HomeMy WebLinkAbout02-5774COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
9th JUDICIAL DISTRICT
COMMONWEALTH OF PENNSYLVANIA
MORTGAGE ELECTRONIC :
REGISTRATION SYSTEMS, Inc. as nominee :
for ST. FRANCISVILLE, L.L.C.,
Plaintiff
WILLIAM A. DOYLE and
PATRICIA A. DOYLE,
Defendants
IN MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. H'you wish to del'end against the claims set forth
in the following pages, you must take action within twenty (20) days after this Complaint is served,
hy entering a written appearance personally or by attorney, and liling in writing with the Court your
defenses or o[2jections to the claims set forth against you. You arc warned that if you f~til to do so, the
case may proceed without further notice tbr any money claimed in the Complaint or for any other
claims or reliet'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.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
9th JUDICIAL DISTRICT
COMMONWEALTH OF PENNSYLVANIA
MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, Inc. as nominee
for ST. FRANCISV1LLE, L.L.C.,
Plaintiff
Vo
WILLIAM A. DOYLE and
PATRICIA A. DOYLE,
Defendants
NO. r>_a-
IN MORTGAGE FORECLOSURE
COMPLAINT
1. Plaintiff is Mortgage Electronic Registration S}stens, Inc. as nominee for St.
Francisville, LLC.
2. The Defendants are William A. Doyle and Patricia A. Doyle whose last known
address is:
4183 Cove Court #108
Mechanicsburg, PA 17050-7644
The Dct:endants are the Mortgagors and real owners of the Premises, hereinafter
described.
4. On December 10, 1998 Defendants made, executed and delivered a mortgage upon
thc Premises hcreinatter described and commonly known as 420 ~ est Mare Street, South Newton
Township, Cumberland County, Pennsylvania which Mortgage is recorded ill the Recorder's Office
lbr Cumberland County in Book 1507 Page 622. See Exhibit "A" attached hereto and incorporated
herein.
5.
Tile Mortgage was assigned to Approved Residential Mortgage, Inc. herein by virtue
of an Assignmcnt dated December I(L 1998 and recorded in the atbresaid Recorder's Office in
Book 600, Page 970, a copy of which is attached hcreto and incorporated herein as Exhibit ~'B".
6. The Mortgage was assigned to Key Bank USA, N.A. herein by virtue of an
Assignment dated Jauuary 29, 1999 and recorded in the aforesaid Recorder's Office in Book 659,
Page 529, a copy of which is attached hereto and incorporated herein as Exhibit "C".
7. The Mortgage was assigned to Mortgage Electronic Registration Systems, Inc., as
nominee fbr St. Francisvillc, LLC. hercin by virtue of an Assignment dated July 12, 2001 and
recorded in the aforesaid Recorder's Olt~ce in Book 681). Pagc 11)64. a copy of xvhich is attached
hereto and incorporated herein as Exhibit
6. The mortgaged Premises are attached as part of Exhibit "A".
7. Thc mortgage is in default in that monthly payments of $717.21 are due for the
month of December 15, 1999 and for each month thercal'ter arc due and unpaid. Such failure to
make monthly payments constitutes a dcfhult under the terms of the mortgage, entitling Plaintiff to
demand payment of the entire principal balance, together with interest, costs and fees.
The tbllowing amounts are due on the mortgage:
Principal balance: $91,332.18
Interest fi'om 12/15/1999 through 1 I / 18/2002 $23.765.52
Attorneys fces 10% $12,302.95
Late Charges $ 1,219.24
Costs of Suit $ 250.00
Title Search $ 150.00
Escrow Deficit $ 6,312.56
Returned Check Fee $ -0-
Per Diem interest of $21.64 from 11/19/02 $ accruing
Total
$135,395.45, plus accruals
9. Thc attorneys lees set forth above are pursuant to the mortgage documents and will
be collected at Sheriff's sale. It' the mortgage is reinstated prior to Sherift's sale, actual and
reasonable attorneys lees will bc charged which in no event will exceed the sum stated above.
10. Thc Notices, if required by Act 6 and Act 91. have been sent separately or in
combined form pursuant to 35. P.S. 1680.403c and are attached hereto and incorporated herein as
Exhibit
11. The tcmporary stay providcd by the [ lomcowner's Mortgage Assistance Act has
terminated because:
a. l)el'endant has failed to mcct with Plaintiff or an authorized Credit Counselor,
or;
b. Defendant's application for assistance has been denied by the Pennsylvania Housing
Finance Agency.
WHEREFORE, Plaintiffdenmndsjudgment in rem against Defendants and the Premises in
the sum orS 135 395.45, plus interest at the rate o f $21.64 per day from November 18, 2002, together
with other costs and sums recoverable under the mortgage and for the tbreclosure and judicial sale
of the Premises.
By:
Respectt'ully submitted,
WIESMET}t & HARDY
ATTORNEYS AT LAW, P.C.
919 Main Street
Stroudsburg, PA 18360
570-424-2848
VERIFICATION
I, Joseph S. Wiesmeth, Esquire, Attorney l})t' l)laintiff, Mortgage Electronic Systems, Inc., as
nominee lbr St. Francisville. LLC, do hereby swear and affirm that the t:acts set forth in the within
Complaint are true and correct to tile best o[' my knowledgc, inlbt'nmtion and beliei; based upon tile
inlbrmation given to me by thc af~resaid party client. I makc this Verification under and subject to the
penalties of 18 I)a.C.S.A., Scction 4904, relating to unsworn [hlsifications to authorities.
.Joseph S. ~¢esmeti~, Esquire
/
Parcel Number:' t--I I -,32.- ~2-cl 2. -~-
' ~ :,:':. "t:OUN f :'-
C .[, .'. :~ t) PA
'98 D[O 21 3 18
[Space Above This Line For Recording Dam]
MORTGAGE
THIS MORTGAGE (~Securit~ Instrument") is given ~ecember 10, 1998 morlgagor is
WILLIAM A. DOYLE and PATRICIA A. DOYLE ("Borrower").
This Security Instrument is given to
APPROVED FEDERAL SAVINGS BANK,~/''
which is organized and existing under the Mws of UNITED STATES OF AMERICA. and whose address is 2380 COUR*
PLAZA DR., VIRGINIA BEACH, VA 23456, ("Leper"). Borrower owes Lender th,e principal sum of NInety-Twl
Thousand and 00/100 Ool~ars (U.S.$92,000.00~)f This debt is evidenced by Borrowers note dated the same date as thi
Secur~y Instrument ("Ncte"),,/a~hich provides for monthly payments, with the full debt, If not paid earlier, due and payable or
December 15th, 2028.V'This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, witl
interest, and all renewals, extensions and modifications of the Note; (b) the payment of ell other sums, with interest, advanced unde
paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreement~
under this Security Instrument and the Note. For this purpose, Borrower does hereDy mortgage, grant and convey to Lender th,
following described property located in CUMBERLAND County, Pennsylvania:
SEE LEGAL DESCRIPTION
which has the address o~ 420 WEST MAIN STREET, WALNUT BOTTOM, PA 17266 ("Property Address");
/
PENNSYLVANIA-SIngle Family-FNMA/FHLMC UNIFORM INSTRUMENT Page t of 6 Form 3039 9/90 Amended 5/9t
I. I :~ ~.~ s.,.,~.. EXHIBIT
. oodSOT t .622 m
.TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, end fixtures
now or hereafter a part o! the property. All replacements and additions shall also be covered by this Security Instrument. All of the
foregoing 'is refer'red to in this Securify Instrument as the "Property."
- BORROWER COVENANTS that Borrower is iew~ully sels~d ot the estate hereby conveyed and has the right to grant and convey
the Property and that the Property is unencumbered, except for encumbrances o! record. Borrower warran!s and will defend generally
the title to the Property against all claims and demands, subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by
Jurisdiction to constitute a uniform security instrument covering real properly.
UNIFORM COVENANTS.. Borrower and Lender covenant and agree as follows:
.1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when due
the principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the Note.
2. Funds for Taxes and Insurance. Subject to appllcabis !aw or to a written waiver by Lender, Borrower shall pay to
Lender on the day month'ly payments are due under the Note, until the Note is paid in full, a sum ("Funds") for: (a) yearly taxes and
assessn~ents wh{ch may attain priority over this Security Instrument as a lien on the Property; (b) yearly leasehold payments or
ground rents on the Property, if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums, if any; (e)
yearly mortgage insurance premiums, if any; and (f) any sums payable by Borrower to Lender, in accordance with the provisions of
paragraph 8, in lieu of the payment of mortgage insurance premiums. These Items are called "Escrow Items." Lender may, at any
time, collect and hold Funds in an amount not to exceed the maximum amount a lender for a federally related mortgage loan may
require for Borrower's escrow account under the federal Real Estate Settlement Procedures Act ot 1974 as amended from time to time,
12 U.S.C. 2601 et seq. ("RESPA"), unless another law that applies to the Funds sets a lesser amount. It so, Lender may, at any
time, collect end hold Funds in an amount not to exceed the lesser amount. Lender may estimate the amount of Funds due on the
basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with applicable law.
The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality or entity (including
Lender, if Lender is such an institution) or fn any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items.
Lender may not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow
Items, unless Lender pays Borrower inlerest on the Funds and applicable iew permits Lender to make such a charge. However,
Lender may require Borrower to pay a one-time charge for an independent real estate tax reporting service used by Lender in
connection with this loan, unless applicable law provides olherwise. Unless an agreement is made or applicable isw requires interest
to be paid, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower end Lender may agree in
wrIting, however, that ~nterest shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the
Funds, Showing credits an, d debits to the Funds and the purpose for which each debit to the Funds was made. The Funds are
pledged as additional security for ail sums secured by this Security Instrument.
It the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shall account to Borrower for the
excess Funds in accordanne with the requirements o! applicable law. If the amount of the Funds held by Lender at any time is not
sufficient lo pay the Escrow Items when due. Lender may so notify Borrower In writing, and, in such case Borrower shall pay to
Lender the amount necessary to make up the deficiency. Borrower shall make up the deficiency in no more than twelve monthly
payments, at Lender's sole discretion.
Upon payment in full of all sums secured by this SecurIty Instrument, Lender shall promptly refund to Borrower any Funds held by
Lender. I!, under paregrapn 21, Lender shall acquire or sell the Proper~y, Lender, prior to the acquisItion or sale of the Property, shall
apply any Funds held by lender at the time ol acquisition or sale as a credit' against the sums secured by this Security Instrument.
3. AppllcaUon of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs
1 and 2 shall be applied: frst, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2; third,
to interest due; fourth, to principal due; and last, to any late charges due under the Note.
4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines and impositions attributable to the Property
which may attain priorIty over this Security Instrumen!, and leasehold payments or ground rents, if any. Borrower shall pay these
obligations in the manner provided in paragraph 2, or if not paid in that manner, Borrower shelf pay them on time direclly to the
person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this paragraph. If
Borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to
the payment ot the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends
against en!orcemant of the lien i~1, legal proceedings which in the Lander's opinion operate to prevent the enforcement of the llen; or
(C) secures from the holder o! the lien an agreement satisfactory to Lender subordinating the llen to this Security Instrument. If
Lender determines that any part of the Property Is subject to a lien which may attain priority over this Security iostrument, Lendsr may
give Borrower a notice identifying the lien, Borrower shall satisfy the lien or take one or more of the actions set forth above within 10
days of the giving of notice.
Page 2 of 6
Form3039 9/90
.5. Hazard or Property Insurance. Borrower shall keep the improvements now existing or hereafter erected
Property i~sured against loss by fire, hazards included within the term "extended coverage" and any othe¢ hazards, including rio(
flooding, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that
requires. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's approva~ which shall r
unreasonably withheld. If Borrower fails to maintain coverage descrioed above, Lender may, at Lender's option, obtain cover;
protect Lender's rights in the Property in accordance with paragraph 7.
All insurance policies and renewals shait be acceptable to Lender and shall include a standard mortgage clause. Lender
have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts o
premiums end renew/al notices. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. L
may make picot o! Ios~ if not made promptly by Borrower.
Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair
Property damaged, it the restoration or repair is economically feasible and Lender's security is not lessened. If the restorati
repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the
secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. If Borrower abandons the Pro
or'doe~ not answer within 30 days a notice from Lender that the insurance carrier has offered to settle a claim, then Lende
collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured b
Security Instrument, whether or not then due. The 3C-day period will begin when the notice is given.
Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpon
due date of the monthly payments referred to in paragraphs 1 end 2 or change the amount of the payments. If under paregral
the Property is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting fi`om damage to the Pr(
prior to the acquisition shall pass to Lender to the extent of the sums secured by this Security Instrument immediately prior
acquisition.
6. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's
Application; Leaseholds. Borrower shall occupy, establish, and use the Property es Borrower's principal residence within
days after the execution of this Security Instrument and shall continue to occupy the Property es Borrower's principal residence
least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreaso
withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, dame
impair the Property, allow the Property to deteriorate, or commit waste on the Property. Borrower shall be in default ~ any fort
action or proceeding, whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeiture ct the Pre
or otherwise materiaJly impair the lien created by this Security Instrument or Lender's security interest. Borrower may cure s~
default and reinstate, as provided in paragraph 18, by causing the action or proceeding 1o be dismissed with a ruling that. in Lei
good faith determination, precludes forfeiture of the Borrower's interest in the Property or other material impairment ct the lien cr
by this Security Instrument or Lender's security interest. Borrower shall also be in defauft if Borrower, during the loan applic
process, gave materially false or inaccurate information or statements to Lender (or falfed to provide Lender with any ma
information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borro
occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with a
provisions of the tease. It Borrower acquires fee title to the Property, the leasehold and fee title shall not merge unless Lender a
to the merger in wri~ng.
7. Protectio~t of Lender's Rights in the Property. if Borrower fails to perform the covenants and agreer
contained in this Security Instrument, or there is a legal proceeding that'may significantly affect Lender's rights in the Property
as a proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulations), then Lender may d(
pay for whatever is ~racessary to protect the value of the Property and Lender's rights in the Property. Lender's actions may in.
paying any sums secured by a lien which has priority over this Security Instrument, appearing in court, paying reasonable attor
fees and entering on the Property to make repairs. Although Lender may take action under this paragraph 7, Lender does not
to do so.
Any amounts disioureed by Lender under this paragraph 7 shall become additional (lebt of Borrower secured by this Se~
Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from the da
disbursement at the Note rate and shall be payable, with interest, upon notice fi`om Lender to Borrower requesting payment.
8. Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan secured by this
Instrument, Borrower shall pay the premiums requ]rsd to maintain the mortgage insurance in effect. If, for any reason, the moil
insurance coverage mquked by Lender ;apses or ceases to be in effect, Borrower shaJ] pay the premiums required to obtain cov;
subst~nti~lly-equivaiont to the mortgage insurance previously in effect, at · cost substantially equivalent to the cost to Borrower c
mortgage insurance previously in eftecl, fi.om an alternate mortgage insurer approved by Lender. If substantially equivalent mort
insurance coverage is not evailable, Borrower shall pay to Lender each month e sum equal to one-twelfth of the yearly mort
insurance premium being paid by Borrower when the insurance coverage lapsed or ceased to be in effect. Lender will accept
and retain these payments as a loss reserve in lieu of mortgage insurance.
Form 3039 9/90
Page 3 of 6
'Loss resents payments may no longer be required, at the option of Lender, if mortgage insurance coverage (in the amount and I
period th~.t Lender requires) provided by an insurer approved by Lender again becomes available and is obtained. Borrower sh~
the premiums requYed to maintain mortgage insurance in effect, or to provide a loss reserve, until the requirement for mo
insurance ends in accordance with any w~itten agreement between Borrower and Lender or applicable law.
9. tnspectJon. Lender or its agent may make reasonable entries ,upon and inspections of the Property. Lender she
Borrower notice et the time of or prior to an inspection specifying reasonable cause for the inspection.
10. Condem~lation. The proceeds of any award or claim for damages, direct or consequential, in connection wit
condemnation or other taking of any part of the Property, or for conveyance in lieu of condemnation, are hereby assigned anc
be paid to Lender.
In the event of a toial taking of the Property, the proceeds shell be applied to the sums secured by this Security InstrL
whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair r
value of the Property Immediately before the taking is equal to or greater than the amount of the sums secured by this Se
Instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by this S~
Instrument shall be reduced by the amount of the proceeds multiplled by the following fraction: (a) the total amount of the
se~ured'lmmediataly before the taking, divided by (b) the fa~ market value of the Property immediately before the taking. Any bt
shall be paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property imme¢
before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender oth~
agree in writing or unless applicable law otherwise provides, the proceeds shall be applied to the sums secured by this Se
Instrument whether or not the sums ere then due.
If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor offers to make an ,
or settle e claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lan
authorized to collect and apply the prececds, at its option, either to restoration or repair of the Property or to the sums secur,
this Security Instrument, whether or not then due.
Unless Lender end Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpor
due date of the monthly payments referred to in paragraphs 1 end 2 or change the amount of such payments.
11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for paym~
modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in inten
Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall n
required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise n
amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrc
successors in interact. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the ex*
of any right or remedy.
12. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenant~
agreements of this ~ecurity Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject I
provisions of paragraph 17. Borrower's covenants and agreements shall be joint and several. Any Borrower who co-sign
Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and conve,.
Borrower's interest In the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the
secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or
any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent.
13. Loan Charges. il the loan secured by this Security Instrur~ent is subject to a law which sets maximum loan chi
and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the
exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge't
permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Bart
Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrov
e refund reduces pr~cipal, the reduction will be trested as a partial prepayment without any prepayment charge under the Note.
14. Notices. Any notice to Borrower provided for in this Security Instrument shell ,be given by delivering it or by mailing
first class mail unles~S applicable law requires use of another method. The notice shall be directed to the Property Address c
other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's ad
stated herein or any other address Lender designates by notice to Sorrower. Any notice provided for in this Security Instrument
be deemed to have been given to Borrower or Lender when given as provided in this paragraph.
15. Governing Law; Severabllity. This Security Instrument shall be governed by federal law and the law ¢
jurisdiction in which tho Property is located. In the event that any provision or clause of this Security Instrument or the Note co~
with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given
without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared tO be sevarabl
16. Borrower's Copy. Borrower shall be given one conformed copy of the Note end of this Security Instrument.
Page 4 of S
Form 3039 9/90
.17. Transfer of the PropertY or a Beneficial Interest in Borrower. if all or any part of the Property
interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural p
without Lender's prior written consent, Lender may, et its option, require immediate payment in full of sit sums secured t
Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the c
this Security Instrumefrt.
If Lender exercises this option, Lender shell give Borrower notice of scceleration. The notice shell provide a period of nc
than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Si
Instrument. It Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permltf
this Security .Instrume~t~wthout further notice or demand on Borrower.
18. Borrower's Right To Reinstate. If Borrower meets certain conditions, Borrower shall have the right to
enfomement of this Security Instrument discontinued at any time prior to the earlier of: (a) 5 days (or such other period as appT
law may specify for reinstatement) before sale of the Property pursuant to any power of sale contained in this Security instrum~
(b) entry of a judgmenl enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums whicf
wo~ld be due under th~s Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any
covenenls or agreements; (c) pays all expenses incurred in enforcing this Security instrument, including, but not limited to. teas(
attorneys' fees; aru:l (d) takes such action es Lender may reasonably require to assure that the lien of this Security Instr[
Lander's rights in the Property and c~orrower's obligation to pay the sums secured by this Security Instrument shall co~
unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully
as if no acceleration had occurred. However, th~s right to reinstate shall not apply in the case of acceleration under paragraph '
19. Sale of Note; Change of Loan Servicer. The Note or a partial interest in the Note (together with this
Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (kno,
the "Loan Servicer") that col~cts monthly payments due under the Note and this Security Instrument. There also may be
more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of tho Loan Servicer, Borrower witl be
written notice ut the change in accordance with paragraph 14 above and applicable law. The notice will state the name and
of the new Loan Se~,icer and the address to which payments should bo made. The noUce will also contain any other inforr
required by applicable law.
20. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release
Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Pr~
that is in violation o~' any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage
Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses
maintenance of the Property.
Borrower shall promptly give Lender wr;tlen notice of any investigation, claim, demand, lawsuit or other action by any governr
or regulatory agenoy or privata party involving the Property end any Hazardous Substance or Environmental Law of which
has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or
remedlatlon of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take a~l necessary ret
actions in accordance with Environmental Law.
AS used in this paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous substanc
E~vironmantal Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticide
hert3icides, volatile So~vents, materiels oontaining asbestos or formaldehy.de, and radoactive materials. As used in this paragra[~
"Env~-onmental Law" means federal laws end laws of the jurisdiction where the Property is located that relate to health, ssi,
environmental protection.
NON-UNIFORM COVENANTS. Borrower end Lender further covenant and agree as follows:
21. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borro,
breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under paragraI
unless applicable law provides otherwise). Lender shall notify borrower of, among other things: (a) the defaul~
the action requlrod to cure the default; (c) when the default must be cured; and'(d) that failure to cure the defa~
specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by ju~
proceedings and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceler
and the right to a~sert in the foreclosure proceeding the non-existence of a default or any other defense of Borro~
acceleration and Itoreclosure. If the default is not cured as specified, Lender, at its option, may require imme
payment in full ef all sums secured by this Security Instrument without further demand and may foreclose
Security lnstrumont by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuin
remedies provided in this paragraph 21, including, but not limited to, attorneys' fees and costs ot title evidence t
extent permitted by applicable law.
22. Release. Upon payment of ell sums secured by th~s Security Instrument, this Security Instrument and the estate con
shelf terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without c
to Borrower. Borrower shall pay any recordation costs.
Form 3039 9190
:' i". ' "'°" °" 626
,23. Waivers. Borrower, to the extent permitted by applicable, waives and releases any error or defects in proceed
enforce th. is Security Instrument, and hereby waives the benefit of any present or future ~aws providing for stay of execution, ex
of time, exemption from atta(~hment, levy end sale, and homestead exemption.
· 24. Reinstatement Period. Borrower's {ime to' r~instate provided in paragraph t8 shell extend to one hour prior
commencement of bidding at a sheriff's sale or other sale pursuant to this*Security Instrument.
25. Purchase Money Mortgage. If any of the debt secured by this Security Insfrument is lent to Borrower to
title to the Property, this Security Instrument shall be a pumhase money mortgage.
26. Interest Rate After Judgement. Borrower agrees that the interest rate payable after a judgement is entered
Note or in an actiun of mortgage foreclosure shall be the rate payable from time to time under the note.
27. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded togelh
this Security Instrument, the covenants and agreements of each such rider shall be Incorporafed into and shall amer
supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument.
applicable box(es)]
[ JAdjustable Rate Rider
[ ]Graduated Payment Rider
[ ]Balloon Rider
[ ~VA Rider
[ ]Condominium Rider
[ ]Planned Unit Development
Rider
[ IRate Improvement Rider
[XX ] Other(s) Ispecih, I LEGAL DESCRIPTION
[ ]1-4 Family Rider
[ ]Biweekly Payment
]Second Home Rid
BY SIGNING UNDER SEAL BELOW, Borrower accepts and agrees to the terms and covenants contained in this S
Instrument and in any rider(s) executed by Borrower and recorded with it.
Witneseesw /~
WILLIAM A. DOYLE ~" Borrower
PATRIClA A. DOYLE Borrower
.(Seal)
420 WEST AIN STR T
Witness my hand this
, do hereby certify that the correct address of the within-named Mortg.
BOTTOM, PA 17266
AganJ, Uc-.gag.
STATE OF PENNSYLVANIA, ~ County ss:
On this ' ~(~) day of , before me, the undersigned officer,'pe~
appeared WILLIAM A. DOYLE and PATRIClA A. DOYLE known to me (or satisfactorily proven) t.o"~be th'&
whose name subscribed to the within Instrument and acknowledged t~D~at .~,:..~, * ' .~; :~ ~
IN W~NE~ WHERE., I h~nto set my hand and off~l seal. [/ J ~ I ~ ~ ~'~ ~ ~:~..~-;' '
-. ~uu~, uauphh Count, PA I ~ Fo~ ~39 9/90' "...:.T.,v'
I ~ C0mml~/on ~l~s Nov. ~5, 19~1
, ~:; PROPERTY DI~.SCRIPrlON
The lend referred Io In this Commitment Is described es follows:
ALL THOSE CERTAIN two (2) traob~ of land with the improvements em,,c, ted.thereon known ,aa 420 V~ eat Main
Stm~ Walnut 8attain, situate In South Newton Town~hip, Cumbede*nd Chun[y, Pennsylvema, bounded end
TRACT NO. t
BEGINNING et e point the Intersection of the center line of State HighWay Route No. 33 and land not ~ or
formerly of Blaine Bl~lec thence In a northerly dlreclion along the lend now or forTnerl¥ of Blaine Bigier two
hundred twenty (2,!0) feet to land now or formedy of W.S. Meals; t.hence in a. Wester.ly_di~.r?ctl,on..elong t.he land
now or formerly of W,$. Meals fifty (50) feet to other lands now ~r mrmerly or said W.=, Meals; mono.~ m a
southerly dlre~ion along lands now or form,e, rly of said W.S. Meals two hundred twe. nty (2~..0) feet to tle center
line of said State Highway Route No. 33 a oietance of fifty (50) feet to · point, the plac~ o! Beginning.
TRACT NO. 2
BEGINNING at a point In the contadina of Walnut Bottom Road et comer of land now or formerly of David G.
Sbayer; thence by the cnnfer of the said road South sixty-seven (67) degrees West sixty-one (61) feut to a point
at land now or formerly of !tarold S. Meals; thence by the same North thirty (30) degrees fifteen (15) minutes
West two hundred t~ftaen (215) feet to a stake; therlc~ by' the same Nmlh sixty-two(62) degrees flfte, m (15)
minutes East sixty.two and two tenths (72.2) feet to a post at land now or formerly of said Da,vid G. Strayer,
thence by the same South twenly-seven (27) degrees thirty (30) minutes East Iwo hundred s~xteen amd nine
tenths (218.9) feet Io a point et the Walnut Bottom Road, the place of beginning.
AND BEING the same two tracts of mai estate which EIdntonC. Comerer, single man by his deed da!ed June
16, 1989 and recorded in the Office of Ihs Recorder of Deeds In and for Cumberland Counb/ Penns~ Ivanla, in
Deed Book "Z" 33, at Page 1080, granted and conveyed to Gary L. Yel'te, the grantor Ilere n.
UNDER AND SUBJECT to the btdldlng and use rest~t~flons ae recorded in Cumberland County Deed Book "F",
Volume 23, et Page 641.
BOOKISO7 ,AGt .628
For vuluable cons~dcr,ntion ~n hm~J pn{d. receipt whcr=o£ is hc~'cby acknowlcdg~!.~l I;I~:O~.D ~ I~ * ~,~
FBDERA[. SA¥1NGS BANK.. Grantor, docs hercby ~et over, transl'~lll~ j~0-'~[~t~ dmlo
Before me, n Notar~ Public in ~'td for d~¢ State and City uforesoid, personally appeared ~rlc Ym~cl
~, APPROVED FEDE~L SAV~GS BAN~ who, bcb~i duly s~m ~ccordlng lo Inw,,?id
depose and ssy ~at ~c foregoin~ Tm~Er nnd ~slgmncnl w~ ~uly ~ecutcd for thc p~rpo~'mtd .
Swmn o and subscribed before mc tbJs d3y .~ ~' ~.'
CUUBERLAND gOU~?y_pA
reear~led In MeA~agel~ook~)~ , PaBe~"~='er the Public Records or Lhe above county, for ~aluable consMcrntlan,
sH eccey L. y~f~f~rRbVr/~ssi~r.,~rr~R~r,~R-v.~.~ ,
Whcn R~ordcd Moll To:
T.D, Service Compeny
!1t20 E. First S;., Suke 300
Santa An;, CA 92705
Aim: As!liBnmcm Coordinator
OU~B£RL~o COUnTy_pA
Prep,red by:
T.D. Bernice Finm~cial
Lo~n #: 000014488.~
AB~DGNM£NT OF MOR'fGA~£
]:or Bood and volunblc eons'dcPaflori, thc sui~c'cney of'whmh is hcrcby ackoawlcdgcd.
Frauglllvlile, LLC, Ira Wuecmlera ..d msigem, P.O. ~x 202~ Fll,~ Mkhi~n ~1-2026
;ny riBh~ d,e or 1o become d~e themoa. S~id Mo~;a~= lot ~02.000.00 ia ~md~ in ~= S~;e o?
· ~m~l~elm~ Townthip o? W~ UT ~O~. Coun~ o~CUMB~D O~cial Records.
D~ember 10, 1998 and rcco~ed on D~m~r 25,199~ as 3:lB P B: 1507~622.
OriBinal Mon~Bor. WII.I.IAJV[ j~
C)riBkal MongaBt'e: APPRO¥~D FKDI~I~L BUGS BAN~
Prop. Address: 420 W~ST NIAI.N' ~TREET, WALNUT BOTT, PA
Date: July 12, 2001
By: Su FmaebvUle, ~C, nUem~-ln-fact
State ar; CAI.IFO~IA
On July 12.20~1 heroin me. thc und~tgned pe~onally appen~ K~ln J. Pn;~ek ns ~b=nt
SiGNI/R IS REPRESE"N'I~G:
Nnm. of person(s) or emily(i~s):
Key l~nnP,, USA, National A~socinfion
I Certify this to be rccordcd
[n Cumberland County PA
May 3 I, 2002
SENT CERTIFIED MAIL / RETURN RECEIPT REQUESTED: 7099 3400 0012 4306 0974
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
Thi~ is an official notice that the morttm~,e on your home is in default, and the lender intends to
foreclose. Specific information about th~ nature pi'the dclhult is provided in the attached pages.
The ItOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (tlEMAP) may be able to help to
save your hon~e. This Notice explains how the pro,ram works.
TO see ofltEMAP can help. you must MEET WI'FII A CONSUMER CREDIT COUNSELING
AGENCY WITItlN 30 DAYS OF TItE DATE OF TillS NOTICE. Take this Notice with you when
you meet with the Counselint, A~encv.
The name. address and t~hone number of Consumer Credit Counselim' Avencies servim, your County are
listed at the end of this Notice. If you have any auestions, you may call the Pennsylvania Housim, Finance
Agency toll free at 1-800-342-2397, (Persons with impaired hearing can call {717)-780-1869.)
This Notice contains i~nportant legal inlbrmation. 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
attorney in your area. The local bar association may be able to help you find a lawyer.
La not ficacion en adjunto es de suma importancia, pues afi:cta su derecho a continuar viviendo en su casa.
Si no comprende el ,~ontenido de esa notificacion obtenga una traduccion immediatamente Ilamando esta
agencia (Pennsylvania ttousing Finance Agency) sn cargos al numcro mencionado arriba. Puedes set
elegible para un prestamo pot el programa Ilamado "Homeowner's Emergency Mortgage Assistance
Program" el cual puede salvar su casa de la pcrdida del derecho a redimir su hipoteca.
HOMEOWNER'S NAME(S)
PROPERTY ADDRESS:
WILLIAM A. DOYLE
420 WEST MAIN STREET, WALNUT BOTTOM,
SOUTH NEWTON TOWNSHIP, CUMBERLAND
COUNTY, PENNSYLVANIA, 17266
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Homeowner's Emergency
144883
APl'ROVED FEDERAL SAVINGS BANK
ST. FRANCISVILLE, LLC / SN SERVICING CORP.
Mortgage Assistance Prograln
You may be eli;,ible for financial assistance which can save your home
from foreclosure and helo you make future morB, a~,e payments
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY liE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
1F YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL;
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, and
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
Temt~orary Stay of Foreclosure - Under the Act, you are entitled to a temporary stay of foreclosure on your
mortgage lbr thirty (30) days from the date of this Notice. During that time you must arrange and attend
a "lhce-to-lhce" meeting with one of the consumer credit cotmseling agencies listed at the end of this Notice.
TillS MEETING MUST OCCUR WITHIN TtlE NEXT THIRTY (30~ DAYS. IF YOU DO NOT APPLY
ISOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP T{.)
DATE. THE PART OF THIS NOTICE CALLED "l IOW TO CURE YOUR MORTGAGE DEI:AULT",
EXPLAINS ItOW TO BRING YOUR MORTGAGE UI:' TO DATE.
Consumer Credit Counselintz Aecncics- If you meet with one ol'the consumer credit counseling agencies
I-isted at the end ot'this Notice, the ender may NOT take act on against you for thirty (30) days after the date
of this meeting. The names, addresses and telephone numbers of desitmated consumer credit counselint,
w, encics for the count'/in which the t~roocrtv is located are set lbrth at the end of this Notice, It is only
n~:cessary to schedule one face-to-face meeting. Advise your lender im~ncdiatclyofyour intentions.
Application lbr Mort[,aue Assistance - Your mortgage is in delhult lbr the reasons set lbrth later in this
notice (see lbllowing pages lbr specific inlbnnation about the nature ol'your del'ault), l[you have tried and
are unable to resolve this problem with the lender, you have lhe right to apply lbr financial assistance l?om
the tlomeowner's Emergency Mortgage Assistance l~rogram. To do so, you must fill out, sign and file a
leted Homeowner's Emergency Assistance Progra n Applicat on with one of the designated consumer
Cr°~iPt counse n, a ,eric es I sted at the e ~d if this Not ce. Only consumer credit counseling agencies have
c · ' · · g-'g ,- .....-~ 'he" will assist you in submitting a complete application to the
appbcat~ons ~or me pr.ogra,, a.~, ,, j,, ' '. :' I',~1 ~:The iedornostnarkedwl~nthrty(30)
Pennsylvania Housing Finance Agency. Your appnca,lon ............. r -
days of your lace-to-lb, ce meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO
NOT FOLLOW THE OTHER TIME PERIODS SET FORTIt IN THIS LETTER, FORECLOSURE
MAY PROCEED AGAINST YOUR IIOME IMMEDIATELY AND YOUR APPLICATION FOR
MORTGAGE ASSISTANCE WILL BE DENIED.
Aoencv Action - Available funds lbr emergency inortgage assistance are very limited. They will be
~ssbur~;ed by thc Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision alter it receives your application. Dnring that time,
no foreclosure proceedings will be pursued against you if you have met the ti~ne requirements set forth
above. You will be notified directly by thc Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CIJRI~.ILNFI,Y PRf)TECTEI) BY '1'I IE Fn,IN( i ()F A PI~TITION IN BANKRUP I'CY, TI IE FOLLOWING
PART OF TI IlS Nt)'FI(_:E IS FOR INFf)It. MATION I'URPOSF~N. ONI,Y AND SI IOUI,D Nf)T BE CONSIDERED AS AN
ATTEMPT 'FO COLLECT A DEBT.
(If you have filed bankruptcy you can still apply lbr emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date)
NATURE OF TItE DEFAULT- The MORTGAGE debt held by the above lender on your property located
at: 420 West Main Street, Walnut Bottom, South Newton Township, Cumberland County, Pennsylvania,
17266, IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS lbr the tbllowing months and
thc tbllowing amounts arc now past due: December 15, 1999 through May 15, 2002.
Other charges (explain/itemize):
(29 months x $717.21= $20,799.09)
Late Charges
Escrow Advances
Returned Check Fee
Title Search
Per Diem Interest of $21.64/day
(from 5/I 5/02 to 5/24/02)
Attorneys Fees
$20,799.09
$ 933.91
$ 910.72
$ -0-
$ 150.00
$ 216.40
$ 50.00
TOTAL AMOUNT PAST DUE $23,060.12
YOU I IAVI'; FAILEI) TO TAKE TI IE FOI,LOWING ACTION (Do not use if not aoplicabl0:
N/A
HOW TO C~ THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date
of this uotice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$23.060.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's
check, certified check or money order made ~mvable aud scut to:
SN Servicing Corp.
51 Veronica Ave
Somerset, NJ 08873
You can cure any other default by taking the tbllowing action within THIRTY (30) DAYS of the date of
this letter: (Do not use il'not ap01icable)
N/A
IF YOU DO NOT CURE THE DEFAULT - Il'you do not cure the delhult within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This
means that the entire outstanding balance of this debt will be considered due immediately and you may lose
the chance to pay the mortgage in monthly instalhnents. If fi~ll payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON - Tile mortga~,ed pronerty will be sold by the Sheriff
to pay offthe mortga~,cd debt. If the lender refers your case to its attorneys, but you cure the delinquency
before thc lender beains Icaal proceedim,s aaainst you. you will still be required to pay tike reasonable
attorney's ii:es that were actually incurred, up to $50.00. I Iowevcr, if legal orocccdines arc started atzainst
you, you will have to pay all reasonable attorney's fccs actually incurred by thc lender even if they exceed
$50.00. Any attorney's t~ees will be added to thc amount you owe the lender,which may als° include °ther
reasonable costs. If you cure the default withiu thc THIRTY (30~ DAY period, you will not be
required to nay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue voa t~crsonallv for thc unoaid nrincipal balance
and all other sums due under the morteaee.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -If yOU have not cured the default
within the TIIIRTY (30) DAY period and lbreclosure proceedings have be~,un, you still have the ri~,ht to
cure the delhult and t>revent the sale at any time up to one hoar belbre the SherilFs Sale. You may do so
by paying the total ainount then past due. plus any late or other chames then due. reasonable attorney's l~:es
and costs connected with the lbreclosure sale. and any other costs connected with the Sherif'Fs Sale as
specified in writinu by tbe lender and by nerlbrming any other requirements under tike mortuage. Curiug
your default in the manuer set forth in this notice will restore your mort~,aee to the same nosition as
if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a SherilFs
Sale of the mortuaged property could be held would be approximately five ¢5) months from the date of
this Notice. A Notice pi'the actual date of thc SherilYs Sale will be sent to you bclbre thc sale. Of course.
the amount needed to cure the dcl'ault will increase the Iota, er you wait. You may lind out at any time
exactly what the required payment or action will be by contacting the lender.
.HOW TO CONTACT THE LENDER:
Name of the Lender: St. Francisvillc, LLC/SN Servicing Corp.
Address: 51 Veronica Avenue
Somerset, NJ 08873
Phone Number:
Fax Number:
Contact Person:
1-800-941-4670 x 2010
1-732-565-7910
Larry Gresack
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. Il' you continne to live in the property after the Sheriff's
Sale, a lawsuit to remove you and yonr li~rnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE - You may or Xmay not (CHECK ONE) sell or transfer
your home to a buyer or transferee who will assume the mortgage debt, provided that all 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 MAY ALSO }lAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT ttAVE THIS RIGHT
TO CURE YOUR DEFAULT MORE TIIAN THREE TIMES IN ANY CALENDAR YEAR).
TO ASSERT TIlE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER TIlE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY:
See Attached Exhibit
SENT CERTIFIED MAIL / RETURN RECEIPT REQUESTED: 7099 3400 0012 4306 0974
135 Edger Street. NW
S&lem, OR 97~4
P*O. Box 5727, Salem, OR. g7~04
Faro (SIS) ~II,AT~I
Box ~82, l~ndlcb3n, OR. 97801-0582
Whir~.h~l) PA 180~2-0235
EO. Box A, Whltch~, PA 18052-0253
l)hoM~ (SI0) 821-~010
Fux~ (610)
A.lb~fl J. l~d~,/~f/CEo .................................. Ex~.
Al~d P, ~d.m, ~ .................................................. EAt.
]v~u~:~l Iklan~ O~drd~ M'm,4~' ......................... gxt. 126
l~l~h r)m Ki~ll ~k'aibl Z)~ ......................... F,3d. 121'
48OO3-O0
CCC$ OF NORTHWF. STF-P..N
PENNSYLVANIA
~ PA 16509
47011-00
CCCS OF GRANTS PASS
!~114 NK ~.r Way
Orants ~ O1~ 975~
Pheno~ (81'1) l~64.0605
· rhcrc iJ no fcc f'~ cobmclin~ Thc fcc to omrt · D~ rtrq~=
l0 MIS, ..
~?009-00 ' ~f~O0$-O0
CCCS OF DELAWARE VALLEY
1515 Mm-kct Street. Sui&~ 1~28
Philadelphia, PA 19t 02
Phone~ (215) $63.S065
Appokmmoutm 1-800-989-2227
Fazt (215) 563-70~0
'-'CV~C~ Or NE~A CLJ~ ~UM
d8006-00
CC:CS OF NORTIIEASTER~
I~NNSYLVANIA ·
1400 Abingtofl Ex~utiw Pad~. Sulfa
Claflts ~ PA 18411
~.J UUO
Rkhaxd F~ust, Pm;dr~ .............................................. Eq, 512
(~ rdd W~x tad, Db~M Ea~ft/m ................................ Ex~. 31'/
Elizabt~ Olccnwood0 D~wM MIS ......................... · E~.
},f~y Bn:nu~, ~ C4m~ ............................... F, xL 313
Nicol~ F.~a~. M~/~4~n ~ ................................. E~t.
Tnb a~ency charge~ no fe~ f.~ budget coon~.iln$ d~b~ num-
qemcnt, ot homing couMel/n~
48OO5-00
CIGcS'OF ~VESTE~ PENNSYLVANIA*
SOO Smithficki Suget, SultZ 2000
Ftmlmr8~, PA 15222
Phono, ('/17)
Appolnbmrmtm 1-800-922-9557
(717) 342-510i
b I~0.
H~on-~S)
Milford-(5)
(412) 471-7584
(,i!2) ,~71.2638
j~ g. o.o~, ~
RmkW. Wfl~o~, FP
48007-00
CCCS OF (]]F.2VTI2A,L
439 Ean ~ S~oet.
Lancaster, PA 17602
l~)nm (717)
Fnt (717)
D. Michael W~av~t,
~lJ agency p~
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
9th JUDICIAL DISTRICT
COMMONWEALTH OF PENNSYLVANIA
MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, Inc. as nominee
h}r ST. FRANCISVlLLE, L.L.C.,
Plaintiff
V.
WILLIAM A. DOYLE and
PATRICIA A. DOYLE,
Defendants
NO. 02-5774 Civil Term
IN MORTGAGE FORECLOSURE
PRAECIPE TO REINSTATE COMPLAINT
TO TIqE PROTHONOTARY:
Kindly reinstate tine Complaint in the above-captioned matter. Thank you.
By:
Respectfully submitted,
WIESMETH & HARDY
ATTORNEYS AT LAW, P.C.
Jose~quire
Att~/'~' Pl',fmt iff'
Att/m~ey ID # 49796
91~ Main Street
Stroudsburg, PA 18360
(570) 424-2848
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2002-05774 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MORTGAGE ELECTRONIC REGISTRAT
VS
DOYLE WILLIAM A ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
DOYLE WILLIAM A
but was unable to locate Him
deputized the sheriff of YORK
in his bailiwick. He therefore
County, Pennsylvania, to
serve the within COMPLAINT - MORT FORE
On February 20th , 2003 , this office was in receipt of the
attached return from YORK
Sheriff's Costs:
Docketing
Out of County
Surcharge
Mileage
Dep York County
18.00
9.00
10.00
8.97
44.28
90.25
02/20/2003
WIESMETH & HARDY
R. [6mas
Sheriff of Cumberland County
Sworn and subscribed to before me
this ~g~ day of '~~
~0~ A.D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2002-05774 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MORTGAGE ELECTRONIC REGISTRAT
VS
DOYLE WILLIAM A ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
DOYLE PATRICIA A
but was unable to locate Her
deputized the sheriff of YORK
in his bailiwick. He therefore
County, Pennsylvania, to
serve the within COMPLAINT - MORT FORE
On February 20th , 2003 , this office was in receipt of the
attached return from YORK
Sheriff's Costs:
Docketing
Out of County
Surcharge
6.00
.00
10.00
.00
.00
16.00
02/20/2003
WIESMETH & HARDY
SO answer ; /~ ~ ........ 3
R/. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this 27 ~ day of ~~
~ ~,~/~ A.D.
P~thonot ary'
lof2
COUNTY OFYORK
OFFICE OF THE SHERIFF
28 EAST MARKET ST., YORK, PA 17401
SHERIFF SERVICE
PROCESS RECEIPT and AFFIDAVIT OF RETURN
1. PLAINTIFF/S/
Mortgage Electronic Registration Systems Inc
3. DEFENDANT/S/
Willaim A. Doyle et al
SERVICE CALL
(717) 771-9601
2. COURT NUMBER
4. T'(PE QF WRIT,OR CQM~LAINT.
re~ns~a~ea No~xce ~ Complaint
in Mortgaoe Foreclosure.
SERVE
AT
5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, A'FI'ACHED, OR SOLD.
Wi 11 iem A. Doyle
6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE)
500 Humper L~ne Di 11 .~burq, PA 17019
7. ,ND,CATESERV'CE: OPERSO"AL OPE.SO"'" CH^"GE OtSTCLASSMA'L OPOSTED OOT,ER
NOW J~u~ 21 ,20 03 I, SHERIFF OF ~ COUNt, PA, do hereby deputize the sheriff of
York COUN~ to execut~~ake return ~ccord, g
to law. This deputization being made at the request and risk of the~laintiff ~ ~;,*%~:~,~c". SHERIFF OF~COUN~ ~' ": ........ ~" '~¥ '~'~;~
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE:
ADVANCED FEE PAID BY ATTY
C~nberland
OUT OF COUNTY
CUMBERLAND
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same
without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff
herein for any loss, destruction, or removal of any property before sheriffs sale thereof.
9. TYPE NAME and ADDRESS of A'rrORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER I 11. DATE FILED
WIESMETH & HARDY 919 MAIN ST. STROUDSBURG, PA 18360 570-424-2848 I 1-21-03
12, SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed).
CUMBERLAND CO SHERIFF
13. I acknowledge mceipt of the writ R. ARHENS 114. DATE RECEIVED
or complaint as indicated above. I 1- 22- 03
16. HOWSERVED: PERSONAL( ) RESIDENCE( ) POSTED( ) POE( ) SHERIFF'S OFFICE ( ) OTHER( )
15. Expiration/Hearing Date
2-20-03
SEE REMARKS BELOW
17. 0 I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below,~
I~. NAJ,IIE,~,ND ]'I[LE OF INDI~JDU/~ SERVED / L ST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 1
~ATTEMPTSlDatelT[rn~[~nt. yate Time Milesl Int. IDate Time Miles Int. [Date Time Miles Int. IDate '1 ne ll~iles'lllnt. [Date ~TimelMiles-Int.
22. REMARKS:
23. Advance Costs
75.00
SO ANSWERS
17.28 40.28
24' Service C°st, 25' NIF18.00 5.00 ~26' Mileage 27. Postage ~al 29. Pound 30. NotarY4.00 I 31' Surchg* 32'T°t'C°sts 33*C°stsDue°~"°'44.28 30.7
40. Costs Due or Refund
41. AFFIRMED , ~"~;~
42.-~m of r' F~-AR1AL sEAL
· ' City of Yor~, ,~ "~,~i '~O, 2OO6~
' ~,~, C~ornmis?on E. xp)res ~P ...... --
'~F AUTHORIZED ISSUING AUTHO
44. Signature. of
~Dep. Sheriff
4~)Signature of York
~ County Sheriff
, WILLIAM M.
48. Signature of Foreign
? County Sheriff
IATURE
HOSE
45. DATE
47. DATE
2-13-03
49. DATE
51. DATE RECEIVED
1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Shedffs Office 4. BLUE - Sheriff's Office
L
2of2
COUNTY OF YORK
OFFICE OF THE SHERIFF
28 EAST MARKET ST., YORK, PA 17401
SHERIFF SERVICE
PROCESS RECEIPT and AFFIDAVIT OF RETURN
1. PLAINTIFF/S/
Mortaage Electronic Registration Systems Inc
3. DEFENDANT/S/
William A. Doyle et
SERVE
SERVICE CALL
(717) 771-9601
4. I~,PE qF V~R, IT,OR_ CO, MFLAINT
al reLns~ate~ NO~lCe & Ccrnplaint
in Mortgage Foreclosure
5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRI =ERTY TO BE LEVIED, ATTACHED, OR SOLD.
Patrici~ A. Doyle
ADC RESS [s'r~ EET C R ~ FO WITH. BOX NL/V BE R, A PT. ~ O, CITY, BORO, TVViP., ,S~TE AND Zip iff~DE) ~ '~ ~%, '"-. - I
PERSONAL ~ PERSON IN CHARGE X~ DEPUTIZE ~ O 1ST CLASS MAIL FI POSTED O OTHER
AT
7. INDICATE SERVICE:
NOW Janu~ 21 20 03 I, SHERIFF OF ~ COUNTY, PA, do hereby deputize the sheriff of
York '
COUNTY. to execute thinnerS.,~ return thereof:~rding
to law. This deputization being made at the request and risk of the plaintiff. -"<~:, ~ ......... .-';~' '
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: ~
OUT OF COUNTY
CUMBERLAND
ADVANCED FEE PAID BY ATTY
NOTE: ONLY APPLICARLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within wdt may leave same
without a watchman, in custody of whomever is found in possession, after notifijing person of levy or attachment, without liability on the par/of such deputy or the sheriff to any plaintiff
herein for any loss, destruction, or removal of any property before sheriff's sale thereof.
9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE
WEISMETH & HARDY [ 10' TELEPHONE NUMBER I 11, DATE FILED
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). 5 7 0-
424-2848 1-21 -03
CUMBERLAND CO SHERFF
13. I acknowledge receipt of the writ
or complaint as indicated above. R. AHRENS 14. DATE RECEIVED 15. Expiration/Hearing Date
16. ~.HOW SERVED: PERSONAL ()RESIDENCE()POSTED, POE()SHERiFF,S OFFICE (, 1- 2 2Oi~E3R () ~E"E2ROE~v~0A ~K S B E L OW
~~a~ ~ividual-~p~ny, etc. named abo~emarks below.)
18 ~~I~SS HERE IF NOT SHOWN ABOVE (Rela~e-o~-Service ~~ic___~
21'ATTEMPTSI[~;~~_~_ Date Time MilesI Int. JDateITimeJMilesl Int. IDateITimeIMilesl Int. JDateJTime MilesI Int. JDateITimelMilesl Int.
22. REMARKS: ' --- ' ' j ' ' ' ~ I I [ I I I / I I
41. AFFIRMED and subscribed to before me this,, ~. 3
42 da~"T ~'~ - ._....[J?[:~ ~...~.~---- ~44. Signature of
~ MELISc~l~vCfSy~c,~y~o~,~ (~tu~n~l~l'/~lOTAR' ~6. Signature ofYork
W . , . Coun~ Sheriff
~ ~y ~mmiss,on Exp,res Apml 2~, 2~ __.
-- I -- '~ / WILLIAM M.
/2~ ~ ~ '/ ~/~ // 48. S gnature of Foreign
~.IQ~~ ~/ '~ ~~~' Coun~Sheriff
· ~ ~ GE RECEIP~F TH~ERIF~S ~N~I~NATURE
~ AUTHORIZED ISSUING AUTHORI~ AND TITLE --
SO ANSWERS
45. DATE
47. DATE
2-13-03
49. DATE
HOSE
51. DATE RECEIVED
1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriffs Office
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
9th JUDICIAL DISTRICT
COMMONWEALTH OF PENNSYLVANIA
MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, lnc. as nominee
for ST. FRANCISVILLE, L.L.C.,
Plaintiff
WILLIAM A. DOYLE and
PATRICIA A. DOYLE,
Defendants
NO. 02-5774 Civil Term
IN MORTGAGE FORECLOSURE
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above-captioned matter. Thank you.
By:
Respectfully submitted,
WIESMETH & HARDY
ATTORNEYS AT LAW, P.C.
Jose '~S W'~iesm~eth Es
Attc~e~. for'Plaintit~f quire
Attorney ID # 49796
919 Main Street
Stroudsburg, PA 18360
(5701) 424-2848
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-05774 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MORTGAGE ELECTRONIC REGISTRAT
VS
DOYLE WILLIAM A ET AL
, Sheriff or Deputy Sher
DAWN KELL
Cumberland County,Pennsylvania, who being duly sworn a
says, the within COMPLAINT - MORT FORE was served
DOYLE PATRICIA A
ff of
cording to law,
, at 1400:00 HOURS, on the 24th day of
DEFENDANT
at 289 PLAZA DRIVE
BOILING SPRINGS, PA 17007
by handing tc
PATRICIA A DOYLE
a true and attested copy of COMPLAINT - MORT FORE
and at the same time directing Her attention to the c(
upon
the
March ,
Sheriff's Costs:
Docketing 18.00
Service 3.45
Affidavit .00
Surcharge 10.00
.00
31.45
together with
2003
>ntents thereof.
Sworn and Subscribed to before
me this ~ ~ day of
So Answers:
R. T~omas ~±ne
03125/2003
WIESMETH & HARDY
Deputy Sheriff
~m/~ ¢Z¢33 A.D.
/ ~rot~not ary
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
9th JUDICIAL DISTRICT
COMMONWEALTH OF PENNSYLVANIA
MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, Inc. as nominee
for ST. FRANCISVILLE, L.L.C.,
Plaintiff
WILLIAM A. DOYLE and
PATRICIA A. DOYLE,
Defendants
NO. 02-5774 Civil Term
IN MORTGAGE FORECLOSURE
IMPORTANT NOTICE
To.'
William A. Doyle
500 Mumper Lane
Dillsburg, PA 17019
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED
OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF
THIS NOTICE, A JUDGMENT MAY BE ENTERED AGA1NST YOU WITHOUT A HEARING AND
YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
9th JUDICIAL DISTRICT
COMMONWEALTH OF PENNSYLVANIA
MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, Inc. as nominee
for ST. FRANCISVILLE, L.L.C.,
Plaintiff
Ve
WILLIAM A. DOYLE and
PATRICIA A. DOYLE,
Defendants
NO. 02-5774 Civil Term
IN MORTGAGE FORECLOSURE
AFFIDAVIT OF SERVICE
I, Christine E. Munch, hereby certify that, pursuant to Court of Common Pleas of the 43rd Judicial
District of Monroe County, Commonwealth of Pennsylvania, Rules of Civil Procedure and/or Pa.R.C.P.
440, that of even date herewith, I sent a true and correct copy of the following document(s) to the
individual(s) and in the manner stated below: If service was made certified mail, return receipt requested,
proof of service is attached hereto.
Document(s)
Manner of Service
Individual(s) Served
Place of Service
10 Day Notice for Default Judgment
First Class Mail, Postage Prepaid
William A. Doyle
500 Mumper Lane
Dillsburg, PA 17019
This affidavit is made subject to the penalties of 18 Pa.C.S. Section 5905 relating to unswom
falsifications to authorities.
Date:
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
9th JUDICIAL DISTRICT
COMMONWEALTH OF PENNSYLVANIA
MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, Inc. as nominee
for ST. FRANCISVILLE, L.L.C.,
Plaintiff
Ve
WILLIAM A. DOYLE and
PATRICIA A. DOYLE,
Defendants
NO. 02-5774 Civil Term
IN MORTGAGE FORECLOSURE
IMPORTANT NOTICE
To.-
Patricia A. Doyle
289 Plaza Drive
Boiling Springs, PA 17007
YOU ARE 1N DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED
OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF
THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND
YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
9th JUDICIAL DISTRICT
COMMONWEALTH OF PENNSYLVANIA
MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, Inc. as nominee
for ST. FRANCISVILLE, L.L.C.,
Plaintiff
Ve
WILLIAM A. DOYLE and
PATRICIA A. DOYLE,
Defendants
NO. 02-5774 Civil Term
IN MORTGAGE FORECLOSURE
AFFIDAVIT OF SERVICE
1, Christine E. Munch, hereby certify that, pursuant to Court of Common Pleas of the 43rd Judicial
District of Monroe County, Commonwealth of Pennsylvania, Rules of Civil Procedure and/or Pa.R.C.P.
440, that of even date herewith, I sent a true and correct copy of the following document(s) to the
individual(s) and in the manner stated below: If service was made certified mail, return receipt requested,
proof of service is attached hereto.
Document(s) :
Manner of Service :
Individual(s) Served :
Place of Service :
10 Day Notice for Default Judgment
First Class Mail, Postage Prepaid
Patricia A. Doyle
289 Plaza Drive
Boiling Springs, PA 17007
This affidavit is made subject to the penalties of 18 Pa.C.S. Section 5905 relating to unsworn
Date:falsifications to authorities. 6///~/~'~ ~t~//~~.Oj_~
Christ~E~Munch, Leg'al Secretary
The last known address of Plaintiff is as follows:
51 Veronica Lane
Somerset, NJ 08873
WHEREFORE, Plaintiff demands judgment in rem against Defendants and the Premises in
the sum of $135,395.45, plus interest at the rate of $21.64 per day from November 18, 2002, together
with other costs and sums recoverable under the mortgage and for the foreclosure and judicial sale
of the Premises.
By:
Respectfully submitted,
WIESMETH & HARDY
ATTORNEYS AT LAW, P.C.
~°t~ ~ rPnheSy~ ;~. ne~f~Esquire
919 Main Street
Stroudsburg, PA 18360
I.D. # 49796
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
9th JUDICIAL DISTRICT
COMMONWEALTH OF PENNSYLVANIA
MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, Inc. as nominee
for ST. FRANCISVILLE, L.L.C.,
Plaintiff
WILLIAM A. DOYLE and
PATRICIA A. DOYLE,
Defendants
NO. 02-5774 Civil Term
IN MORTGAGE FORECLOSURE
AFFIDAVIT OF NON-MILITARY SERVICE
Sworn to and,~b_scribed before me this
o~g'l day of~ ,2003.
~:F6'~aryP~bl~-/-,~/"
Before me, the undersigned authority, personally appeared Joseph S. Wiesmeth, Esquire, who
being duly sworn according to law, deposes and says that he is the attorney of record for the within
Plaintiff; that as such he is duly authorized to make this Affidavit on its behalf; and that to the best
of his knowledge, information and belief, the within Defendants, William A. Doyle and Patricia A.
Doyle, are not in the military service of the United States of America.
Joseph S. _~ies~'eth,~Esquire
Attorney ~br Plaintiff