principal and Interest a1 Vllriable.R.tes. This mortgage secures 011 payments at principal
and intereSt due on l a variable tate loan, The eonltact rate of interest and payment BmOUll18 may be subject to
chal1gl;> IS provi4ed i!> the Nots, Borrowers shall promptly pay when due all amounts required by the Note.
2. FUlUb ror Tares and Insurance. Subject to awlle.bl. law or ...iver by L:nder, Borrowet' ehall pay to
Lender on the day thoolhly paymenls of principal and interest ore payable under Ihe Note, until the Note is paid
in full, a sum (hoor.,;!' "Punds"1 equal to one"twelfth of the yearly ta'ios and SS!ICBBments (lncl\lding enndominium
and planned unit developm...! assessments, if Iny) which msy attain priority over Ihis Mortgage and ground !'tnIS
,on-the .Property,.;r.iny. pl"".one"twelfth-ol-yeorly'premium-i~\Im.ntl>'for-t..w.rd' Uisuniilcei' 'pliJs-oi\~'welfth 'of -.
yearly premium instl.lIml'l!lts fol' mottgsge idSurance, if any, 1Il1 as <__nably estimated irti!ially lUld from time to
time 'by l...end.,. on !the basis of assessments and bi.11s llDd reasonable estimates thereof. Borrower sholl not be
obl[g.ted to malee six;h payments of Funds 10 Lender to Ihe extent that BortOwer makes such paymento to the
holder of a prior m<{rtgage or deed of trust if such holdc:r is an instltution.allender.
II BorroWer pays Funds to Lender, the F1Jnds shall be held in an institution the dcpositsot accounts of which
are insured or guaranteed by a Federal or slate agency (including LendCt if Lender is sueh an iostitution). Le>tder
'shall apply the Fun!ls to pay said taxes, """",,"men.ts, insUranco premiums and ground l'Olll$. Lender may not
charge for so holding and appl)'ing \he Fonda, analyzing Sllid account or venfyine and compiling ";d lI5SOSSments
a'ld bills, unless Lender pe,ys Borrower interest on the Funds and applic.ble law' permits Lender to make such a
charge, Borrower ana Lender may .agree in writing al the time of execution of this Mortgage that interesl OQ the
Funds shall be paid to Borrower. and 'unless s\lQI1 agreement is 'made Or SWlica ble law'requin:s $Ucli intet'O$t to be
paid, Lender Ghall n?t be requircdto pay Borrower any jntol<si or earnings on the F1Jnda, Lender shall give to
Borrow..., without charge. an Innual accounting of lh<> Funds sho\\ing c~ts and debits to the Funds and the
purpose fat which e4ch debil to Ihe Funds was made. The Funds are pledged as additional aecurity for the SUms
=unod by thia Mortgage,
If the amOllnt <if tbe Funds held by Lender, 'togetber with the fulure monthly ~lIm""ts of Funds payable
prior 1.0 tM d\Jt\ dates of tans, _mellts, insural\~ promiUS!l$ and grolllld tents, shall eJreeed the amount
n:quiroo to pay said lues, .......", ""Ill. insuranc. premiums and ground tents as Ihey fall due, such IIC_ shell be.
at BOl'tO...er'. opuorl, either promptly ~aid 10 Borrower or eredited to Borro...... Of> mootbly installments of
funds, If the amourit ot the Funda held by Lender shall not be sufticient to pay taxes, llSSessments. illSuraooe
premiur'n$ ana eroudd feD18 all they fall due, Bor:rowet sball pay to tender .ny amount necessary to make up the
deficiency io one orJ!~ pay~~lj; ~,Len<1"" maY_"':9!!ire. __.___", .." ,~____, __.-_~ _ - ,.
. . - -- ,..tif>on Pay,liint'in fUll of all sums eec:ured by th.s Mortgage, Lender sholl pcomptly refund to Sorrower any
funds held by Lcnd~, If "ndor paralP"'l'h 17 hereot the PropertY is sold Of the Property is otherwise acquired by
Lender, Lender shall, apply, no later than immedialely prior to the sale of the Property or ita scquisilion by
Lender. a,ny Funds held by Lender at the time ot application as a credil agaillSt the sums secured by this
Mortgage. , I
3, Applicltion I of Payments. Except for loans made pursuant to the Pennsylvania Consumer Discount
Company Act. all payments received by Ulnder under the Note and peragraphs 1 and 2 hereof shen be applied by
l..ruler first in paym~t of amounts payable to Lender by Bol'1'O...... undor paragraph 2 hereof. then to interest, a.nd
thon to Ih.~ Principal.'
4. PdQ< Mortga~. and Deed of Trust; Cllartes; Liens. Borrower o!\all t:'erform all 0 of Borrow.,....
obligations' under anli mortgage. deed of trust Dr other security agreemen~ wi~ a lien which has priority ov!,~, this
Mortgage, i!"Ciuding ~l'1'OWet'S COV1lnants to make payments ...h.en due, Borrow"" ahall pay or ~use to be paid 011
tu.... .......sm'ents and other charges. tines and impositions attributable to tile Property which may atloin a priority
OVtr this Mortgage, aM. leasehold payments or ground rents, if allY. ' 0 ' .
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P.05/14
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, " Hanrd 1l1suranCle. BOlTOwe( shatlleeep the improvements now existing o.r hm;sllct ereoled on the Property
insured against loss by fire, haurds included within the wm "ezt<<tded covC(~ge'- and IlUCh other hazards ~ Lender
may requi117.
The il1S~ caTrier providing the insul'lloce sh.all be chosen by the Borrower subject w'approvaJ by Lender;
provided, that such approval shall not be unreasonably withheld. All insurance pol;.,ies and reo""'.!s thereQf shall be in
. form aoceptable, to ,Lender IQld shall include a ,standard mortgage clause in favor o~ and in a form acceptable to
Lender. Lender shall haY<: the right to hold the policica and renewals thereof, subjecllo the terms of any mortgage,
deed of irust or other security agreem.....t wilh a lien which has priority over this Mortgage,
In the event of loss, Borrower shall give prompt notice to the illS\lts\lOO carrier 'and Lender. Lender may make
proof of loBS if nol made promptly by Borrower.
If the Pl'OP."rtr is abandoned by Bortower, or if Borrower fails to respond to Lender within 30 day:< from the
date notioe is mailed by Lender to Borrower that the insurance carrier 'Offers to settle a claim for insurance ben.filS,
Lender is authorized to collect and apply lhe iM"r..,ce proceed. at Lender's option either to restoration o.r repair of
the Property or to the sums secured by this Mor~.
6. ?re.ervation and Maintc>nanee of Ptopeny;' Loaa>e.bold$; Conelominium.; Plalllled Uo.it
Development.. Borrower s!ulll keep the Property in good repair and shall not OOtl\m!t waste Ot' permit imp3irment
or deterioration of the Property, aod.shall.oomply. with the pro,vi$ionS"of,any.lees.e.if.th,is Mort~is on,~..l_hold.1f
this Mortgage is on a unit in a oondominium or . planned IltIit QcvelQpment, Bol'l'Qwe< shan perform all 'of
Borrower's oblilll'tiollS under the declaration or oovenant. creating or goverlllng the condominium or "Ianned unit
development, tho by-laws and regulations of Ih. condominium or planned unit development, and conSlltU6llt
documents.
7. Protection of Lender's Security, If Borrower lails to perform the oovcnanlS and agreements conuined in
this Mort&age, or if any action or proceeding is oOl'llmenccd which materially affects Lender's interesl in the Property,
then Lender, at Lender's option. llpon notice 10 Borrower, may make such appearances, disb\ll'ge such sum" including
reasonable attorneys' !_, and take such action as i. """..sary 10 pro_ Lender'. intea'esl.
" Any llmounu.dillburoed by Lender PUl'$uant to this Jl'Il'IIt:I'llph 7, with inlerf>st lheroon, at the contraCt rate. 'shall
,become additional indebitdnc:ss of Borrower secured by this Mortgage, Unl_ Borrow... and Lenoo- agree to other
'lem,. of payment,' Bu<;h amounts sMlI be payable up'n notice from Lendet to,~rrower requesting paymentthercof,
,Nothillg,conta,inOd ,in tbis para~ph 7 s~all.R<.luite .LetIder to,inc,ur any expeme or Ia~any action h01'Wndcr., '
8. Inspeetion. Lender ",.y tske Or ClIuse to, be made teaIlunable entriO$ upon Illd inspections of the Property,
provided that Lendar shall give BOt't'Ower notice prior to any =1i inspection specifying tossonable ca"",! Iherefor
relaled to Lender's interest in tbe PropertY,
9. Condemnation. The proceeds of any award or claim for damages, direcl or consequential, in connection with
any condemnation or other takifli 01 the ProperlY, Or part thereof, or lor conveyance in li<ru of condemnation. are
hereby assigned and shall be paid to Lendet, subject to the terms of any mortgage, deed of trust Or orher -...rity
agreement with a lien. which b~ priority over this Mortg;ige.
, '10. Borrower No~ ~leBsed: Forbearance, By Lender Not a Waiver. enellSion or the time for payment or
modification of amottizslion of the sums secured by this Mort,gage granled by J.onder 110 any liUCCCSSOt in ;n_ of .
Borrower shall nol operate to release, in any manner, the liability of tile original Borrower and Borl'OWer's s~
in interest= teniler shall not be required to commonce procoedingS'8pin&t such successor or refuse weneod.time for
payment or otherwise modify .morthalion of tbe sUms secured by this Mortgage by reason of any demand tt1&Qe by
the original Borrower and Borrower's successors in inlereat. Any forbearance by Lender in exercising any right or
remedy hereunder, or otherwise afforded by applicable law, shall not be . waiver of 01' preolude the exercise 01 allY
sUch right or remedy, ' ,
11. Successors anel Assigns Bound; Joint and S.veral J:.iabillty; Co-signers, The covenants and agreements
herein contained sball bind, and the rights hereunder shall inure 10, the respective _cessors and assigns or Lender and
BOl'l'ower, subject to the provisiollS of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint
.M several. Av;y Borrower who oo-signs this Mortgage, but dCJe$ nol ~ute the Note, (a) is oo'"Signing this Mortg~ge
""ly 10 mortgage, grant and convoy tha~ BOlTowQr'. intt:~ in the .Property to Lender under the terms of this
Morigoge, (b) is not' petoonally .liable on the Note or ilnder this Mortgage, ;l1Id. (c) agrees that, Lender and an,y,olher
Borro"'",, l1oreurid~ may agree to extend, ",odify, forbear, or mak,? any othet llOOOinmodations with regard to the
terms 'of this Mortgage or the Note' without that Borrower's consent aM without releasing that !3otl'ower Or
mOdifying this Mortgage IS to that BorrowC('s interest in the Propert)'.
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12. Notice. &ci'P1 tor any "oti~ required under applicable Jaw to be given in lnotb.cr manner, (al any notice to
BortQwer provided iF in thi. Mortgage sball be given by delivering it or by mai!in* such notice '1>)' ewtified mail
l\<.ldrCSl!ed to Borrow~ at the Properly Add""", or at such other address.. Barrower may designate by notice to Lender
os Pt'Ovicled herein, and (b) any notice to Lender shall be given by ~Ij<>el mail to Lender's address s,tat<<! herein 9r ,to
such other address asfLendeJ< ~ay dcaignate ,by l.'loti,ce to Borrower as provi.4ed he;rem. Any notice pro'!;ded for in.this
Mortgage slJ4ll be dee,m.ed to havc ~ gl,,~ tQ !l9rrower Qr Lender when given in till! lnal!tl<ll" deal~t<1d,herein, ,
{3, Governing 'JAw; Severability. The,8tate and loeallaws applicable to this MorIse.ge obaU be the laws at the
jUli$diotion in which the P<operty is located. The foregoing scn_c:e shall \'lot Jim; t lite applicability of ,F<oderallaw to
this Mol1gage. In the FVeDt thAt any provision.or clause of this MortJ;age Or the Note confllC18 with applicable law, SWb
conrHct sb",1 notllltcct !)the!' provisiollS of tbis Mortgage or the Note which C4!l be given effect without the conflicting
provision, and to thi~ end tile Pt'Ovisions. at this Mortgage and tile Not.e Ire dr.cland to be severable. ,A,;,\lSC>d hct~n,
-costs." "o1<J?C>noes" aIu1 .attorneys' fees" include all sums to the extent m;)t prohibltod by applicable law or limited
herein, I
/4, Borrower's CopY. Borrower shall be furtdshed a COIlf<lr1ned copy of the No.... and of this Mortgage at the
time of o_utionor after recordation hereof. '
15. Rebabilitatloll LOUD A~meJlt, Borro....er shall fulfill all rl Borrower's obligations uncler aw home
re~b~ji!l!llo~. j!l1~!!"!!~k!!P~!, or other..l.'l!!IU~!!101l~,)Yl)ich .B.grrtJ..'![er.$l!'t!'!S into..~.~.~er.-J.e<!der, II.
Lend6-'s option. may require BotTOwer to exe<:Uto and deliver to tender. in a form acceptable to lender, an
assignment of any rights, claims Or defM.os which Borrower may hAve against parties who supply tabor, materials or
services in connecti~ with imp<ovemont4 made to the P<opetty
16. Trat\ofer of; tho Property. If Borrower sells or 'ltBrI.Ilfers all or any part of the Property"" an interest
\herein, excluding (oji the creation of a lien or encumbrance subordinate to Ibis Mortga!:e. (b) . transfer by deVise.
descent. or by operation of I... upon the d""th of a joint tenant. Cc) the 8f8nt of any leasehold intera;t of Ihroe years or
IC/lll nOI containing ah option to purcha.se, Cd) lite creation or a purcheae mQllOY security intorest for ha_hald
lpplionce&, (e) . ~er to a relative R$ulting from the, death of a Borrower, (f) a transfer whore the spowe or
children 01' the Borrower become IliI owner of the property. (g) a 'transfer resulting lrom a clect= of diMolution at
mattioge, leeal sep.ra~on agreernenl. or from an incidental properly settlement agreement, by wbich the spouse of th~
BOl':l'Ower becom... a.n owner of the propct1Y, (b) a transfer into an later viVO<! trust in whiCh the Borrower is and.
romains a beneficiary/and whicb does not relate to a traru<fer of righls of occupancy in tho propo. t,), or Ci)BlIY other
tnmsler or dispooitio!l described in regulations ~bed by the Federal Home Loan Bank Board. Borrower shall
cause to be submitted inlonnation required by Lender to evaluate the mnsre.-ee as if a new loan wote being made 10
the Irawferce. Borrorer will continue to be obHpted under the Note and Ihi. MorIllIl&e uol_ Lender releases
B<lrrower i1t wrilinc. I
If Lender does..ot agree to $\ICh sale Or trll1Sf~. l.eilder may declare ell 01 the sums ~<>el by this Morlga.ee 10
be immediately d~ ;\od peyahle. If Lender e:xetei..s such option 10 a"""erate, Lender shall mail Borrower noli"" of
accel.etation in accordMc.. witb paragraph 12 hereof. Sucl1110tlce $hall provide a period of Dot less than 30 days from
the dare the Mliee is kailed or delivered witllln whiCh Bortow.... may pay tpe sums declared due, If Borrower fails to
pay suoh sums prior. ~ the expiration of such period. LendOf' may. withQutfurther notice or demand on Borrower,
inVOke any rem<>elies i><:nnitte<1 blf pengraph 11 hereof.
NON=UNIFORM, COVEN:ANTIk-:&rrower'Bn,H.endor futtl1et'covSI'Ianl atld' ogree'as'folJows: -~ ,..... - -, .
17. A<<:eIeratio.rl.; Remedies. EXeepi a5 provided ID paragraph 16 hereof. upon lJorrower'. In'...cl1 of Day
covell...t ot al:reerntnl of Bortower iu this Mongage. including the covell...t. to pay whea due any sums
secured by this Mc}rlpge, Lender prior to accele1'8tioll shall live Dotl"" to Borrower .. provided in
paragraph 12 bereof,specitying: (I) the b~; (2) tbe setion re'luired to cure "oeb breach; (3) s dat~. Dot
less tha.; 30 daY$ frOM the date the notice is mailed to Borrower, by which silch breAcb mUSl be cured; and
(4) that failure tocu}" snch breach on or before the dote specified in tlle notice may result io. eccelcration of
t~ sums sc<;ured bYl tbis Mortgage, foreclosure by judicial pt'OCeOding, IWd Clale of tbe Propecty. The Dotice
shall further iuf",m Borrower of the tipt to reln.tat" after acceleration and tbe right to __rt iu the
foreclosure proceediug the nonexi.teoce of a default or ."1 other defense of :1SoN'ower to acceleratiou and
foreeJosure, If the tlreacll is nol cured On or before 'lbe <l4le specified ill the notice., Lender, 8t Lender's
,oplion, may declare!all of dIe sums secured by thi. Mortgage 10 be Immediately du" and payable without
further demand and \may foreclo~ this Mortgag" by judicial ptO<:CediDg. len<ler shall he entitled to collect
io sueb proceeding a~1 etpea$C$ of foreclosure, iJlcludi';8. bot not limited to, reasooable attottleyo' fess and
costs ofdoculneutllty evlde"ce, abstractS and title reports.
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10-01-98 MTG
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18. Borrower'. Right to Reinstate. Notwithsbulding Lender's lIC(Jelerlltion of the SUms by this Mortgage due
to Borrower's breach, Borrower shall have the right to have any proceedings begun by Lender to enforce this
Mortgage discontinued 01 any time priot to entry of a judgment enforcing this Mortgage if; (a) 1301'tOwer Pllys
Lender all .ums which would be then due und.,. this Mortgll8e and the Note had no acceleration occurm:l; (b)
BOITOwer cures on bre.aehes of any other oaVctUll1tll ot agreements of, Bprrowor eont.ined in this Mortgage; (o)
Borrow"," payS 'all ;re8sona ble.expenses incurred by Lender in enforcing the covenants and agreements of. Borrower
'contained, in .this Mortgage..and.in enforcing LenW. rem'edies as provided in I"'tagraph 17 horeaf, includitig, but
not limited 10, reasOnable attorneys' fees; and (d) Borrower,takes such 'action. as Lender ""Y reasonably require to
assure that the lien of this Mortgage, Lender's intorO<<! iri the Propc:rty and BOtl'ower'. obligation to pay th" 80m.
seGured by this Mortjjage shall continue unitI'Jpaired, Upon such payment and cute by Borrower, this MortRage and
the obligations secured h01'eby shall remain in full foroe and effect 85 if no aoceleration hed o=red.
19. A..ignmentl';'jR."!lt#;-Ap99intment of Receive...As additional ecourity hoteUllder. Borrower hereby
assigns t'l' !:endei"the/r';"18 of the Property, provided .that Borrower shell, prior ~ acceleration under pare,gnlph 11
hereof, h'> abaridonment or the Property. have the righl to collect and retain such rents as tlley become dl,le and
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payable. ,\. ", " .~ .._............
Upqn acceleration~,\Il\de'r I"'tligraph 7 her..of of aootidonment of Ih. Property, Lender shall be enttlled to heve
a receiv';: &pp.,int.!d :bY''& cQl,Irt to,enter, upon;--l8ke possessio!, of and manage the Property OIjd ,to colle<;! the rents
or tho :Property including those po$! duo, All r<>Ilts collected by the receiver shall be applied first to payment of the
costs of management of tho Property and collection of rents, including. but not limited to, receiver's I.....
premiums On receoivoc's bonds and reasonable attorneys' feos, and then to the sums secured by this Morlgage. The
rece;ver shall be liable to account only for those ants acfuaIly received.
20. Release. Upon payment of all sums Secuted by this Mortl:Jlge, Lender shall rel..- this Mortgage without
charge to BarTOwer. BQtt'Ower shall pay all costs of reeordatiOll, if any.
21. Weive. of Home.t"d. Borro......r hereby weives all righl of homestead exemption in the Property under
state or Fedorallaw.
22.. Inte...t Rete After l!1dgment. Borrower agrees the inWt'est rate payable a~ter a judgment is entered on
the Note or in ao'.c:'tioll of mortgage f~losure shall he the rete stated in the Note. '
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REQUEST FOR NOTICE Oll DEFAULT
I AND FORBCLOSURE UNDIlR SUPERlOR '
I MORTGAGES OR DEEDS OF TRUST
Borrower and Lmclei' requ"'il the holder of any mortgage. dc:cd of trust or other encumhfllllC" with a lien which has
priority over this Mdrtga". to give Notice to Le;oder, at Lender's addres; set forth on paS" one of Ib.ia Mortpge, of any
default under the suJ'>erior eneumbran<;ll ...0. of any sale or other ~losure aetl<m.
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1 hereby certify tbat 'the precis.. add.-- of the l=der (Mortgagee} is:
MECRAN1CSBURG!PA 17055
On behalf ojt the Leddllr. By: HEATIlER L CLUGSTON
COMM,ONWEAL T.H OF PENNSYLVANIA, l.ANCAS'tIlR
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I. HEATHER L CLU.GSTON ,~ Notari" Pul>JiQjl1 and for Slid ""ullly and $tate, do hOfQby certify that
DAVID T H1LSINqER AND ~UR1~ E nILSINGEK, Hl~ WIFE
personalty k:l).own to ~c to be the same person{s} whose name(s} ARE su\$::ribed to the foregoing i.-ument,
appeared before me this day in person, and acknowledte th.al..!- he Y signed and delivered tbe said illllttument os
THEIR OWN I free voluntary eet, tor Ihe \J6e8 and purpo_ therein '!lOt forJ:b.
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Oi veil under my hand and official seal, this
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My Com missiOll exPires:
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4910 CARLISLE PIKE SUITE 104
Title: MANAGER
CounlYBB:
21ST da:y of JUNE. , 19 99 .
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otary l'ubllc
This instrument was pADStl'Jd by:
:BEN!F!CIAL CO~S~R DISCO~'1. Cb~AN!~D/~!A
lll!NE-nciAi:. MORTGAGE CO OJ' I?ENNSYLVANIA
(N._)
4910 caRLISLE PIKE S01TE104
MECHANICS80RG,PA 17055
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January 24, 2000
Ellen Deschenes
1600 Orrsbridge Road
Enola, P A 17025
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose,
Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEAP) mav be able to help to save vour
home,
This Notice explains how the program works,
To see if HEAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the
Counseling Agencv.
The name. address and phone number of Consumer Credit Counseling Agencies serving vour Countv are listed
at the end oflhis Notice. Ifvou have anv questions. vou mav call the Pennsvlvania Housing Finance Agencv
toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869,
This Notice contains important legal information. If you have any questions, rep. resen~v'fr!\te Consumer
Credit Counseling Agency may be able to help explain it. You may als, 0 want ~ntM ~LOmey in your
area. The local bar association may be able to hel ~~ ,wyer.
LA NOTIFICATION EN ADJUNTO ES DE SUMA 1M I ~~ AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASE. SI NO NDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIA T AMENTE LLAMANDA EST A AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR
SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCOUNT NUMBER:
ORIGINAL LENDER:
Ellen Deschenes
1600 Orrsbridge Road. Enola. P A 17025
711714-00-5128273
Beneficial Consumer Discount Companv d/b/a Beneficial Mortgage
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Company ofPennsvlvania
CURRENT LENDER/SERVICER: Beneficial Consumer Discount Company d/b/a Beneficial Mortgage
Company ofPennsvlvania
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTuRE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
- IF YOUR DEF AUL T HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
- IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
- IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA
HOUSING FINANCE AGENCY,
TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice. During Ihat time you must arrange
and attend a "face-to-face" meeting with one oflhe consumer credit counseling agencies listed at the end of this
Notice, THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE
PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEF AUL T." EXPLAINS HOW TO
BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days
after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit
counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only
necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSIST ANCE-- Your mortgage is in default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default). If you have tried
and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from Ihe
Homeowner's Emergency Mortgage Assistance Program, To do so, you must fill out, sign and file a completed
Homeowner's Emergency Assistance Program Application with one ofthe designated consumer credit counseling
agencies listed at the end oflhis Notice. Only consumer credit counseling agencies have the applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency,
Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting,
YOU MUST FILE YOUR APPLICA TION PROMPTL Y. IF YOU FAIL TO DO SO ORIF YOU DO NOT
FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED
AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE
WILL BE DENIED.
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,AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance
Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure
proceedings will be pursued against you if you have met the time requirements set forth above, You will be notified
directly by the Pennsylvania Housing Finance Agency of its decision on your application,
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO
COLLECT THE DEBT,
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance,)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to date).
NATURE OF THE DEF AUL T-- The MORTGAGE debt held by the above lender on your property located at 1600
Orrsbridge Road. Enola. P A 17025 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the following amounts are now
past due: approximately $1011.72 for the months of November. 1999 through December. 1999
Other charges:
TOTAL AMOUNT PAST DUE: $2023.44
HOWTO CURE THEDEF AULT-- You may cure this default within THIRTY (30) DAYS of the date of this Notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2023.44. PLUS ANY
MORTGAGEP A YMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD, Pavments must be made either bv cash. cashier's check. certified check or monev order made pavable
and sent to:
Margaret Smith
Beneficial Consumer Discount Company d/b/a Beneficial Mortgage
Company of Pennsylvania
961 Weigel Drive, P.O, Box 8604
Elmhurst, IL 60126
IF YOU DO NOT CURE THE DEF AUL T --If you do not cure the default within THIRTY (30) DAYS ofthe date
of this Notice, the lender intends to exercise its ril!:hts to accelerate the mortgage debt. This means that the
entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay Ihe
mortgage in monthly installments. Iffull payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mortl!:aged
property.
IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by Ihe Sheriff to payoff
the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender
begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were
actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all
reasonable attorney's fees actually incurred by the lender even if they exceed $50,00. Any attorney's fees will be
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.added to the amount you owe the lender, which may also include other reasonable costs. If yOU cure the default
within the THIRTY (30) DAY period, YOU will not be required to pay attorney's fees.
OTHER LENDER REMEDIES-- The lender may also sue you personally for the unpaid principal balance and all
other sums due under Ihe mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--Ifyou have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, YOU still have the rig-ht to cure Ihe default and
prevent the sale at any time UP to one hour before the Sheriff's Sale, You may do so bv paying the total amount then
past due. plus any late or other charges then due. reasonable attorney's fees and costs connected wilh the foreclosure
sale and any other costs connected with the Sheriffs Sale as specified in writing by Ihe lender and by performing
any other requirements under the mortgage. Curing your default in the manner set forth in this notice will
restore your mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale
of the mortgaged property could be held would be approximately five months from the date of this Notice. A
notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to
cure the default will increase the longer you wait. You may find out at any time exactly what the required payment
or action will be by contacting the lender.
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HOW TO CONTACT THE LENDER:
Name of Lender: Beneficial Consumer Discount Company d/b/a Beneficial Mortgage
Company of Pennsylvania
Address: 961 Weigel Drive. P.O. Box 8604. Elmhurst. IL 60126
Phone Number: 1-800-958-2540. Ext.
Fax Number: 630-617-7529
Contact Person: Margaret Smith
EFFECT OF SHERIFF'S SALE-- You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to liye in the property after the Sheriffs Sale, a lawsuit to
remove you and your furnishings and other belongings could be started by the lender at any time,
ASSUMPTION OF MORTGAGE-- Y ou mayor X may not sell or transfer your home to a buyer
or transferee who will assume the mortgage debt, provided that aU the outstanding payments, charges and attorney's
fees and costs are paid prior to or at the sale and that the other requirements of Ihe mortgage are satisfied,
YOU MAY ALSO HAVE THE RIGHT:
- TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
- TO HAVE THIS DEF AUL T CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
- TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD
OCCURRED, IF YOU CURE THE DEF AUL T. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
~~
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,- TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOSURE PROCEEDING OR
ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
- TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER,
- TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE
THE ATTACHED LIST.
NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the
validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notifY this office in
writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain
a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any
information which you supply to this office may be used by us in the collection of the debt. If you request this
office in writing within thirty (30) days after receiving this, this office will provide you with the name and address
of the original creditor.
THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THIS PURPOSE.
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SENT VIA REGULAR MAIL AND
CERTIFIED MAIL NUMBER Z 162295647
RETURN RECEIPT REQUESTED
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US Postal SerVice
Receiptfor Certified Mail
No Insurance Coverage Provided.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-02422 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
DESCHENES ELLEN J
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
DESCHENES ELLEN J
the
DEFENDANT
, at 0014:13 HOURS, on the 26th day of April
, 2000
at 1600 ORRSBRIDGE ROAD
ENOLA, PA 17025
by handing to
ELLEN J. DESCHENES
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
8.68
.00
10.00
.00
36.68
So Answers:
~~-.~~t
R. Thomas Kline
04/27/2000
MCCABE, WEISBER
Sworn and Subscribed to before By:
me this f~
day of
~ ;lcnro A,D.
q -(. a }1A.LiD.~~-
r~thonotary ,
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013
Curtis R. Long
Prothonotary
To: Ellen J. Deschenes
16000rrsbridge Road
Enola, PA 17025
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
1
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ELLEN J. DESCHENES
NUMBER 200-2422 CIVIL
NOTICE
Pursuant to Rule 236, you are hereby notified that a
JUDGMENT has been entered in the above proceeding as indicated
below.
Curtis R. Long
Prothonotary
XX Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
If you have any questions concerning this Judgment, please call
Terrence J. McCabe. ESQuire at (215) 790-1010.
,- ".-
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
ELLEN J. DESCHENES
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"'4-'."';'__
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 200-2422 CIVIL
ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment by default in favor of Plaintiff and
against Defendant in the above-captioned matter for failure to
answer complaint as required by pennsylvania Rules of Civil
Procedure and assess damages as follows:
Principal
Interest from 3/4/00 - 6/8/00
TOTAL
$90,875.21
$ 3.007.68
$93,882.89
c~
SQUIRE
tiff
AND NOW, this
/A day
of
~U"-'E...
, 2000,
Judgment is entered in favor of Plaintiff, Beneficial Consumer
Discount Company, d/b/a Beneficial Mortgage Company of
Pennsylvania, and against Defendant, Ellen J. Deschenes, and
damages are assessed in the amount of $93,882.89, plus interest
and costs.
BY THE PROTHONOTARY:
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
Attorney for Plaintiff
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ELLEN J. DESCHENES
NUMBER 200-2422 CIVIL
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF CUMBERLAND
The undersigned, being duly sworn according to law, deposes
and says that the Defendant is not in the Military or Naval
Service of the United States or its Allies, or otherwise within
the provisions of the Soldiers' and Sailors' civil Relief Act of
Congress of 1940 as amended; and that the Defendant, Ellen J.
Deschenes, is over eighteen (IS) years of age, and resides at
1600 Orrsbridge Road, Enola, PA 17025.
SWORN TO AND SUBSCRIBED
BEFORE ME THIS f/oI.or DAY
0cJt'I'I!....-
OF
2000.
---; 1/-v1 ~ /~ /rL~
TERRENCE J. MCCABE(jESQUIRE
Attorney for plaintiff
-
TARY PUBLIC
NOTARIAL SEAL
GLORIA D.,. MITCHELL, Notary Public
Clly of Ptllladelph.a, Phila, County
M Commission Expires June 2, 2003
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McCABE, WEISBERG AND CONWAY, P.C.
BY, TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
Attorney for Plaintiff
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ELLEN J. DESCHENES
NUMBER 200-2422 CIVIL
CERTIFICATION
Terrence J. McCabe, Esquire, attorney for Plaintiff, being
duly sworn according to law, deposes and says that he deposited
in the United States Mail a letter notifying the Defendant that
judgment would be entered against her within ten (10) days from
the date of said letter in accordance with Rule 237.5 of the
Pennsylvania Rules of Civil Procedure, A copy of said letter is
attached hereto and marked as Exhibit "A."
SWORN TO AND SUBSCRIBED
fj+1-
DAY
~~.l~
TERRENCE J. McCABE, ~QUIRE
Attorney for Plaintiff
BEFORE ME THIS
;) (/ t1 -e-
OF
~-
[) . CJdI
N TARY PUBLIC ~
. NOTARIAL SEAL
GLORIA D. ' MITCHEll, Notary Public
City ofPl1iladelphia, Phila. County
. Mv Commis~ion Expires June 2, 2003
, 2000.
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VERIFICATION
The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby
certifies that he is the attorney for the Plaintiff in the within
action and that he is authorized to make this verification and
that the foregoing facts are true and correct to the best of his
knowledge, information and belief and further states that false
statements herein are made subject to the penalties of 18 PA.C.S.
Section 4909 relating to unsworn falsification to authorities.
---;~~,(hc~
TERRENCE J. M E, ESQUIRE
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013
LAWRENCE E. WELKER
Prothonota:t:'y
May 17, 2000
To: Ellen J. Deschenes
1600 Orrsbridge Road
Enola, FA 17025
Beneficial Consmuer Discount
Company d/b/a Beneficial Mortgage
Co. of Pennsylvania
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v
Ellen J, Deschenes
NUMBER 2000-2422 CIVIL
NOTICE, RULE 237.5
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
IMPORTANT NOTICE
NOTIFICACION IMPORTANTE
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 withih ten
(10) days from the date of this notice, a '
judgment may be entered against you w.it.hout
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:
Ust~d se ~ncuentra en estado de rebeldia por
no:haber present ado una comparecencia escrita,
ya:.'sea personalmente 0 par abogado y par no
haber raAicado par escrito con este Tribunal
sus defensas U objeciones a Los reclamos
formulad~s en contra suyo. AL no tamar La
accion debida dentra de diez (10) dias de La
fecha de ~sta notificacion, eL Tribunal podra,
sin necesidad de comparecer usted en corte u
oir preuba alguna, dictar sentencia en su
contra' y usted podria perder bienes u otros
derechos importantes. Debe llevar esta
notificacion a un abogado inmediatamente. Si
usted no tiene abogado, 0 si no tiene dinero
suficiente para tal servicio, vaya en persona
o llame par telefono a la oficina, nombrada
para averiguar si puede conseguir asistencia
legal,
Court Administrator
Cumberland County Courthouse
Carlisle, PA 1701~
(717) 240-6200
Court Administrator
Cumberland county Courthouse
Carlisle, PA 17013
(717) 240-6200
If you have any questions concerning this notice, please call:
at
Terrence J. McCabe, Esquire
McCABE, WEISBERG AND CONWAY, P.C.
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109. ~O
this telephone number',,, (215) 790~ \
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McCA~E, ~EISBERG AND CONWAY, P.C.
BY: T!RRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
Attorney for Plaintiff
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ELLEN J. DESCHENES
NUMBER 200-2422 CIVIL
AFFIDAVIT OF SERVICE
I, Terrence J. McCabe, Esquire, attorney for the Plaintiff
in the withiri matter, hereby certify that on the 5th DAY OF SEPTEMBER,
2000, a true and correct copy of the Notice of Sheriff's Sale of Real
Property was served on all pertinent lienholder(s) as set forth in the
Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A".
Copies of the letter and certificate of mailing are also
attached hereto, made a part hereof and marked as Exhibit "B."
,,\ ~S\ 0 ~ ~O _~ '\rv\. ~ t ~
TERRENCE- :-' McCA E, ESQUIRE
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 5~ DAY OF
SEPTEMBER, 2000.
NOTARY P LI
TARIAL SEAL
TRACY A. RIFF. NolBI'Y Public
City of I"hiladelphia, Phila, County 0
M Commission Ex ires Oct. 2~, 200
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TE~ENCE J. McCABE, ESQUIRE
Iden~ification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
Attorney for Plaintiff
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ELLEN J. DESCHENES
NUMBER 200-2422 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above
action, set forth as of the date the Praecipe for the Writ of Execution was
filed the following information concerning the real property located at 1600
Orrsbridge Road, Enola, PA 17025, a copy of the description of said property
is attached hereto and marked Exhibit "A."
1. Name and address of Owner(s) or Reputed Owner(s):
Name Address
Ellen J. Deschenes
1600 Orrsbridge Road
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
Name Address
Ellen J. Deschenes
1600 Orrsbridge Road
Enola, PA 17025
3 .
judgment
Name and last known address
is a record lien on the real
Name
of every judgment creditor whose
property to be sold:
Address
Plaintiff herein.
4.
record:
Name and address of the last recorded holder of every mortgage of
Name
Address
Plaintiff herein.
5. Name and address of every other person who has any record interest
in or record lien on the property and whose interest may be affected by the
sale: Name EXH'B'ldl!~'
None.
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6 .
knowledge
sale: .
Name and address of every other person of whom the Plaintiff has
who has any interest in the property which may be affected by the
Name
Address
Occupant(s)
1600 Orrsbridge Road
Enola, PA 17025
Domestic Relations
Cumberland County
P.O. Box 320
Carlisle, PA 17015
I verify that the statements made in this Affidavit are true and correct
to the best of my personal knowledge or information and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
September 5, 2000
~Q S\J\OM~ ~ ~
TERRENCE J. McC E, QUIRE
Attorney for Plaintiff
DATE
EXH\B\T "1\'
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McCABE, WEISBERG AND CONWAY, P. C.
BY: TER;RENCE J. McCABE, ESQUIRE
Identification Number 16496
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Attorney for Plaintiff
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ELLEN J, DESCHENES
NUMBER 200-2422 CIVIL
DATE: September 5, 2000
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
OWNER(S): Ellen J. Deschenes
PROPERTY: 1600 Orrsbridge Road, Enola, PA 17025
IMPROVEMENTS: Residential Dwelling
The above-captioned property is scheduled to be sold at the Sheriff's
Sale on December 6, 200 at 10:00 a.m. in the Commissioner's Hearing
Room located on the 2nd Floor of the Cumberland County Courthouse, 1
Courthouse Square, Carlisle, Pennsylvania 17013, Our records indicate
that you may hold a mortgage or judgments on the property which will be
extinguished by the sale. You may wish to atten~ the sale to protect
your interests.
A schedule of distribution will be filed by the Sheriff on a date
specified by the Sheriff not later than 30 days after sale.
Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the
schedule.
EXHIBIT "B"
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BENEFICIAL CONSUMER DISCOUNT COMPANY,
d/b/a BENEFICIAL MORTGAGE CO. OF
PENNSYLVANIA
IN WE COURT OF CXMDN PLEAS OF Clt1BERIAND CXXJNI'Y, PENNSYLVANIA
CIVIL DIVISION
File No.
2000-2422 CIVIL
$93,882.89
from 6/9/00
Arrount Due
v.
Interest
ELLEN J. DESCHENES
Atty's Corrm
Costs $1,015.00
TO THE PROTHONOrARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail
installrrent sale, contract, or account based on a confession of judgment, but if it does,
it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for "eal property pursuant to ACt 6 of 1974 as amended.
PRAOCIPE FOR EXECUTION
Issue writ ot: execution in the above rmtter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described property of the
defendant(s) 1600 Orrsbridge Road, Enola, PA 1'7025
(See attached description).
PRAECIPE FOR A'I'i'ACfi1.lENl' EXEX:l1l'ION
Issue writ of attacl1rrent to the Sheriff of Nlfl County, for debt,
interest and costs, as above, directing attachment against the above-named garnishee(s) for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
~
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee ( s) .
(Indicate) Index this writ against the garnishee( s) as a lis pendens against
real estate of the defendant(s) described in the attached exhibit.
DATE:
7~j')~OO
Signature:
Print Name:
~~ ,/!$(rOA:.
Terrence J (McCabe, Esq.
123 S. Broad St., Suite 2080
Address:
AttOl:ney for:
Telephone:
Phila., PA 19109
Plaintiff
(215) 790-1010
Supreme Court ID No.:
16496
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Notes: If real property, supply six copies of description including irrproverrents and an
original and copy of affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
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ALL THAT CERTAIN PIECE OR PARCEL OF LAND WITH THE BUILDINGS AND lMI?ROVEMENTS
THEREON ERECTED, SITUATE IN HAMPDEN TOWNSHIP, CUMBERLAND COUNTY,
PENNSYLVANIA, BOUNDED ~ DESCRIBED AS FOLLOWS:
BEGINNING AT A PIN ON THE EASTERN LINE OF A PUBLIC ROAD LEADING FROM U.S.
ROUTE 11 TO THE WERTZVILLE ROAD AT CORNER OF LAND NOW OR LATE OF OVIDIO ACRI,
ET UX; THENCE BY THE EASTERN LINE OF SAID PUBLIC ROAD, NORTH 15 DEGREES EAST
120 FEET TO A PIN AT CORNER OF LANDS NOW OR LATE OF HAROLD E, KRAMER AND
ELSIE KRAMER, HIS WIFE; THENCE ALONG SAID LANDS SOUTH 82 DEGREES EAST 242
FEET TO A PIN AT LANDS NOW OR LATE OF SAMUEL MOORE THENCE BY SAID LAND SOUTH
15 DEGREES WEST 120 FEET TO A !?IN AT LANDS NOW OR LATE OF OVIDIO ACRI, ET
UX;. THENCE BY SAID LANDS, NORTH 82 DEGREES WEST 242 FEET TO A PIN, THE PLACE
OF BEGINNING.
CONTAINING .67 ACRES.
Being known as 1600 Orrsbridge Road.
Tax I.D. No. 10-15-1285-006
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
Attorney for Plaintiff
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ELLEN J. DESCHENES
NUMBER 200-2422 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
I, Terrence J. McCabe, Esquire, attorney for Plaintiff in
the above action, set forth as of the date the Praecipe for the
Writ of Execution was filed the following information concerning
the real property located at 1600 Orrsbridge Road, Enola, PA
17025, a copy of the description of said property is attached
hereto, and marked Exhibit "A."
1. Name and address of Owner(s) or Reputed Owner(s) :
Name
Address
Ellen J. Deschenes
1600 Orrsbridge Road
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
Name
Address
Ellen J. Deschenes
1600 Orrsbridge Road
Enola, PA 17025
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3. Name and last known address of every judgment creditor
whose judgment is a record lien on the real property to be sold:
Name
Address
Plaintiff herein.
4. Name and address of the last recorded holder of every
mortgage of record:
Name
Address
Plaintiff herein.
5. Name and address of every other person who has any
record interest in or record lien on the property and whose
interest may be affected by the sale:
Name
Address
None.
6.
Plaintiff
which may
Name and address of every
has knowledge who has any
be affected by the sale:
other person of whom the
interest in the property
Name
Address
Occupant(s)
1600 Orrsbridge Road
Enola, PA 17025
Domestic Relations
Cumberland County
P.O. Box 320
Carlisle, PA 17015
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge or information
and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
7-//. On
McCABE,ESQUIRE
Plaintiff
DATE
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ALL ~HA~ CER~AIN PIECE OR PARCEL OF LAND WI~H ~HE BUILDINGS AND IMPROVEMEN~S
THEREON EREC~ED, SI~UA~E IN HAMPDEN ~OWNSHIP, CUMBERLAND COUN~Y,
PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
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BEGINNING A~ A PIN ON ~HE EAS~ERN LINE OF A PUBLIC ROAD LEADING FROM U.S.
ROU~E 11 ~O ~HE WER~ZVILLE ROAD A~ CORNER OF LAND NOW OR LA~E OF OVIDIO ACRI,
E~ UX; THENCE BY ~HE EAS~ERN LINE OF SAID PUBLIC ROAD, NOR~H 15 DEGREES EAS~
120 FEE~ ~O A PJ:N A~ CORNER OF LANDS NOW OR LA~E OF HAROLD E. KRAMER AND
ELSJ:E KRAMER, HJ:S WJ:FE; ~HENCE ALONG SAJ:D LANDS SOU~H 82 DEGREES EAS~ 242
FEE~ ~O A PJ:N A~ LANDS NOW OR LA~E OF SAMUEL MOORE THBNCE BY SAJ:P LAND SOU'l'H
15 DEGREES WES~ 120 FEE~ ~O A PJ:N A~ LANDS NOW OR LA~E OF OVJ:DIO ACRI, E~
UX;, ~HENCE BY SAJ:D LANDS, NOR~H 82 DEGREES WES~ 242 FEE~ ~O A PIN, ~HE PLACE
OF BEGJ:NNING.
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Being known as 1600 Orrsbridge Road.
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CON~AINING ,67 ACRES,
Tax I.D. No. 10-15-1285-006
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
Attorney for Plaintiff
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ELLEN J. DESCHENES
NUMBER 200-2422 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Ellen J. Deschenes
1600 Orrsbridge Road
Enola, PA 17025
Your house (real estate) at 1600 Orrsbridge Road, Enola, PA
17025 (more fully described as attached) is scheduled to be sold
at Sheriff's Sale on December 6, 2000 at 10:00 a.m, in the
Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle,
Pennsylvania 17013, to enforce the court judgment of $93,882.89
obtained by Beneficial Consumer Discount Company, d/b/a
Beneficial Mortgage Co. of Pennsylvania against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Beneficial
Consumer Discount Company, d/b/a Beneficial Mortgage
Co. of Pennsylvania the back payments, late charges,
costs, and reasonable attorney's fees due. To find out
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how much you must pay, you may call Terrence J. McCabe,
Esquire at (215) 790-1010.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the
judgment was improperly entered. You may also ask the
Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other
legal proceedings.
You may need an attorney to assert your rights. The sooner you
contact one, the more chance you will have of stopping the sale.
(See the following notice on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriff's Sale is not stopped, your property will be
sold to the highest bidder. You may find out the price bid
by calling Terrence J. McCabe, Esquire at (215) 790-1010,
2. You may be able to petition the Court to set aside the sale
if the bid price was grossly inadequate compared to the
value of your property.
3. The sale will go through only if the buyer pays the Sheriff
the full amount due on the sale. To find out if this has
happened, you may call Terrence J. McCabe, Esquire at (215)
790-1010.
4. If the amount due from the buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale
never happened.
5. You have a right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a
deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was paid
for your real estate. A schedule of distribution of the
money bid for your real estate will be filed by the Sheriff
within thirtv (30) days of the sheriff's sale. This
schedule will state who will be receiving that money. The
money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed schedule of
distribution is wrong) are filed with the Sheriff within ten
(10) days after the filing of the schedule of distribution.
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7. You may also have other rights and defenses, or ways of
getting your real estate back, if you act immediately after
the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE.
GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
4TH FLOOR.
CUMBERLAND COUNTY COURTHOUSE
CARLISLE. PENNSYLVANIA 17013
(717) 240-6200
OR
CUMBERLAND COUNTY
BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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ALL THAT CERTAIN FIECE OR FARCEL OF LAND WITH THE BUILDINGS AND IMPROVEMENTS
THEREON ERECTED, SITUATE IN HAMFDEN TOWNSHIF, CUMBERLAND COUNTY,
FENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A FIN ON THE EASTE~ LINE OF A FUBLIC ROAD LEADING FROM U.S.
ROUTE 11 TO THE WERTZVILLE ROAD AT COMER OF LAND NOW OR LATE OF OVJ:DIO ACRI,
ET UX; THENCE BY THE EASTE~ LINE OF SAID FUBLIC ROAD, NORTH 15 DEGREES EAST
120 FEET TO A FIN AT CO~ER OF LANDS NOW OR LATE OF HAROLD E. KRAMER AND
ELSIE KRAMER, HIS WIFE; THENCE ALONG SAID LANDS SOUTH 82 DEGREES EAST 242
FEET TO A FIN AT LANDS NOW OR LATE OF SAMUEL MOORE THENCE BY SAID LAND SOUTH
15 DEGREES WEST 120 FEET TO A FIN AT LANDS NOW OR LATE OF OVIDIO ACRI, ET
UX;, THENCE BY SAID LANDS, NORTH 82 DEGREES WEST 242 FEET TO A FIN. THE FLACE
OF BEGINNING.
CONTAINING .61 ACRES,
Being known as 1600 Orrsbridge Road.
Tax I.D. No. 10-15-1285-006
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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} SS.
Robwer P Z%egler
~ ______________________________________________________________________________Ilecorderof
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Deeds in and for said County and State do hereby certify that the Sheriffs need in which _____n__n_____
Beneficial C D C dba Beneficial Mtg Co of Pa
nn_______________n______.n_n__n__n_______ n___dn___nn_nn_nnnn_n___ is the grantee
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the same having been sold to said grantee on the _n__fit.b______________________________nn_____ day of
December xxOO
nnn____nn_n_n____________________ A. n" 19________, under and by virtue of a wriL_____n__n__
Execution 18th
_ n______u___nnn_n _____ _____ ___ ___ __ __ _____ issued on the _ __ ___ __ _____ ___ __ __ n nn___nn_ n_
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July A D lxx2000 .
day of __n______________________ , ., ::or.:nn_' out of the Court of Cornman Pleas of said County as of
Civil xx2000
__n_____________n_n____ n__"n_____ ___ __ n_ __ __ __ _____ __ __ n_ __ nn____ __ n __ _ Term, 19_______
Beneficial C D C dba Beneficial Mtg Co of PA
Number __2422.____n' at the snit of __________________n____n_n____nn_______n____'n---n----_
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___m_____m_m__________mn__ againsL__________~~~~_~_~_~~~~<:~~~_nmm____m__n is
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duly recorded in Sheriffs Deed Book No. __n___?2:'L_, Page _____J9_~___.
IN TESTIMONY WHEIlEOF, I have hereunto
set my hand and seal of said office this ___2~_ day
of m___ ~~__________ A. p., l&-_~~_>u
TU~ (} l'vL", \
_____,___________~~J----~----
~ Record& of Deeds
ft~ttitt!~r of 0e81ls. Cumberlarnl County, Ca~is\e, PA
My Commluion Expires the Fim MondlY ot Jan. 2002
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Beneficial Consumer Discount Company
dfb/a Beneficial Mortgage Co. of
-vs-
Ellen 1. Deschenes
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 2000-2422 Civil
Kennelh E, Gossert, Deputy Sheirff, who being duJy sworn according to law, says on
August 21, 2000 at 6:10 o'clock P.M. EDST, he served a true copy of Real Estate Writ
Notice and Description in the above entitled action upon the within named defendant to
wit: Ellen J. Deschenes by making known unto Ellen Deschenes at 1600 Orrs Bridge
Road, Enola, Cumberland County, Pennsylvania, it contents and at the same time handing
to her personally the said true and attested copies of the same.
Kenneth E. Gossert, Deputy Sheriff, who being duJy sworn according to law, says on
October 6, 2000 at 3:50 o'clock P.M. EDST, her posted a copy of Real Estate Writ
Notice Poster and Description on the property of Ellen J. Deschenes located at 1600 Orrs
Bridge Road, Enola, Cumberland County, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the
above Real Estate Writ Notice Poster and Description in the following manner: The
sheriff mailed a notice of the pendency of the action to Ihe defendant Ellen J., Deschenes
by regular Mail to her last known address 1600 Orrs Bridge Road, Enola, P A This letter
was mailed under the date of October 9, 2000 and never returned to the Sheriff's Office.
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 premises at public
venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on
December 6, 2000 at 10:00 o'clock A.M. EST and sold the same to Attorney James
Flower for Beneficial Consumer Discount Company dfb/a Beneficial Mortgage Company
of P A. It being the highest bid and best price quoted for the same Beneficial Consumer
Discount Company dfb/a Beneficial Mortgage Company of P A of 961 Weigel Drive,
P.O. Box 8604, Elmhurst, IL being the buyer in this execution paid to sheriffR. Thomas
Kline the sum of $ 660,29 it being costs.
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Sheriffs Costs:
Docketing
Poundage
Advertising
Posting Bills
Acknowledging Deed
Auctioneer
Law Library
County
Mileage
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
30.00
12.95
15.00
15.00
30.00
10.00
.50
1.00
18.60
,69
15.00
20.00
200.30
216.60
23.15
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Distribution of Proceeds
Sheriffs Deed
25.00
26.50
$ 660.29 Pd By Atty
12/19/00
Sworn and Subscribed To Before Me
This q lL- Day oq~ ~/')./ . _ ~ '"
d Q ()~ _.~~-r~
200", A.D. ". ,
Pro olotary ,~ R. Thomas Kline, Sheriff
Bytt..- ~
Real Estate Deputy
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
Attorney for Plaintiff
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ELLEN J. DESCHENES
NUMBER 200-2422 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
I, Terrence J. McCabe, Esquire, attorney for Plaintiff in
the above action, set forth as of the date the Praecipe for the
Writ of Execution was filed the following information concerning
the real property located at 1600 Orrsbridge Road, Enola, PA
17025, a copy of the description of said property is attached
hereto and marked Exhibit "A,"
1. Name and address of Owner(s) or Reputed Owner(s) :
Name
Address
Ellen J. Deschenes
1600 Orrsbridge Road
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
Name
Address
Ellen J. Deschenes
1600 Orrsbridge Road
Enola, PA 17025
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3. Name and last known address of every judgment creditor
whose judgment is a record lien on the real property to be sold:
Name
Address
Plaintiff herein.
4. Name and address of the last recorded holder of every
mortgage of record:
Name
Address
Plaintiff herein.
5. Name and address of every other person who has any
record interest in or record lien on the property and whose
interest may be affected by the sale:
Name
Address
None.
6.
Plaintiff
which may
Name and address of every other person of whom the
has knowledge who has any interest in the property
be affected by the sale:
Name
Address
Occupant(s)
1600 Orrsbridge Road
Enola, PA 17025
Domestic Relations
Cumberland County
P.O. Box 320
Carlisle, PA 17015
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge or information
and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa,C.S. Section 4904 relating to
unsworn falsification to authorities.
7- ! / . On
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TERRENCE J.
Attorney fo
'r G.
McCABE, ESQUIRE
Plaintiff
DATE
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ALL THAT CERTAIN PIECE OR PARCEL OF LAND WITH THE BUILDINGS AND IMl'ROVEMENTS
THEREON ERECTED, SITUATE IN HAMPDEN TOWNSHIP, CUMBERLAND COUNTY,
PENNSYLVANIA, BOUNDED ~ DESCRIBED AS FOLLOWS:
BEGINNING AT A PIN ON THE EAST~RN LINE OF A PUBLIC ROAD LEADING FROM U.S.
ROUTE 11 TO THE WERTZV:tLLE ROAD AT CORNER OF LAND NOW OR LATE OF OVIDIO AClU,
ET 11.lt; THENCE BY TIlE EASTERN LINE OF SAID PUBLIC ROAD, NORTH 15 DEGREES EAST
120 FEET TO A PIN AT CORNER OF LANDS NOW OR LATE OF HAROLD E. KR.!\MER AN:b
ELSIE KRAMER, HIS WIFE; THENCE ALONG SAID LANDS SOUTH 82 DEGREES EAST 242
FEET TO A PIN AT LANDS NOW OR LATE OF SAMUEL MOORE THENCE BY SAID LAND SOUTH
15 DEGREES WEST 120 FEET TO A PIN AT LANDS NOW OR LATE OF OVIDIO ACRI, ET
u.K;, THENCE BY SAID LANDS, NORTH 82 DEGREES WEST 242 FEET TO A PIN, THE PLACE
OF BEGINNING.
CONTAINING ,67 ACRES.
Being known as 1600 Orrsbridge Road.
Tax I.D. No. 10-15-1285-006
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
Attorney for Plaintiff
BENEFICIAL CONSUMER DISCOUNT
COMPANY, d/b/a BENEFICIAL MORTGAGE
CO. OF PENNSYLVANIA
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ELLEN J. DESCHENES
NUMBER 200-2422 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Ellen J. Deschenes
1600 Orrsbridge Road
Enola, PA 17025
Your house (real estate) at 1600 Orrsbridge Road, Enola, PA
17025 (more fully described as attached) is scheduled to be sold
at Sheriff's Sale on December 6, 2000 at 10:00 a,m. in the
Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle,
Pennsylvania 17013, to enforce the court judgment of $93,882.89
obtained by Beneficial Consumer Discount Company, d/b/a
Beneficial Mortgage Co. of Pennsylvania against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Beneficial
Consumer Discount Company, d/b/a Beneficial Mortgage
Co. of Pennsylvania the back payments, late charges,
costs, and reasonable attorney's fees due. To find out
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how much you must pay, you may call Terrence J. McCabe,
Esquire at (215) 790-1010,
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the
judgment was improperly entered. You may also ask the
Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other
legal proceedings.
You may need an attorney to assert your rights. The sooner you
contact one, the more chance you will have of stopping the sale,
(See the following notice on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriff's Sale is not stopped, your property will be
sold to the highest bidder. You may find out the price bid
by calling Terrence J. McCabe, Esquire at (215) 790-1010.
2. You may be able to petition the Court to set aside the sale
if the bid price was grossly inadequate compared to the
value of your property.
3. The sale will go through only if the buyer pays the Sheriff
the full amount due on the sale. To find out if this has
happened, you may call Terrence J, McCabe, Esquire at (215)
790-1010.
4. If the amount due from the buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale
never happened.
5. You have a right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a
deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was paid
for your real estate. A schedule of distribution of the
money bid for your real estate will be filed by the Sheriff
within thirtv (30) davs of the sheriff's sale. This
schedule will state who will be receiving that money. The
money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed schedule of
distribution is wrong) are filed with the Sheriff within ten
(10) days after the filing of the schedule of distribution.
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7. You may also have other rights and defenses, or ways of
getting your real estate back, if you act immediately after
the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE.
GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
4TH FLOOR,
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
OR
CUMBERLAND COUNTY
BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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ALL THAT CERTAIN PIECE OR PARCEL OF LAND WITH THE BUILDINGS AND IMPROVEMENTS
THEREON ERECTED, SITUATE IN HAMPDEN TOWNSHIP, CUMBERLAND COUNTY,
PENNSYLVANIA, BOUNDED M.ID DESCRIBED AS FOLLOWS:
BEGINNING AT A PIN ON THE EAST~RN LINE OF A PUBLIC ROAD LEADING FROM U,S,
ROUTE 11 TO THE WER'rZVILLE ROAD A'r COBNER OF LAND NOW OR LA'rE OF ov:rDIO ACRI,
E'r UX; 'rHENCE BY THE EASTERN LINE OF SAID PUBLIC ROAD, NOR'rH 15 DEGREES EAST
120 FEET 'rO A PIN A'r CORNER OF LANDS NOW OR LATE OF HAROLD E, KRAMER AND
ELSIE KRAMER, HIS WIFE; THENCE ALONG SAID LANDS SOU'rH 82 DEGREES EAST 242
FEET TO A PIN AT LANDS NOW OR LATE OF SAMUEL MOORE THENCE BY SAID LAND SOUTH
15 DEGREES WEST 120 FEET TO A PIN AT LANDS NOW OR LATE OF OVIDIO ACRI, ET
UX;. THENCE BY SAID LANDS, NORTH 82 DEGREES WEST 242, FEET TO A PIN, THE PLACE
OF BEGINNING.
CONTAINING . 67 ACRES.
Being known as 1600 Orrsbridge Road.
Tax I.D. No. 10-15-1285-006
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PEt-lNSYL VANIA)
COUNTY OF CUMBERLAND)
NO. 00-2422 CIVIL 1liX Tenn
CIVIL ACTION - LAW
TO THE SHERIFF OF
Cumberland
COUNTY:
To satisfy the debt, interest and costs due Beneficial Consumer Discount Corrpany, d/b/a
Beneficial M6rtgage Co. of Pennsylvania PLAINTlFF(S)
from Ell f>n .1 _ fl<>",,,hf>np,,,, 1 fiOO Orr",hri ilgf> R=il. Enol a. PII 1 7025
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notny the garnishee(s) that: (a) an attatfirnent has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property ofthe defendant(s) not levied upon an subjectto attachment is found in the possession of anyone other
than a named garnishee, you are directed to notny him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Interest j;~ p;:~;:RO
Atty's Comm
%
L.L.
Due Prothy
Other Costs
$.50
$1. 00
$1,015.001
Amount Due
$93,882.89
Atty Paid
Plaintiff Paid
$108.68
Date:
,1111y 1 R, ?onn
Curti", R. Long
Prothonotary, Civil Division
~.a~-7''' p 7I(~T?/UTl~~\
Deputy
REQUESTING PARTY:
Terrence J. McCabe, Esq.
123 S. Broad St., Suite 2080
Philadelphia, PA 19109
Attorney for: Plaintiff
Telephone: 215-790-1010
, <f'
Supreme Court 10 No. '16496
Name
Address:
!Ili~$_I.bilC",""-TIf!'1tmll~~n~ilI9iilI'MllH#~"'!llliiif;~..~~~~idWlilI.
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REAL ESTATE SALE No.y
Un M @-7. H-r-e> the sheriff levied upon the defendants
interest in the real property situated in j./...-A __;_1- 7"1'Lt/"lnA lp
Cumberland County !,noc',nd numbered as: It tI[) rPAA/>4 t. ~et
~L- and mOl<
;cribed on exhibit "A" filed with
this writ and by this reference incorporated herein.
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'--~EI\l.-ESTATE5Al"NO:'4---'
\V(1t No, 2000-2422
Clvilrerm
Beneficial Consumer
Discount COlTlpany, d1bfa .
Se'neficial Mortgage Co. '
of Pennsyll1ania
vs
Ellen J, Deschenes
Atty:Terrel1ce J, McCabe
, 'DESCRIPTION
, A~C "tHAT .C~RTAiN rie<:e or parcel of land
,: , 1,0,>1[11 fhe buJidmgs and J.mprovements thereon
. er~ctcd, situate in. P.:ampd~n TOWIlShip,
Cumberland Countv, V~'nnsvlvanial bounded
.md described as (allows: .
BEGINNING at a pin Qn the eastern line of a
"public road leading from US, Route 11 to the
'Wertzville Road at corner of land now or Late
of .Ovidio Am, et ttx; thence bv the eastern
. line of said public: road, north 1j degrees east
, 120 feet to <l pin at corner of lands now (lr late
! of Harold E. Kramer and Elsie Kramer, his
I . Wife; thence along t-aid lands south$2 degrees
. t'.<lst 2.12 feet to a pin' at la,nds 00\" o~ late of
Satilud Moore thence bv said land $.outh 15
, degrct;sJ"cst 120 fcet to a pin at lqnds now or
. late , of Oridio Acri, et ux; thcne,," by ~aid
lands, ndrth 82 degrees west 242 ft'd to a pin;
lhe]'iace,of bcgtnnlng. ' '
! 'Coblaining .67 acres.
i" Heingknown as 1600 OmbridgeROJd
'c~____~~:_NO. 10.1t~:006. ~_ _~_
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No, 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} 55
.
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager of The Patriot News Co" a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818
Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The
Patriot-News and The Sundav 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 andlor Sundayl Metro editions which appeared on the 31 st day of October and the 7th and 14th
day(s) of November 2000. Thilt neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of t.,he saidfO pany and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in iscellaneous Book "M",
Volume 14, Page 317. ~
't
PU B L1CA TION ,..,.. .....,...., ........... ..Y.'............... ......... .......................................
COpy , m is 1st day D mber 2000 AD.
E Notarial Seal
S A L #4 Teny L. Russell, Notaoy Public
Hamsbulll, Oauphln COUnty
My Commission Expires June 6, 2002
Mambar, PennsylVania Association of Notaries My commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
.,
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
215.10
1,50
216,60
Publisher's Receipt for Advertising Cost
The Patriot News Co" publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid,
By...,.".............,.,."..,........,.........,.,.,..,.,.",....,.,
REAL ESTATE SALE NO. 4
Writ No, 2000-2422 Civll
Beneficial Consumer Discount
Company, d/b/a Beneficial
Mortgage Co. or Pennsylvania
vs.
Ellen J. Deschenes
Atty.: Terrence J, McCabe
ALL TIiAT CERTAIN piece or par-
cel or land with the buildings arid
improvements thereon erected, situ-
ate In Hampden Township, Cumber-
land County, Pennsylvania, bound-
ed and descrtbed as follows:
BEGINNING at a pin on the east-
ern line of a public road lead1ng from
U.S. Route II to the Wertzv1lle Road
at corner of land now or late or
Ovideo Acrt, et ux; thence by the
eastern line of said public road,
North 15 degrees East 120 reet to a
pin at corner of lands now or late of
Harold E. Kramer and Elsie Kramer,
his wife; thence along said lands
South 82 degrees East 242 reet to
a pin at lands now or late of Samuel
Moore thence by sald land South
15 degrees West 120 reet to a pin
at lands now or late of Ovidio Acrt,
et ux; thence by said lands, North
82 degrees West 242 reet to a pin.
the place or begirlIl1ng.
CONTAlNING ,67 acres.
BEING known as 1600 Orrs-
bridge Road.
Tax I.D, No, 10-15-1285-006.
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
55.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, ofthe 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 of the said Cumberland Law
Journal on the following dates,
VIZ:
OCTOBER 27, NOVEMBER 3, 10,2000
Mfiant 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.
~ IOY/)./l -
Roger J: Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
10 day of NOVEMBER. 2000
NOTARfA SEAL
L0I5 E. SNYDER, Notary I'ubIIc
Car/ill. Boro, Cumberland County, PA
My CornmiMion Expir.. Man:l, St2001