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HomeMy WebLinkAbout97-04434 ~ o II) ~ I ~I ~ . ~ I t' ' ~ \. ~ " 4: '') J /: )' ~ ") :>. ':t t:. 0.. ~ 1. Plaintiff is Conti Mortgage Co., with its principal offices at 500 Enterprise Rd., Horsham, PA 19044. 2. Defendant is Regina L. Robinson, with an address as set forth above. 3. On August 12, 1996 Regina L. Robinson executed and delivered a Mortgage upon premises hereinafter described to Alternative Lending Mortgage Corporation, which mortgage was recorded in the Department of Record at Cumberland County, Pennsylvania in Mortgage Book 1339, at page 1075 on September 5, 1996. 4. The said mortgage was assigned on August 12, 1996 to Conti Mortgage Co., said Assignment being recorded in Assignment of Mortgage Book No. 529, Page 983 on September 11, 1996. 5. The premises subject to said Mortgage are known as 353 W. Ridge St., Carlisle, PA 17013 and are more particularly described in Exhibit "A" attached hereto and incorporated herein by reference. 6. The Defendant is Regina L. Robinson the record and real owner of the said real estate subject to the Mortgage. Frank B. Robinson departed this life on the 31st day of October, 1989, whereby title to subject premises became vested in Regina L. Robinson, by right of survivorship. 7. The said Mortgage is in default by reason of the fact that the monthly installments of principal and interest a. due on January 16, 1997, and as due on the sixteenth day of each month thereafter are still due and owing and have not been paid; and by ;) ~ , the terms of the said Mortgage, upon failure to make such payments when due, the whole of the principal balance and all interest due thereon, together with late charges and other recoverable sums and attorney's fee are now due and payable forthwith. 8. The monthly installment payment composed of principal and interest due under the terms of said Mortgage and Mortgage Note for each such month was SIX HUNDRED TWENTY DOLLARS AND 39 CENTS ($620.39) . 9. The following amounts are therefore due and owing on said Mortgage: (a) Principal Debt (b) Late Charges at $31. 02 per month from 1/16/97 to 8/10/97 (c) Interest from 12/16/96 through 8/10/97 at $20.45 per diem $ 48,273.18 $ 217,14 (d) Total Escrow Deficit to date $ 4,846.65 $ 825.75 (e) Reasonable Attorney's fees as in the above stated amount reflect third party sale only. If the Mortgagor reinstates the account, attorney's fees will be reasonable based upon work performed. TOTAL AMOUNT DUE $ 2,413." $ 325.00 $ 115.50 $ $ $ 57.016.88 (f) Title Report (g) Court Filing Charge (h) Uncollected Late Chugels) Ii) Escrow Credit In addition, interest at the rate of $20.U per day on the unpaid principal balance will cOl'Itinue to acerue until the default 18 4 resolved. Any payments which are allowable under the mortgage document and are necessary to protect Plaintiff. relating to real estate taxes owed or which become due on the mortgaged property together with fire or homeowners insurance premiums necessary to protect the Plaintiff, or any reasonable costs necessary to protect the property from waste or vandalism shall also become due and owing by Defendant to Plaintiff when expended by Plaintiff. 10. Pursuant to the provisions of Act No. 6 of the Pennsylvania General Assembly dated January 30. 1974, as amended, a Notice of Intention to Foreclose Mortgage was mailed by Certified Mail. Return Receipt Requested to the Defendant at the aforesaid mortgaged premises. True and correct copies of said Notices are attached hereto and made a part hereof as Exhibit "S" and same are incorporated by reference herein as though here fully set forth at length. 11. Pursuant to the provisions of Act 91 of the Pennsylvania General Assembly dated December 13, 1983, "The Emergency Mortgage Relief Act,. notices in accordance with the Homeowners' Emergency Assistance Act of 1983 were mailed by regular 1st class mail to the Defendant at the aforesaid mortgaged premises. WHEREFORE, Plaintiff prays judgment against Defendant in the sum of $57,016.88 plua interest and late charges at the contract 5 Z 341 073 548 n I.AWOFnCIS )MROE, ii1NG & ASSOCIATES SUITE 1400 1700 MARKI:T STREET rllll.ADEI.PIIlA. PA 19103.3914 us POSI.11 S('f\'I[I' Receipt for Certflied-Mail No InSUldnc~ CO\lelago Prowit>d Do not use 10f Inlematlonal Mall See revelsP Sent.. SU'" NurMef (2 IS) 561-ll400 FAX NUMBER (21S) 561.5560 - --.-..--....-.....".., .. ~ I o.te Oetvered ~ __SIoml~-, :t 0..,"'_'_ I TOTAL P-' Foo. S :; -:) .;;t ~ _w_ 5/;)9/97 SUBURBAN OfFICE P.O. BOX 901 BRYN MAWR, PA 19010 May 28, 1997 Regina L. Robinson ~~~ W Ridge Street carliJle. PA 17013 RE. PROPERTY ADDRESS 353 W. Ridge Street Carlisle. PA 17013 HOTl:Cl!: OP nrrmrrrOH, TO PORBCLOSE MORTGAGE The MORTGAGE held by ~I MORTGAGE CO.. (hereafter we. us or ours). IS IN SERIOUS DEFAULT as a result of your failure to pay your mortgage payments for the months of 01/16/97 through OS/28/97. Late charges have also accrued to this date. The total amount now required to cure this default or. in other words. get caught up in your payments. as of the date of this letter. 1s set forth below: 01/16/97 through OS/28/97 payments at 620.39 each 01/16/97 through OS/28/97 late charges at 31.02 each $3101.95 $ 155.10 Accrued late charges prior to your default: $0 NSF Charges: $0 Lass partial payment received: $0 TOTAL AMOONT DUE TODAY: $3257.05 The daily interest per dielll on your loan i8 $20.45. ;ou tIUl)' alrt!l ~his dflfau1~ vi~hin "I'IItRTY 1301 tU.YS qf t.h. dA~iI!l of ~~~1:::~~~ ~Yi~ ~o us ~o ~hil!l ......\lnt. of U.2S7.0S. 91\18 any t: h vaVftNllln~. and lat:tt ~h.arqt'l tdti~h .y f.11 due durin9 t.his period, Such payments must be \Ilade either by cash, cashier.s check, certified check or money order, and made at: COMROE, HING & ASSOCIATES 1700 Market Street, Suite 1400 Philadelphia, PA 19103 If you do not cure the default ~:ithin THIRTY (30) DAYS, lrle. intend to exercise our riaht to accelerate the mortaaae payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit t.~ for@clost! your mortaa9@d cropertv. If th@ mortqA9~ ia foreclosed. your mortgaged property will be sold Qy the Sheriff to payoff the mortgage debt. If we refer your case to our attorneys, but you cure the default befo;-e they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable fees. If you cure the default within the thirty {30} day period. you will not be reqldred to pay At.t.orn@y feea~ We may also sue personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty (30) day period and foreclosure proceedings have begun, you still have th~ ri9ht to ~rl!! t:h@ d@f.l!lult Rnd prt!!vf!nt. t.h@ BAtt!! At. any t.illN! "9 t.o one Ii} hour b@fore t.hA gh~riff'R farecloRur@ Ball!!. You may do 80 by payinq t.hA t.ot.al .1N"1unt' t1f r:hfl! uflpaid mnnf"hly p"~nt:R ~1t1.11 .n~ lat.1!!!! or othfllT' ~l"llrvf!. th@n due _ AB Wt!11 as t:hll!! r"..nnabll!l attorney'. feAR and cn.t.. ~n~~t.ed wit.h t.h@ fnr@~lo.urft .alA ,.nA pf!rform any ot:hll!!r rt!qlJi.......t'NIlnt.1!I undf!!r t.hf! mnrtaaaf!!l. It 1. estimated that the earliest date that such a Sheriff's sale could be held would be approximately 12/03/". A notice of the date of the Sheriff aale will be sent to you before the aale. Of courae, the amount needed to cure the default will increa.e the longer you wait. You _y find out at any time exactly what the required payment will be by calling us at the following number: (:115) 5"- 0400. rhia pa}'lllef\t IIUst be in cash, cashier's check. certified check or money order and made payable to ua at the addre.. .tated PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Your mortgage is in serious default because you have failed to pay promptly, installments of principal and interest, as required for a period of at least sixty (60) days. The total amount of the delinque~cy is $3257.05. That sum includes the following: 01/16/97 through OS/28/97 payments at $620.39 each 01/16/97 through OS/28/97 late charges at 31.02 $ 3101.95 $ 155.10 Your mortgage is also in default for the following reason: YOU may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowner's Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of the Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. That meeting must occur in the next thirty ()O) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address and telephone number of our representative is: David 8. COllIroe, laquire 1100 Market Street, suite 1400 philadelphia, PA 19103 TELEPHONE NUMBER: (~15) 568-0400 The na_lsl and address{es} of lal designated consumer credit counseling agency(ies) is (are): SEE ATTACHED LIST. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance fund. In order to do this, you must fill out, sign and file a completed Homeowner's Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be filed or pOBtmarked within thirty (30) days of your face-to-face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street; P. O. Box 8029; Harrisburg, PA 17105. Telephone number is: (717) 780-3800 or 1-800-342-2397 (toll free number). An application for assistance may be obtained from this lender, from a consumer credit counseling agency, or directly from the Pennsylvania Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency has sixty (50) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time '. ..... , , I. Conti Mortgage Corporation vs Regina L. Robinson In the Court of Common Pleas of Cumberland County. Pennsylvania No. 97-4434 Civil Term Timothy Reitz. Deputy Sheriff. who being duly sworn according to law. says on January 6. 1998 at II :41 A.M. E. S. T.. he posted a copy of Real Estate Writ Notice Poster and Description at 353 West Ridge Street. Carlisle. Cumberland County. Pennsylvania according to law. Kenneth E. Gossert. Deputy Sheriff. who being duly sworn according to law. says on October 17.1997 at 3:25 P.M. E. D. S. T.. he served a copy true and allested copy of Real Estate Writ Notice and Description at 353 West Ridge Street. Carlisle. Cumberland County. Pennsylvania. according to law. David E. Mckinney, Deputy Sheriff. who being duly sworn according to law, says on October 17. 1997 at 3:25 P. M. E. D. S. T.. he served a true and attestcd copy of Reai Estate Writ Notice and Description upon the within named defendant to wit: Regina L. Robinson 353 West Ridge Street. Carlisle, Cumberland County, Pennsyivania. by handing to Kimberly Bowcnnaster, its contents and at the same lime handing to her personally the said true copies of the same. R. Thomas Kline. Sheriff. who being duly sworn according to law. says he mailed by regular maii a copy of Real Estate Writ Notice and Poster to Regina L. Robinson at 353 Ridge Street, Carlisle, Pennsyl\1IIIia. The letter was not returned to the office of the sheriff. 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 Court Uouse, Cariisle. Cumberland County. Pennsylvania. on March 4, 1998 at 10:00 o'clock A.M.E.S.T.. and sold the same to for tbe sum of S 1.00 to Attorney Scott Dietrich for Conti Mortgage Corporation, Its successors and a..~igns. It being the highest bid and best price received for the same Conti Mortgage Corporation, Its successors and assigns. Being the buyer in this Execution paid to SheriffR. Thomas Kline the sum ofS 1.633.21 it being the bid price and poundage etc. SheriIT's coslS listed below. SheriIT's Costs: Docketing Poundage I'osting Bills Advertising Acknowledging Deed Auctioneer lawlibrar} County Mlle. ('ertifi(d Mail I.e\}' Sllrt~ 1.01\\ .Iuurnal I'atriol N\:ws S~ of Rills U"trikltklll ,~f Prol.~ 30.00 32.02 15,00 15.00 30.00 10.00 .50 \.00 6,20 1.50 15.00 UX) 166.25 IfitSO ~SJI 2~\ln LAW OFFlCES COMROE. HING & ASSOCIATES SUITE 1400 1700 MARKET STREET PHlLADELPIUA. PA 19103-J914 (2Il) l6I4loo FAX NUMBER (2Il) l6l.ll60 DAVID B. COMROE GLENN F. H1NO ROBERT J. WILSON' SUBURBAN OFFlCE P.O. BOX 903 BRYN MAWR. PA 19010 OF COUNSEL REBECCA M LANDES . . ALSO MEMBER NJ. BAR W. Esther Napper 817 N. 16th St. HarriBburg, PA 17103 October 3, 1997 RE: Conti Mortgage Co. vs. Regina L. Robinson Docket No.: Term. No. 97-4434 civil Property Address: 353 W. Ridge St., Carlisle, PA 17013 NOTICE OF SALE OF REAL PROPERTY Dear Sir/Madam: Please be advised that the property and improvements, if any, as set forth above, will be sold by the Sheriff of CUMBERLAND County, in the Courthouse, at the Office of the Sheriff of CUMBERLAND County, S. Hanover Street. Carlisle, PA 17013, on March 4. 199B, at 10:00 a.m. This property and improvements, if any, is being sold pursuant to a Judgment entered in favor of Plaintiff and against Defendant in the Court of Common Pleas of CUMBERLAND County. The name of the owner. real owner and reputed owner of the aforesaid property is as set forth as the Defendant above. It has come to our attention that you might be a creditor to the Defendant named herein. Sheriff's Sale of the mortgaged property could adversely affect your interest if you are, in fact. a junior creditor herein. A Schedule of Distribution will be filed by the sheriff on a date specified by the Sheriff no later than thirty (30) days after said sale. and a di.tribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10l day. after the date said schedule. You should check with the Sheriff'. office by calling 117-2.0.6390 to determine the actual date of the filing of the .aid schedule. Qve~,tru ]UU' . (?.(l-L~_' , .r::' 041 LAWOmCES COMROE, HING & ASSOCIATES sum; 1400 1700 MARKET STREET PHILADELPHIA. PA 1910J.J914 (215) 5614100 FAX NUMBER (2Il) 561.5560 DAVID B. COMROE GLENN F. HlNO ROBERT J. WILSON' OF COUNSEL REBECCA M. LANDES . . ALSO MEMBER NJ. BAR SUBURBAN OFFlCE P.O. BOX 903 BRYN MAWR. PA 19010 Douglas C. McKillip 1416 Bradley Dr. Carlisle, PA 17013 October 3, 1997 RE: Conti Mortgage Co. vs. Regina L. Robinson Docket No.: Term, No. 97-4434 civil Property Address: 353 W. Ridge St.. Carlisle, PA 17013 NOTICE OF SALE OF REAL PROPERTY Dear Sir/Madam: Please be advised that the property and improvements. if any, as set forth above. will be sold by the Sheriff of CUMBERLAND County, in the Courthouse, at the Office of the Sheriff of CUMBERLAND County, S. Hanover Street, Carlisle. PA 17013, on March 4, 199B, at 10:00 a.m. This property and improvements. if any, is being sold pursuant to a Judgment entered in favor of Plaintiff and against Defendant in the Court of Common Pleas of CUMBERLAND County. The name of the owner, real owner and reputed owner of the aforesaid property is as set forth as the Defendant above. It has come to our attention that you might be a creditor to the Defendant named herein. Sheriff's Sale of the mortgaged property could adversely affect your interest if you are. in fact. a junior creditor herein. A Schedule of Distribution will be filed by the sheriff on a date specified by the Sheriff no later than thirty (30) day. after said sale. and a distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) day. after the date said schedule. You should cheek with the Sheriff's office by calling 717.~40.'390 to determine the actual date of the filing of the said schedule. ~ t~Y~., U~ /5. (?~.~-~ ~vid 8. C"0lIIf'04I - LAW OFFlCES COMROE, HING & ASSOCIATES sum; 1400 1700 MARKET STREET PHlLADELPIUA. PA 1910J.J914 (2Il) 5684100 FAX NUMBER (215) 561.5560 DAVID B. COMROE GLENN F. IUNO ROBERT J. WILSON' OF COUNSEL REBECCA M LANDES . . ALSO MEMBER NJ. BAR SUBURBAN OFFlCE P.O. BOX 90J BRYN MAWR. PA 19010 Samuel George Payne 1332 N. 15th St. Harrisburg, PA 17104 October 3, 1997 RE: Conti Mortgage Co. vs. Regina L. Robinson Docket No.: Term, No. 97-4434 civil Property Address: 353 W. Ridge St., Carlisle, PA 17013 NOTICE OF SALE OF REAL PROPERTY Dear Sir/Madam: Please be advised that the property and improvements, if any, as set forth above, will be sold by the Sheriff of CUMBERLAND County, in the Courthouse, at the Office of the Sheriff of CUMBERLAND County, S. Hanover Street. Carlisle, PA 17013. on March 4. 199B, at 10:00 a.m. This property and improvements. if any, is being sold pursuant to a Judgment entered in favor of Plaintiff and against Defendant in the COurt of Common Pleas of CUMBERLAND County. The name of the owner. real owner and reputed owner of the aforesaid property is as set forth as the Defendant above. It has come to our attention that you might be a creditor to the Defendant named herein. Sheriff's Sale of the mortgaged property could adversely affect your interest if you are, in fact, a junior creditor herein. A Schedule of Distribution will be filed by the sheriff on a date specified by the Sheriff no later than thirty (30l days after said sale. and a distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) day. after the date said schedule. You should check with the Sheriff'. office by calling 117-240-6390 to determine the actual date of the filing of the said schedule. ~~7l ~s. /J iJ ' 1:5. l~tb.,<.U' Dav i . \,,\'.)ll\r-oe ~ VI MAYBE USED '011 DOMESnC AND lNTtRNA nONA", MAil. DOli NO pOOVIOlFO.,NSUOANC.-.osr....sTtll Cont1-Rob1nsOl "tcetvtd From: David B. Comroe, EC2uire ~nOE. hu,u &: A:S3 rAl!! SUITE 1400 llWloWll\tllil~1 . . . ~ 10KlH1l14.;r-- ". '(~' \ ~ ~)~.. " '" .~." . ~.(, \ "'., ~r ....~.. .' .' OM _. of 0IdNty l'NiI eddrIt.Md to: 1332 N. 15th Street Harrisburg, PA 17104 PS Fonn 3817. MOt. 1989 ..:!f GpO I 1993 0 . .Sl ....Y.. USID _ DOMUTIC...... _~ -. ooa HOT __ _ _'OOCI-I'OITYASTIlI Cont1-1l0b1nson -- David Bc&:~j3mI~'~ SUI1t 1400 ,. ~alta~_._ ~~ 0... ... .. ...-wy ... ....... .: V.Eather Napper 117 N. 16th St. HarrisburR. PA 1710] PS,..... 3117. _. 111I ~ ..' David I, Coaroe, la,ulre 1:OIlIQ,.. , ~t'lOt'.11I .'" t~ ,Ita MMIIt II'lIIIIT 0. ....., ..... .... .......... ~ ~a1aa C. Melllll>> 14" Ir&.tley Or. Carll.la. PA 11Qll '" ,_ MH. 'lito< Il1ft "",,' , " '. " ~ , '. ~ \ I I , i "'ltIx",_ln_ , ..__lOll. _...............of' ~..curreMl .... " ," '. - I~;: .' \'i( .:'.. ,. ,\ \...... ..... '.t"o . , .. DO . ltt) CI . Ul-0Sl ;.-- .. .~.h .~ i !;y..... "~ \.'-- ..... At....". .,,",,--- ~ . ."1 CI . ,11>0'1 "......-..- .--.... _ _. ...... of , w,t.. .. ____ .... Comroe, Hing & Associates By: David B. Comroe Identification No. :25694 1700 11arket Street, Suite 1400 Philadelphia. PA 19103 215-568-0400 Attorney for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Conti Mortgage Co. 500 Enterprise Rd., Horsham, PA 19044, vs. Regina L. Robinson, 353 W. Ridge :ACTION OF MORTGAGE FORECLOSURE St., Carlisle, PA 17013, Term No. 97-4434 civil Defendant ::::: ::: ::: ::::::::::::::::::::::::::::::::: ::::::::::::::::::::: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Regina L. Robinson Your property at 353 W. Ridge St., Carlisle, PA 17013 in CUmberland County, pennsylvania is scheduled to be sold at Sheriff's Sale on March 4, 1998, at 10:00 a.m., in the Office of the Sheriff of CUMBERLAND County, S. Hanover Street, Carlisle, PA 17013, to enforce the Court Judgment of $ 58,183.42 obtained by Conti Mortgage Co. against you. . NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to Comroe, Hing & Associates, attorneys for the Plaintiff, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-568-0400 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the greater chance you will have of stopping the sale. (See notice below to find out 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 bid price by calling the Sheriff of CUmberland County at 717-240-6390. 2. Vou 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 the Sheriff of CUmberland County at 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. ~ .. . . REf\L ESlf\lE SJ\LE :lo~ @.... ~~W~i;':'; OR (n~t(,(... ~ It /I (7 the sheriillcvi~d upon Ihe d!:f:.~~;;:' , I) II IntGrastln the real proporty sillj;,[cd iilCAJ.t",,(rOl'~&: Cu,..,h.n."land Co' "I'J Pa L-nt\v - ...-,,: fil'........'."...... -l ~"':'. 44("'( ::.2: ,,1 A;; ~ r- .".....'tJI..f . <I.. } I ,,1\ ..m ;,':!;.. ....:......:~:. "'-0 .-'.~...;:~_!.~~.. ~ U rl\"-C"..J.l. nd m r 1"'0 d~'-'._;.,,'.!,....r& ~ E:-"-~;":'" I' '-'I ':'...,,'. a tiQ.e u;y :"~...tl,,;....... (1 ,i.: ...... I.. Lh'.... th!s Vlrlt and by thl:; rCiCfi:iliCe in:;:;rp.;ri:Lu i1~fCii1. ~: / (' ,j (,.. . 'r I Ell:44:-.i..!...J~;:L~ . . Rt . C [oJ r: (<- .t!..JJt:r; ~HiV"~- ,~n1d l&. Wilt 9 ~p~ . . ,... Ii'L " ,,, J-'l.J..tO (a) Principal Debt (b) Late Charges at $31.02 per month from 1/16/97 to 10/ 3/97 (c) Interest from 12/16/96 through 10/ 3/97 at $20.45 per diem (d) Total Escrow Deficit to date $ 4B,273.18 $ 279.18 $ 5,950.95 $ 825.75 (e) Reasonable Attorney's fees as in the above stated amount reflect third party sale only. If the Mortgagor reinstates the account, attorney's fees will be reasonable based upon work performed. (f) Title Report (g) Court Filing Charges (h) Uncollected Late Charge(s) (i) Escrow Credit $ 2,413.66 $ 325.00 <- $ 115.50 > $ $ TOTAL AMOUNT DUE $ 58,183.22 t 5 f. fJ P .7") - Respectfully submitted, COmroe, Hing , Associates B;;:V~~~ David B. Comroe____ Attorney for Plaintift Damages assessed as~ve this Ijd.. da Of( C~{., If 1 ~ (\, lell/~ (tMo.(r$,.I7,.. 0.-.( ",.rw.~' {..u. nUll If 11~ ;a . -~ "".- .~ ~ .... --' I .., , ~~-. - \:' ..- .t. LA W (Janns COMROE. I liNG & ASSOCIATES SIlITl' 1400 1700 MARI(I'T STRlTT PIIII.AUU.P1I1A. PA 1910J.J914 121l) 568.o.loo .-AX NUMRI'R C211) S68.11100 llA VIP 0. COMROE Glum F. lIINO ROBERT I WIL'iON . OF COUNSEL REBECCA M. LANDES . . AL<;O MEMBER N.J BAR SUBURBAN OFFlCE PO. BOX 90J BRYN MAWR. PA 19010 W. Esther Napper 817 N. 16th St. Harrisburg, PA 17103 October 3, 1997 RE: Conti Mortgage Co. vs. Regina L. Robinson Docket No.: Term, No. 97-4434 civil Property Address: 353 W. Ridge St., Carlisle, PA 17013 NOTICE OF SALE OF REAL PROPERTY Dear Sir/Madam: Please be advised that the property and improvements, if any, as set forth above, will be sold by the Sheriff of CUMBERLAND County, in the Courthouse, at the Office of the Sheriff of CUMBERLAND County, S. Hanover Street, Carlisle, PA 17013, on March 4, 1998, at 10:00 a.m. This property and improvements, if any, is being sold pursuant to a Judgment entered in favor of Plaintiff and against Defendant in the Court of Common Pleas of CUMBERLAND County. The name of the owner, real owner and reputed owner of the aforesaid property is as set forth as the Defendant above. It has come to our attention that you might be a creditor to the Defendant named herein. Sheriff's Sale of the mortgaged property could adversely affect your interest if you are, in fact, a junior creditor herein. A Schedule of Distribution will be filed by the sheriff on a date specified by the Sheriff no later than thirty (30) days after said sale, and a distribution will be made in accordance with the schedule unle8s exceptions are filed thereto within ten IIOl days after the date said schedule. You should check with the Sheriff's office by calling 117-2.0-6390 to determine the actual date of the filing of the said schedule. ~...." v.'er. y trull'-';)urs, "\ }.. ;/ j )~ : ./ '.' (r{n".A...,'-( Oa"fd . Comtce I.A W On'IClc~ COMROE, BING & ASSOCIATES SUITE 1400 1700 MARKH STREET P1111.ADI'I.P1I1A. P^ 19103.J914 11Il) 5614100 FAX NlJMlIl:R (215) S6R.5560 DAVID B. COMROE GLENN F. lUNG ROOERT J. \\1LSON . SlJBURBAN OmCE P.O. BOX 903 BRYN MAWR, PA 19010 OF COUNSEL REBECCA M LANDES . , ALSO MEMBER NJ. BAR Douglas C. McKillip 1416 Bradley Dr. Carlisle, PA 17013 October 3, 1997 RE: Conti Mortgage Co. vs. Regina L. Robinson Docket No.: Term, No. 97-4434 civil Property Address: 353 W. Ridge St., Carlisle, PA 17013 NOTICE OF SALE OF REAL PROPERTY Dear Sir/Madam: Please be advised that the property and improvements, if any, as set forth above, will be sold by the Sheriff of CUMBERLAND County, in the Courthouse, at the Office of the Sheriff of CUMBERLAND County, S. Hanover Street, Carlisle, PA 17013, on March 4, 1998, at 10:00 a.m. This property and improvements, if any, is being sold pursuant to a Judgment entered in favor of Plaintiff and against Defendant in the Court of Common Pleas of CUMBERLAND County. The name of the owner, real owner and reputed owner of the aforesaid property is as set forth as the Defendant above. It has come to our attention that you might be a creditor to the Defendant named herein. Sheriff's Sale of the mortgaged property could adversely affect your interest if you are, in fact, a junior creditor herein. A Schedule of Distribution will be filed by the sheriff on a date specified by the Sheriff no later than thirty (30l days after said sale, and a distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date said schedule. You should check with the Sheriff's office by calling 717-240-Q390 to determine the actual date of the filing of the said schedule. "-V~ry tru}y 0's, I) 1) · f / [< (/ ". ()L.~ ,J. .~~- David a. COlli roe I.A W m....'us COMROE, BING & ASSOCIATES SIJITE 1400 1700 MARKET STREET P1111.AIJIUII1A, PA 1910J.J914 (21515684100 FAX NUMBER (2151568.5560 DAVID B. COMROE GI.FNN F. 1111'10 ROBERT I. WILSON. SUBURBAN OFFICE P.O. BOX 903 BRYN MAWR. PA 19010 OF COUNSEL REBECCA M. LANDES ' . ALSO MEMBER NJ. BAR Samuel George Payne 1332 N. 15th St. Harrisburg, PA 17104 October 3, 1997 RE: Conti Mortgage Co. vs. Regina L. Robinson Docket No.: Term, No. 97-4434 civil Property Address: 353 W. Ridge St., Carlisle, PA 17013 NOTICE OF SAT.F. OF REAL PROPERTY Dear Sir/Madam: Please be advised that the property and improvements, if any, as set forth above, will be sold by the Sheriff of CUMBERLAND County, in the Courthouse, at the Office of the Sheriff of CUMBERLAND County, S. Hanover Street, Carlisle, PA 17013, on March 4, 199B, at 10:00 a.m. This property and improvements, if any. is being sold pursuant to a Judgment entered in favor of Plaintiff and against Defendant in the Court of Common Pleas of CUMBERLAND County. The name of the owner, real owner and reputed owner of the aforesaid property is as set forth as the Defendant above. It has come to our attention that you might be a creditor to the Defendant named herein. Sheriff's Sale of the mortgaged property could adversely affect your interest if you are, in fact, a junior creditor herein. A Schedule of Distribution will be filed by the sheriff on a date specified by the Sheriff no later than thirty (30) days after said sale, and a distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date said schedule. You should check with the Sheriff's office by callin9 711-240-6390 to determine the actual date of the filing of the said schedule. ,,~ tfUlY':'08. i )~: L/ t< (?B'A.~.~--- O.avid 11. C'QI!Iroe NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to Comroe, Hing & Associates, attorneys for the Plaintiff, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-568-0400 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the greater chance you will have of stopping the sale. (See notice below to find out 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 bid price by calling the Sheriff of Cumberland county at 717-240-6390. 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 the Sheriff of Cumberland county at 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. s. You have a right to remain in the property until the full amount due 18 paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring le9al proceedings to evict you. J - .~,~.~" r' "n r.~ , ~ ..... .~ " .,'.'. - c, ., ......; ") ;:, \() -. --