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Home My WebLink About00-02931 =~~~~ .. -'.', ,;J ( i ~ j il FEDERMAN AND PHELAN By: Frank Federman, Esquire Atty. LD. No.: 12248 Two Pe1111 Center Plaza, Suite 900 Philadelphia, P A 19102-1799 (215) 563-7000 :-! ATTORNEY FOR PLAINTIFF !:! ii L! i-,! :,1 Ii !.i i'l :-1 !:i I. Ii Matrix Financial Services v. Cumberland County Court of Common Pleas Civil Division i' i.i i; I': ;1 1:1 No. 00-2931 Civil I'; i' Jean L. Soisson ", '-I i,i PRAECIPE !: " , , , TO THE PROTHONOTARY: " X A. Plaintiff hereby withdraws the complaint filed in this matter. Please mark this case discontinued and ended without prejudice. .', i.' I I.: I': I;; B. Please mark this case settled, discontinued and ended. ~'1o~Mn~ Frank Federman Attorney for Plaintiff " h.~ ~"" I ~., c ~,~"-,~~ "'''Ii. FEDERMAN AND PHELAN By: F~FEDE~,ESQlITRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPffiA, PA 19102 (215) 563-7000 MATRIX FINANCIAL SERVICES 2133 WEST PEORIA PHOENIX, AZ 85029 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO, to - ';;C)3/ c:aJ v. CUMBERLAND COUNTY JEAN L. SOISSON 32 ESSEX ROAD CAMP illLL, P A 17011 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE "TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, TillS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, :,',': ~:,', i,' 1;1 !.i ,) i:j , I:~ ~ , ,.j l~ ;J ';' '. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #, 0637076 1. Plaintiff is MATRIX FINANCIAL SERVICES 2133 WEST PEORIA PHOENIX, AZ 85029 2. The name(s) and last known addressees) of the Defendant(s) are: JEAN L. SOISSON 32 ESSEX ROAD CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 10/31/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PROVIDENT MORTGAGE CORPORATION, T/A CONSOLIDATED MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1290, Page 224. By Assignment of Mortgage recorded 11/6/95 the mortgage was assigned to PROVIDENT BANK OF MARYLAND which Assignment is recorded in Miscellaneous Book No. 507, Page 744. By Assignment of Mortgage recorded 3/3/97 the mortgage was assigned to WENDOVER FUNDING, INC. which Assignment is recorded in Miscellaneous Book No. 541, Page 90 I. By Assignment of Mortgage recorded 6/1/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Miscellaneous Book No. 577, Page 1040. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." - ., '-. , 6. The following amounts are due on the mortgage: 7. 9. Principal Balance Interest 11/1/99 through 4/1/00 (Per Diem $14.32) Attorney's Fees Cumulative Late Charges 10/31/95 to 4/1/00 Cost of Suit and Title Search Subtotal $65,332.54 2,176.64 3,266.00 130.49 550.00 71,455.67 Escrow Credit Deficit Subtotal 0.00 100.84 100.84 I:"~ " i i TOTAL $71,556.45 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. " Iii ~! ;" I:: fi~ ~" 'I' ~i i:: The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. g1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. '" i;1 I:: 'il I,: 'Ii WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $71,556.45, together with interest from 4/1/00 at the rate of$14.32 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. t~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff . February 04, 2000 FZ=~;jj~;~Z;i L;clj MATRIX [,oJ III FlNAt'llCIAL C .. SERVICES ...'1 CORI'ORITIO:i 1". ~EL=__}p~/'~~J ~ 10" '; 11 :1 ;1 1I 'I :1 II II ~ " ,I 'I !I 'I ~I Jean L soisson 32 Essex Rd Camp Hill, PA 17011-0000 ( ACT 91 NOTICE **TAKE ACTION TO SAVE ,YOUR HOME FROM FORECLOSURE** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL, BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCB IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Dear Mortgagor: This is an official notice that the mortqaqe on your 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 (HEMAP) may be able to help save your home. This Notice explains how the proqram works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counselinq Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). The Notice contains important legal information. If you have any ques~ions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICATION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTlNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PRO- GRAMA LLAMADO "HOMBOWNERS'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 201 W. Coolidge 51., Phoenix, AZ 85013-2710 (602) 650,0838 . FAX (602) 631,4377 EXHiBiT A. " "' -- ,.'- ~_, J Page 2 Loan Number: 063707-6 Homeowners Name(s): Jean L Soisson Property Address: 32 Essex Rd Camp Hill PA 17011 Loan Acct. No.: 063707-6 1 Original Lender: Provident Mortg~e Corp. Current Lender/Servicer: Matrix Financial services Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORT- GAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR ~4ERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit pounseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR m1ERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE t>;:FAULT", 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, 'che lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of desiqnated consumer credit counselinq 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 ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) i , 89504/016/323 :~' , I' I'~' I. . hJ \., EXHIBIT A "' . , '-.'" '" '1' j, I l'age 3 Loan Number: 063707-6 If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the disignated consumer credit counsel- ing agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application of the Pennsylvania Housing Finance Agency. Your applica~ion MUST be filed or postmarked ~ithin thirty (30) days of your face~to-face meeting. ~OU;MUST FILE YOUR APPLICATION PROMPTLY, IF YOU FAIL TO DO SO OR IF YOuoo-NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLI- CATION FOR MORTGAGE ASSISTANCE WILL BE.DEINED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibil- ity 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 notifed directly by the Pennsylvania Housing Finance Agency of its decision on your application. I 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 I; \ THE DEBT. " ' (If you have filed bankruptcy you can still apply for l 'I' Emergency Mortgage Assistance.) t ,"j., ; I' ;HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). j 1,1 NATURE OF THE DEFAULT -- The of your property located at: MORTGAGE debt 32 Essex Rd Camp Hill PA held by the above lender 17011 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and' the following amounts are now past due: December 1, 1999 thru February 1, 2000: December 1, 1999: $585.93 January 1, 2000: $585.93 February 1, 2000: $585.93 . .: $ I TOTAL PAYMENTS: $1,757.79 Late Charges: $ 55.76 NSF Fee(s): $.00 Property Inspection Fee(s) Other: $ Less Suspense: $ 87.70 TOTAL PAST DUE: $1,733.85 $8.00 C0505/042/323 EXHIBIT A - " "~- ~^'] , I"~ Page 4 Loan Number: 063707-6 I' ' , ' ~.: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: NA HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,821. 55, PLUS ANY MORTGAGE PAYMENT AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash! cashier'~ check or money order payable and sent to: Matrix Financ1al Services Corp., 201 W. Coolidge street, Phoenix, AZ 85013-2710. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: NA IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. Th~s means that the entire outstanding balance of this debt will be 90nsidered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total ~mount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to foreclose ~pon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sherrif to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. , . '1, l ~~HER LENDER REMEDIES -- The lender may also sue you personally for ~p~iunpaid principal balance and all other sums due under the mortgage. F,., Ii ftIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not 9ured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default a~d prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. CURING YOUR DEFAULT IN THE MANNER SET FORTH IN THIS NOTICE WILL RESTORE YOUR C0506/016/323 I I,i;. . Ie:, . i :\i; EXHiBf{ A " " ~' .- '-~ '_~I Page 5 Loan Number: 063707-6 , . ~ortgage to the same position as if you had never defaulted. 1'" EARLIEST POSSIBLE SHERRIF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property ~ould be held would be APPROXIMATELY SIX (6) MONTHS FROM THE DATE OF THIS NOTICE. A notice of the actual date of the Sheriff's Sale will he sent to you before the sale. Of course, the amount needed to cure ~he default will increase the longer ~ou wait. You may find out at any time exactly what the required payment or aciton will be contacting ,the lender. HOW TO CONTACT THE LENDER: Matrix Financial services Corporation 201 W. Coolidge street 1-800-888-805-4027 1-602-631-4382 !' Contact Person: Shawn Greer EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgage property and your right to pcc~py it. If you continue to live in the property after the Sheriff's ~ale, a lawsuit to remove you and your furnishings and other belongings J.,! . . rOU1d be started by the lender at any t~me. , , ASSUMPTION OF MORTGAGE -- You mayor may not (CHECK ONE) sell pr transfer your home to a buyer or transferee who will assume the mort- gage 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 othe requirements of the mortgage are satisfied. All assumptions require Matrix Financial Services Corporation approval. Please contact your Assumption Department at 1-800-243-6372. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER INSTITUTION TO PAYOFF THIS DEBT. rO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. i. \ ~O lLAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OC9URRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT tt'6"CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ~"" ' to ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAW- SUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVICING YOUR COUNTY C0507/007/323 E)(HlB\T A ,-, -, " '~ Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) Lj7COllling,Clinton Counces Commission t" C . 2138 Lincoln S~ .ommwut"f A.::ion (STEP) P. O. Box 1325 _e_ Willi3msoor.: '" 1--03 (5-0) 3 . ~ ..~ I I . 26-D58. FA."!: (570) 322.2197 CCCS oO.or.:.'>.e3.Ster:> P"- 201 Ba,;in Street . Wtlliams (5-0) 3~~PCrt, PA 17703 , 40,)-6627 FA."!:(5iO) 323-8626 CLINTON COlJ"NTY CCCS ofNor.heaster:> P,,- 1631 S Ather.cn St . Suite lOO S"'te College, PA 16801 (S14) 23S-3668 F.~(S14)238-3669 COLUMBIA COl.rl';-rr CCCS of No,..~'leastertl Pennsvlvania 1400 .'>hington E:cec-~cve Park Suite 1 Clarks Summit: P.... l8411 (570) 58.,9163 or (SOO) 922.9537 FA."{ (570) 587-913419135 31 W. Marut St:'eet POB 1127 WIlkes-Barre, P." 1S.02 (570) 821-OS37 or (800) 922.9537 FA.."{ (570) 821.1785 Commis3ion on Economics Oppcrtwlit'1 of Lu:eme Count;r l63 Amber Lane WIlkes-Barre, PA 18702 (570) 826-D510 or (800) 822-0359 F....."{ (570) 829-l665-CALL BEFORE FA.'UNG (570) 4554994 HAZELTON F....."{ (5.0) 455-5631-CALL BEFORE F.....'UNG (570) 836.4090 TIJNK:H.......""'NOCK Booker T. Washington Center 1720 Holland St:'eet Erie, PA l6503 (S14) 453,5744 F.....X (814) 453,5749 John F. Kennedy Center, !.ne. 2021 East 20th St"",t Erie, PA 16510 (814) 898.0400 FAX (814) 898-1243 CCCS of Western Pennsvlvania. !.ne. 2000 t.ing!estown Road .. Har.'.sburg, PA 17102 (717) 541,1757 Urban League oD!etropclitan Har.isb~ N. 6th St:'eet Harrisburg, PA 17101 (717) 234-5925 F.....X (ili) 234.9459 Co=unit"1 Ae-:ion Co= of the Capital Region 1514 Demr Street Hanisburi, P." 17104 (717) 232-9757 F....."{ (717) 234-2227 CRAWFORD COLNTI Greater ~rie Communit'/.-\.c:ion Co=it"..ee 18 West 9th St:'eet Erie, PA 16501 (S14) 45~581 FAX (814) 456-0161 Shenango Valley Urban teague. toe 601lndiana Avenue Farrell. PA 16121 (412) 981-5310 CUMBEm..A.'ID COUNTY Fi"~,'n...;::t!I ,'Counseling Serrices of Fr:mklin 31 West i3m St:'eet WayUes~ro, PA 17268 (717) 762-32S5 YWCAof;Carlisle 30l.G Str..et Carlisle; fA 17013 (717) 243,.38l8 F.;.~(717)731,95B9 Adams Count'1 Housing Aut.'lorit'1 l39-143 Carlisle Se Gettysb}lrg, PA 17325 (717) 334-1518 F....."{(717) 334-8325 PENNSYl.VANIA SUUETlN, VOl.. 29, NO. 2:l. JIlNE 5, 1m EXHIBIT ft. ~ , "0, ALL IJlul certain piece or parcel of lanel, with lh~ buiJclirigs i:lnd il1"lprOVClncuf~, thereon erected, .situule in Lower Allen Townshipl ClIlnbe.rIand Counly, PennsyJ"uniH. luore particularly bounuet.l ancl uescl'ibed as follows. lO wil: AEGINNING at a point on tile northerly line ofParkJea Road which point i~ one hundred lwenty (120) feel e",slwal'cUy of the norlheaslerlyeol'11er of Es.ex Rond and Pal'k-lca Roads; lhcllCl.: along the.: northel'ly line of ?Hrklca Road south 65 cJ~grcc~ 44 lllrnulc,!:i 30 seconcJ~ West. niuely-five (95) feet to a pO;llt: thence in an afC h.lving a radil1s of twenty-five (25) [eet in ill. northweSlet"Jy cliecrion thirty-nine and ~venty-scven hundredths (3.9.27) feet {"a a poinl on the e'IMerly line of Essex Road;lhence along snme north 24 degrees 15 minutes 30 <eeOllds 'vVe,<t tilly (50) feet (0 a poilH al dividing Jine between lots Nos. 5 and 6, 1'l'nct No. 3 "'~ the hcrcin~fter mentione'" plan of Jots; thence along said dividing line in an easterly direction one h"nured '''''emy (120) feel to " point;lhcnee south 24 degrees 15 rnin"tes 30 seconus eaSl, seventy-live (75) feet to a point. the place of beginning. BEli'>iG LOT NO,S, Trllet No.3. on plan of lots known as Cumberland Park. which plan i.II:; recordeu in the CUl11berland County RccnrderJs Office in Plan Book 6. pugc 3. and being known ~~.... 32 ECi!o'C.':. Ro..I<.1. " ~ , ~,._l, ~ . "__~,_~_,~.,~_u_ :;.~, I; VERIFICATION , 'i" t n~ \: '); 1!~ MICHAEL R. SCHLAFF hereby states that he is VICE-PRESIDENT of ::' _'1_' ~j: :1' It;: ;11 U:: !:I': II H:, f" I', fi:1 m,' !"i f', MATRIX FINANCIAL SERVICES CORPORATION mortgage servicing agent for plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of /7~~ }~ II" [I I, Ii f~ i~ !~ i:' Ii ];1 Ii II! Ii; li~ I I [n ~l' ii' !ll I I' t I;'; ll; Ii.; his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.s. Sec. 4904 relating to unsworn falsiflication to authorities. DATE: 5/cr 1m . I'.. :_~ ~~ , ' !1lil~'- ~'_~~llr&>ilil!lttili~l~iWt.~li~~aJ-i-.~~.~~ w -~""'IDIIllI_ ,~ cf~ ~ ~. ~Q Ill!! ~ ~~ Cf\ ~~ ~ \ ~ ~ ' ~ ~ ~ - o C 4~~ -otFi n!n~l :-2.::0 --0" ,.~. ./_-...,. ~J-?: .....L_. ~~ z;.2 -='--.: )>~; ~~ --< ...........L.c..." '.,. ~ Cl c? :-Jt :;:( ,"') 'n ;1~-n , "\-: -r..m -:"1'- o ..."\ '."';0 -----..,." () ::n :~::::M ~~ ;t> ~ ,.,. :1b ::::> co - , ---I !:'I !i: !;- ii~ " i ii' i~ , Ii i: i, I:: :) i] 'j I: 11 SHERIFF'S RETURN - REGULAR CASE NO: 2000-02931 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MATRIX FINANCIAL SERVICES VS SOISSON JEAN L HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, DEFENDANT , at 0018:32 HOURS, on the 23rd day of May , 2000 i i ~ !,' t.! fi i , " Ji ~,j says, the within COMPLAINT - MORT FORE was served upon SOISSON JEAN L the at 32 ESSEX ROAD CAMP HILL, PA 17011 JACK RIDGE (HUSBAND) by handing to a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.06 .00 10.00 .00 36.06 So ;;~~t R. Thomas Kline OS/24/2000 FEDERMAN & PHELAN Sworn and Subscribed to before By: 7~~ Deputy sher{tf~ me this 1AA- day of ~ ,2.tnriJ A.D. (,J.,~Q. /'nuL~ Ppfothonotary -~