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1.
caption
is such
Plaintiff is the Corporation designated as such
on the preceding page. If Plaintiff is an assignee
by virtue of the following recorded assignments:
in the
then it
Assignor: Sovr.an Mortgage Company
Assignments of Record- to: Housing and Urban Development
Recording Date: 6/6/94 Book: 475 Page: 358
Assignor: Housing and Urban Developm~nt
Assignments of Record to: Ocwen Feaeral Bank, FSB
Recording Date: "LODGED FOR RECORDING" Book: Page:
2. Defendant(s) is the individual designated as such on the
preceding page, whose' last known address is as set forth in the
caption, and unless designated otherwise, is the real owner(s) and
mortgagor(s) of the premises being foreclosed.
3. On or about the dace appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant (s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g)
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 103 North Enola Drive
MUNICIPALITY/TOWNSHIP/BOROUGH: East Pennsboro
COUNTY: Cumberland
DATE EXECUTED: 8/13/90
DATE RECORDED: 8/23/90 BOOK: 988 PAGE: 469
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all ,!Urns
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After' demand, the Defendant (s) contimles to fail or
refuses to comply with the terms of the Note as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
10/3/97 :
Principal of debt due and unpaid
Interest at 10%
from 5/1/93 to 10/3/97
(the per diem interest accruing on
this debt is $13.64 and that sum
should be added each day after
10/3/97)
Title Report
Court Costs (anticipated, excluding
Sheriff's Sale costs)
Escrow Overdraft/ (Balance)
(The monthly escrow on this account
is $49.85 and that swn should
be added on the first of each
month after 10/3/97)
Late Charges
(monthly late charge of $19.52
should be added on the flfteenth of
each month after 10/3/97)
Pees Billed
Attorneys Fees (anticipated and actual
to 5% of principal)
TOTAL
.$49,120.67
21,735.91
250.00
280.00
1,874.45
1,015.04
479.50
2.456.03
$77,211.60
7. The attorney's fee set forth above are in conformity
with the mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sherif f' s
Sale. If the mortgage is reinstated prior to the sale, reasonable
attorney's fees will be charged in accordance with the reduction
provisions of Act 6, if applicable.
8. Notice of Intention to Foreclose under Act 6 of 1974
of the Commonwealth of Pennsylvania has been sent to each
Defendant, certified mail, in accordance with the requirements of
this letter, by paying to us the obove amount of $28,272.95, plus
any addi tional monthly paFments and late charges which may faU due
during this period. Such payment must be made either by cash,
cashier's check, certified check or money order, and made at
MARK J. UDREN, ESQUIRE
1700 SANSOM STREET - 6TH FLOOR
PHILADELPIIIA, PA 19103-6615
If you do not cure the default within THIRTY (30) DAYS, we intend
to exercise the ,lender's right to accelerate the mortgage 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 default is not made within THIRTY
(30) DAYS, the lender also intends to instruct our firm to start a
lawsuit to foreclose your mortgage property. If the mortgage is
foreclosed your mortgaged property will be sold by the Shedff or
ocher similar official Co payoff che morcgage debt. If you cure
the default before we 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 the lender, which may also include our reasonable
costs. If you cure the default wichin the THIRTY (30) DAY period
you will not be required to pay attorney's fees.
The lender may also sue you 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 the right to
cure the default and prevent the sale at any ~ime up to one hour
before the Sheriff's or other similar official foreclosure sale.
You may do so by paying the total amounc of the unpaid monthly
payments plus any late or other charges then due, as well as the
reasonable attorney's fees and costs connected with the foreclosure
sale and perform any other requirements under the mor:tga'le. It is
estimated that the earliest date that such a Sheriff's or other
similar official's sale could be held would be approximately six
months from the date of this letter. A notice of the date of the
Sheriff's or similar official sale will be sent to you before the
sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at arlY time exactly
what the required payment will be by calling us at the following
number: (215) 568-9500. This payment must be cash, cashier's
check. certified check or money order and made payable to us at the
''''
""
address stated above.
You should realize that a Sheriff's or other similar official sale
will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the
Sheriff's or other similar official sale, a lawsuit could be
started to evict you.
You shall have the right to assert in the foreclosure proceedings,
the non-existence of a default or any other defense that you may
have to acceleration or foreclosur.e.
You ha~e additional rights to help protect ynur interest in the
property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY
TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER
LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY ~~VE THE RIGHT
TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER
OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL
THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S fEES AND COSTS ARE
PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER
THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT
CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE
THIS DEFAULT 'CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
If you cure tbe default, tbe mortgage will be restored to tbe same
posi tion as if no defaul t had occurred. However, you are not
entitled to this right to cur.e your default more than three times
in any calendar year.
Very truly yours,
/~
MARK J. UOREN
MJU/tmr
cc: First Class Mail
" ,,'
LA W OFPlCES
MARK J. UDREN & ASSOCIATES
1700 SANSOM STREET. 6T11 FLOOR
PHILADELPHIA, PENNSYLVANIA 19103
21$.568. 9500
FAX: 215 . 568. 1/41
MARX I. UDREN'
STUMlT WINNEG
lAMES D, DEASY
'ADM/TrID AJ.J'o J,V /II, ",'VO'L
FREDDIE MAC
PENNSYL Y ANI A
DESIGNATED COUNSEL
TINA MARIE RICH
O,,,C, Ao.wIN/JTI<<TO~
NEW JIiR~RY OFFICI;'
/8/0 SI'RlNGDALE ROM!
CHERRY HILL, NI0800J
60P, 48P. 1710
60Y, 48P. 7720 r,Lf
October 17, 1997
CERTIFIED MAIL
RETURN REC~PT REQUESTED
ARTICLE # I' 3 ~~, -;' ~i-.Ij C;, ~/~
Kathleen Staley
103 N. Enola Drive
Enola, PA 17025
RE: Mortgage Loan dated 8/13/90
Dear Mortgagor:
The Mortgage held by Sovran Mortgage Corporation(hereinafter we, us
or ours) on YOllr property located at 103 N. Enola Drive, Enola PA
17025 IS IN SERIOUS DEFAULT because you have not made the monthly
payments of $488.00 for the months of 6/1/93 through 10/1/97.
NOTICE OF INTENTION TO FORECLOSURE MORTGAGE
The last assessed late charge on this aCCOunt was $19.52 at a late
charge rate of 4% for each delinquent payment (s). As of today,
late charges have accrued to the total amount of $.00. Other
charges ,including an escrow advance, satisfaction fee and quote fee
and fees billed have accrued at the total amount of $2,408.95. 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 is
$28,272.95.
You may cure this defaul t wi ~hin THIRTY (30) DAYS of the da te of
.1
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 (30) 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 this meeting.
The name, address and telephone of our representative is:
MARK J. UDREN, ESQUIRE
1700 SANSOM STREET - 6TH FLOOR
PHILADELPHIA, PA 19103
(215) 568-9500
The name Is) and addressles) of la) designated consumer
counseling agencylies) are included on the attached sheet.
only necessary to sch8dule one fdce-co-face meeting, You
advise this lender immediately of your intentions.
credit
It is
should
Your mortgage is in 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
delinquency is $28,272.95. That sum includes the following:
Monthly payments from 6/1/93 through 10/1/97, and late charges from
6/93 through 10/97 and other charges including escrow advance,
quote fee, satisfaction fee and fees billed have accrued at the
total amount of $2,408.95. The total now required to cure this
default, or in other words, get caught up in YOllr payments, as of
the date of this letter is $28,272.95.
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 Homeowners' Emergency Assistance Application with
one of the designated consumer credit counseling agencies listed on
the attached list. An application for assistance may only be
obtained from a consumer credit counseling agency. The consumer
credit counseling agency will assist you in filling our your
application and will submit your completed application to the
Pennsylvania Housing Finance Agency. Your application must be
filed or postmarked within thirty (30) days of your face-to-face
meeting.
It is extremely important that you file your application
,. "
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 mp.eting must occur in the next
thirty (30) days.
If you attend a face-to-face meeting with this lender, or with
a conRumer credit counseling agency identified in this Notice, no
further proceeding in mortgage foreclosure may take place for
thirty (30) days after the date of this meeting.
The name, address and telephone of our representative is:
MARK J. UDREN, ESQUIRE
1700 SANSOM STREET - 6TH FLOOR
PHILADELPHIA, PA 19103
(215) 568-9500
The namp.(s) and address (es) of (al designated consumer
counseling agency(iesl are included on the attached sheet,
only necessary to schedule one face-to-face meeting. You
advise this lender immediately of your intentions,
credit
It is
should
Your mortgage is in default because you have failed to pay
promptly installments of principal and interest, as required, for
a period of at least sixty (60) days. Tile total amount of the
delinquency is $28,272.95. That sum includes the following:
Monthly payments from 6/1/93 through 1011/97, and late charges from
6/93 through 10/97 and other charges including escrow advance,
quote fee, satisfaction fee and fees billed have accrued at the
total amount of $2,408.95. The total now required to cure this
default, or in other words, get caught up in your payments, as of
the date of this letter is $28,272.95.
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 Homemmer' s Emergency Mortgage
Assistance Fund. In order to do this, you must fill out, sign and
file a completed Homeowners' Emergency Assistance Application with
one of the designated consumer credit counseling agencies listed on
the attached list. An application for assistance may only be
obtained from a consumer credit counsel ing agency. The consumer
credit counseling agency will assist you in filling Ollr your
application and will submit your completed application to the
pennsyl vania Housing Finance Agency. Your appl.tcat ion must be
filed or postmarked within thirty (30) days of your face'to-face
meeting.
It is extremely important trlat YOtl file YO',IZ' appl icat.ion
. .
MARK J, UCii:W ,~, r,"~~CIATl!S
eTH FLOO~~~~6~i~HIA; PA 19103
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8TH FLOOR PHILADELPHIA. PA 19103
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SHEfl IFF' S IH-:TUIIN . HO'/' FOUND
CASE NO. 1997-0G85G P
COMMONWEALTH OF' PENNSYL.VANIA:
COUNTY OF CUMBERLAND
OCWE1L FEDERAL BANK F'ii!l___
VS.
JEFFREY E STALEY
~.iruL
, Sher1ff, who be1ng duly sworn according
to law, saya, that he made a diligent search and inquiry for the within
named defendant, to wit: STALEY M KATHLEEN
but was unable to locate Her
the COMPLAINT - MORT FORE
NOTICE
NOT FOUND . as to the within named defendant
~~EN
pEFT MOVED AND LEFT NO FORWARDING ADDRESS,
in his bailiwick. He therefore returns
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers:
6.00
.00
.00
2.00
;- '~ _ .'-"..1:-:.r'.f' _.
fr.-::"tno';ii~- Kl~ne,- ~he;1f;(
~'Qf MARK J. UDREN
12129/1997
Sworn and subscribed to before me
this J,9 -tt; day of _M..<LI."t.........
19_'21. A. D.
_()...u- f.' )k,;"C I ~r'~
~ I ..t..prcrrfluno ar..y
I
;.
Mark J. Udren, ESQUIRE
ATTY I.D. NO. 04302
MARK J. unREN & ASSOCIATES
1700 SANSOM STREET, 6TH FLOOR
PHILADELPHIA, PA 19103
(215) 568-9500
ATTORNEY FOR PLArNTIFF
We Hereby Certify The
WiI:lin To Bo A True And
Corroct Copy 01 Tho Original
Ocwen -~ederal Ban!<-, Fsa ...-.-..--.------
1675 P~lm Beach Lake Boulevard
West Palm Beach, FL 33401
COURT OF COMMON PLEAS'
CIVIL. DIVISION
PlaintiEE
v.
Curnberlard COUNTY
JeEErey E. Staley
M. Kathleen Staley
103 North Enola Drive
Enola, PA 17025
De' Eendant (eJ)
NO, Cft~l.,.~(, C/~'l'( kRJ>7
CO/1PLAINT [N MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT, tE you wish to deEend against the
claims set Eorth in the Eoll.owinq paqes. YOll must take actlon
within twenty (20) days aEter this Complaint and Notice are served,
by entering a written appearance p"rsonally Ot' by attonley and
Eilinq in writing with the Court your deEenses or objections to the
claims set Earth against YOll, You are warned that if you Eail to
do so t.he case mdY procr3ed wLt.hout you ,-uvl ..1 -judqm8nt. may be
entered ag;linst you by the Cm:rt without. furtrloOr not ice Eor any
money claimed in the Complaint or Ear any other claim or relieE
reque"lted by the Plaint,iEE. You may lose money Ot. property or
other rights important to you,
YOU SHOUI,D TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAV~ A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYERS REFERRAL SERVICE
Court Administrator
Cumberland Counti' Courthoust1
1 Courthouse Square
C2:rlisle, J?A 17013-3387
7[7-2'10 -6200
TRUE COpy FROM RECOR~nd
In T 31tl(i',';I\1' 'I,Mn~ol, l!lere o~o\r:. ~
~n(j \ne ,il'~l ,,1 ~',"!d Court at r 5 '~
"rhl~!~;dat\ OY~h?<;("
-~. P1othOnotaIV
.
AYl.s.Q
Le han demundado a usted en la corte. S1 usted quiere defenderse
de estas demundas expuestas en las pag1nas siguinetes, usted tiane
veinte (20) dias de plaza ai partir de la Eecha de la escrita 0 en
persona 0 con un abogado y entregar a la corte en forme escrita sus
defensas 0 sus o)ojections alas demanandas on c;ontra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
pueded continuer la domanda en contra suya sin previo aviso 0
notificacion. Ademas la corta puede decidir a favor del demandanto
y requiere que usted cumpla con todas las provisiones de esta
demanda. Usted puede perdar dinaro 0 sus propiedadas u 0 tros
derachos importances para usted.
LLEVE BSTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
o SI NO TIENE EL DINERO SUFICIENTE DE PAOAR TAL SERVICIO, VAYA EN
PERSONA 0 LLAME POR TELEFONE A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Court Administrator
Cumberland CQunty Courthouse
I Courthouse Square
Carlisle,I'A 17013,3387
717.2-10.6200
"
,
NOTICE
The Ulllount of your deht is us stuted in the uttuched document. The nume of the creditor
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to whom the debt is owed is us nUllled in the uttuched doculllent. lJnless you notify us within
30 duys ufter receipt of this Notice ~1I1l1 the uttuched docullIent thut the vulidity of thc stated
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debt, or ~lIIY portion of it, is disputed, we will assume that the debt is vulid. If you do notify
us in writing of a dispute within the 30 day period, we will obtain verificution of the debt or
a copy of a judgment against you, and mail it to you. Also, upon your written relluest within
the 30 day period, we will provide you with the name and address of the originul creditor if
different from the current creditor.
If you notify us in wril.ing within the 30 day period us stuted above, we will ceuse collection
of your dcbt, or uny disputed portion of it, ulltil wc obtain thc informution thut is required
and muil it to you, Oncc we huve mailcd to yuu thc required informatiun, we will the.1
continuc the collection of )'IHlr debt.
This Notice and the attachcd ducumcnt is un attempt to collect u debt, and auy inforlllutiun
obtained will be used for that purpose.
LAW OFFICES OF MARK .1. lJl>REN
Isl M:lI'k .1. Udren, Esquire
1700 Sansolll Street, 6th Floor
Philadelphia, P A 19103
(215) 5611-9500
I, PlaintlfE ls the Corporation deulgnated as such In the
caption on the preceding page. [f plaintlEE is an assignee than it
is such by virtue of th(~ folJ.owin'J r.!corded ,:"lfIi'Jrlm,qnt.s:
Ass ignor: Sov ran Mortgaqt' company
Assignments of Record' to: Housing and Urban Dave lopment
Re.r.ording Date: 6/6/94 Book: 475 Pag.o: 3'ifl
Assignor: Housing and Urban Development
Assignments oE R~cord to: Ocwen Federal Bank, FSB
Recording Date: "LODGED FOR RECORDING" 800k: Page:
2, Defendant(s) is the individual designated aB such on the
preceding page, whose' last known address is as set Eorth in the
caption, and unless d,;signated othel'wise, is the ('.Jeli owner (s) elnci
mortgagor(s) oE the premises being Eoreclosed,
3, On or about the date appeariwJ on t:ha MortcFlge
hereinaEter described. at the instanco and r:equ.;st of n,,,frondant (s) ,
plaintifE (Ot' its predecessor, hereinaftet' c~lll"d Plclint.UE) loaned
to the Detend,lllt (s) the sum appearing on IFlicl Mortgage,
which
Mortgage was executed and delivered to Plaintiff as BAcurity for
the inclebcednesn.
Said MO.':.t.g'::lqt:~ L~l Lrlcor:pot.,jt(~d here in by
reference in accordance with PeI.R.C,P, 1019 (g)
The inEormat~ion l"'lCJar.di.wJ t[v, ~knt'Ja'.I" oeiwJ t:()l',~,,::Loseci
tollows:
MORTGAGED PREMISES: 103 North Enola nrive
MUNICIPALITY/TOWNSEHP/ElOROUGH: East Pennsboro
COUNTY: Cumberland
DATE EXECUTED: 8/13/90
DATE RECORDED: 8/23/90 BOOK: 988 PAGE: 469
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as
The legal description oE the mortgaged premises is attached hereto
and made part hereoE,
4, Said r~o!:"tgaq'" i,J .in deEauLt. b,~caLlse the !:"equired payments
have not been made as set Eorth b,,~ low, and by its t.of!rms, upon
bt'each and falll.lr"~ [,0 ClI!:"of! said ot'each aftet' notice. all slims
secur,~c1 by said ~lol'tqa'Je, toqethet' with otfwr ch'ilrCfe,i authoriz,~d by
said Mortgagof! itemized below, shall be immediately clue,
5, AEte,r d",m:H1d. th., [)(!c,,[v:lant(:oJ) cont_l.n'!".!:'J to EaLi or
refuses to comply with th'l temls of th., Note .IS follows:
(a) by falllng Ot" refusing to P,lY th" lnstallm8nts of
princlpal and interest when riue in the amounts lndicated
below;
(b) by failing or: r..>tuslng to pay other: charges. if any,
indicated below.
6. The following amount,l at'e dw, on the saId Mortgage as of
10/3/97:
Principal of debt due and unpaid
Intet"est at 10%
from 5/1/93 to 10/3/97
(the per diem inter:est accr:ulng on
this debt is $13.64 and that Bum
should be added each day after
10/3/97)
Title Report
Court Costs (anticipated, excluding
Sher:iEf's Sale costsl
Escrow Over:draEt/(Balance)
(The monthLy escrow on this account
is $49.85 and that sum should
be added on the first of each
month after 10/3/971
L.ate Charges
(monthly late charge of ~19,5~
s~~uld be added on the flfteenth of
each month after: 10/3/971
Fees Billed
Attorneys Fees (anticipated and actual
to 5% of principal)
TOT AI,
,$49,120.67
21,735.91
250.00
280,00
1.87'1,45
1, r] 15,0,1
479,50
2.456,03
$77,211.60
7. The attorney's fee set forth above are in conformity
wit;h the mortgage documents and Pennsylvania Law, and wilL be
collected in the event of a thin! party pur:chaser at Sheriff's
Sale.
If the mor:tgage is re instated prior to the sale, r-.,asonab Le
attorney's fees will be char-gad in accordance with the r:eduction
provisions of Act 6, if appLicabL~.
8, Not lce ':If [nl;ention t,o ForecLos;, und',r- j\ct 6 of 1974
of the Commonwealth of Pennnylvanla has been Bent to each
Defendant, cI-Jr-t.LE.led mall, in .)cc0t'ddnc~~ 'IIith th':.~ t'~-!ql.li.r..';~m....~nt::J ot"
this letter, by paying to us the above amount of $28,272.95, pIllS
any addi dona I monthly paymen ts and la te charges which m<1Y fall due
during this pe.riod. Such payment. must be made either by cash,
cashier's check, certifi~d check or money order, and made at
MARK J. UDREN, ESQUIRE
170p SANSOM STREET - 6TH FLOOR
PHU,ADELPHIA, PA 19103-6615
If you do not cure the default within THIRTY (30) DAYS, we intend
to exercise the lender'S right to accelerate the mortgage 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 inscallmencs.
If full payment of the amount of default is not made within THIRTY
(30) DAYS, the lender also intends to instruct our firm to start a
lawsui t to foreclose your mortgage properey. If the mortgage is
foreclosed your mortgaged property w,ill be sold by the Shariff or
other similar o::ficial to pay o::f t.he mor'tga:]e debt, If you cure
the default before we begin legal proceedings against you. you will
still have to pay the reasonable attorney's fees accually incurred,
up to $50,00, Howevet', if legal proceedi.ngs are started against
you, you will have co pay the r'=iJsonable attorney's fees even if
they are over $ 5 0 . 00, Any at torn"y' s fees wi II be added to
whatever you owe the lender, which may also i~clude our reasonable
costs, If you cure che defaulc within che THIRTY 1]0) DAY period
you will noC be required co pay attorney's fees.
The lender may also sue you personally for the unpaid principal
balance and all other sums d~e under the mortgage.
IE you have not cured the default within r.he THIRTY (30) DAY period
and foreclosure proceedings have begun, you seill have the righc to
cure the defaul c and preven t Che sal e a c any ,time up co one hOll!'
befor.e the Sheriff's or ocher similar official foreclosure sale.
You may do so by paying the total amount of the unpaid monthly
paymencs plus any lace or other charges then due, as well as the
reasonable attorney's fees and costs connected with the foreclosure
sale and perfor.m any other requirements under the mortgage. It is
estimated that the earliest dat'i! that such a Sheriff's or other
similar official's sale could be held would be approximately six
months from the date of this letter. A notice of the date of the
Sheriff's or similar official sale will be sent to you before the
sale. Of course, t,he amount needed to cure the de faul. t wil.l
increase the longer.' you wait. You may fLnd out; at any time exactly
whac the requir.ed payment will be by calling us at the following
number: (215) 568'9500. This paym.,mt m'-lst be cash, cashier's
check, certified check or monoiJY ot-der and made payabie to us at the
address stated above.
You should realize that a Sheriff's or other similar. official sale
will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the
Sheriff's or other similar official sale, a lawsuit could be
started to evict you.
You shall have the right to assert in the foreclosure proceedings,
the non-existence of a default or any other defense that you may
have to acceleration or foreclosure.
You have additional rights to help protect your interest in the
property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY
TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW ~IONEY FROM ANOTHER
LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT
TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER
OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL
THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE
PAID PRIOR TO OR AT THE SALE. AND THAT THE OTHER REQUIRE~IENTS UNDER
THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE tINDER WHAT
CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE
THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
If you cure the default, the mortgage will be restored to the same
posi tion as if no defaul t had occurred. However, YOll are not
entitled to this right to cure your default more than three times
in any calendar year.
Very truly yours,
~Z----'
MARK J. UDREN
MJU/tmr
cc: First Class Mail
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 meet ing must occur in the next
thirty (30) 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 this meeting.
The name, address and telephone of our representative is:
MARK J. UDREN, ESQUIRE
1700 SANSOM STREET - 6TH FLOOR
PHILADELPHIA, PA 19103
(215) 568-9500
The name{s! and 3ddressles) of (a) d~sign;lted sanSllm~r
c'Junselina ag~2nc'l( L'::-:SI ,:\~.:':: lni:l1J(1--=dJ;-: th.~ ,.:\tr..;I-:h~d ~Jh...:;>:-"!,:.
only nece~sary t'.:J :;..::ii.~::::iu L._; ,:.Jt1.-.= tae".: - t,:..; -. ::l!'>': rn,-::~;",: J.n]. '{I.) '..1
advise this lend-:::r imm,:~d;.~1r:>~l'l ()f ,/'T..11:- i.nt~2ntlons.
ct"~d t
. ~
Sh'.Jl~ d
Your mortgage is in default because you have failed to pay
promptly installmenr;s '::Jf princi.pal and interest, as required, for
a period of at least sb:t:y (60) days, The total amount of the
delinquency is $28.272,95. That sum includes the following:
Monthly payments from 6/1/93 through 10/1/97. and late charges from
6/93 through 10/97 and other charges incll,ding escrow advance.
quote fee, satisfaction f~e and fees billed have accrued at the
total amount of $2,408.95. The total now required to cure this
default, or in other words, get caught up in your payments, as of
the date of this letter is $28,272.95.
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 Homeowners' Emergency Assistance Application with
one of the designated consumer credit counseling agencies listed on
the attached list. An applicat ion for assistance may only be
obtained from a consumer credit counseling agency. The consumer
credit -::ounseli.ng agency '"ill assist you in filling our your
al'plication and will submit your completed application to the
Pennsylvania Housing Pinance Agency. Your application must be
filed or postmarked wi.t.hin thirty (30) days of your face-to-facF.l
meeting.
It is extremeJ,y important that YOll tile your application
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 (30) 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 af.ter the date of this meeting.
The name, address and telephone of our representative is:
MARK J. UDRF.N, ESQUIRE
1700 SANSOM STREET - 6TH FLOOR
PHILADELPHIA, PA 19103
(215) 568-9500
The name(s) and addr~ss(~s) of (a) d~signat~,i consumer ct'edit
counseling agencylles) ,3r~ incLl:d~d on th~ actach~d she~t. It is
only necessary to sch0dule one face,co-Eace meecLng, You should
advise this lender immeJlat~ly of your intentions.
Your mortgage is in default because you have failed to pay
promptly installments of principal and interest, as t'equired, for
a period of at least sixty (60) days, The tocal amount of the
delinquency is $28,272.95, That sum includes the following:
Monthly payments from 6/1/93 through 10/1/97, and late charges from
6/93 through 10/97 and ether charges including escrow advance,
quote fee, satisfaction Eee and fees bille,d have accrued at the
total amount of $2,408.95. The total now required to cure this
default, or in other words. get caught up in you~ payments, as of
the date of this letter is $28.272,95,
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 Homeowners' Emergency Assistance Application with
one of the designated consumer credit counseling agencies listed on
the attached list. An application for assi.stance may only be
obtained from a consumer credit counseling agency. The consumer
credit counseling agency will assist you in filling our YOllr
application and will submit i'our completed application to the
Pennsylvania Housing Finance Agency. Your applicat,ion must be
filed or postmarked within thirty (30) da(5 of your face-to-face
meeting.
It is e..>{tremely important thdt you file YOUl' applic,nion
promptly. If you do not do so, or if YOll do not follow the other
time periods set forth in this lp.tter, foreclosure may proceed
against your home ,immediately.
Available funds for emergency mortgage assistance are very
limited. 1'hey will be disbl~rsed 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 Pennsylvania Housing Finance
Agency has sixty (60) days to make a decision after it receives
your application, During that addit ional time, no foreclosure
proceedings will be pursued against you if you have met the time
requirements set forth above, You will be notified directly by
that Agency of its decision on your application,
The Pennsylvania Housing !l.gency is located at 2101 North Front
Street, P.O. Box 8029, Harrisburg, PA l7105, Telephone No, 71.7-780-
3800 or 1-800'342-2397 (toll free numbet'), Persons with impaired
hearing can call (717) 780-1869,
In addition, you may ~ec~i'/~ ano~~l~~ notic~ tram this ofEic~
under Act 6 of 1974. That notlce is called a "Notice of Intention
to Foreclose". You must read both notices, since they both explain
rights that you now have under Pennsylvania law, However. if you
choose to exercise your rights described in this notice, we cannot
foreclose upon you during that time, Also, if you receive
financial assistance from the Pennsylvania Housing Finance Agency,
your home cannot be foreclosed upon while you are receiving that
assistance.
VerY,truly yours,
/;v----
MARK J. UDREN
MJU/er
Enclosure
cc: Certified Mail
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M 1700 SANSOM ST,
6TH FlOOR PHILADELPHIA, PA 19103
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1. Plaintiff is the Coq)(H'ation designated as such in the
caption on the preceding page.
rf Plaintiff is an assignee then it
is such by virtue of the following recorded assignments:
Assignor: Sovran Mortgage Company
Assignments of Record to: Housing and Urban Development
Recording Date: 6/6/94 Book: 475 Page: 358
Assignor: Housing and Urban Development
Assignments of Record to: Ocwen Federal Bank, FSB
Recording Date: "LODGED FOR RECORDING" Book: Page:
2. Defendant (s) is the individual designated as such on the
preceding page, whose' last known address is as set forth in the
caption, and unless designated otherwise, is the real owner(s) and
mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter. described, at the instance and request of Defendant (s) ,
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant (s) th'2 sum appearing on selid Mortgage,
which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgaqe is incorpot'ated herein by
reference in accordelnce with Pa.R.C,P. 1019 (g)
The information t'~~gard.Lng the r/!Ol"t']age b~~~ing Eut"~clo8ecl is as
follows:
MORTGAGED PREMISES: 103 North Enola Drive
MUNICIPALITY/TOWNSHIP/BOROUGH: East pennsboro
COUNTY: Cumberlan.d
DATE EXECUTED: 8/13/90
DATE RECORDED: 8/23/90 BOOK: 988 PAGE: 469
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said
Mortgage
made as
is in default because the required payments
set forth below, and by its terms, upon
have not been
breach and failure to cure said breach after notice, all sums
secured by said Mortgage. together with other char.ges authorized by
said Mortgag~ itemLzed below, shall be immediately due.
5. Aftar d",mancl, th., Defc-,ndant (s) cant i.nl.les to faLl or'
this letter, by paying to us the "bov~ amount of $28,272.95, plus
any addi tional monthly payments and 1.'1 te charges which may fall due
during this period. Such payment: must b.; made either by cash,
cashier's check, certified check or money order, and made at
MARK J. UDREN, ESQUIRE
1700 SANSOM STREET - 6TH FLOOR
PHILADELPHIA, PA 19103-6615
If you do not cure the default within THIRTY (30) DAYS, we intend
to exercise the lender's right to accelerate the mortgage payments.
ThlS 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 default is not made within THIRTY
(30) DAYS, the lender also intends to instruct our firm to seart: a
lawsuit co foreclose your moregage property. If ehe moregage is
foreclosed yoc:r moregaged properey will be sold by the Sheriff or
other similar offi~ial to payoff the mortgage debt, If you cure
the default before we begin legal proceedings against you, you will
still have to pay the reasonable attorney's fees actually incurred.
up to $50.00. Hm.,ever, if legal proceedings are starte.d against
you. you will have to pay the reasonable attorney's fees even if
they are over $50.00. Any attornAY's fees will be added to
whatever you owe the lender. which ma:; also include our reasonable
costs. If you cure the default withi."! the THIRTY (JO) DAY periocl
you will not be required co pay aeeorney's fees.
The lender may also sue you per.sonally 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 seill ha\'e ehe righe to
cure the defaul t and preven t ehe sale .'Ie anyeime up co one hour
before the Sheri ff' s or othel' similar official forec1.osure sal e.
You may do so by paying ehe total amoune of the unpaid monthly
payments plus any late or other charges then due, as well as the
reasonable aetorney's fees and costs conneceed wieh the foreclosure
sale and perform any ocher requirements under the mortgage. It is
estimated that the earliest date that such a Sheriff':3 or other
similar official's sale could be held would be approximately six
months from the date of this letter. A notice of the date oe the
Sheriff's or similar official sale wLll be sent to you before the
sale. Of cour.se, the amount needed to cure ::he default will
increase the longer you wait. You may find out at any time exactly
what the required payment. will be by calling us at the followi.ng
number: (215) 568-9500. ThLs payment must be cash, cashier's
check. certified check or money order and made payable to us at the
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
THE COMMONWEALTH OF PENNSYLVANIA'S
HOMEOWNERS EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
i\[.'\ Y BE ABLE TO HELP YOU,
READ THE FOLLOWI[\;G NOTICE TO FIND OUT
HOW THE PROGRAM WORKS
If you need more infomlatiol1 ~all the Pennsylvania
Housing Finance Agency at 1(1100) 342-.2397
LA NOTIFICATION EN ADJUNTO ES DE SUi'vlA IMPORTANCIA, PUES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CAS:\. SI NO
COMPRENDE EL CONTENIDO DE ESTA NOTlFICACION OBTENGA UNA
TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA
(pamSYL VANIA HOUSfNG FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA, PUEOES SER ELEGIBLE PARA UN
PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE
'SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR SU
HIPOTECA,
EXHIBrr
"8-
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L.\ IV On:ICES
LlylARK./. UDREN & ASSOCIATES
1700 SANSOM STREET, ~TH FLOOR
PHll.-lD/:"LPfIlA, PF:NNSYL V..INI.'\ /?/OJ
1li . 56,~ . 9500
F.,IX: 1/5 . 5~8 , 1/4/
FREDDIE M..IC
PENNSYL V..INIA
DESIGNATED COUNSEL
,If,IRK J UDRE.V .
STl/,tRT IVI'vI"w"EG
lUIES 0 DE.lSY
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FR.I.VK J. ,l/.IRTOSE pC,'
4 ORIGI/TON ROAD
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T/,V.\ ,\lARIE RICI/
Ul(tICt 1(J,'III.~I:Jr",1 Wit
UIPOP.TANT: NOTICE 0"' flONSQ\'~rE?S'
ENEP.GSNCY NORTG.'\.GE ASSISTANCE A(:T Of 1983
?LEASE READ THIS NOTICS. YOU ~l\,{ ES z:..rGIELi:: fOP.
FINANCIAL ASSISTt~.NCE TOWARD 'fOU~ NO?TGArJZ PAY(-.1ENTS
Octobe~ 17, 1997
TO: Kathleen Staley
103 ~f. Enal,a DrLI!e
Snola, ~..; 171)25
",RON: NA.''l.K J. UDREN. ESQ,
RE: Note & NOt"tgage dated 8/13/90
Nortgagee: Sovran MOt"tgage COt"po~ation
I?t"emisas: 103 N, Enola Dt"ive. Enola, Pi". 17925
Dear 80t"t"0'"et":
You may be eligible for financial assis~ance ~ha~ will preven~
foreclos~re on your mor~gage if you comply wi~h ~he provisions of
the Homeowners' Emergency Assis~ance Ac~ of 1983 (~he "Ac~"). You
may be eligible for &met"gency t~\porary assis~ance if your de~ault
has been caused by circumstances beyond you~' con~rol, and if you
meet the eligibility requiremen~s of the Act as de~ermined by the
Pennsylvania !lousing Finance Agency. "lease read all of ~his
Notice. It contains an explanation of your righ~s.
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Undai:' tha Act. you ,aJ:"~ ~ntL,.l~d to a tampot"at"Y stay of
Eorecl09ut"d on yout" mOt"tgaqe EOt" thiJ:"ty (JOI days Et"om the data oE
this Notic.~, O',I~Ln'3' chat tLme you must a~range and att.;!nd a cace-
ta..Ec:1c.e m~<9ti.ng wLth .:1 t"~SJr~3~nr':'"\tLv~ ot thiS lo:!nder, ot" with a
designated consumer credit counseling agency. The purpose of that
meeting is to attempt to wo~k out a ~epayment plan, or to otherwise
settle your delinquency. That meeting must occur in the next
thirty (30) 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 this meeting.
The name, address and telephone of our ~epresentative is:
MARK J. UDREN, ESQUIRE
1700 SANSOM STREET - 6TH FLOOR
PHILADELPHIA, PA 19103
(215) 558-9500
The name(s) and addresq,(~s} of la) d~~Lgnat~d conSllmer
counsalin') a';]~ncYI'.l'2;~;': J;::e l:1(:lu(j~~j ,'):-: r:h'~:1~:Jr.:h.~d dho::et.
only necessar.y :0 ;:j;.:::h':.',:iul..':: 'Jrk~ ta,>::-t':J-:,:1.f~,:: m-=~~:in'?,. ':.'r':::'~l
advise this lend~r imm~j:ately of ~.~I~r :n:~n:lons.
cr~-::i __
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Your mo~tgage is in default because you have failed to pay
promptly installments of principal and interest. as l'equired. for
a period of ac least sixty (601 d3Ys, The cocal amount of the
delinquency is $28.272,95. Thac sum includ'Js the following:
~Ionthly payments from 6/1/93 through 10/1/97, and late charges from
6/93 through 10/97 and ocher charges including escrow advance.
quote fee, sat is fact ion fee and fe<!ls billed ha'!e accr1.led at the
total amount of $2,408.95. The total now required co cure this
default, or in other words, get caught up in your payments. as of
the date of chis lecter is $28,272.95.
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 Homeowners' Emergency Assistance Application with
one of the designaced consumer credit counseling agencies listed on
the attached list. An application for assistance may only be
obtained from a consumer credit counseling agency. The consumer
credit counseling agency will assist you in filling our your
appl.ication and will submit you~ completed application to the
I?ennsyl vania Housing Finance Agency. Your application must be
filed 01' postmarked within thirty DO) days of you~ eace-to-face
meeting.
It ,i.s extrem'2ly i.mpol'tant that you fi le your application
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 (30) 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 this meeting.
The name, address and telephone of our representative is:
MARK J. UDREN, ESQUIRE
1700 SANSOM STREET - 6TH FLOOR
PHILADELPHIA, PA 19103
(215) 568-9500
The name Is) and addresslesl of (a) designated consumer
counseling agency(iesl are included on the attached sheet,
only necessary to sch,=dule on~ face-tcl-tac8 me'::t.ing. "\JU
,dvise this lender 1mmediately of your intentions,
credit
I t is
should
Your mortgage is in default because you have failed to pay
promptly installments of principal and interest, as required, for
a period of ~t least sixty (60) days, The total amount of the
delinquency 1S $28,272,95, That sum includes the follo'ling:
Monthly payments fr'om 6/1/93 through 10/1/97, and late charges from
6/93 through 10/97 and other charges including escrow advance,
quote fee, satisfaction fee and fees billed have accrued at the
total amount of $2,408.95. Tho:! total now required to cure this
default, or in other words, get caught up in your payments, as of
the date of this letter is $28,272,95.
If you have tried and are unable to resolve this problem at or
after your Eace-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 Homeowners' Emergency Assistance Application with
one of the designated consumer credit counseling agencies listed on
the attached list. An application for assistance may only be
obtained from a consumer. credit counseling agency. The consumer
credi.t counseling agency will assist you in filling our your
application and will submit your completed application to the
pennsyl vania Housing lFinance Agency. Your app 1 icat ion must be
filed or postmarked within thirty (30) days of your face-to-face
meeting.
It is extremely import'ant that you file your application
. ,
J ....'.'i ,', nJOCIATES
MP.Fl~ ~._,,-, 'r
'iiC03;';I:;'~M..) PA 19103
FLOOR ptUL)<DEI.PHIA,
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Mark J. Udren, Esquire, hereby states that he is the attorney
for the plaintiff, a corporation unless designated otherwise; that
he is authorized to take this Verification and does so because of
the exigencies regarding this matter, and because plaintiff must
verify t.lUch of the information through agents, and because he has
personal knowledge of some of the facts averred in the foregoing
pleadina; aad thar. the statements made in \:.h-:: foreg'1 ing pleading
are true and correct to the best of his knowledge, information and
belief and the source of his information is public.' recor.ds and
reports of plaintiff's agents.
The undersigned understands t.hat
this statement her"in is made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to
authoritie!l .
--~~
Mark J. ~dren, ESQUIRE
MARK J. UDREN & ASSOCIATES
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