HomeMy WebLinkAbout00-03081
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I.D. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
BARRY E. ZOOK
DEBRA A. ZOOK, A/K/A DEBRA CONDRAD ZOOK,
A/K/A DEBRA A. CONRAD
CIVIL DIVISION
NO. 00-3081-CIVIL
PRAECIPE FOR RULE TO SHOW CAUSE
TO THE PROTHONOTARY:
Kindly enter a Rule upon BARRY E. ZOOK & DEBRA A. ZOOK, A!K!A DEBRA
CONDRAD ZOOK,A!K!A DEBRA A. CONRAD, Defendant(s) to show cause why the attached
Order for Reassessment of Damages should not be entered.
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Daniel G. Schmieg, Esquire
Attorney for Plaintiff
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I.D. No. 62205 ATTORNEY FOR PLAINTIFF
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs. CIVIL DIVISION
BARRY E. ZOOK
DEBRA A. ZOOK, A/K/A DEBRA CONDRAD ZOOK,
A/K/A DEBRA A. CONRAD NO. 00-3081-CIVIL
RULE
AND NOW, this
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day of
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, a Rule is
entered upon BARRY E. ZOOK & DEBRA A. ZOOK, A/K/A DEBRA CONDRAD ZOOK,A!K!A
Reassessment of Damages should not be entered.
DEBRA A. CONRAD, Defendant(s) to show cause why the attached Order for
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RULE RETURNABLE the 3/JIt day of au~
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FEDERMAN AND PHELAN
by: Daniel G: Schmieg, Esquire
Atty. I.D. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
BARRY E. ZOOK
DEBRA A. ZOOK, A/K/A DEBRA CONDRAD ZOOK,
A/K/A DEBRA A. CONRAD
CIVIL DIVISION
NO. 00-3081-CIVIL
ORDER
AND NOW, this
day of
, the
Prothonotary is ORDERED to reassess the damages in this case as follows:
Principal Balance
Interest Amount
12/1/99 through 9/5/01
Late Charges
Legal fees
Cost of Suit and Title
Sheriff's Sale Costs
Inspections/Other
Appraisal Fees
Escrow
Credit
Deficit
31,802.23
5,741.99
608.20
1,300.00
1,782.00
565.11
123.25
0.00
0.00
1,204.86
TOTAL
$43,127.64
Plus interest per diem from 9/5/01 through Date of Sale at six (6%) percent.
NOTE: THE ABOVE FIGURE IS NOT A PAY OFF - SHERIFF'S SALE COSTS
AND COMMISSION ARE NOT INCLUDED IN THE ABOVE FIGURES.
BY THE COURT:
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I.D. NO. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
BARRY E. ZOOK
DEBRA A. ZOOK, A/K/A DEBRA CONDRAD ZOOK,
A/K/A DEBRA A. CONRAD
CIVIL DIVISION
NO. 00-3081-CIVIL
PLAINTIFF'S PETITION FOR REASSESSMENT OF PAMAGES
Plaintiff, by its Attorney, Daniel G. Schmieg, Esquire, moves the Court
to direct the Prothonotary to reassess the damages in this matter, and in
support thereof avers the following:
1. This is an action in Mortgage Foreclosure in which Judgment was
entered by default dated on AUGUST 2, 2000 in the amount of $35,531.90.
2. A Sheriff's Sale of the mortgaged premises was postponed or stayed
for the following reasons:
The Defendant (s) filed a Chapter 13 Bankruptcy
(#00-05093RJW) filed on NOVEMBER 21, 2000.
The Bankruptcy was dismissed by
order of court dated MARCH 12, 2001.
3. The mortgaged premises are listed for Sheriff's Sale on SEPTEMBER 5,
2001.
4 . Addi tional sums have been incurred or expended on Defendant (s) ,
behalf during the time the sale was postponed or
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stayed, and Defendant(s) have been given credit for any payments that have been
made since the judgment, if any.
The amount of damages should now read as
follows:
Principal Balance
Interest Amount
12/1/99 through 9/5/01
Late Charges
Legal fees
Cost of Suit and Title
Sheriff's Sale Costs
Inspections/Other
Appraisal Fees
Escrow
Credit
Deficit
31,802.23
5,741.99
608.20
1,300.00
1,782.00
565.11
123.25
0.00
0.00
1,204.86
TOTAL
$43,127.64
5. Under the terms of the mortgage, Plaintiff is entitled to inclusion
of the figures set forth in paragraph four in the amount of judgment against
the Defendant(s).
WHEREFORE, Plaintiff respectfully requests this Honorable Court issue an
Order to the Prothonotary to reassess the damages as set forth above.
rDOL
Daniel G. Schmieg, ESQUIRE
Attorney for Plaintiff
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I.D. No. 62205
One Penn Center Plaza, Suite 1400
philadelphia, PA 19102-1799
(215\ 563-7000
GMAC MORTGAGE CORPORATION
ATTORNEY FOR PLAINTIFF
CUMBERIJ\ND COUNTY
COURT OF COMMON PLEAS
vs.
BARRY E. ZOOK
DEBRA A. ZOOK, A/K/A DEBRA CONDRAD ZOOK,
A/K/A DEBRA A. CONRAD
CIVIL DIVISION
NO. 00-3081-CIVIL
BRIEF OF LAW IN SUPPORT OF
PLAINTIFF'S MOTION TO REASSESS DAMAGES
I. BACKGROUND OF CASE
Plaintiff and Defendant (8) entered into a Promissory Note and Mortgage
Agreement, wherein Defendant (8) agreed to pay Plaintiff principal, interest,
late charges, real estate taxes, hazard insurance premiums and mortgage
insurance premiums as said monies became due.
In turn, Plaintiff's Note was
secured by a mortgage on the subject premises.
The Mortgage Agreement
indicates that in the event Defendant(s) defaults, Plaintiff may pay any
necessary obligations in order to protect its collateral, the subject premises.
In the case sub ludicia, Defendant (s) failed to abide by the Mortgage
Agreement by failing to tender numerous, promised monthly mortgage pa:yrnents.
Accordingly, after Plaintiff determined that Defendant (s) were not going to
cure the default and bring ,the loan current, Plaintiff commenced a Mortgage
Foreclosure Action.
Judgment was subsequently entered by the Court, and the subject property
is scheduled for Sheriff's Sale.
Because of the excessive period of time between the initiation of the
Mortgage Foreclosure Action, the entry of Judgment and the Sheriff's Sale date,
damages as previously assessed by the Court are outdated and must be increased
to include current interest, real estate taxes, insurance premiums, and other
expenses which Plaintiff has been obligated to pay under the Mortgage Agreement
in order to protect its interest.
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II. lIRGUMENT FOR REASSESSMENT OF PAMAGES
The Pennsylvania Rules of Civil Procedure are silent with respect to the
issue of Reassessment of Damages; however, Rule 1037 provides, "the
Prothonotary shall assess damages for the amount which Plaintiff is entitled if
it is a sum certain or which can be made certain by computation..." In the
instant case, the amount to which Plaintiff is entitled is readily calculated
by review of the Mortgage Agreement, which is of record, together with the
Complaint which specifically lists the items chargeable.
Clearly, if Rule 1037 gives the Prothonotary the right to assess damages
for the amount to which Plaintiff is entitled as set forth in the Complaint,
the Court has similar power to reassess damages at a later date.
In addition, Rule 1037(a) provides that the Court, on motion of a party,
may enter an appropriate judgment against a party upon default or admission.
If the Court has the power to enter judgment, it certainly has the power to do
a lesser act, to wit, reassess damages.
It is settled law in Pennsylvania that the Court may exercise its
equitable powers to control the enforcement of a judgment and to grant any
relief until that judgment is satisfied. 20 P.L.E., Judgments Sec. 191. See
also, Stephenson v. Butts, 187 Pa.Super 55, 59, 142 A.2d 319, 321 (1958); Chase
Home Mortqaqe Corporation of the Southwest v. Good, 537 A.2d 22, 24 (Pa.Super
1988) .
In Chase Home Mortqaqe, the Court stated that where a judgment has been
assessed following defendant's failure to file a responsive pleading in a
mortgage foreclosure action, a mortgagee "... could properly move the court to
amend the judgment to add additional sums due by virtue if the mortgage's
failure to comply with the terms of the mortgage agreement..." Id. at 24.
Because a judgment in mortgage foreclosure is strictly in rem, it is critical
that the judgment reflect those amounts expended by the Plaintiff in protecting
the property. See Meco Reality Company v. Burns, 414 Pa. 495, 200 A.2d 335
(1971) .
plaintiff submits that if Plaintiff went to sale without reassessing
damages, and if there was competitive bidding for the subject premises,
Plaintiff would suffer irreparable harm in that it would not be able to recoup
monies it paid to protect its interest. Conversely, a reassessment of damages
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will not be detrimental whatsoever to Defendant (s) as it imputes no personal
liability.
The Supreme Court of Pennsylvania found in the Landau v. Western Pa. Nat.
Bank case that the debt owed on a mortgage
changes and can be expected to change from day to day, because Western
Pennsylvania must pay expenses for the property in order to protect its
collateral.
445 Pa. 117, 282 A.2d 335 (1971). Because a mortgage lien is not
extinguished until the debt is paid, Plaintiff must protect its collateral up
until the date of sale.
See Beckman v. Altoona Trust Co., 332 Fa. 545, 2 A,2d
826 (1939).
Therefore, Plaintiff respectfully submits that if the enforcement of its
rights are delayed by legal proceedings and enforcement of its judgment, and
such delays require the mortgagee to expend additional sums pursuant to the
Mortgage, then said expenses become part of the mortgagee's lien and should be
included in said judgment.
As the Court indicated in FNMA v. Jefferson, an
unreported case a copy of which is attached hereto, since the charges
enumerated in Plaintiff's Motion for Reassessment of Damages were incurred
pursuant to the Mortgage Agreement, and the mortgage had not yet been paid,
said charges should be included in Plaintiff's judgment amount. May Term, 1986,
No. 2359 (CCP PHILA. 1986).
III. CONCLUSION
Plaintiff respectfully requests this Honorable Court grant its Petition to
Reassess Damages.
Plaintiff respectfully submits that it has acted in good
faith in maintaining the property in accordance with the Mortgage, and in
reliance on said instrument
with the understanding that it would recover the monies it expended to protect
its collateral.
wHEREFORE ,
Plaintiff respectfully requests this Honorable Court to
reasseSS the damages as set forth in the Petition to Reassess Damages.
FEDERMAN AND PHE~
Q)l/l
DANIEL G. SCHMIEG, ESQUIRE
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FEDERAL NhTION~ MORTGAGE
ASSOCIl\'l'IOH
COUR'J: OF CO~MOH PLl;7IS
I'H!L~.DELPllIl\ COWl'ry
CIVIL TRIAL DIVISION
vs.
JOSEPH JEFE'ERSO!'l' and,
, ROSIE JEFFE.1<SON, his '>life
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HAY TERM," 1982:' ;'r,
NO. 2359 ~ ,ff)i)
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ORDER AND OPINION
WHITE, J.
/\.NO NOI'l,this
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UPon consideration of Plaintiff: FedcrO\l National t~ortgaqc
As$ociation's Petition for .Reconsideration Nunc Pro Tunc of
this Court' s Order of November 7, 1985 and tho Answer thlJrGto
of Oefendantsl Jos~ph Jefferson and Rosie Jefferson, it is
hereby'ORDERED and DECREED as'fOllOWS:\
1) Said p~~~~on is GRANTED:
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2) ~~~ir~~rt;s Order of November ;, 1965 i~
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REVERSED and P 1aintiff\' ~ Motio~_for ReaS'sessment.'o~ DamaCjes j.s
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3) J'u'~~;t is hClrolJy l.nCrOalll;d to $6,147,,7L.
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13ecaus<~ l?l,!:lintiff was req;;ired to aC':Gpt cut"r'lnt
mortgage payments upon thG f,iling of ,Defendants' bilnk::-upt<:y
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Plltit1cn and in fact did so, it is necossary to rC<lSSCSS
the an:ount of da~laqe.$ that initially were assess<.Hl ..fter
jUdgmant by default was' entered in this action, Because
D~fendants have not refutGd the specific amcunts claimed
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by Plaintiff in the instant Motion for Reassessmor.t. tlli,;
pursuant to Pa. R.C.? l029(c).
Court finds that Def~ndants have admitted thc~e amounts"
BY THE COURT:
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THOMAS A. WHITE, J~
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VERIFICATION
Daniel G. Schmieg, Esquire, hereby states that he is the attorney for Plaintiff
in this action, that he is authorized to take this affidavit, and that the
statements made in the foregoing Petition for Reassessment of Damages are true
and correct to the best of her knowledge, information and belief. The
undersigned understands that this statement herein is made subject to the
penalties
18
Pa.
c.s.
54904
relating to unsworn falsification to
of
authorities.
DATE: August 14, 2001
CD ~A
Daniel G. Schmieg, Esquire
Attorney for Plaintiff
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FEPERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I.D. No. 62205 ATTORNEY FOR PLAINTIFF
One Penn Center Plaza, Suite 1400
philadelphia, PA 19102-1799
(215\ 563-7000
GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs. CIVIL DIVISION
BARRY E. ZOOK
DEBRA A. ZOOK, A/K/A DEBRA CONDRAD ZOOK,
A/K/A DEBRA A. CONRAD NO. 00-3081-CIVIL
AFFIDAVIT OF SERVICE
Daniel G. Schmieg, Esquire, hereby certifies that a copy of
Plaintiff's Petition for Reassessment of Damages have been sent to the
individuals indicated below on Auqust 14, 2001.
BARRY E. ZOOK
601 HUNTINGTON AVENUE,
F/K/A 25 HUNTINGON ST.
ENOLA, PA 17025
DEBRA A. ZOOK
314 LINDA STREET
DEER PARK, TX 77536
DATE: August 14, 2001
O~LA
Daniel G. Schmieg, Esquire
Attorney for Plaintiff
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ENTIT1~~ VENDOR
FAP.- Frothy of Cumberland County [FCUMB]
CHECK DATE
8/14/20,01
CHECK NO.
150625
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DOC APPLY APPLY TO
NO TO DATE INVOICE INVOICE DOC AMOONT DISCOUNT PAYMENT AMOUNT
150625 13617 4 08/14/01 217250844 9.00 0.00 9.00
ZOOK, B
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FEDERMAN & PHELAN 9.00
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ATTORNEY ESCROW ACCOUNT
ONE PENN CENTER, SUITE 1400
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ATTORNEY ESCROW ACCOUNT PHILADELPHIA, PA 19148 150625
ONE PENN CENTER. SUITE 1400
PHILADELPHIA, PA 19103-1814
OFIM Oll-14-21JOl
DATE
8/14/2001
AMOUNT
***********9.00
Pay
NINE AND 00/100 DOLLARS
VoId after 90 days
To The
Order
Of
Frothy of Cumberland County
Cumberland County Courthouse
One Courthouse Square
Carlisler FA 17013
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-03081 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GMAC MORTGAGE CORPORATION
VS
ZOOK BARRY E ET AL
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
ZOQK BARRY E
the
DEFENDANT
, at 0017:20 HOURS, on the 31st day of May
, 2000
at 601 HUNTINGTON AVENUE
ENOLA, PA 17025
by handing to
BARRY ZOOK
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
So Answers:
18.00
9.92
.00
10.00
.00
37.92
1't~l"~~f
R. Thomas Kline
06/01/2000
FEDERMAN & PHELAN
Sworn and Subscribed to before By:
me this ? f!:-' day of
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Q IU.; 0. !Vi (RfJ~ - ~
~rothonotary ,
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2000-03081 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
GMAC MORTGAGE CORPORATION
VS
ZOOK BARRY E ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
ZOOK DEBRA A AKA DEBRA CONRAD ZOOK AKA DEBRA A CONRAD ZOOK
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOTI CE
, NOT FOUND , as to
the within named DEFENDANT
, ZOOK DEBRA A AKA DEBRA CONRAD
ZOOK AKA DEBRA A CONRAD ZOOK
DEFT. NO LONGER RESIDES AT ADDRESS STATED, NOW
LIVING AT: 314 LINDA ST, DEER PARK TX 77536
Sheriff's Costs:
Docketing
NOT FOUND RETURN
Affidavit
Surcharge
6.00
5.00
.00
10.00
.00
21. 00
County
FEDE & PHELAN
06/01/2000
Sworn and subscribed to before me
this ?tz? day of r
,)Jnn) A.D.
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Pr onotary
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO, 12248
TWO PENN CENTER PLAZA, SillTE 900
PHILADELPHIA, PA 19102
(215) 563-7000
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
ATIORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CML DMSION
TERM
Plaintiff
v.
NO, tftJ- 30f"1
CUMBERLAND COUNTY
BARRY E, ZOOK
DEBRA A. ZOOK,
AfKjA DEBRA CONRAD ZOOK,
AfKjADEBRAA. CONRAD
601 HUNTINGTON AVENUE,
FfKJA 25 HUNTINGTON STREET
ENOLA, PA 17025
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 TIllS 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
/:;C~,
We hereby certify the
within to be a true and
correct copy of the
original filed of record
FEDERMAN AND PHELAN
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LffiERTI AVENUE
CARLISLE, PA 17013
(717) 249-3166
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Loan #: 217250844
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1. Plaintiff is
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
2. The name(s) and last known address(es) of the Defendant(s) are:
BARRY E. ZOOK
DEBRA A. ZOOK,
A/KJA DEBRA CONRAD ZOOK,
A/KJADEBRAA. CONRAD
601 HUNTINGTON AVENUE,
F/KJA 25 HUNTINGTON STREET
ENOLA, PA 17025
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described,
3. On 12/24/87 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to COMMONWEALTH NATIONAL BANK which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 890, Page 994. By Assignment of Mortgage recorded 12/29/87 the mortgage was
assigned to MELLON BANK, NA, which Assignment is recorded in Assignment of
Mortgage Book No. 344, Page 647. By Assignment of Mortgage recorded 11/22/89 the
mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of
Mortgage Book No. 372, Page 737.
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 1/1100 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."
..-.,
:<;::~"Yi
f ~
,.
.
,
~ ~""'"'~
6. The following amounts are due on the mortgage:
Principal Balance
Interest
12/1/99 through 5/1/00
(per Diem $8.93)
Attorney's Fees
Cumulative Late Charges
12/24/87 to 5/1/00
Cost of Suit and Title Search
Subtotal
$31,802.23
1,357.36
800,00
80,65
550.00
34,590.24
Escrow
Credit
Deficit
Subtotal
0,00
111.17
111.17
TOTAL
$ 34,701.41
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.
8. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. ~1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
9. 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.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$ 34,701.41, together with interest from 5/1/00 at the rate of$8.93 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.
/s/ Frank F edennan
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
lRUE COPY FROM RECORD
In Testimony whereof. I here unto set my hancJ
and the seal of said Court at CarlIsle. PI.
This } fr: day ~ ~. ,,2DrrJ
(1...... - (-., ~f'
I , Prothonotary
~,., ~, ~'tc
GMAC Morl(,~ue Corporalion
P,O,. Box 85671
Sar, Diego, CA 92186-5071
3451 Hammond Ave
P.O. Box 780
Waterloo, IA 50704.0780
Servicing
G"AIL..'"
--:-'_._~
Mortgage
Date: March 13, 2000
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
~
This is all orlicialllotice that the mort211ee on your home is in default. and the leuder inte~ds to Coredose,
Spccific inCormation about the nature oC the default is Drovided in the attached Daees.
The HO'mOW:\ER'S MORTGAGE ASSISTA.'I'CE PROGRAM (REMAP) mav be able to helD to save your
home. This ~otice explains how the orOi!rain works.
To see if IIK\IAP can help. you must :'IIEET 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
Counseline AeencY ,
The name, address and phone number of Consumer Credit Coonseline Aeencie! servine voor Coonty are
listed at the end of this Notice. Ifvou have an". Questions.. vou may ClU the Pennsvlvania Housini! Finance
A 2('11 e\' toll Cree at 1.800.342.2397, (Persons with impaired hearine can call (717) 780.1869),
This Notice COli (a illS importantlegal informatioo, If you have any qnestion5. representatives at the Consumer
Credit CoulISclillg 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 NOTlFICACI01\ EN ADJUNTO ES DE SmlA IMPORTANCIA, PUES AFECT A SU DERECHO A
CONTlNUAR VIVmNDO EN SU CASA, SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTlFICACI01\ OBTENGA UNA TRADUCCI01\ I:'IIMEDIATAMENTE Ll.AMAJ'IlDO EST A AGENClA
(pENNSYI,VA1\1A HOUSING FINAJ"iCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA, PUEIJ ES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO
"HOMEOW1\J<:It'S K\IERGENCY MORTGAGE ASSISTAJ'IlCE PROGRAM" EL CUAL PUEDE
SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDIl\IIR SU HIPOTECA
HOMEOWNI':!('S 1\,"IE(S):
PROPERTY ADDRESS:
BARRY E. ZOOR
601 HUNTINGTON AVEN
ENOLA, PA 17025'2629
LOAN ACCT. "0.:
ORIGI:\'AI. I.E"IlER:
CURRENT U:.'\IlElUSER\1CER:
217 250844
N/A
GMAC Mortgage
E)C\..\\~rr ~
~ -~-""
~";~I
GMAC Mortgage Corporation
P,O, Box 85071
Sail Diego, CA 92186-5071
3451 Hammond Ave
P.O, Box 780
Waterloo, IA 50704-0780
Servicing
GMAC
Mortgage
Dare: March 13, 2000
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
~
This is an official notice that the mort2a2e 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 pa2es.
The HOMEOWNER'S MORTGAGE ASSISTA:\CE PROGRAM (REMAP) mav be able to help to .ave vour
home. This :-Iotice explains how the pr02ram works.
To see ifllEMAP can help, you must ~IEET "UH A CONSUMER CREDIT COUNSELING AGENCY
WImIN 30 DAYS OF mE DATE OF THIS l'iOTICE. Take this Notice with vou when vou meet with the
Counselin2 A2encv.
The name. address and Rhone number of Consumer Credit Counselin2 A2eneies servin2 VOUI' County are
listed at tbe ead of tbis Notice, If vou have anY' questions, vou may call the Pennsvlvania Housin2 Finance
A2cncv toll free at 1.800.342.2397, (Per.ons with Unoaired heariu can call (717) 780.1869),
This Notice contain. important legal information. If you have any questions, representatives at the Consumer
Credit Counseling Agcncy ma)' 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 )'OU find a lawyer.
LA NOTIFICACION Ei'." ADJUNTO ES DE SmlA nlPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENIlO EN SU CASA. SI:\O CD:\IPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBU:i'."GA UNA TRADUCCIO:\ nmEDIATAMENTE LLAMANDO ESTA AGE:\CIA
(PENNSYLVANIA HOUSING FINM,CE AGEl'iCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUEIlES SER ELEGIBLE PARA UN PREST A~IO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S E~lERGENCY MORTGAGE ASSIST ^,"CE PROGRAM" EL CUAL PUEDE
SAL VAR SU CASA DE I,A PERDIDA DEL DERECHO A REDIl\DR SU HIPOTECA
HOMEOWNER'S NA~lE(S):
PROPERTY AIlDRESS:
DEBRA A. ZOOR
601 HUNTINGTON AVEN
ENOLA, PA 17025-2629
LO^," ACCT. NO.:
ORIGI:-IAL LE:\DER:
CURRE:\T LE:\DER/SERVICER:
217250844
N/A
GMAC Mortgage
EXHIBIT A
".~j(c
IIO:\IEOWNER'S E:l-IERGENCY :l-IORTGAGE ASSISTANCE PROGRAM
YOU MAY liE ELIGIBLE FOR FlNA.'iCIAL ASSISTAi'..CE WHICH CAJ'I SAVE YOUR HOME FROM
FORECLOSURE AJ'iD HELP YOU :l-JAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMI'LY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANO: ACT OF 1983 (THE" ACT"), YOU:l-1A Y BE ELIGIBU FOR E~JERGENCY MORTGAGE
ASSIS1A"CE:
11' YOUR DEFAULT HAS BEE:'>i CAUSED BY CIRCUMSTANCES
YOUR CONTROL,
IF YOU IIAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
~IORTGAGE PAY:l-JE:'>iTS, A.'iD
IF YOU :l-IEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
TilE PENNSYL V A.'UA HOUS~G FlNA,'1CE AGE:\'CY.
TEMPORARY STAY OF FORECLOSURE -- ender the Act, you are entitled to a temporaIy stay of foreclosure
on your mortgage Ie" thirty (30) days from the date of this :--Iotice. DtIring that time you must arrange and attend a
"face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS
MEETING MUST OCCUR WITHIN TDE NEXT/30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY
MORTGAGE ASSIST A;\"CE. YOU MUST BRING YO"LR MORTGAGE UP TO DATE. TIlE PART OF TIllS
NOTICE CALLED "HOW TO CURE YOUR :\fORTGAGE DEF AUL T". EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE,
CONSUMER CI: EI>IT COUNSELING AG ENCIES -- If you meet with one of the consumer credit cOlmseling
agencies listed at the end of this notice, the lender may :\"OT take action against you for thirty (30) days after the date
of this meeting.The names. addresses and tele1lhone munbers of designated consluner credit counseling agencies for
the county in which the 1lro1lertv is located are set foIth at the end ofthis Notice, It is only necessary to schedule one
face-to-face meeti,,!O, Advise your lender immediate Iv of your intentions.
APPLICA TIOXI'OR ~IORTGAGE ASSIST.-\. 'iCE -- Your mortgage is in default for the reasons set forth later
in this !>."otice (se,' lelllowing pages for specific infonnation about the nature of your default.) If you have tried and
are lmable to re,,' \'e this problem with the lender, you have the right to apply for financial assistance from the
Homeowners En"Tgency \Iortgage Assistance Program, To do so, you must fill out, sign and file a completed
Homeowners En,,'rgency Assistance Program Application with one of the designated conSluner credit cOlmseling
agencies listed at lhe end of this l'otice. Only conSluner credit cOlmseling agencies have applications for the
program and they will assi,t you in Sllbmitting a complete application to the Pennsylvania Housing Finance Agency.
Your applicatioll .'.1L"ST be filed or postmarkod within thiIty (30) days of you face-to-face meeting.
YOU MUST Fill' YOUR APPLICATION PRO:l-IPTI.Y, IF YOU FAIl, TO DO SO OR IF YOU DO NOT
FOLLOW THL I JTllER TI~IE PERIODS SET FORTH IN THIS UTTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IM:l-IEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE \'.11.1. BE DENIED.
AGENCY ACT'. IN -- Available fimds for emergency mortgage assistance are very limited. They will be disbursed
by the Agency u" ler the eli!Oibility criteria established by the Act. The Pennsylvania Housing Finance Agency has
si,,<ty (60) days to :nake a decision after it receives your application. DtIring that time, no foreclosure proceedmgs
will be pursued a,'ainst you if you have met the time requirements set forth above. You will be notified drrectly by
the Pennsylvania ,lousing Finance Agency of its decision on your application. -
EXH\BIT A
.-0
-
I ~
, ,
-
--'Y-~
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BAJ'lKRUPTCY ]
THE FOLl,O\HNG PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND '
SIIOill,D :'I'OT BE CO:'l'SIDERED AS A.'1 ATTE:\IPT TO COLLECT THE DEBT.
(1 f you have med bankruptcy you can stilI apply for Emergency Mortgage Assistance.) .,
HOW TO CURE YOUR MORTGAGE DEFAULT lBrin2 it up to date),
NATURE OF Tll E DEFAULT -- The MORTGAGE debt held by the above lender is on your property located at:
601 Huntington Aven Eno1a, PA 17025'2629 IS SERIOUSLY IN DEFAULT because:
YOU ILl, VE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
fOllowing amounts are now past due: January 1, 2000 through ~arch I, 2000.
See attached Exhibit for payment breakdown.
Monthh Payments
Late Cli"rges
NSF
Inspections
Other
Suspense'
1,242.99
350.12
0.00
14.50
0.00
TOTAl. A:\IOUl\T PAST DUE:
1,607.61
B. YOU HAVE F ,\ILED TO TAKE THE FOLLOWI/liG ACTION (Do not use if not all1l1icable ):
HOW TO CURl: TilE DEFAULT -- You may cure the default within THIR1Y (30) DAYS of the date of this
notice BY PAYL\G THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$ 1,607.61 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING "]'1 IE THIRTY (30) DAY PERJOD, Payments must be made either by cash. cashiets check.
certified check or money order made llayable and sent to:
GMAC Mortgage Corporation
ATTN: Payment Processing
P.O. Box 780
Waterloo, IA 50704-0780
You can cure any ntherdefault by taking the following action within THIR1Y (30) DAYS of the date of this letter:
(Do not use ifno:;'1111licable.) Not Applicable
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIR1Y (30) DAYS of the date
ofthis Notice, tIOl', lender intends to exercise its ri2hts to accelerate the mort2af.e debt, This means that the entire
outstanding bal",,,. of this debt will be considered due immediately and you may ose the chance to pay the
mortgage in monl;,ly installments, Iffull payment of the total amount past due is not made within THIR1Y (30)
DAYS, the lender ,d50 intends to instn,ct its attorneys to start legal action to foreclose upon your mortl!3l!Cd
propertY ,
IF THE MORn;AGEIS FORECLOSED UPON n The mortgaged property will be sold by the Sheriff to payoff
the mortgage dek If the lender refers your case to its attorneys, but you cure the delinquency before the lender
begins legal proce'cdings against you, you will still be required to pay the reasonable attorney's fees that were
actually incurred, up to $50.00. Howeyer, if legal proceedings are started against against you, you will haye to pay all
reasonable atton1l'Y's fees actually incurred by the lendereyen 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 (i,'fault wiihin the TmRTY (30) DAYS period. you wI'll not be reauired to pay attorney's fees.
EXHIBIT A
.
"
.b&lII<;lk;
OTHER LE~DF1( RE:\IEDIES -- The lender may also Sl.e you personally for the \mpaid principal balance and all
other SlunS due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the defaultwilhin
the TIlIR1Y (30) DAY period and forecloSlIft proceedings have beg.m, vou still have the ri2ht to cure the default
and llrevent the sal e at any time Ullto one hour before the Sheriffs Sale , You may do so by navine: the total arnOlmt
then llast due. Dlus anv late or other chaNes then due. reasonable attornev's fees and costs connected with the
forecloSllre sale allll anv other costs connected with the Sheriffs Sale as sllecified in writine: bv the lender and bv
llerfonnine: anv other reQUIrements under the morte:ae:e, Curing your default in the manner set forth in this
uotiee will restore your mortgage to the same position as if you had never defaulted.
EARLIEST POSSIRLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale
of the mortgaged I"operly could be held would be approximately six (6) mouths from the date of this Notiee, A
notice Qfthe actua. date of Lhe Sheriffs Sale will be sent to you before the sale, Of course, the arnmmt needed to
cure the default will increase the longer you wail. You may fmd out at any time exactly what the required payment
or action will be by \,;ontacting the lender.
HOW TO CONTACT THE LENDER:
Name of Le"der:
Address:
GMAC Mortgage Corporation
401 West 24tn Street
National City, CA 91950
Phone )lumber:
Fax Number:
Conti<et Person:
(800) 850 -4622
(619) 470-5579
Collection Department
EFFECT OF SnnUFJ"S SALE -- You should realize that a Sheriffs Sale will end your ownership of the
mortgaged property and your right to occupy il. If you contimle to live in the property after the Sheriffs Sale, a
lawsuit to remove you and your lilmishings and other belongings could be started by the lender at any time.
ASSUMPTION OF :\IO](TGAGE -- You mayor may not sell or transfer your home to a buyer or transferee who
will assume the mel igage debt, provided that all the outstanding payments, chalges and attorney's fees and costs are
paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU :\J.-\Y ALSO HAVE THE RIGHT:
TO SELL TilE I'ROPER1Y TO OBTAI:\ \IO:\EY TO PAY OFF TIlE MORTGAGE DEBT OR TO
BORRO\'>' \IO:\I,Y FROM A:\OTIlER LE:\DI:\G INSTITUTION TO PAY OFF TIllS DEBT.
TO HAW THIS DEFAULTCCREDBY A:--',' THIRDPAR1Y ACTING ON YOUR BEHALF,
TO HA VITI If \ 10RTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD
OCCURRFD.IF YOC CURE TIlE DEFACLT. (HOWEVER, YOU 00 NOT HAVE TIllS RIGHT TO
CURE YOCR PH' ACLT \10RE THAS TIlRH TIMES IN A1W CALENDAR YEAR,)
TO ASSERT TIll', NONEXISTE:\CE OF A DEE AULT IN ANY FORECLOSURE PROCEEDING OR
A", 011 ;ER LA WSClT I:\STIITTED L":\DER THE MORTGAGE DOCUMENTS,
TO ASSrn..\ '\Y OTHER DEFFSSE YOl' BELlEVE YOU ~1AY HAVE TO SUCH ACTION BY TIlE
LENDE](,
TO SEEK PROTLCTION Ul'<'DER TIlE FEDERAL BANKRUPTCY LAW.
CONSl' \1 U( CREDIT COIDiSELI~G AGE:-iCIES SERVING YOUR COUNTY IS ENCLOSED
EXHIBIT A
"" 'ilii
Pennsylvania Housing Finance Agency
Homeownet"'s Emergency Mortgage Assistance Program
Consumet" Ct"edit Counseling Agencies
(Rev. 5/99)
Lc7COC1ing-Clil:r.o" Caunces
Om.c::u.s.sIOQ COOl" C .
2138 Lincoln 5 .. a=lUUt"f Ac::ian (STEP)
.1'. O. Box 1325 ~.
'Vt;.lli.=spor:. PA 17703
(5,0) 325-<l5d7
FA.."!: (570) 322-2197
ioCCS aOfor_i.e"""""" PA
b~ 1 Bas~ S~o,
..Uliam3 ~c_.
(5-0 port, PA 17703
, ) 323-0627
r_~"!:(570)323-o626
CLINTON COUNTY
CCCS ofNor.lleastern P!\'
1531 S Ather""n St .
Suite 100
St:lte College, PA 15801
(814) 238-3668
F.~"{(814) 238-3569
COLUMBIA COlJ1'oTI
cces of~or-_i.eastern PenilSvlvania
1400 Abingtcn E..'tOC'.lcve Park
Suite 1
Clarlts Summit: PA 18411
(570) 587-9153 ad800) 922-9537
FA,"{ (570) 587-913419135
31 W. Marlut Sc...et
POB 1127
W'1lkes.Bar:e. P.'\. 18702
(5701 821-0837 or (800) 922-9537
FA.."!: (570) 821.1785
Commission on Economics Opportunity of Lu:zern.e Count::r
183 .\mber Lane
W'Ukes-Bar:e, PA 18702
(570) 826-<l510 or (800) 822-0359
F.~"{ (570) 829-1665-CALL BEFORE FA."<lNG
(570) 4554994 Ii....zELTON
F.~"{ (570) 455-5631-CALL BEFORE F.~"<lNG
(570) 8364090 TUNKH...."""OCK
Boolur T. Washington Center
1720 Holland St:'eet
Erie, PA 16503
(814) 453-5744
F_~"!: (814) 453-5749
John F, K..nnedy Center, Inc.
2021 East 20th. St~t
Erie, PA 15510
(814) 898-0400
F.~,,{(814) 898-1243
CCCS o(We.tern Pennsv{vania. Inc.
2000 Ling!estown Road'
F...:='.sburg, P.'\. 17102
(717) 541-1757
Urban League oOlet:'Opolitan Harrisburg
N. 6th St::eet
Har:'.sburg, PA 17101
(717) 234-5925
F.~"!: <il7) 234-9459
Co=unit'f .-'.c:ion COaml of the Capibl Region
1514 Oer:-v Sc...et
Harr'.sbu:i, P.'\. 17104
(717) 232-9757
FAX (717) 23+-2227
CRAWFORD COL"l'<TI
Grearar Erie Co=unit"f .-'.c:ion CoClmit"-""
18 We.t 9t.i. Sc...et
Erie, PA 15501
(814) 459-4581
FAX (814) 456-0161
She=go Valley t: <ban League. !nc
601 Indiana Avenue
Farrell. PA 15121
(412) 981-5310
CUMBE1l.l.A....."1) CO'l.;"N'1'Y
Financial COWlSeling Sertico..s of F::utklin
31 West 3rt! St::eet
Waynesborn. P.'\ 17268
(717) 762-3285
YWCA of Carlisle
301 G Street
Carliale. P.'\ 17013
(717) 243-3818
F.~"< (717) 731-9589
Adams COUllt"1 Housing Authorlt"f
139-143 Carlisle St
G.ottysbW'i. PA 17325
(717) 334-1518
F.~"!:(717) 334-8325
EXHIBIT A
PENNSYl.VAHIA BULl.ET1N, VOl.. 29, NO. 2:l, JlJNE 50 1999
. -
~,,~,
, ,
ALto THAT CERTAIN tract or E'arceJ. of J.ana with th.a buildings ar,d
improve~ents thereon erected situate in East Pennsboro
TownShip. Cumberland County. Pet,nsylvania. more particularly
boundea and described as foJ.lows. to wit:
BEGINNING a1;. a point at. the Northwesterly corner of Huntingtoll
Street and Chester Avenue: thence aJ.ong tha,Northerly line of
Huntingto,n, Street S,outh,_ 87, degrees 30.,minutes West. J.OO feet .~o
a poi.nt:' 'the~ce,N!=';:th ,;Z degree,s, 30 minutes West, 1.<12 fee':, to ;\
point. at the ,~,oU1:.ne!=lY..,line of a. ~S feet pUblic alley; thence
along same N9~~~_~7,~~qrees ~9 m~nutes East. 100 feet to a
point on th,e..Wes.te;:lY, 1iD..e, of Chester,-Avenue aforesaid; thenea
'41.ong same. So.U'eh 2 "deg-rees 3<;1' ,minutes East, ~'l2 feet to a ",oi:1.t
the pl.aee of Beginning. -. Being premises known as No. 601
Huntingt,on, Avenue I former1y known as 25 Huntington Street.
BEING the sa~e premises which John S. Putt and Mary Helen Putt,
his wife. by, their, Deed dated -January 1.:1.. J.957. and recorded ill'
the O~eiee of Recorder of Deeds ~n and for Cumcerland County.
PennsyJ.van~a. in Deed Book "0". Vol. 17. Page 578. granted and
conveyed unto Charles William Snyder and Olq~a A. Snyder. his
wife. said Olg-ia A. snyder having died on /174,:+ .:23, / f<5~-. r:.itle,
thereto vested in Charles WiJ.lia~ Snyder. a/~a Charles W.
snyder.
PREMISES: 601 HUNTINGTON AVENUE
~
.
l"- 'b~.
. '
VERIFICA nON
SHIRLEY J, EADS hereby states that she is FORECLOSURE SPECIALIST ofGMAC
MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she 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 her knowledge, information and belief. The undersigned
understands that this statement is made subject to the penalties 'of 18 Pa, C.S, See, 4904 relating to unsworn
falsification to authorities,
DATE: 5/1 ~16CJ
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTlFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
COURT OF COMMON PLEAS
CML DMSION
ATTORNEY FOR PLAINTIFF
Plaintiff
TERM
NO, trlJ. 30$1 ~ I~
CUMBERLAND COUNTY
v,
BARRY E. ZOOK
DEBRA A. ZOOK,
A/KJA DEBRA CONRAD ZOOK,
A/KJA DEBRA A. CONRAD
601 HUNTINGTON AVENUE,
F/KIA 25 HUNTINGTON STREET
ENOLA, PA 17025
Defendant(s)
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
"THIS 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 TIllS DEBT WAS NOT REAFFIRMED, THIS
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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
We hereby certify the
within to be a true and
correct copy ofthe
original filed of record
FEDERMAN AND PHELAN
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, P A 17013
(717) 249-3166
Loan#: 217250844
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1. Plaintiff is
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
2.
The name(s) and last known address(es) of the Defendant(s) are:
BARRY E. ZOOK
DEBRA A. ZOOK,
NKJA DEBRA CONRAD ZOOK,
NKJA DEBRA A. CONRAD
601 HUNTINGTON AVENUE,
FIKIA 25 HUNTINGTON STREET
ENOLA, P A 17025
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3, On 12124/87 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to COMMONWEALTH NATIONAL BANK which mortgage is
recorded in the Office of the Recorder ot1CUMBERLAND County, in Mortgage Book
No, 890, Page 994. By Assignment of Mortgage recorded 12/29/87 the mortgage was
assigned to MELLON BANK, N,A., which Assignment is recorded in Assignment of
Mortgage Book No. 344, Page 647. By Assignment of Mortgage recorded 11/22/89 the
mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of
Mortgage Book No. 372, Page 737,
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 1/1/00 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. "
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6, The following amounts are due on the mortgage:
Principal Balance
Interest
12/1/99 through 5/1/00
(per Diem $8.93)
Attorney's Fees
Cumulative Late Charges
12/24/87 to 5/l100
Cost of Suit and Title Search
Subtotal
$31,802.23
1,357.36
800.00
80,65
550,00
34,590.24
Escrow
Credit
Deficit
Subtotal
TOTAL
0,00
111.17
111.17
$ 34,701.41
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
Sherif1's Sale, If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. ~1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A,"
9. 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,
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$ 34,701.41, together with interest from 5/1/00 at the rate of$8,93 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.
/s/ Frank Federman
FRAJ{KFEDE~,ESQlITRE
Attorney for Plaintiff
TRUE COpy FROM RECORD
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10 Testimony whereof. I here unto set my hano
and tile seal of said Court at Car1lsle. ~
This r~ day ~~.. ~2Z1L
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Prothonotary
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Mortgage "'
GMAC Mort('~(;e Corporation
P,q, Box 856'7r
Sa" Diego, CA 92186-5071
3451 HammOnd Ave
P.O. Box 780
Waterloo, IA 50704-0780
Date:
March 13, 2000
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
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Tbis h an official notice tbat tbe mort2a2e on vour bome is in defanlt. and tbe lender intends to foreclose.
Snecifie information abont tbe nature oUhe defan!t isorovided in the attached oa2es.
),
Tbe HOMF:OW~ER'S MORTGAGE ASSISTA,,'o/CE PROGRAM (BEMAP) mav be able to helD to save vour
bome. Tbis ~otice exolains how the or02ram works,
To see if lIDIAP can helD. vou must :\IEET WITH A CONSUMER CREDIT COUNSELING AGEJ'iCY
WITIlIN 30 DAYS OF THE DATE OF TBIS NOTICE. Take this Notice with vou when vou meet with the
Counselin2 A2encv. .
The name. address and ohone nnmber of Consumer Credit Counselin2 A2encies servin!! vour County are
listed at tile end oUhis Notice, Uvou have anv questions. vou mav call the Pennsvlvania Bousin!! Finance
A~"lIcv toll free at 1-800-342-2397. (Persons with imoaired hearin2 can call (717) 780-1869).
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This Notice co"l"ins important legal information. Uyou have any qnestions, representatives at the Consnmer
Credit Counseling Agency may be able to belp 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 NOTIFICAClO:\ E~ ADJWlTO ES DE SU:\IA IMPORTAJNCIA, PUES AFECTA SU DERECBO A
CONTINUAR VIvmNDO EN SU CASA, SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACIO:\ OIlTE:\GA UNA TRADUCCION IMMEDIATAMENTE U.AMAJNDO EST A AGENCIA
(PENNSYI.vA:\IA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUEIl ES SER EI.EGIBLE PARA WI PREST AMO POR EL PROGRAMA LLAMADO
"BOMEOW:\Elt'S EMERGENCY MORTGAGE ASSISTAJNCE PROGRAM" EL CUAL PUEDE
SALVAR Su CASA DE LA PERDlDA DEL DERECBO A REDII\UR SU HIPOTECA
BOMEOWNJo:lt'S :\,nlE(S):
PROPERTY AIlIlRESS:
BARRY E. ZOOR
601 HUNTINGTON AVEN
ENOLA, PA 17025-2629
LOAJ'i ACCT. :\0.:
ORIGI:\AI. U:.'\IJJo:R:
CURRENT LE:\IJEIUSER\1CER:
217 250844
N/A
GMAC Mortgage
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GMAC Mor'aage Corporation Servicing
P,Q, Box 85 71 i
San Diego, CA 92186-5071 GMAC
3451 Hammond Ave " ' .'
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P,Q. Box 780 Mortgage I'
Waterloo, IA 50704-0780 "
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Date: March 13, 2000
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
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This is an official notice that the mort!a!e on your home is in default. and the lender intends to foreclo.e.
SDecific iI,formation about the nature of the default is Drovided in the attached pa!es.
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To see ifIlE:\IAP can helD. \'Ou must :\IEET \nTH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS :\"OTICE, Take this Notice with vou when vou meet with the
Coun.elin! A!encv.
The name. address and Dhone number of Consumer Credit Counselin! A!encies servin! vour County are
listed at the end of tltis Notice. If vOU have anv auestions. vOU mav caD the Pennsvlvania Housin! Finance
A!.ncv toll f"ee at 1-800-342.2397, !Person. with imDaired hearin! can call (717) 780-1869).
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The HOMEOWNER'S MORTGAGE ASSISTA ","CE PROGRAM IHEMAP) mav be able to helD to save vour
home. This ~otice eXDlains how the DrOl!J'3m works.
This Notice cont,dns important legal information. If you have any questions, representatives at the Consumer
Credit Coun.elin g Agcncy may be able to help explain it. You may' also wanttn contact an attorney in your
area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION E:-i ADJUNTO ES DE SmlA I:\IPORTAi"CIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENHO EN SU CASA. SI:\"O CmlPRENDE EL CONTENIDO DE ESTA
NOTIFICACIO:\" OBTE:\"GA UNA TRADUCCIO:\" HnIEDlATAMENTE LLAMANDO ESTA AGENCIA
(PENNSYL V AMA HOUSING FINAJ"ICE AGE:\"CY) SIN CARGOS AI" NUMERO :\IENCIONADO
ARRIBA. PUEHES SER ELIGIBLE PARA IDi PRESTA:\IO POR EL PROGRAMA LLAMADO
"HOl\IEO\\'NER'S E:\IERGE:'>iCY MORTGAGE ASSlSTAJ"ICE PROGRAM" EL CUAL PUEDE
SAL V AR SU CASA DE I.A PERDIDA DEL DERECIlO A REDlMIR SU HIPOTECA
HO:\IEOWNER'S :\"A:\IE(S):
PROPERTY ADDRESS,
DEBRA A. ZOOK
601 HUNTINGTON AVEN
ENOLA, PA 17025.2629
LOA"I ACCT. NO.:
ORlGI:\'AL LE:'\DER:
CURRE:-iT LE:\HERlSERVICER:
217250844
N/A
GMAC Mortgage
EXHiBiT A
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HO:\IEOWNER'S E:\IERGE~CY :\IORTGAGE ASSIST MICE PROGRt~'1
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YOU:\I,\ Y BE ELIGIBLE FOR Fl~t~"iCIAL ASSISTA."iCE WHICH CA." SAVE YOUR HOME FROM
I;ORECLOSURE AND HELP YOU :\IAKE FUTURE MORTGAGE PAYMENTS
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IF YOU COMI'LY WITH THE PRO\1SIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTA:-ICE ACT OF 1983 (THE" ACT"), YOU :\IAY BE ELlGIBI.E FOR EMERGENCY MORTGAGE
ASSISTA.'liCE:
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IF YOUR DEFAULT HAS BEE~ CAUSED BY CIRCUMSTANCES
YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
~IORTGAGE PAUIE:It"TS, A.'liD
IF YOU :\IEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
TilE PENNSYLVANIA HOUSr.\'G FI:-IA.'1CE AGENCY.
TEMPORARY STAY OF FORECLOSURE .. Under the Act, you are entitled to a temporaI)' stay offoreclosure
on your mortgage l(lT thirty (30) days from the date of this )lotice. Thrring that time you must arrange and attend a
"face.to.face" meeting with one of the consurnercredit counseling agencies listed at the end of this Notice. THIS
MEETING MUST OCCUR WITmN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY
MORTGAGE ASSIST Al\CE. YOU MUST BRING YOCR MORTGAGE UP TO DATE. TIlE PART OF TIllS
NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEF AmT". EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUMER C]( EDIT COUNSELING AGENCIES .. If you meet with one of the consmner credit cmmseling
agencies listed at the end of this notice, the lender may ~OT take action against you for thirty (30) days after the date
of this meeting, The names. addresses and telellhone munbers of desi211ated consumer credit cmmseline aeencies for
the county in which the orooertv is located are set forth at the end of this Notice, It is only necessary to schedule one
face.to-face meetille, Advise your lender inunediatelv of your intentions.
APPLICATIO:\" FOR :\IORTGAGE ASSISTA."iCE -- Your mortgage is in default for the reasons set forth later
in this l"otice (se,' !()llowing pages for specific information about the nature of your default.) If you have tried and
ate lmable to rese ,'e this problem with the lender, you have the right to apply for financial assistance from the
Homeowners En"Tgency ~-[ortgage Assistance Program. To do so, you must fill out, sign and file a completed
Homeowners Erll.' rgency Assistance Program Application with one of the designated conSluner credit cmmseling
agencies listed allhe end of this ]\;otice, Only conSluner credit cmmseling agencies have applications for the
program and they will assist you in Sllbmitting a complete application to the Pennsylvania Housing Finance Agency.
Your applicatioll :, ICST be filed or postmarked within thirty (30) days of you face-to.face meeting,
YOU MUST FII Y YOUR APPLICATIO~ PRO:\IPTI.Y, IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW THE l JTlIER TI:\IE PERIODS SET FORTH IN THIS LEITER, FORECLOSURE MAY
PROCEED AG,\I~ST YOUR HOME UUIEDIATELY t~'1D YOUR APPLICATION FOR MORTGAGE
ASSISTt~'1CE \"11.1. BE DENIED.
AGENCY ACTI' )~ -- Available funds for emergency mortgage assistance are very limited. They will be disbursed
by the Agency 11(' tor the eJieibility criteria established by the Act. The Pennsylvania Housing Fmance Agency has
sixty (60) days to ,nake a decision after it receives YOllf application. During that time, no forecloSlIl"e proceedmgs
will be pursued ",'ainst you if you have met the time requirements set forth above, You will be notified drrectly by
the Pennsylvania: lousing finance Agency of its decision on your application.
EXH\B\T A
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NOtE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BAl'lKRUPTCY
THE FOLLOWL"iG PART OF THIS ~OTICE IS FOR INFORMATION PURPOSES ONLY AND '
SIIOm.D :-\OT BE CO:-\SIDERED AS A.'I ATIE:\-IPT TO COLLECT THE DEBT.
(1 f YOII have med bankruptcy YOII can still apply for Emergency Mortgage Assistance.)
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HOW TO CURE YOUR ~IORTGAGE DEFAULT (Brin2 it 110 to date),
NATURE OF Tll E DEFAULT -- The MORTGAGE debt held by the above lender is on your property located at:
601 Huntington Aven Eno1a, PA 17025'2629 IS SERIOUSLY IN DEFAULT because:
YOU ll:\ VE NOT MADE MONTHLY MORTGAGE P A YMEl'-liS for the following months and the
f0110winQ amounts are now past due: January 1, 2000 through March 1, 2000.
See attached Exhibit for payment breakdown.
Monthh' Pavments
Late C1;'''ges
NSF
Inspections
Other
Suspens,'
1,242.99
350.12
0.00
14.50
0.00
TOTAl. A:\IOU;\T PAST DUE:
1,607.61
B. YOU HAVE F AILED TO T AleE THE FOLLOWIl'G ACTION (Do not use if not annlicable ):
HOW TO CURl: TIlE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this
notice BY PAYI"G THE TOTAL ^,\IOUNT PAST DUE TO THE LENDER, WHICH IS
$ 1,607. G1 ,PLUS .-\.,-y :<.10RTGAGEPAYMENTS AND LATE CHARGES \",HICH BECOME
DUE DURING TI IE THIR'!y (30) DAY PERIOD, Pavments must be made either bv cash, cashiers check.
certified check or monev order made navable and sent to,
GMAC Mortgage Corporation
ATTN: Payment Processing
P.O. Box 780
Waterloo, IA 50704,0780
You can cllre any Diller default by taking the following action within THIRTY (30) DAYS of the date of this letter:
(Do notllse ifnn' :>\l11licahle,) N tAl' '1
o pp leaD e
IF YOU DO NOT CURE THE DEFAULT ulfvou do not cure the default within THIRTY (30) DAYS ofthe date
of this Notice, thc lender ihtends to exercise its ri hts to acc,eIerate the mort a e debt, This means that the entire
olltstanding bala",:c ofthi. debt will be considered due immediately and you may ose the chance to pay the
mortgage in montldy installments, Iffull payment of the total amount past due is not made within TIIlRTY (30)
DAYS, the lender :11 so intends to instnlct its attorneys to start legal action to Coreclose UDon vour mort2a2ed
Dronerty,
IF THE l\IORTC AGE IS FORECI.OSED UPO~ -- The mortgaged property will be sold by the Sheriff to payoff
the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender
begins legal proc,'cdings against you, you will still be required to pay the reasonable attorney's fees that were
actually incurred, up to $50,00, However, iflegal proceedings are started against against you, you ~ll have. to pay all
reasonable attoDwy" 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.
Ifvou Cllre the (:"r"ult within the TIDRTY (30) DAYS period. vou wiD not be required to Dav attornev's fees.
EXHIBIT A
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OTHER I.E;\iDEI( RE:\IEDIES -- The lender may also sue you personally for the unpaid principal balance and all
other slUns due under the mortgage,
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE --If you have not c\lred the default within
the TIlJRTY (30) DAY period and foreclosure proceedings have begun, vou still have the ril!bt to cure the default
and Drevent the sale at anv time UD to one hour before the Sheriff's Sale. You mav do so by navin!! the total amount
then Dast due. Dlus anv late or other char1!es then due. reasonable attornev's fees and costs connected with the
foreclo~re sale ami anv other costs connected with the Sherifl's Sale as sDecified in writin!! by the lender and bv
DerfornUn!! anv other reamrements under the mort!!a!!e, Curing your default in the manner set forth in this
notiee will rest"rc your mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SAI.E DATE -- It is estimated that the earliest date that SIIch a Sherifl's Sale
ofthe mortgaged J" operly could be held would be approximately six (6) months from the date of this Notiee. A
notice of the aclt'"' date of lhe Sheriff's Sale will be sent to you before the sale. Of course, the amOlmt needed to
cure the default will increase the longer you wait. You may fmd out at any time exactly what the required payment
or action will be h)' contacting the lender.
HOW TO CONTACT TilE LENDER:
Name of Lender:
Addrcs s:
GMAC Mortgage Corporation
401 West 24th Street
National City, CA 91950
PhOne:: ~umbcr:
Fax N'Jmber:
Cont,;ct Person:
(800) 850'4622
(619) 470-5579
Collection Department
EFFECT OF SnLRU'F'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Shenfl's Sale, a
lawSllit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF :\IOI:TGAGE -- You may or ma~' not sell or transfer your home to a lmyer or transferee who
will assume the mOl igage debt, provided that all the outstanding payments, charges and attorney's fees and costs are
paid prior to or atlhe sale and that the other requirements of the mortgage are satisfied.
YOU 'lAY ALSO HAVE THE RIGHT:
TO SELl. TIlE PROPERTY TO OBTA]:,\ ~lOVY TO PAY OFF TIlE MORTGAGE DEBT OR TO
BORRO\\' ~IO:"I,Y FROM ANOTHER LE:\DI:\G INSTITUTION TO PAY OFF THIS DEBT
TO HAVE THIS DEFAULT CURED BY A),,' THIRD PARTY ACTING ON YOUR BEHALF,
TO HA VI' 'I'llI' ~IORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURR}'I), IF YOC CURE THE DEFACLT (HOWEVER, YOU 00 NOT HAVE THIS RlGHT TO
CURE YOlK DH ACL T MORE THA:'\ THRl;E TIMES IN ANY CALENDAR YEAR.)
TO ASSFRT 1'1 II: NONEXISTENCE OF A DEFAU.T IN ANY FORECLOSURE PROCEEDING OR
A;-''Y 01'1 lER LA WSCIT I:'\STITCTED C:\DER THE MORTGAGE DOCUMENTS,
TO ASSrn ,\ -.;,. OTHER DEFE"SE I'm' RELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER,
TO SEEK l'ROTI',CTION UNDER TIlE FEDERAL BANKRUPTCY LAW,
CONS1'\IE1: CREDIT COUNSELING AGE~'CIES SERVING YOUR COUNTY IS ENCLOSED
EXHIBIT A
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Pennsylvania Housing Finance Agency
Homeowner's Emergency Mortgag~ Assistance Program
Consumer Credit Counseling Agencies
(Rev. 5/99)
L7COIl1ing.Clic"'n Counties
Colnlltiss' l:' .
2138 !..inc:ll: ~~So=w:ut'j A.c:ion (STEP)
p. 0, Box 1323 ---
Willi.:unsocr-.: tl:\ 1--0
(5-0)3' -" ,,3
, :~5dj
FA..'C (570) 322.2197
~CCS of ~or-~'le:1St.e~ P.>"
1 a""", St:-.!..
WUliam.. --
(5-0) port, PA 17703
j 323..0627
F_~'C,(570) 323-ao26
CLIN'rON CotINTY
CCCS ofNor-.heaste~ P!\.
16~1 S Ather-.:on St ..
Swte 100
St:lte College. PA 16S0 1
(814) 238-3668
F_~(814) 238-3669
COLtJ"7ilBIA COl.J1't"TY
31 W. Market St:-eet
FOa U27
W1lkes-B=. FA 18702
(570) 821-<)837 or (SOO) 922.953.
F.~'C(5.0) 821-1785
Commission on Ec:lnornio OpportuIlit"J of Lu:erne Co=t"!
163 _~ber Lane
W1lkes.B=. PA 18702 .
(510) 826-0510 or (800) 822-0359
F..~'C (570) 829-1665-CALL BEFORE FA."'aNC
(570) 4554994 l:L-'lZELTON
F_~'C (570) {S5-5631-CALL BEFORE F.~"'aNC
(570) 836-4090 TU1't"KE.-\J,""NOCK
CCCS of)(or-_'leastern PenllSv!vanla
1{00 .\bington Exec-.lcve Park
Suite 1
Clarks S=.rnitt PA 184U
(570) 587-9163 od800) 922-953.
F.~'{ (570) 567-913-109135
Booker T. Washington Center
1720 Holland St:'l>et
Erie, PA 16503
(814) {53-5744
F_~,{(81{) 453-57{9
John F. K..nn.edy Center, Inc.
2021 East 20t.'l St:-e<!t
Erie, PA 16510
(81{) 898-0400
FA-X (814) 898-1243
CRAWFORD COl,1't"TY
Greater Erie Co=unit"j "":ion Co=it'".ee
18 West 9th Street .
Erie, FA 16501
(814) {59-l581
F.~ (814) 456-0161
She=ngo Valley 1.; rban teague. Inc
601 Indiana Avenue
F=eU. FA 16121
(412) 981-5310
CCCS of Wester:> Pennsv!vania, Inc.
2000 ting!estown Road .
F....",...burg. F.>" 17102
(717) 541-1757
Urban League of "letropolit3n F....",...bur;r
N. 6th St:r'eet
H.ar:"..burg, PA 17101
(717) 234-5925
F A-'C (717) 234-9459
Co=unit'j .~:::on Co= of the Capital Region
1514 Der.v St:'eet
Han-'..buri;, FA 17104
(717) 232.9757
F.~"{ (717) 234-2227
n"MBER.LA.. 'lD COl,1't"TY
Fin!lnt"'!'!Il Counseling Serrices ofF:"3l1klin
31 West 3rt! Street
Wayuesbor<l. P.>" 1n68
(7l7) 762-3285
YWCA of Carlisle
301 G St>=t
Carlisle. FA 17013
(717) 243-3818
FA.'{ (711) 731-9589
Adams Count"l Housing Aut.'lorit'j
139-143 Carlisle St
c"ttysburg, P.... 17325
(117) 334-1518
F.~"{ (717) 334-8325
EXHIBIT A
PENNSYl.VAN/A SUu.ETlN. VOL 29, NO. 2:3, JUNE 5, 1999
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ALl:. THAT CERTAIN tract or l?arce1. of lanCl ",ien th.. buildings ar,Cl
improvements thereon erected situate in East Pennsboro
TownShip, Cumberland County, Pet.nsylvania, more particularly
bounded and describeCl as ~o1.lows, to "'it:
BEGINNING at a point at the Northwesterly corner of Huneington
Street and Chester Avenue: thence along tne,Nortnerly line of
Huntinqto,nStreet S,outh.,. 87, de<;zrees 30.lninut.es West, lOa feet ':0
a point;"ther>"ce,Np;t.h ,2 degree,s, 30 minutes West.. 1.'12 feet, to ,1
point' at the South'erly..line pf a 15 feet pUbl.ic alley; thence
along same N9i;:'t,h.B,7:.deqrees 3,9 minutes EaSt. lOa feet to a
point on the, West'er'ly, 1ine, of Chester'.Avenue aforesaid.; thene.
'a:long saine 'South 2 "deg-ree's 39' ,minutes East, 1.4.2 feet to a 1'oi:1t
the place of Beginning." Being- premises known as No. 601
Hunting-t,on Avenue I formerly known as 25 Hunti.ngton Street.
BEING the same premises which John S. Putt and. Mary Helen Putt.
his ",if... by, their, Deed dated -January 1.1.. 1.957, and. reeorCled. in
tbe O~fiee of Reeorder of Deeds in and for CumberlanCl County.
PennSYlvania. in Deed Book "0", Vol. l7, Page 578, qran~ed aod.
conveyad unt.o Charles William Snyder and Olqia A.Snyder. his
wife. Said Olqia A. snyder having died on /174.:;t .:<3, / r'6"!;)-. l:itle
thereto vested in Charles William Snyder. a/~a Charles w.
snyCler.
PREMISES: 601 HUNTINGTON AVENUE
"
. .
VERIFICATION
SHIRLEY], EADS hereby states that she is FORECLOSURE SPECIALIST ofGMAC
MORTGAGE CORPORA nON mortgage servicing agent for Plaintiff in this matter, that she is
authorized to take this Verification. and that the sratements made in the foregoing Civil Action in Mortgage
Foreclosure are true and correct to the best of her knowledge, infomlation and belief. The undersigned
understands that this statement is made subject to the penalties of 18 Pa, C.S, Sec, 4904 relating to unsworn
falsification to authorities,
DATE: 5/ ~ (j U
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AFFIDAVIT OF SERVICE - CUMBERLAND **NO RII**
PLAINTIFF GMAC MORTGAGE CORPORATION NO. 00-3081-CIVIL
DEFENDANT BARRY E. ZOOK
DEBRA A. ZOOK,A/K/A
DEBRA CONRAD ZOOK, A/K/A
DEBRA A. CONRAD
TYPE OF ACTION
xx Mortgage Foreclosure
XX Civil Action
SERVE AT: 314 LINDA STREET
DEER PARK, TX 77536
SERVE~ tt
g:.~:~~a~~do~a.~~ekn1..rt t~a{;l~~. .z~oo, at ~~~~
_ o'clock, ~. M., at 31~'_~_ed,fJea_h~ _
"1'lt;')3Lp , City in the manner described below:
X Defendant personally served.
Adult family member with whom Defendant(s) reside(s).
Relationship is
Adult in charge of Defendant's residence who refused to give
name/relationship.
Manager/Clerk of place of lodging in which Defendant(s) reside(s)
Agent or person in charge of Defendant's office or usual place of
business.
and officer of said defendant
company.
Other:
I ,1OrnoJ/l L'1irtt;l , a competent adult, being duly s accorqin to,
law, depose ana state that I personally handed to fi .
_ a t:tue and correct copy of the fOil 'vi'( .0'h'OI1..
issued in the captioned case on the date d at the address indicated
above.
and sU9{l~ibed
this !;tiS' d
,2-
aru;r~
NOT SERVED
ay 0
n !itM~
rJAVCOMM~~
May 30. 2003
, 2000, at
o'clock
ause:
No Answer
Vacant
Sworn to
Before me
Of
Notary:
and subscribed
the day
, 2000.
By:
ATTORNEY OF PLAINTIFF
FRANK FEDERMAN, ESQUIRE - I.D.#12248
Two Penn Center Plaza - Suite 900
philadelphia, PA 19102
(215) 563-7000
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
Attomey for Plaintiff
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff
: CIVIL DIVISION
VS.
: NO. 00-3081-CIVIL
BARRY E. ZOOK
601 HUNTINGTON AVENUE
FIKfA 25 HUNTINGTON STREET
ENOLA, PA 17025
DEBRA A. ZOOK
AlKfA DEBRA CONRAD ZOOK
AlKfA DEBRA A. CONRAD
314 LINDA STREET
DEER PARK, TX 77536
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment, in rem, in favor of the Plaintiff and against BARRY E. ZOOK and
DEBRA A. ZOOK. AlKfA DEBRA CONRAD ZOOK. AlKfA DEBRA A. CONRAD.
Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service
thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as
follows:
As set forth in Complaint
Interest 5/1/00 TO 08/01/00
TOTAL
$34,701.41
$830.49
$35,531.90
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above,
and (2) notice has been given in accordance with Rule 237.1, e Z~~
RANK FEDERMAN, ESQUIRE
Attonrey roc pJmntijf ~
DAMAGfJ, ARE HEREBY ASSESSED AS INDICATED. a A-:;/;;; /)"
DATE: 'J 9 ,,2 ::1.000 4" I ).
. , PRO PROT
"THIS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FORTHAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS
NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ..
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FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563 -7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
vs.
CUMBERLAND COUNTY
BARRY E. ZOOK
DEBRA A. ZOOK, A/K/A DEBRA
CONRAD ZOOK, A/K/A DEBRA A.
CONRAD
NO. 00-3081-CIVIL
Defendant(s)
TO: BARRY E. ZOOK
601 HUNTINGTON AVENUE,
F/K/A 25 HUNTINGTON STREET
ENOLA, PA 17025
DATE OF NOTICE: JULY 18. 2000
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN
AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this:
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
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FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
vs.
CUMBERLAND COUNTY
BARRY E. ZOOK
DEBRA A. ZOOK, A/K/A DEBRA
CONRAD ZOOK, A/K/A DEBRA A.
CONRAD
NO. 00-3081-CIVIL
Defendant
TO: DEBRA A. ZOOK, A/K/A DEBRA CONRAD ZOOK, A/K/A DEBRA A. CONRAD
314 LINDA STREET
DEER PARK, TX 77536
DATE OF NOTICE: JULY 18. 2000
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS
NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A
DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CillvIBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
. ,
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.
FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
Attomey for Plaintiff
GMAC MORTGAGE CORPORATION
: CUMBERLAND COUNTY
Plaintiff
: Court of Common Pleas
vs.
: CIVIL DIVISION
BARRY E. ZOOK
DEBRA A. ZOOK
AfK/A DEBRA CONRAD ZOOK
AfK/A DEBRA A. CONRAD
: NO. 00-3081-CIVIL
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attomey for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the
following facts, to wit:
(a) that the defendant(s) is/are 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
(b) that defendant BARRY E. ZOOK is over 18 years of age and resides at 601
HUNTINGTON AVENUE, F/KIA 25 HUNTINGTON STREET, ENOLA, P A 17025.
(c) that defendant DEBRA A. ZOOK, AfK/A DEBRA CONRAD ZOOK, AfK/A
DEBRA A. CONRAD is over 18 years of age, and resides at 314 LINDA STREET, DEER
PARK, TX 77536.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unswom falsification to authorities.
2:r~k~~
FRANK FEDERMAN
Attomey for Plaintiff
i.
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,
.
(Rule of Civil Procedure No. 236 - Revised)
GMAC MORTGAGE CORPORATION
: CUMBERLAND COUNTY
Plaintiff
: Court of Common Pleas
vs.
: CIVIL DMSION
BARRY E. ZOOK
DEBRA A. ZOOK
AlK/A DEBRA CONRAD ZOOK
AlK/ADEBRAA. CONRAD
: NO. 00-3081-CIVIL
Defendant(s)
Notice is given that a Judgment in the above captioned matter has been entered against you on
AUGUST d1.. .2000. ..
BYlsj(L~~;,.;/i2;/~ ~~1
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESQUIRE
Attomey for Filing Party
SUITE 900
TWQ PENN CENTER PLAZA
PHILADELPHIA. PA 19102
(215) 563-7000
**TIDS 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 TIDS DEBT WAS NOT REAFFIRMED, TIllS IS NOT
AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY, **
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GMAC Mortgage Corporation In The Court of Common Pleas of
Cumberland County, Pennsylvania
-vs- No.2000-3081 Civil
Barry E. Zook and Debra A. Zook alkJa Debra A. Conrad
R. Thomas Kline, Sheriff, who being duly swom according to law, says this writ
is returned STAYED.
Sheriff's Costs:
Docketing
Poundage
Advertising
Posting Bills
Law Library
County
Mileage
Certified Mail
Levy
Postpone Sale
Surcharge
Law Journal
Patriot News
Share of Bills
30.00
11.08
15.00
15.00
.50
1.00
19.82
6,81
15.00
20.00
30.00
232.85
144.90
23.15
$ 565.11yarty
12/07/00
Sworn and subscribed to before me
~R~t:~
R. Thomas Kline, Sheriff
This .?iA-l-dayof l.rbu.~L. ,
2000, A.D. Q;{h' ~ (J I'hdh. " r
TO onotary
Byl4/hi)i/#
eal Estate Deputy
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Plaintiff,
v.
BARRY E. ZOOK
DEBRA A. ZOOK,
AlK/A DEBRA CONRAD ZOOK,
AlK/A DEBRA A, CONRAD
Defendant(s).
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CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 00-3081 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 601 HUNTINGTON AVENUE,
ENOLA, P A 17025.
1. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
BARRY E. ZOOK
DEBRA A. ZOOK,
A/K/A DEBRA
CONRAD ZOOK, A/K/A
DEBRA A. CONRAD
601 HUNTINGTON AVENUE,
F/K/A 25 HUNTINGTON STREET
ENOLA, PA 17025
314 LINDA STREET
DEER PARK, TX 77536
2. Name and address ofDefendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
Bank of New York,
The Trustee
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
C/o Rosicki, Rosicki and Associates
One Ole Country Road, Suite 375
Carle Place, NY 11514
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4. v N~e and address of the last recorded holder of every mortgage of record:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
The Bank of New York
as Trustee under the
Pooling and Servicing
Agreement dated as of
11/30/95, Series 1995-C
100 Barclay Street
New York, NY 10286
5. Name and address of every other person who has any record lien on the property:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate,)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any int(:rest
in the property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
601 HUNTINGTON AVENUE
ENOLA, PA 17025
Domestic Relations of
Cumberland County
13 North Hanover Street
Carlisle, P A 17013
East Pennsboro Township
98 South Enola Drive
Enola, P A 17025
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 ofI8 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities.
September 8. 2000
DATE
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GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-3081 CIVIL
BARRY E. ZOOK
DEBRA A. ZOOK,
AfKIA DEBRA CONRAD ZOOK,
AlKfA DEBRA A. CONRAD
Defendaot(s).
September 8, 2000
TO: BARRY E. ZOOK
601 HUNTINGTON AVENUE
F/KlA 25 HUNTINGTON STREET
ENOLA, P A 17025
DEBRA A. ZOOK,
AKJA DEBRA CONRAD ZOOK,
AIKJ A DEBRA A. CONRAD
314 LINDA STREET
DEER PARK, TX 77536
"
""THIS 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, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.""
Your house (real estate) at 601 HUNTINGTON AVENUE. ENOLA, PA 17025, is scheduled
to be sold at the Sheriffs Sale on DECEMBER 6,2000 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by
GMAC MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is
postponed, the property will be relisted for the MARCH 7, 2001 Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
f
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attomey's fees due, To find out how much you must pay, you may
call: (215) 563-7000.
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.
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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 notice on page two 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.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
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2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
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.
I 5. Y ouhave the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may -bring legal proceedings'to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses. or ways of getting your home back. if you act
immediately after the sale.
YOU SHOULD TAKE TmS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFVICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249~3166
(800) 990-9108
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DESCRIPTION
ALL TfJA T CERTAIN [fact or parcel of land with the buildings and irnproveI1lems thereon erected
situate in E:J.st Pennsboro Township. Cumberland County, Pennsylvania, more 'particularly bounded
and described as follows. to wir: "
BEGINNING at a point at the ~orthwesterly corner of Humington Street and Chester .-'\.venue:
thence along the Northerly line of Humington Street South 87 degrees 30 minutes West, 100 feet to
a point; thence North 2 degrees 30 minutes West, I.Q feet to a point at'the Southerly line of a 15
feet pubii<.: alley; thence along same )lorth 87 degrees 30 minutes East, 100 feet to a point on [he
Westerly line of Chester Avenue aforesaid; thence along same South 2 degrees 30 minutes East. 1-1-2
feet to. a poim the place of beginning, .
BEI:'-1G premises knovill as :'-10, 601 Humington .-\ venue , formerly known 3.S 25 Humington Street.
TITLE TO SAID PREy!ISES [5. VESTED [01 Debr:l .-'\., Conr:ld Zook and Bam E. Zook. wife
. .
and husband by Deed from Sar:lh How3.rd. Executrix of the Estate of Charles W. Snyder. late dated
12!l/87, recorded 12/29/87. in Deed Book C33, P:lge 867, I
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO.
00-3081 CIVIL 19
CIVIL ACTION - LAW
TO THE SHERIFF OF
CUMBERLAND
COUNTY:
GMAC MORTGAGE CORPORATION
To satisfy the debt, interest and costs due
PLAINTIFF(S)
HUNTINGTON ST., ENOLA PA
a/k/a DEBRA A CONRAD, 314
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from BARRY E ZOOK, 601 HUNTINGTON AVE, f/k/a 25
17025 AND DEBRA A ZOOK a/k/a DEBRA CONRAD ZOOK
LINDA ST., DEER PARK TX 77536
DEFENDAtlIT(S)
REAL ESTATE LOCi\.TED
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(SEE ATTACHED
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(1) You are directed to levy upon the property of the defendant(s) and to sell
AT 601 HUNTINGTON AVE., f/k/a 25 HUNTINGTON ST., ENOLA
LEGAL DESCRIPTION.)
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(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 notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the d~lendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property ofthe defendant(s) not levied upon an subjecllo attachment is found inthe possession of anyone1other
than a named garnishee, you are directed to notffy himlherthat he/she has been added as a garnishee and is enjPined as above
stated,'
AmountDue $35,531.90 L.L. $.50
Interest 8/1/00 - 12/6/00 ($5.84/diem) $747.56ueProthy $1.00
Other Costs
Atty's Comm %
Atty Paid $130.92
Plaintiff Paid
Date: September 12, 2000
CURTIS R. LONG
Deputy
by:
REQUESTING PARTY:
Name FRANK FEDERMAN ESQUIRE
Address: TWO PENN CEN'IER PLAZA STE 900
PHILADELPHIA PA 19102
PLAINTIfF
Attorney for
Telephone:
Supreme Court ID No,
(215) 563 7000
12248
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FEDE~andPHELAN
By: FRANK FEDE~
Identification No. 12248
Snite 1400
One Penn Center at Suburban Station
Philadelphia, PA 19103
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
BARRY E, ZOOK
DEBRA A. ZOOK A/KJA DEBRA CONRAD ZOOK
A/KJA DEBRA A. CONRAD
NO. 00-3081-CIVIL
Defendant(s),
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attomey for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
() an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom
falsification to authorities.
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Attomey for Plaintiff
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GMAC MORTGAGE
CORPORATION,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
CIVIL ACTION - LAW
00-3081 CIVIL
BARRY E. ZOOK, DEBRA A.
ZOOK, a/kJa DEBRA CONRAD
ZOOK, a/k/a DEBRA A. CONRAD, :
Defendants
IN RE: PETITION FOR REASSESSMENT OF DAMAGES
ORDER
AND NOW, this
3/ ... day of August, 2001, this matter having been called for
hearing and neither party having appeared, the matter is continued generally.
BY THE COURT,
Daniel G. Schmieg, Esquire
For the Plaintiff
-7<~ /Ii
K/. Hess, J.
Barry E. Zook
601 Huntington Avenue
flkIa 25 Huntington Avenue
Enola, P A 17025
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Debra A. Zook
314 Linda Street
Deer Park, TX 77536
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I.D. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
BARRY E. ZOOK
DEBRA A. ZOOK,
A/K/A DEBRA CONDRAD ZOOK,
A/K/A DEBRA A. CONRAD
CIVIL DIVISION
NO. 00-3081-CIVIL
PRAECIPE TO WITHDRAW MOTION FOR
REASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly withdraw the Motion for Reassessment of Damages filed
in the above captioned matter. The motion is now moot.
FEDERMAN AND P~AN
Dj~"MIEG' ~
Attorney for Plaintiff
September 10, 2001
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPlllA, PA 19102
(215) 563-7000
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DMSION
Plaintiff
TERM
NO. tJ..V.. 3D fI ~ ,- ~
v.
CUMBERLAND COUNTY
BARRY E- ZOOK
DEBRA A. ZOOK,
A/KJA DEBRA CONRAD ZOOK,
A/KJA DEBRA A. CONRAD
601 HUNTINGTON AVENUE,
FIKIA 25 HUNTINGTON STREET
ENOLA, P A 17025
Defendant(s)
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
"THIS 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, THIS
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 THIS PAPER TO YOUR LAWYER AT ONCE- IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LffiERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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1.080#: 217250844
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1. Plaintiff is
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
~. The name(s) and last known address(es) of the Defendant(s) are:
BARRY E. ZOOK
DEBRA A. ZOOK,
A/KJA DEBRA CONRAD ZOOK,
A/KJA DEBRA A. CONRAD
601 HUNTINGTON AVENUE,
FIKIA 25 HUNTINGTON STREET
ENOLA, PA 17025
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 12/24/87 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to COMMONWEALlHNATIONAL BANK which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 890, Page 994. By Assignment of Mortgage recorded 12/29/87 the mortgage was
assigned to MELLON BANK, NA, which Assignment is recorded in Assignment of
Mortgage Book No. 344, Page 647. By Assignment of Mortgage recorded 11/22/89 the
mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of
Mortgage Book No_ 372, Page 737.
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 1/1/00 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."
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6.
The following amounts are due on the mortgage:
Principal Balance
Interest
12/1/99 through 5/1/00
(per Diem $8.93)
Attorney's Fees
Cumulative Late Charges
12/24/87 to 5/1/00
Cost of Suit and Title Search
Subtotal
$31,802.23
1,357.36
800.00
80_65
550_00
34,590.24
Escrow
Credit
Deficit
Subtotal
0_00
111.17
111.17
TOTAL
$ 34,701.41
7 _ The attorney's fees set forth above are in confonnity 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.
8_ The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. ~1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A"
9. 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.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$ 34,701.41, together with interest from 5/1/00 at the rate of$8.93 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.
tr;:;!;-7;:!;
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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Servicing
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GMACI:
Mortgalge I,
'G,MAC Morl(,"ge Corporation
P.O. Box 85671
. San Diego, CA 92186-5071
3451 Hammond Ave
P.O. Box 780
Waterloo, fA 50704-0780
Date: March 13, 2000
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
Tbis is an official notice that tbe mort2a2e on vour bome is in default. and tbe lender intends to foreclose.
Spccific information about tbe nature oftbe default is orovided in the attacbed oal!Cs.
Tbe HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM lHEMAP) mav be able to help to save vour
bome, This Notice exolains bow the or02ram works,
To sec if HEMAP can belo. vou must ~lEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take tbis Notice with vou when vou meet with tbe
Counselin2 A2encv,
Tbe name, address and obone number of Consumer Credit Counselin2 A2encies servin2 vour Countv are
listed at tbe end of this Notice. If -ou have an' uestion ou ma caD tbe Penn Ivania Housin Finance
MOllcy toll free at 1.800.342.2397. (Persons with imoaired hearin2 can ca0(717) 780-18 9).
Tbis Notice COlita ill s important legal information, If you bave any questions, representatives at tbe Consumer
Credit Coullscling Agcllcy may be able to belp explaill it, You may also want to contact an attorney in your
area. Tbe local bar association may be able to belp you find a lawyer,
LA NOTlFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTlNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTlFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE lLAMANDO ESTA AGENCIA
(PENNSYI~V ANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA, PUEIJES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO
"HOMEOWNm:'s EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE
SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA
HOMEOWNEI:' S :-; A~lE(S):
PROPERTY AIlIJRESS:
BARRY E, ZOOK
601 HUNTINGTON AVEN
ENOLA, PA 17025-2629
LOAN ACCT. ;-';0,:
ORIGINAL LK'\I)ER:
CURRENT LK\IlEIUSERVICER:
217250844
NIA
GMAC Mortgage
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G.MAC Mortgage Corporation
P.O. Box 85071
San Diego, CA 92186-5071
3451 Hammond Ave
P_O. Box 780
Waterloo, JA 50704-0780
Servicing
GMAC
Mortgalge
Dare: March 13, 2000
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mort2a2e on vour home is in default. and the lender intends to foreclose,
Specific information about the nature of the default is Drovided in the attached pa2es,
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM CBEMAP) mav be able to helD to save vour
home. This Notice e'Dlains how the Dr02ram works,
To see ifllEMAP can helD. VOR must ~fEET ''nTH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the
Counselin2 A2encv.
The name. address and Dhone number of Consumer Credit Counselin2 A2encies servin2 vour Countv are
listed at the end of this Notice, If vou have anv auestions. vou mav call the Pennsvlvania Housin2 Finance
A2encv toll f,'ee at 1-800-342.2397, (Persons with imDaired hearin2 can call (717) 780.1869).
This Notice conloins imp0l1ant legal information. If you have any questions, representatives at the Consumer
Credit Counseling Agency may be able to help explain it, You may also want to contact an attorne}- in your
area. The local bar association may be able to help you fmd a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VlVIENDO EN SU CASA. SI NO CO~IPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION aIMEDIATAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE
SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR SU HIPOTECA
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
DEBRA A. ZOOR
601 HUNTINGTON AVEN
ENOLA, PA 17025-2629
LOAJ" ACCT. NO,:
ORIGINAl, LENDER:
CURRENT LENDERlSER\lCER:
217250844
N/A
GMAC Mortgage
EXHIBIT A
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HOMEO"'NER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MA Y liE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMI'LY "lTH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE" ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTAI'iCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES
YOUR CONTROL,
IFYOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AI"D
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY ST AY OF FORECLOSURE -- Under the Act, you are entitled to a temponny stay offoreclosure
on your mortgage ror 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 cOlmseling 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. TIlE PART OF TIllS
NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUMER CmmlT COUNSELING AGENCIES -- If you meet with one of the consumer credit cOlmseling
agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date
ofthis meeting.The names, addresses and teleuhone numbers of desil!llllted consumer credit cOlmseling agencies for
the cOlmlY in which the Drouertv is located are set forth at the end of this Notice. It is only necessary to schedule one
face-to-face mecling_ Advise your lender immediate Iv of your intentions.
APPLICATIO!'\ FOR MORTGAGE ASSISTANCE n Your mortgage is in default for the reasons set forth later
in this Notice (sec' !allowing pages for specific information about the nature of your default.) If you have tried and
are lmable to res,,:,'e this problem with the lender, you have the right to apply for financial assistance from the
Homeowner's Emergency evlortgage Assistance Program_ To do so, you must fill out, sign and file a completed
Homeowner's Enwrgency Assistance Pragrnm Application with one of the designated consumer credit cOlmseling
agencies listed at I he end of this Notice. Only consumer credit cOlmseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.
Your application :.lL'ST be filed or postmarked within thirty (30) days of you face-to-face meeting.
YOU l\IUST FlI.J<: YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW THl'; OTIIER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACT} 0 N .. Available fimds for emergency mortgage assistance are vel)' limited. They will be disbursed
by the Agency u"dcf 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 ~oreclo~ pro~eedmgs
will be pursued a,'ainst YOll if you have met the time requirements set forth. above. You \V1ll be notified directly by
the Pennsylvania i lousing Finance Agency of its decision on your applicanon.
EXHIBiT A
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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 1\,'1 ATTEMPT TO COLLECT THE DEBT,
(I f you have med bankruptcy you can still apply for Emergency Mortgage Assistance.) .
HOW TO CURE YOUR MORTGAGE DEFAULT CBrin2 it UD to date),
NATURE OF 1'1 I E DEFAULT .- The MORTGAGE debt held by the above lender is on your property located at:
601 Huntington Aven Eno1a, PA 17025-2629 IS SERIOUSLY IN DEFAULT because:
YOU H:\ VE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
fOllowing amounts are now past due: January 1, 2000 through March 1, 2000,
See attached Exhibit for payment breakdown.
Monthly Payments
Late Ch:lJ-ges
NSF
Inspections
Other
Suspens,'
1,242.99
350.12
0.00
14.50
0.00
TOTAL AMOUNT PAST DUE:
1,607.61
B. YOU HAVE F AILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot aDDlicable ):
HOW TO CURl,: TIlE 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
$ 1,607,61 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING TJ IE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. casille"s check.
certified check or monev order made Davable and sent to:
GMAC Mortgage Corporation
ATTN: Payment Processing
P.O, Box 780
Waterloo, IA 50704-0780
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter:
(Do not use ifnol "pJllicable.) N tAl' b1
o pp 1ca e
IF YOU DO NOT CURE THE DEFAULT --If you do not cure the default within THIRTY (30) DAYS of the dale
ofthis Notice, thr lender illtends to exercise its ri hts to accelerate the mort e debt, This means that the entire
outstanding balance of this debt will be considered due inunediately and you may ose the chance to pay the
mortgage in monthly installments.lffull payment of the lotal amount past due is not made within TIIIRTY (30)
DAYS, the lender olso intends to instnlet its attorneys to start legal action to foreclose UDOD vour mort2a2ed
DrODem,
IF THE MORTe AGE IS FORECI,OSED UPON -- The mortgaged property will be sold by the Sheriffto 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 ~ started again~t against you, you ~ll have. to pay all
reasonable attonwy's fees actually incurred by the lender even If they exceed $)0.00. Any attomey s fees will be
added to the amOllll1 you owe the lender, which may also include other reasonable costs.
Ifvou cure the <il-fault wi(hin tbe TIDRTY (311) DAYS Deriod. vou wm Dot be required to Dav attornev', fee"
EXHIBIT A
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OTHER I"ENDI<:J: REMEDIES u The lender may also sue you personally for the lmpaid principal balance and all
other SlunS due under the mortgage.
RIGHT TO CURE THE IlEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within
the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the ril!bt to cure the default
and Drevent the sale at anv time UD to one hour before the Sheriffs Sale. You mav do so bv Davin!! the total ammmt
then Dast due. Dlus anv late or other chames then due. reasonable attornev's fees and costs connected with the
forecloSlITe sale and anv other costs connected with the Sherifl's Sale as sDecified in wrilinl! by the lender and bv
Derfonnin!! anv other requirements under the mort!!a!!e_ 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,
EARlJEST POSSIBLE SHERIFF'S SALE DATE n It is estimated that the earliest date that such a Sherifl's Sale
of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A
notice of the actuai date ofLhe Sheriffs Sale will be sent to you before the sale. Of course, the ammmtneeded to
ClITe the default will increase the longer you wait. You may fmd out at any time exactly what the required payment
or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender:
Address:
GMAC Mortgage Corporation
401 West 24th Street
National City, CA 91950
Phone Number:
Fax Number:
Contact Person:
(800) 850-4622
(619) 470-5579
Collection Department
EFFECT OF SHYRlFI<"S SALE u You should realize that a Sheriffs Sale will end your ownershil' of the
mortgaged property and your right to occupy it. If you contimle to live in the property after the Shenfl's Sale, a
lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OJ! :\IO)(TGAGE ". You mayor may not sell or transfer your home to a buyer or transferee who
will aSSllme the mO'igage debt, provided that all the outstanding payments, charges and attorney's fees and costs are
paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU :\IAY ALSO HAVE THE RIGHT:
TO SEI.J. TilE PROPERTY TO OBTAIN MO):EY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MO):J.y FROM ANOTHER LE!\DI):G INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE TIllS DEF AULT CURED BY A]\:1' THIRD PARTY ACTING ON YOUR BEHALF
TO HA VI'. TilE ~lORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD
OCCUR](I'J), IF YOU CURE THE DEF AULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO
CURE YOl'R DEl' AULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
TO ASSERT TIlL NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR
ANY OTI IER LAWSUIT lNSTIThTED tiNDER THE MORTGAGE DOCUMENTS,
TO ASSF~n A):1' OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
TO SEEK PROT] :CTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSl!\lIm CREDIT COUNSELING AGENCIES SERVING YOUR COUNlYIS ENCLOSED
EXHIBIT A
L",
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Pennsylvania Housing Finance Agency
Homeowner's Emergency Mortgage Assistance Program
Consumer Credit Counseling Agencies
(Rev. 5/99)
LYCOIl1ing-Clinton Counti
Com", . T;' os
2138 Li::~nS' or Co=tU1it"J Ac:ion (STEP)
P UJ. c:"ee"
- O. Box 1328 -
Willinm.spor:. FA 17703
(5.0) 326-0587
F.~~(570) 322-2197
CCCS of ,"or:he3.Ster::l F'\.
201 Basin S~O. -
Williams ..-...-
(5-0).3 port, PA 17703
, 2.3-6627
FA.~(570) 323.8625
CLINTON COu"NTY
eCCS ofNortheaster::l P'\.
1~1 S AthertOn St .
Swte 100
St:1te College, PA 16801
(814) 238-3568
F.~~ (814) 238-366;1
COLtJMBIA COlJ1'o'TY
CCCS ofNort!leastem Pennsvlvania
1400 Abington E."l!C'~tive Park
Suite 1
Clarlts Summitt F.... 18411
(570) 587.9153 or (800) 922.9537
F.-\..~ (570) 587.913419135
31 W. Markat Street
POB 1127
WUke.-Barre. PA 18702
(570) 821-0837 or (800) 922.9537
F.~~ (570) 821.1785
Commission on Eoonomics Opportunity of Lu:erne Count::'
163 Amber Lane
WUkos-Barre, PA 16702
(570) 825-0510 or (800) 822-0359
F.~~ (570) 829-166S-CALL BEFORE F.-\..-aNG
(570) 455-4994 H.~LTON
FA.~ (570) 455-5631-CALL BEFORE F.~-aNG
(570) 835-4090 TUNKH.....""OCK
Bookar T. Washington Center
1720 Holland Sl::'eet
Erie, FA 15503
(814) 453.5744
F.~"{ (814) 453-5749
John F. ~nnedy Center, Inc.
2021 East 20t.'1 St=t
Erie, FA 15510
(814) 898-0400
FAX (814) 898-1243
CCCS of We.tern Pennsvlvania, Inc.
2000 Linglestown Mad'
Har:'.sburg, PA 17102
(717) 541-1757
Urban League oOletropolitan Harrisburg
N. 6th St:-eet
Har:'.sburg, F_'\. 17101
(717) 234-5925
F_~~ (717) 234-9459
Communit"J .-\.c::ion Comm of the Capital Region
1514 Derrv Stteet
Harr'.sbu";', P_"- 17104
(717) 232-9757
F.~~ (7171 234-2227
CRAWFORD COUNTY
Greater Erie CommtU1it"J A.::ion Commit'....
18 We.t 9th St:-eet
Erie, PA 16501
(8141459-4581
FAX (814) 456-0161
Shenango Valley Urban teague, Inc
601 Indiana Avenue
Farrell. PA 16121
(4121 981-5310
CUMBERLAND COUNTY
Fin.n..;.1 Counseling Ser,.;ce. ofF=klin
31 West 3rd Street
Waynesboro, PA 17258
(717) 762-3285
YWCA of Carlisle
301 G St:-eet
Carlisle, PA 17013
(717) 243-3818
F.-\.."{ (717) 731-9589
Adams County Housing Authorit"J
139-143 Carlisle St
Gettysburg, FA 17325
(717) 334-1518
F.~"{ (717) 334-8325
EXHIBIT A
PENNSYLVANIA 8UL.l.ETlN, VOL 29, NO. 2:l. JUNE 5, 1999
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AL[. THA'r CER'rAIN tract or l?arce~ of lan4 with th.a bui~4ings ar.4
i~provements thereon erecte4 situate in East Pennsboro
Townsh.ip. CUlllber~and County, Pet.nsy~vania, more part.icu1arly
boundeCl and describeCl as follows, to wit:
BEGINNING at a !?oint at the Northwesterly corner of Huntingtoll
Street and Chester Avenue: thence a~onq the. North.erly line of
Huntinqto.n Stl:eet S.outhc_B7,degrees 30_..minutes Wesl:., 100 feel:. .~o
a point:'.'th.~li}=e,Np~th,~ degree.s- 30 minutes West, 142 feet to 11
point. at the Soutnerly._line of a ~5 feet pUblic alley; thence
along same N9.i;'t,b..8.7:.deqree.B 3..9 minutes' East, lOa feet to a
point on th.e..~e~t'e;).Y,1.in_e,af Chester, Avenue aforesaid,; l:.henC3
'a::Long same. 'So.u'th.' 2 ..degrees 3Q- .minutes East, 1.42 feet to a poitlt
the place of Beginning.-' Being premises known as No. 601
Huntingt.on Avenue, formerl.y ,known as 25 Huntington Street.
BeING th.e same premises whieD John S. Putt and Mary Helen Putt.
his wife. by. ,their. De.ed dated -January 11. ~957. and recorde4 in
t~e Office of Recor4er of Deeds in and for Curnoer1ana County.
pennsy1vania, Ln Deed Book "0". Vol.. 1.7, Pa~e 578, ~ranl:.ed a~d
conveyea unl:.O Char1es Wi11iam Snyder and Olgia A. Snyder. his
wife. Said Olgia A. Snyder having died on /174':+ 023, /':6:'-, r:.it1e
t~ereto vested in Char1es Wi1~iam Snyder. a/~a Charles w.
Snyder.
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PREMISES: 601 HUNTINGTON AVENUE
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VERIFICATION
SHIRLEY J_ EADS hereby states that she is FORECLOSURE SPECIALIST ofGMAC
MORTGAGE CORPORA nON mortgage servicing agent for Plaintiff in this matter, that she 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 her knowledge, information and belief. The undersigned
understands that this statement is made subject to the penalties of 18 Pa. C.S_ Sec. 4904 relating to unsworn
falsification to authorities_
DATE: 5'
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
v.
No.OO-3081-CIVIL
BARRY E. ZOOK
DEBRA A. ZOOK AIKIA DEBRA CONRAD WOK
AIKIA DEBRA A. CONRAD
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$35,531.90
Interest from 8/1/00 to 9/5/01
(per diem - $5.84)
$2,336.00and Costs
TOTAL
$37,867,90
Wl~rc
FRANK FED RMAN, ESQUIRE
ONE PENN CENTER at SUBURBAN STATION
SUITE 1400
PHILADELPHIA, PA 19103
Attorney for Plaintiff
Note: Please attach description of property, No,
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DESCRIPTION
ALL TH.-\ T CERT.-\IN tract or parcel of land with the buildings and improvemems thereon erected
situate in East Pennsboro Township. Cumberland Counry. Pennsylvania. more particularly bounded
and described as follows. to wir:
BEGINNING at a poim at the Northweste~ly comer of Huntington Street and Chester .-\ venue:
thence along the Northerly line of Huntington Street South 87 degrees 30 minutes West. 100 feet to
a point: thence North 2 degrees 30 minutes West. 1-1-2 feet to a point at the Southerly line of a 15
feet public alley: thence along same North 87 degrees 30 minutes East. 100 feet to a point on the
Westerly line of Chester Avenue aforesaid: thence along same South :2 degrees 30 minutes East. 1-1-2
feet to a point the place of beginning.
BEI:-<G premises known as No. 601 Huntington .-\venue. formerly known as 25 HuntingtOn Street.
TITLE TO SAID PRE~nSES IS VESTED IN DebrJ .-\_ Conrad Zook and Barrv E. Zook. wife
and husband by Deed from Sarah Howard. Executrix of the Estate of Charles \V~ Snyder. late dated
12/1/87. recorded 12,29/87. in Deed Book C33. Page 867.
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-3081 CIVIL
BARRY E. ZOOK
DEBRA A. roOK,
A!KJA DEBRA CONRAD ZOOK,
A!KJA DEBRA A. CONRAD
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$35.531.90 J
Interest from 8/1/00 (12/6/00
$747.52 and Costs
(per diem - $5,84)
36.279.42 TOTAL
F FEDE
TWO PENN CE
SUITE 900
PHILADELPHIA, PA 19102
Attorney for Plaintiff
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ALL THAT CERTAIN tract or parcel of land with the buildings and improvements thereon erected
situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded
and described as follows, to wit:
BEGINNING at a point at the Northwesterly corner of Huntington Street and Chester Avenue:
thence along the Northerly line of Huntington Street South 87 degrees 30 minutes West, 100 feet to
a point; thence North 2 degrees 30 minutes West, 142 feet to a point at the Southerly line of a 15
feet public alley; thence along same North 87 degrees 30 minutes East. 100 feet to a point on the
Westerly line of Chester Avenue aforesaid; thence along same South 2 degrees 30 minutes East. 1+2
feet to a point the place of beginning.
BEING premises known as No. 601 HuntingtOn Avenue, formerly known as 25 Huntington Street.
TITLE TO SAID PREMISES IS VESTED IN Debra A. Conrad Zook and Barry E Zook, wife
and husband by Deed from Sarah Howard, ExecutrL'( of the Estate of Charles W_ Snyder, late dated
12/1/87, recorded 12/29/87, in Deed Book C33, Page 867.
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GMAC MORTGAGE CORPORATION
Plaintiff,
v.
BARRY E, ZOOK
DEBRA A. ZOOK,
AIKIA DEBRA CONRAD ZOOK,
AIKIA DEBRA A. CONRAD
Defendant(s).
,.
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CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DMSION
NO. 00-3081 CIVIL
AFFIDA VII PURSUANT TO RULE 3129
(Affidavit No. I)
GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 601 HUNTINGTON AVENUE.
ENOLA. P A 17025.
1. Name and address ofOwner(s) orreputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
BARRY E. ZOOK
DEBRA A. ZOOK,
A/KIA DEBRA
CONRAD ZOOK, A/KIA
DEBRA A. CONRAD
601 HUNTINGTON AVENUE,
FIKJA 25 HUNTINGTON STREET
ENOLA, PA 17025
314 LINDA STREET
DEER PARK, TX 77536
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3, Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
Bank of New York,
The Trustee
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate,)
C/o Rosicki, Rosicki and Associates
One Ole Country Road, Suite 375
Carle Place, NY 11514
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Nmne and address of the last recorded holder of every rnortgage of record:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
The Bank of New York
as Trustee under the
Pooling and Servicing
Agreement dated as of
11/30/95, Series 1995-C
100 Barclay Street
New York, NY 10286
5. Nmne and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Nmne and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Nmne and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate,)
Tenant/Occupant
601 HUNTINGTON AVENUE
ENOLA, PA 17025
Domestic Relations of
Cumberland County
13 North Hanover Street
Carlisle, PA 17013
East Pennsboro Township
98 South Enola Drive
Enola, P A 17025
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 ofl8 Pa. C.S. Sec, 4904 relating to unsworn falsification to authorities.
September 8. 2000
DATE
F FEDE , ESQUIRE
Attorney for Plain Iff
1i18i~~l1ilI~MhlIlMii>r.li-'l<",&OJ:~: o"At&~".1if,i;i;i8i1!;jhU~4M<@;I:"-!"""'"l"'~i..\mcldh'~f!~a.b\W;!'Mll;i#Ns~~-.;t~'*!'lliIi,:~W'.~jl-_I!\..' "~-WIiliilW:~~~~.a:Jj_ ._._woo~. lti1itmlll~
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FEDE~A.NandPHELA.N
By: FRANKFEDERMA.N
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
BARRY E. ZOOK
DEBRA A. ZOOK,
AIKIA DEBRA CONRAD ZOOK,
AIKIA DEBRA A. CONRAD
NO. 00-3081 CIVIL
Defendant(s).
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
() an FHA rnortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
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Attorney for Plaintiff
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GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-3081 CIVIL
BARRY E. ZOOK
DEBRA A. ZOOK,
AfKIA DEBRA CONRAD roOK,
AfKIA DEBRA A, CONRAD
Defendant(s).
September 8, 2000
TO: BARRY E. ZOOK
601 HUNTINGTON AVENUE
F/K/A 25 HUNTINGTON STREET
ENOLA,PA 17025
DEBRA A. ZOOK,
AK/A DEBRA CONRAD ZOOK,
AlK/A DEBRA A. CONRAD
314 LINDA STREET
DEER PARK, TX77536
"TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VB PREVIOUSLY RECENED A DISCHARGE IN
BANKRUPTCY AND TillS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at 601 HUNTINGTON AVENUE. ENOLA. FA 17025. is scheduled
to be sold at the Sheriff's Sale on DECEMBER 6. 2000 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by
GMAC MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is
postponed, the property will be relisted for the MARCH 7, 2001 Sheriff's Sale,
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due, To find out how much you must pay, you may
call: (215) 563-7000.
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,
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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 notice on page two 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000,
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate cornpared to the value of your property.
3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as ifthe sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6, You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheliffwithin ten 00) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTIW
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
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DESCRIPTION
ALL THAT CERTAIN tract or parcel of land with the buildings and improvements thereon erected
situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded
and described as follows, to wit:
BEGINNING at a point at the Northwesterly corner of Huntington Street and Chester A venue:
thence Jlong the Northerly line of Huntington Street South 87 degrees 30 minutes West, 100 feet to
a point; thence North 2 degrees 30 minutes West, 142 feet to a point at the Southerly line of a 15
feet public alley; thence along same North 87 degrees 30 minutes East, 100 feet to a point on the
Westerly line of Chester Avenue aforesaid; thence along same South 2 degrees 30 minutes East. 142
feet to a point the place of beginning.
BEING premises known as No. 601 Huntington Avenue, formerly known as 2S Huntington Street.
TITLE TO SAID PREMISES IS VESTED IN Debra A. Conrad Zook and Barrv E. Zook wife
, ,
and husband by Deed from Sarah Howard, ExecutrL'{ of the Estate of Charles W_ Snyder, late dated
12/1/87, recorded 12/29/87, in Deed Book C33, Page 867.
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AFFIDAVIT OF SERVICE
PLAINTIFF
GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
No.00-3081 CML
DEFENDANT(S)
BARRY E. ZOOK
SERVE AT
601 HUNTINGTON AVENUE,
F/K1A 25 HUNTINGTON STREET
ENOLA, PA 17025
Type of Action
- Notice of Sheriff's Sale
Sale Date: DECEMBER 6, 2000
SERVED
Served and made known to 6~ ~-I' 1 'R f ::::;(00 J< ,Defendant, on the ':<"3 I<. L
at IO~'B , o'clocka._m_, at (PO! HVtJ\-;Nj-\Ot-J 'A"~lj ,E:.t-Ju{a.. fA
of Pennsylvania, in the manner described below:
X Defendant personally served.
Adult family member with whom Defendant(s) reside(s). Relationship is
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place oflodging in which Defendant(s) reside(s).
Agent or person in charge ofDefendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
day of 'S er.J.e... kit., 20090
170;;J,5'" . Commonwealth
Other:
d r I 11>5 11\ l2 d
Description: Age2.2. HeightL Weight~ Race /AlL-.. Sex~ Other Ve.<H<.
I, cb-(,l.1v(!.'t- l, C'Cl~ *:1 ' "!~~ompetent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated abov
Sworn to and subscribed
before me thiso(~"~day
of s.r;4~2000-
Notary: '11 ILL. )Z; ,
NOTARIAL SEAL
ANNE G. BORYAN, Notary PublIc
MChambersburg Bora, Franklin
Y.isslon Expires Dee.
By:
ot~9
NOT SERVED
On the day of
,200_, at
o'clock _.m., Defendant NOT FOUND because:
Moved Unknown
No Answer
Vacant
Other:
Sworn to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire - 1.0. No, 12248
Two Penn Center Plaza, Suite 900
Philadelphia, P A 19102
(215) 563-7000
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AFFIDAVIT OF SERVICE
PLAINTIFF
GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
No.00-3081 CIVIL
DEFENDANT(S)
DEBRA A, ZOOK,
AlKlA DEBRA CONRAD ZOOK,
AIKIA DEBRA A. CONRAD
Type of Action
- Notice of Sberifrs Sale
SERVE AT
314 LINDA STREET
DEER PARK, TX 77536
Sale Date: DECEMBER 6, 2000
SERVED 'Ho- @)
Served and made known to ~rA A. 2..co\:. ,Defendant, on the ~ day of~, 20lJD,
at ~ o'clock~.m., at ~'-I- L\ N;J::>A S)) "Dee,"?~ ~ J --r:e x,lK,. . Commonwealth
of Pennsylvania, in the manner described below:
Defendant personally served.
Adult family member with whom Defendant(s) reside(s). Relationship is
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship_
Manager/Clerk of place oflodging in which Defendant(s) reside(s).
Agent or person in charge ofDefendant(s)'s office or usual place of business.
~ an officer of said Defendant(s)'s cornEY. I ..
v' Other: 4pl),a" ,.... C~(".fCjC eo'" 't;le~""'P/'7rI'i> '~!a.Jd~r-lc..~ N....~P Jo~ s.l.AJI.5.~e<"
Description: Age ~ Height~ Weight l.:5b Race ~ Sex '('Q Other
I, .J<:: 1f"Y'-( ~e:l&c:;.. , a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and co~ect copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated above.
Sworn to and subscribed
before me this ~ day
of ,2
Notary:
SERVED
at o'clock _.m., Defendant NOT FOUND because:
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Other:
Sworn to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire - I.D. No. 12248
Two Penn Center Plaza, Suite 900
Pbiladelpbia, PA 19102
(215) 563-7000
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GMAC MORTGAGE CORPORATION
Plaintiff
CIVIL DIVISION
vs,
No. 00-3081 CIVIL
BARRY E. ZOOK
DEBRA A. ZOOK,
AlKJA DEBRA A CONRAD ZOOK,
AlKJA DEBRA A. CONRAD
Defendants
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
SS:
CUMBERLAND COUNTY
J, FRANK FEDERMAN, ESQ., attorney for GMAC MORTGAGE
CORPORATION, hereby verify that on SEPTEMBER 15.2000, true and correct copies
of the Notice of Sheriff's Sale were served by certificate of mailing to the recorded
Iienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the
Notice of Sale was sent to defendant(s) on SEPTEMBER 15, 2000 by first class mail
and certified mail return receipt requested, see Exhibit "B" attached hereto.
:;t;~J~
FRANK F ERMAN, ESQUIRE
Attorney for Plaintiff
Date: November 2. 2000
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(.3, _Article Addressed to:
~:1DEBRA A. ZOOK, AlK/A DEBRA CONRAD
l~OK,AlK/A DEBRA A. CONRAD
~'::n'l LINDA STREET
: DEER PARK, TX 77536
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j 3. Article Addressed fe:
i BARRY E. ZOOK
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: 601 HUNTINGTON AVENUE, F/K/A25
. HUNTINGTON "STREET
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8. Addressee's Address
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BARRY E. lOOK
601 HUNTINGTON AVENUE, FIKIA 25
HUNTINGTON STREET
ENOLA,PA 17025
TO:
SENDER:
REFERENCE:
DMK
SALES
PS,FORM 3800 SEPTEMBER 1995
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Certified Fee
RETURN
RECEIPT
SERVICE
Retum Raceipl Fee
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ReslricteclDellvery
Total Postage and Fees
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do not use for International Mail
2.65
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TO:
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DEBRA A. lOOK, AlK/A DEBRA CONRAD
lOOK,AlK/A DEBRA A. CONRAD
314 LINDA STREET
DEER PARK, TX 77536
SENDER:
REFERENCE:
DMK
SALES
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PS FORM 3800 SEPTEMBER 1995
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RETURN
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Rel1JmRecelptFee
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US Postal Service
Receipt for
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No Insurance Coverage Provided
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GMAC MORTGAGE CORPORATION
Plaintiff
CIVIL DIVISION
vs.
No, 00-3081 CIVIL
BARRY E, ZOOK
DEBRA A ZOOK,
A/KfA DEBRA A. CONRAD ZOOK,
A/KfA DEBRA A. CONRAD
Defendants
"
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AMENDED
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEAL TH OF PENNSYLVANIA
SS:
CUMBERLAND COUNTY
I, FRANK FEDERMAN, ESQ" attorney for GMAC MORTGAGE
CORPORATION, hereby verify that on SEPTEMBER 15, 2000 and NOVEMBER 6,
2000, true and correct copies of the Notice of Sheriff's Sale were served by certificate of
mailing to the recorded Iienholder(s), and any known interested party, see Exhibit "A"
attached hereto, and the Notice of Sale was sent to defendant(s) on SEPTEMBER 15,
2000 by first class mail and certified mail return receipt requested, see Exhibit "B"
attached hereto.
Date: November 7. 2000
~
GMAC MORTGAGE CORPORATION
Plaintiff,
v.
BARRY E. ZOOK
DEBRA A. ZOOK,
A!K/A DEBRA CONRAD roOK,
A!K/A DEBRA A. CONRAD
Defendant(s).
-" "-_U,l~~c'-
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 00-3081 CIVIL
AMENDED
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK i.
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 601 HUNTINGTON AVENUE.
ENOLA. PA 17025.
NAME
1. Name and address ofOwner(s) or reputed Owner(s):
BARRY E. ZOOK
DEBRA A. ZOOK,
A/K1ADEBRA
CONRAD ZOOK, A/K1A
DEBRA A. CONRAD
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
601 HUNTINGTON AVENUE,
F/K/A 25 HUNTINGTON STREET
ENOLA,PA 17025
314 LINJj)A STREET
DEER PARK, TX 77536
2. Name and address ofDefendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate,)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
Bank of New York,
The Trustee
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate,)
C/o Rosicki, Rosicki and Associates
One Ole Country Road, Suite 375
Carle Place, NY 11514
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Name and address of the last recorded holder of every mortgage of record:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tbe Bank of New York
as Trustee under tbe
Pooling and Servicing
Agreement dated as of
11/30/95, Series 1995-C
100 Barclay Street
New York, NY 10286
Goldbeck, McCafferty
and McKeever
111 S. Independence Mall E #500
Philadelphia, PA 19106
5. Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest rnay be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate,)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
601 HUNTINGTON AVENUE
ENOLA, P A 17025
Domestic Relations of
Cumberland County
13 North Hanover Street
Carlisle, P A 17013
East Pennsboro Township
98 Sonth Enola Drive
Enola, P A 17025
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 rnade subject to the
penalties ofl8 Pa. C.S. Sec. 4904 relating to .unsworn falsification to authorities.
Novernber 7. 2000
DATE
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F FE RMAN, ESQUIRE
Attorney for Plaintiff
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F.-,DEBRA A. zaOK, NK/A DEBRA CONRAD
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,14 LINDA STREET
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GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
Plaintiff,
v,
COURT OF COMMON PLEAS
BARRY E. ZOOK
DEBRA A. ZOOK A!K/A DEBRA CONRAD ZOOK
A1K1A DEBRA A. CONRAD
CIVIL DIVISION
NO.OO-3081-CIVIL
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No, I)
GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 601 HUNTINGTON AVENUE, F/I(fA
25 HUNTINGTON ST. ENOLA, PA 17025
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Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
BARRY E. ZOOK
601 HUNTINGTON AVENUE, FIKlA 25
HUNTINGTON ST.
ENOLA, PA 17025
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DEBRA A. ZOOK
AJK/A DEBRA
CONRAD ZOOKA/K1A
DEBRA A. CONRAD
314 LINDA STREET
DEER PARK, TX 77536
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Name and address ofDefendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Bank of New York,
The Trnstee
Clo Rosicki, Rosicki and Associates
One Ole Country Road, Suite 375
Carle Place, NY 11514
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4. Name and address of the last recorded holder of every mortgage ofrecord:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
The Bank of New York as
Trustee under the Pooling
and Servicing Agreement
dated as of 11/30/95, Series
1995-C
100 Barclay Street
New York, NY 10286
5. Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6_ Name and address of every other person who has any record interest in the property and whose interest
may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
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Name and address of every other person whom the plaintiff has knowledge who has any interest in the
property, which may be affected by the sale:
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LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
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Tenant/Occupant
601 HUNTINGTON AVENUE, FIKIA 25
HUNTINGTON ST.
ENOLA, PA 17025
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Domestic Relations of Cumberland
County
13 North Hanover Street
Carlisle, P A 17013
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Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, P A 17105
East Pennsboro Township
98 South Enola Drive
Enola, P A 17025
1 verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. 1 understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904
relating to unsworn falsification to authorities. 1- 1 , 1]_
June 4, 2001 /~ -D
DATE FRANK FEDERMAN, ESQUffiE
Attorney for Plaintiff
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03/24/01 14:48 FA! 215 882 1940
1ilI002
G!lACM - CORP DEFAULT
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UNITED STATFSBANDUPrCY COURT
MIDDLE DISTRICT Ol!" PENNSYLVANIA
INRE:
ZOOK. BARRY I!UGENE
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DebIOr(S)
NOTICE TO CREDITORS AND OTHER PARTIES IN INTEREST
. ---
Notice ill hereby given that the Court has entered an Order dated MARCH 12, 2001 DlSMISSING
the above-capnoned case due to:
The DEBTOR has FAILED TO Al>PEAR at Scheduled 341 Meeili1gs_
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DEFAULT DEPARTMENT
MAR 2 1 200t
RECEIVED
DATE: March 12. 2001
Clerk. U.S. Bankrup~ Court
22ll WALNUT ST1U!ET
P.O. BOX 908
HARRISBURG, PA 171Oll-O!lOll
VAN-87
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GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
v.
No.OO"3081-CIVIL
BARRY E. ZOOK
DEBRA A. ZOOK AlK/A DEBRA CONRAD ZOOK
AlK/A DEBRA A. CONRAD
-.."
Defendant{s).
June 4, 2001
TO: BARRY E. ZOOK
601 HUNTINGTON AVENUE, F/K/A 25 HUNTINGTON ST.
ENOLA, PA 17025
DEBRA A. ZOOK AlK/A DEBRA CONRAD ZOOK AlK/A DEBRA A. CONRAD
314 LINDA STREET
DEER PARK, TX 77536
""THIS 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, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATIEMPT TO COLLECf A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.""
Your house (real estate) at 601 HUNTINGTON AVENUE, F/K/A 25 HUNTINGTON ST.
ENOLA, P A 17025is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a.rn.
in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court
judgment obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. Ifthe
Sheriffs sale is postponed, the property will be relisted for the DECEMBER 5, 2001 Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
L The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attomey's fees due_ To find out how much you must pay, you may
call: (215) 563-7000.
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 irnproperly entered. You rnay also ask the Court to
postpone the sale for good cause,
3, You rnay also be able to stop the sale through other legal proceedings.
-
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You may need an attorney to assert your rights, The sooner you contact one, the rnore chance
you will have of stopping the sale. (See notice on page two 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000. - ,
2, You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property,
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house, A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale, This
schedule will state who will be receiving that rnoney, The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed,
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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DESCRIPTION
ALL TH.-\. T CERT.-\.IN tract or parcel of land with the buildings :md improvemems thereon erected
situate in East Pennsboro Township. Cumberland County. Pennsylvania. more panicul:.lrly bounded
and described as follows. to wir:
BEGINNING at a point at the ;'Iiorthweste~ly corner of Huntington Street and Chester _-\.venue:
thence J.!ong the Northerly line of Huntington Street South 87 degrees 30 minutes West, 100 feet to
a point; thence North 2 degrees 30 minutes West. 1+2 feet to a point at the Southerly line of a 15
feet public J.!ley; thence along same North 87 degrees 30 minutes East. 100 feet to a point on the
Westerly line of Chester .-\. venue aforesaid: thence along same South 2 degrees 30 minutes East. 1+2
feet to a point the place of beginning.
BEING premises known as No. 601 Huntington .-\.venue. formerly known as 25 Huntington Street.
TITLE TO SAID PRE~nSES IS VESTED IN Debra _-\._ Conrad Zook and Barry E. Zook. wife
and husband by Deed from Sarah Howard. Executrix of the Estate of Charles W. Snyder. late dated
12/1/87. recorded 12;29/87. in Deed Book C33. Page 867.
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AFFIDAVIT OF SERVICE
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PLAINTIFF
GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
N o.00-3081-CIVIL
DEFENDANT,S) BARRY E. ZOOK
DEBRA A. ZOOK A!K/A DEBRA CONRAD
ZOOK A!K/A DEBRA A. CONRAD
Type of Action
- Notice of Sheriff's Sale
SERVE DEBRA A.. roOK AIKIA DEBRA CONRAD WOK AIKIA
DE~RA A. coNIW> AT
314 LINl>A SllREET
DEERI'ARK,TX 77536
- 5ale Date: SEPTEMBER 5, 2001
SERVED
RECEIVED
JUN 2 1 2001
BY:?: 15 P.AJ
~~ day of .JUN(" ,
Served and made known to ~ /J . "ZD':;J:. .
. Defendant, on the
at 1<;:</0 , o'clockj2.m.. at ~j+ GnP,,>;sr; veelt- ?'lrk)
of Pennsylvania, in the manner described below:
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/ Defendant personally served.
\/' Adult family member with whom Defendant(s) reside(s). Relationship is ~-eI" - IN - I ""N
Adult in. charge ofDefendant(s)'s residence who refhsed to give name or relationship.
Manager/Clerk of place oflodging in which Defendant(s) reside(s).
Agent or person in charge ofDefendant(s)'s office or usual place ofbusiness_
an officer of said Defendant(s)'s company.
Other:
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Elescription: Age --Ll.L Height ~ Weight ~ Race ~ Sex r' Other
1,:J;;C:1 1<'05 <, , a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and cdrrect copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date ,rod at
the address indicated above.
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~ry Public, Slate on.xas 200_, at
My ommissiofi Expirds ,~
. _yMfii~D03 No~wer
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o'clock _.m, Defendant NOT FOUND because:
Vacant
Other:
Sworn to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire - I.D. No. 12248
One Penn Center at Suburban Station
1617 John F. Kennedy Bllulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
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AFFIDAVIT OF SERVICE
P.LAINTIFF
GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
No.00-3081-CIVU.
DEFENDANT(S) BARRY E. ZOOK
DEBRA A. WOK A!KIA DEBRA CONRAD
ZOOK A!KIA DEBRA A. CONRAD
Type of Action
- Notice of Sheriff's Sale
-,
SERVE BARRY.E. ZOOK AT
601 HUNTINGTON AVENUE, F/KJA 25 HUNTINGTON ST.
ENOLA, PA 17025
Sale Date: SEPTEMBER 5, 2001
SERVED
Served and made known to fj -;;Jf-.'f..j [:, Zoo k
at 7: fa . o'clock fm, at . to I HvN+'IJ, tOlJ .A1I~,,. E/JO 1<1
of Pennsylvania. in the manner descnbed below:
-X-Defendant personally served.
Adult family member with whom Defendant(s) reside(s). Relationship is
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place oflodging in which Defendant(s) reside(s).
Agent or person in charge ofDefendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
, Defendant, on the
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dayof ~ N ~ .200J,
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. Conunonwealth
Other:
1#$ - _/:2_ J
Description: Age-#Q HeightJL(2' Weight.j..&.j- Race \}l~ Sex~ Other {:...;eiM
I, c.l<:lt.e10c€- L, ~1'- -t l.::r: competent adult, being duly sworn according to law, depose and state that 1 personally handed
a true and correct copy of the Noti e of Shenfrs Sale m the manner as set forth herem, Issued m the capnoned case on the dale and at
the address indicated above_
~{r
NOT SERVED
On the __c:~ day of
, 200~ at
o'clock _.m, Defendant NOT FOUND because:
~1ovcd
Unknown
No Answer
Vacant
Other:
Sworn to and ,ubscribed
before me this ____ day
of ".l 200 _'
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire - I.D. No. 12248
One Penn Center Suhurban Station, Suite 1400
Philadelphia, P A 19103
(215) 563-7000
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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} ss.
Robert P Ziegler
I, ______________________________________________________________________________Recorderof
Deeds in and for said County and State do 'hereby certify that the Sherifrs Deed in which _nn__n_______
GMAC Mtg Corp .
---------------------------.---------------------------_____________________________ ~ thegranree
the same having been sold to said grantee on the -----~:~-________________n__n________n___n day of
September . 01 "
____________________n__________n___n_ A. D., ' n___' under and by virtue of a wnL____n____n_
7th
Execution .
____________________________n______ _____ _ _ ___ _ _ISSued on the _ __________ __ ___ ____ __ __ n __ n _______
June
clay of __________________________ A. D.,
Civil
---------------------------- - -.--______ - _________ __ nn___ ___ ______n__ ____ __ _____ Term, :
01
-----, out of the Court of Cornman Pleas of said Countyas.o. f
2000
. 3081 GMAC Mtg Corp
Number --------------, at the suit of ------_n___________n__________________________n___nn_n___
Barry E Zook Debra A Zook aka Debra Conrad Zook
. Debra A Conrad .
---________________________________agalnst____________________________________________________ ~
248 3237
duly recorded in Sherifr. Deed Book No. __n_n_n__' Page ______n____.
uka
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this ___~n_ clay
(!), , -/-" ~r /1tV I
of ____n_(..d~___n_______n____ A. D., _n___
~-~-----------------
Recorder of Deeds
Reconlef 01 Deeds, Cuinbetland County. Carlisle, FA
My CommiSSion Expires the First MoIidIy GI JaB. 2llQ2
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GMAC Mortgage Corporation
VS
Barry E. Zook and Debra A. Zook
Alida Debra Conrad Zook aIkIa Debra
A. Conrad
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2000-3081 Civil Term
David McKinney, Deputy Sheriff, who being duly sworn according to law, states
on July 02, 2001 at 6:03 o'clock P.M., EDST, he served a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon one of the
within named defendants, to wit: Barry E. Zook, by making known unto Barry Zook at
601 Huntington Ave., Enola, Cumberland County, Pennsylvania 17025 its contents, and
at the same time handing to him personally the said true and attested copy of the same.
David McKinney, Deputy Sheriff, who being duly sworn according to law, states
on July 2, 2001 at 6:03 P.M., EDST, he posted a true copy of the within Real Estate Writ,
Notice, Poster and Description, in the above entitled action upon the property of Barry E.
Zook and Debra A. Zook aIkIa Debra Conrad Zook aIkIa Debra A. Conrad located at 601
Huntington Ave., Enola, Cumberland County, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
maimer: The Sheriff mailed a notice of the pendency of the action to one of the within
ll<m1ed defendants to wit: Debra A. Zook aIkIa Debra Conrad Zook aIkIa Debra A.
Cobrad, by certified mail return receipt requested, restricted delivery, deliver to addressee
only to her last known address of3l4 Linda Street, Deer Park, Texas 77536. This letter
was mailed under the date of June 29, 2001. Letter was received by Debra A. Zook aIkIa
Debra Conrad Zook aIkIa Debra A. Conrad on July 2, 2001 with return receipt card
signed by Debra A. Zook.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
served the within Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a pendency of the action by regular mail, to one of the
within named defendants, to wit: Barry E. Zook, at his last known address of 601
Huntington Ave., f/k/a 25 Huntington Street, Enola, PA 17025. This letter was mailed
under the date of July 05, 2001 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
served the within Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a pendency of the action by regular mail, to one of the
within named defendants, to wit: Debra A. Zook aIkIa Debra Conrad Zook aIkIa Debra
A. Conrad, at her last known address of 314 Linda Street, Deer Park, TX 77536. This
letter was mailed under the date of July 06, 2001 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 within described
premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County,
Pennsylvania, on September 5, 2001 at 10:00 o'clock A.M., E.D.S.T" and sold the same
for the sum of $1.00 to Attorney Dale Shughart (for Attorney frank Federman) for
GMAC Mortgage Corporation. It being highest bid and best price received for the same,
,
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GMAC Mortgage Corporation of500 Enterprise Road, Horsham, PA 19044, being the
buyer in this execution, paid SheriffR. Thomas Kline the sum of $682.34, it being costs.
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Sheriff's Costs:
Docketing $
Poundage
Posting Handbills
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Legal Search
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
Sworn and subscribed to before me
2001, A.D.
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30,00
13.38
15,00
15.00
30.00
10,00
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197.58
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26.50
$682.34 paid by attorney
09-26"01
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R. Thomas Kline, Sheriff
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--.GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
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Plaintiff,
v.
COURT OF COMMON PLEAS
BARRY E. ZOOK
DEBRA A. ZOOK AIKIA DEBRA CONRAD ZOOK
AIKIA DEBRA A. CONRAD
CIVIL DIVISION
NO:1l0-3081-CIVIL
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 601 HUNTINGTON AVENUE. F/K/A
25 HUNTINGTON ST. ENOLA. PA 17025
1. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
BARRY E. ZOOK
601 HUNTINGTON AVENUE, F/K/A 25
HUNTINGTON ST.
ENOLA, PA 17025
DEBRA A. ZOOK
AlK/A DEBRA
CONRAD ZOOKAlK/A
DEBRA A. CONRAD
314 LINDA STREET
DEER PARK, TX 77536
2. Name and address ofDefendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3, Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Bank of New York,
The Trustee
C/o Rosicki, Rosicki and Associates
One Ole Country Road, Suite 375
Carle Place, NY 11514
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Name and address of the last recorded holder of every mortgage of record:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
.
The Bank of New York as
Trustee under the Pooling
and Servicing Agreement
dated as of 11/30/95, Series
1995-C
100 Barclay Street
New York, NY 10286 - ~
5, Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose interest
may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7, Name and address of every other person whom the plaintiff has knowledge who has any interest in the
property, which may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
601 HUNTINGTON AVENUE, FIKIA 25
HUNTINGTON ST.
ENOLA, PA 17025
Domestic Relations of Cumberland
County
13 North Hanover Street
Carlisle, P A 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, PA 17105
East Pennsboro Township
98 South Enola Drive
Enola, P A 17025
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
infonnation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.s. Sec. 4904
relating to unsworn falsification to authorities. W ~
June 4. 2001
DATE FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
v.
No.00-3081-CIVIL
BARRY E. ZOOK
DEBRA A. ZOOK A/KIA DEBRA CONRAD ZOOK
A/KIA DEBRA A. CONRAD
-'"
Defendant( s).
June 4, 2001
TO: BARRY E. ZOOK
601 HUNTINGTON AVENUE, F/KJA 25 HUNTINGTON ST.
ENOLA, PA 17025
DEBRA A. ZOOK A/KJA DEBRA CONRAD ZOOK AlKJA DEBRA A. CONRAD
314 LINDA STREET
DEER PARK, 'IX 77536
""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.""
Your house (real estate) at 601 HUNTINGTON AVENUE, F/KJA 25 HUNTINGTON ST.
ENOLA, P A 17025is scheduled to\fu-sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a.m.
in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court
judgment obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. Ifthe
Sheriffs sale is postponed, the property will be relisted for the DECEMBER 5, 2001 Sheriffs Sail:.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you rnust take immediate action:
I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
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.
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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 notice on page two 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 (215) 563"7000. -..
2, You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the Salll, To
find out if this has happened, you may call (717) 240-6390.
4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict
you.
6. You maybe entitled to a share of the money which was paid for your house. A schedule of j
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale, This
schedule will state who will be receiving that money. The rnoney will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
ALA \\'YER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
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DESCRlPTION
ALL THAT CERTAIN tract or parcel of land with the buildings and improvements thereon erected
siruate in East Pennsboro Township. Cumberland County. Pennsylvania. more particularly bounded
and described as follows. to wir:
BEGINNING at a point at the Northweste~ly comer of Humington Street and Chester Avenue:
thence along the Northerly line of Huntington Street South 87 degrees 30 minutes West, 100 feet to
a point: thence North 2 degrees 30 minutes West. 1.+2 feet to a point at the Southerly line of a 15
feet public alley: thence along same :-.forth 87 degrees 30 minutes East. 100 feet to a point on the
Westerly line of Chester Avenue aforesaid: thence along same South 2 degrees 30 minutes East. 1.+2
feet to a point the place of beginning.
BEING premises known as .\io. 601 Humington .-\venue. formerly known as 25 Huntington Street:
TITLE TO SAID PRE:ynSES IS VESTED IN Debr:J. _-\. Conr:J.d Zook :J.nd Barry E Zook. wife
and husband by Deed from Sar:J.h Howard. Executrix of the Estate of Charles W. Snyder. late dated
12/1/87. recorded 12,29/87. in Deed Book C33. Page 867.
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WRITOF EXEctrfldN and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 00-3081 CIVIL ~ TERM
CIVIL ACTION - LAW
TO THE SHERIFF OF
Cumberland
COUNTY:
To satisfy the debt, interest and costs due GMAC Mortgage Corporation
PLAINTIFF(S)
from Barry E. Zook, 601 Huntington Avenue, F/K/A 25 Huntington St., Enola, PA 17025
Debra A. Zook A/K/A! Debra Conrad Zook A/K/A Debra A. Conrad, 314 Linda Street,
Deer Park. 'IX 77536 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 notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt;:10:~r for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
theniof:.
,"\
:.(3) If property ofthe defendant(s) not levied upon an subject to attachment is found in the possession of anyone other
thana-named garnishee, you are directed to notny him/herthat he/she has been added as a garnishee and is enjoined as above
staietl.
Amount Due $35.53] .90 LL
fran 8/1/00 to 9/5/01
Interest (pcffiicm $5.84) $2366. and costs- Due Prothy
Atty's Comm % Other Costs
Atty Paid $708.53
Plaintiff Paid
$1.00
Date:
June 7, 2001
Curtis R. Long
Prothonotary, Civil Division
b~O/)'o 0 _ P 7J;-J? /J.A(, r-------
Deputy
REQUESTING PARTY:
Frank Fedennan, Esg.
Address: One Penn Center at Suburban station,
Name
Suite 1400
philadelphia, PA 19103
Attorney for: Plaintiff
Telephone: 215-563-7000
Supreme Court 10 No. 12248
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Gii CJU VLQ- 13 { ;( rm I the snentt levied upon the aetendantil,
interest in the real property situated in Eilof P.u'l.f\E hora 1w(J,
C,umberland County I Pa" known and numbered as: (,01 l-h::f;;rJ' ~ ~.
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!:::t/Pu.v _ and more fully described on exhibit "A" filed wit
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this writ and by this reference incorporated herein.
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REAL ESTATE SALE NO. 27
Writ No. 2000-3081 Civil
GMAC Mortgage Corporation
vs.
Barry E. Zook and Debra A
Zook a/kj a Debra A. Conrad
Atty.: Frank Federman
DESCRIPTION
ALL THAT CERTAIN tract or par"
eel of land with the buildings and
improvements thereon erected situ-
ate in East Pennsboro Township,
Cumberland County. Pennsylvania,
more particularly bounded and de-
scribed as follows. to wit:
BEGINNING at a point at the
Northwesterly Corner of Huntington
Street and Chester Avenue: thence
along the Northerly line of Hunting_
ton Street South 87 degrees 30 min-
utes West. 100 feet to a point thenct:L
North 2 degrees 30 minutes West.
142 feet to a point at'the Southerly
line of a 15 feet public alley; thence
along same North 87 degrees 30
minutes East. 100 feet to a pOint
on the Westerly line of Chester AVe-
nue aforesaid; thence along same
South 2 degrees 30 minutes East.
142 feet to a point the place of be-
ginning.
BEING premises known as No.
601 Huntington Avenue, formerly
known as 25 Huntington Street.
'I1TLE TO SAID PREMISES IS
VESTED IN Debra A Conrad Zook
and Bany E. Zook. Wife and hus-
band by Deed from Sarah Howard.
Executrix of the Estate of Charles
W. Snyder, late dated 12/1/87. re-
corded 12/29/87, in Deed Book
C33, Page 867_
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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 :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
VlZ:
JULY 20, 27, AUGUST 3, 2001
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.
r ~"~ __
Roger , Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
3 day of AUGUST. 2001
~~~~~. J~r/AJ
" NOI'ARIAI:'sEi4.
LOIS E. SNYDER, NoIatyPullllc
Carlisle Bolo, CumberIaniI County
My Commla&lon ExpiIIs MaR:h 8; 2005
."
r
.
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Pr.oof of Publication
Under Act No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin) ss
James L. Clark being duly sworn according to law, deposes and says:
That he is the 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 Th e
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 and/or Sunday/ Metro editions which appeared on the 24th and 31 st day(s) of July and the 7th
day(s) of August 2001. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in rellaneous Book "M",
V;~:~g;~:~: ~(jmm;;~...._._.~;.~.......~.~~~;._~:~.
S ALE #27 Notanal S.. ,
Terry L. RUSSfilll, N fY ~b ~
Harrisburg. oaupl'i{n 96!!!: ~~
My Commission Explfe; June S, 2002 TARY PUBLIC
Member, PennsylVania Association at Netarie;... . J 6 '. 2002
MY commiSSion expires une, _
REAL ESTATE SALE No. 27
Wrft No.20D0-3081
Civil Term.
GMAC Mortgage
CorporatIon
vs
Barry E. Zook and'
Debra A. look 'aIkIa
Debra A. Conrad
Atty: Frank Federman
DESCllIPTION
CUMBERlAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COUR1HOUSE
CARLISLE, PA. 17013
A~ THAT CERl:AJ~ tract or pated of land
wlm dle .hul1dlOg~ and ImproVt'lTlCnts thereon
t:n.~lC4.,' situate in f~$t Pcnnsboro TownshIp,
, CU11,1berland County, Pennsyhamll, more
I r;!ttlcuJar!~ oounuoo and ckM:nbed a~ followS: (0
Wit:
! BEG1t:'lN1NG -m a pOt>>! at the NottiJv:eslerly
wmer of HUlltmglO1l Street and Chcster Avcnue:
thence along ,the NQrtherly line'or Huotmgton
Street South ,'t7 dl'!tfCeS 30 mmutes We'>t, -](10
J feet tl) a -"'Jmt: thence Nonh .2 degI're'> 30
" r~toutes West, 142 feet to a pom! at the Southerly
hne ora [5 fc,,'Ct public alley; thence along same
N~rth 87 dcgree~ 30 minutes East, 100 fet,'l to a
C po/m" ~Ij' the Westerly - line of Chester Avenue
, _aforesaid: !hence along same South:: degrees 30
t - minutes East, 1.+2 fCt't to a pOlOt the place of
BEGlNNfNG.
BEING:preml~s known as No. 60f HUnltngton
Av~ue; . fooncrl.l' known as 2.5 HlIntjoglQr]
StR'Ct.
r TffiE TO SAID PREMISES IS vested to Dehra
A. Conrild Zook and Barry E. Zook, wife and
hUsOOn~, by deed fmm Sarah Howard, becutrix
,?f the btillc- of ('hark~ W. Sny<kr, late dated 121
1/87. recorded ]2f:29~7, HI Deed Book en
PageR07., ' ,"".
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 $
196.08
1-50
197.58
'ublisher's Receipt for Advertising Cost
lublisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
receipt of the aforesaid notice and publication costs and certifies that the same have
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