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Home My WebLink About98-01590 I ~I I . I ~l <I I 't ...... ij ~I 1 I , I ~ ~ I I ~ ~ ~ I It ~ I . 'tl ~ ~ \ \ \ ! I I i ) I J / ,I )' ../i- \' ( '~ 7' .. .':l ~I () ~ "'! "I , , u..1 l\)-.I f I 'I ~I i I ,;' NOTIC.: The amount of your dellt is us sMed in the uttuehed document. The nllme of the creditor to whom the dellt is owed Is us nllmcd in thc IIttuchcd doculllcnt. lInlcss you notify us within ':40 dllYs ufter recclpt of' this Noticc 1I1l11 thc uttuchcd documcnt that thc \'alidity of the stuted deht, or any portion of it, is disputed, we willussume that thc deht Is valid. If you do nolif)' us in writing of II dispute within the 30 day pCI'iod, we will ohtuin verlfielltion of the debt or a copy of 0 judgmcnt agulnst you, and mail it to yon, Also, upon )'our writtcn rCI/uest within the 30 day period, we will pro\'lde you with the Illlme und Hddl'css of thc original ereditor If' diffcrent from the current crcditor. If you notify us iu writing within the 30 day period liS stilted above, we will eellse collcction of your dcht, or any disputed portion of it, until we ohtaln the information that is required and mllil it to you. Once wc have mailed to you the required informlltion, we will then continue the collection of your deht. This Notice and thc attllched document is aUllttempt to collect II debt, and any information ohtained will be used for that purpose, LA W OFFICES OF MARK J. UnREN Isl Mark J. Udren, Esquire /700 Sansom Street, 6th Floor Philade/phla, PA 19103 (2/5) 568-9500 1. eapt ion on 18 such by PlaIntIff iA the Corporation deAignated as such in the the preceding page. If PlaintJff in an iJssignee then it virtue of the following recorde1d ass:lgnments: AssIgnor: Parent Federal Savings Bank Assignl)1ents ot Record tc,: PNC Bank,~ Kentucky, lne, Recordlllg Date: 10/28/93 Book: 4!,1 Page: 834 2, Defendant (s) iE: 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) 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. 1.01.9 (g), The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: Lot. 23 Crossroads School Road a/k/a 385 Crossroads School Road MUNICIPALITY/TOWNSHIP/BOROUGH: West Pennsboro Township COUNT\~: Cumberland DATE EXECUTED: 4/1.0/90 DATE RECORDED: 4/1.1/90 BOOK: 972 PAGE: 770 The legal descript.ion 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 sums secured by said Mortgage, together wi th other charges authorized by said Mortgage itemized below, shall be immediately due. 5, After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of (b) principal and interest when due in the amounts indicated belowl by f,lil;l.ng or refusing to pay other charges, if any, indicated below, The following amounts are due on the said Mortgage as of 6, 3/9/98: Principal of debt dUB and unpaid Interest at 9,75% from 10/1/97 to 3/9/98 (the per diem interest accruing on this debt is $18,89 and that sum should be added each day after 3/9/98) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $116.13 and that sum should be added on the first of each month after 3/9/98) Late Charges (monthly late charge of $32,22 should be added on the fIfteenth of each month after 3/9/98) Attorneys Fees (anticipated and actual to 5% of principal) $70,700,36 3,022,40 250,00 280,00 (92,55) 161,10 TOTAL 3.535.02 $77,856,33 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 Sheriff'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 is not required as principal specified Act 91 of amount exceeds the sum of $50,000,00. the original The notice by the Homeowner's Emergency Mortgage Assistance Program, 1983, has been sent as required on the date appearing on the copy attached hereto as Exhibit "A", and Defendant (s) have failed to proceed within the ineligible, or Plaintiff has of Defendant(s) eligibility, WHEREFORE, the PJ.aintiff demands judgm~)llt, in rem, against the Defendant(s) herein in the sum of $'77,856,]3, pJ.us interest, cost.s and at torneys fees as more fully set forth ,j,n thl,'l Complaint, and for foreclosure and sale of the Mortgaged premises. time J.imits, or have not besn notified in bCisn determinl;ld a t.lmeJ.y mallner ~.A^---- Mark J, Udren, ESQUIRE MARK J, UDREN & ASSOCIA7'ES Attorney for Plaintiff Attorney I,D, No, 04302 ,"'1 ZZ110 ACT 91 NOTICE BS210-1 IMPORTANT: NOTICE OF HOMEOI'INERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY fiE ELIGIBJ"E FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR }'OME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGA<:E PAYMENTS JANUARY 12, 1998 JAMES A EVELHOCH NORMA SUE EVELHOCH 385 CROSS RD SCH RD NEWVILLE PA 17241 RE: LOAN NIIMBER: 803972 PROPERTY Ani IRESS: 385 CROSS RD SCH RD NEWVILLE PA 17241 YOU MAY BE ELIGIBl,E; FOR FINANCIAL ASSISTANCE THAT Wn,L PREVENT FORECLOSURE ON YOUR MORTGAGE IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"). YOU MAY BE ELIGIBLE FOR EMERGENCY TEMPORARY ASSISTANCE IF YOUR DE~'AULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, YOU HAVE A REASONABLE PROSPECT OF RESUMING YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYINANIA HOUSING FINANCE AGENCY. PLEASE READ ALL OF THIS NOTICE. IT CONTAINS AN EXPLANATION OF YOUR. RIGHTS, UNDER THE AC'f, YOU ARE ENTITLED TO A TEMPORARY STAY OF FORECLOSURE ON YOUR M(IR'I'GAGE FOR THIRTY (30) DAYS FI<:UM THE DATE OF THIS NOTICE. DURING THAT TIME YOU MUST ARRANGE AND ATTEND A "FACE-TO-FACE" MEETING WITH A REPRESENTATIVE OF THIS LENDER, OR WITH A DESIGNATED CONSUMER CREDIT COUNSEl,ING AGENCY. THE PURPOSE OF THIS MEETING IS TO A'I'TEMPT 1'0 WORK OUT A REPAYMENT PLAN, OR TO OTHERWISE SETTLE YOUR DELINQUENCY. THIS MEETING MUST OCCUR IN THE NEXT (30) DAYS. IF YOU ATTEND A FACE-TO-FACE MEETING WITH THIS LENDER, OR WITH A CONSUMER CREDIT COUNSEJ.ING AGENCY IDENTIFIED IN THIS NOTICE, NO FURTHER PROCEEDING IN MORTGAGE FORECLOSURE MAY TAKE PLACE P'OR (30) DAYS AFTER THE DATE OF THIS MEETING. THE ADDRESS AND TELEPHONE NUMBER OF YOUR REPRESENTATIVE IS: PNC MORTGAGE, 539 SOUTH FOUR'fH AVf.NUE, LOUISVILLE, KY 40202 TOLL FREE (800)736-9090 THE NAMES AND ADDRESSES OF DESIGNA'I'ED CONSUMER CREDIT COUNSELING AGENCIES ARE SHOWN ON 'fHE ATTACHED SHEET. IT] S ONLY NECESSARY TO SCHEDULE ONE FACE-TO-FACE MEETING, YOU SHOULD ADVISE THIS LENDER IMMEDIATELY OF YOUR IN'fENTIONS , YOUR MORTGAGE IS IN DEFAULT BECAUSE YOU HAVE FAILED TO PAY PROMPTLY INSTALl,MENTS OF PRINCIPAL AND INTEREST/AS Rb~QUIRED, FOR A PERIOD OF AT LEAST SIXTY (60) DAYS. 'I'HE TOTAL AMOFNT OF THE DELINQUENCY IS 2,378.16. 'J'IlAT SUM INCLUDES THi~ FOLLOWING: . . . . . . PAYMENT AMOUNT PAYMENTS NOW DUE LATE CHARGES RETURN CHECK CHARGE OTHER FEES LESS UNAPPLIED FUNDS 760.50 3 96.66 .00 .00 .00 EXHIeIT IAI ,- BS210-2 IF YOU HAVE TRIED AND ARE UNABLE '1'0 RESOLVE THIS PROBLEM AT OR AFTER YOUR FACE-TO-FACE MEETING, YOU HAVE 'I'HE RIGH'I' TO APPLY FOR FINANCIAL, ASSIST- ANCE FROM THE HOMEOWNERS' EMrmGENCY MORTGAGE ASS I STANCE I~UND, IN ORDER TO DO 'I'HIS, YOU MUST FH,L OU'I', SIGN AND FILE A COMPLETED HOMEOWNERS' F.MERGENCY ASSISTANCE APPLICA'I'ION WI'I'H ONE OF THE DESWNA'I'ED CONSUMER CREDIT COUNSEL.ING AGENCIES I.,ISTED ON THE A'I"I'ACHMENT, AN APPIJICA'I'ION FOR ASSISTANCE MAY ONLY BE OBTAINED FROM A CONSUMER CREDIT COUNSELING AGENCY, 'rHE CONSUMER CREDIT COllNSEl,ING AGENCY WILL, ASSIST YOU IN FILLING OUT YOUR APPl,ICATION AND WII,L SlIBMIT YOUR COMPLETED APPLICATION TO THE PENNSYLVANIA HOUSING FINANCE AGENCY. YOUR APPLICATION MUST BE FILED OR POSTMARKED, WITHIN 'I'HIR'I'Y (30) DAYS OF YOIIR FACE-TO-FACE MEE'rlNG, I'l' IS EXTRE~IELY IMPORTANT THAT YOU FILE YOUR APPLICATION PR.OMPTLY, IF YOU DO NOT DO SO, OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PR.OCEED AGAINST YOUR HOME IMMEDIATELY, AVAIl~BLE FUNDS FOR EMERGENCY MORTGAGE ASSISTANCE ARE VERY LIMITED. THEY WILL BE DISBURSED BY 'I'HE AGENCY UNDER 'I'HE ELIGIBILITY CRITERIA ESTABLISHED BY THE ACT, IT IS EXTREMEI,Y IMPORTANT 'I'HAT YOUR APP1"ICATION IS ACCURATE AND COMPI,ETE IN EVERY RESPECT. THE PENNSYLVANIA HOUSING FINANCE AGENCY HAS SIXTY (60) 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 REQUIREMENTS SET FORTH ABOVE. YOU WILL BE NOTIFIED DIRECTLY BY 'I'HAT AGENCY OF ITS DECISION ON YOUR APPLICATION. THE PENNSYLVANIA HOUSING FINANCE AGENCY IS LOCATED AT 2101 NORTH FRONT STREET, POST OFF'ICE BOX 8029, HARRISBURG, PENNSYLVANI.l'\ 17105. TELEPHONE NO. (717-780-3800 OR 1'800-342-2397), PERSONS WITH IMPAIRED HEARING CAN CALL (717) 780-1869. IN ADDITION YOU MAY RECEIVE ANOTHER NOTICE FROM THIS LENDER UNDER ACT 6 OF 1974, THAT NOTICE IS CALLED A "NOTICE OF INTEN'I'ION TO FORECLOSURE". YOU MUST READ BOTH NOTiCES, SINCE THEY BOTH EXPLAIN RIGHTS THAT YOU NOW HAVE t1NDER PENNSYLVANIA LAW. HOWEVER, IF YOU CHOOSE TO EXERCISE YOUR RIGHTS DESCRIBED IN THIS NOTICE, YOU CANNOT BE FORECLOSED UPON WHILE YOU ARE RECEIVING THAT ASSISTANCE. VERY TRULY YOURS, PNC MORTGAGE CORP OF AMERICA CUSTOMER SERVICE DEPAR'l'MEN'I' COPY VIA U.S. POSTAL SERVICE "FEDERAL LAW REQUIRES THA'I' WE NOTIF'Y YOU THAT THIS IS AN AT'I'EMPT '1'0 COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE" B8206 I I I~ i'i; CI'I f' ....~ (:i ~;;2 ~IJ .,. ~~ (,,) ..i... ftr,t: .....1; ( )Ie' 6" ..:r " ,) t i~ /'L ('.J G: l~ 1 (" r: ." :It; b 0;> C1' .~ f;. ~:) i I; ('\"'. -'j:"; 'I'(? . i Ifi} "0__. ;~ L'j i) ~~~ r ~ ~ "*' ~~~ ~ ~ ,~ ~~~ Q3 ~~ ~ ir: 0\ ::- ~- ,;I' ..:J I,:,; I..' !;,~ .,. ~q \ ..,- , S #~. ';:tl,;':': & ~ ~~. j .,J.. \.J', ~,;T fl(J; , >; ~ ~ ).-. I i t'-... G '"' _~t' ( ~ )C,-__ -J'-" N f ",: '-.'.::t ~ "'0 fl.:'" ~I.I ('., 1':111 '~ ' .. I.. "":, "0. J. 2e t5 0:' ;:i ~ ~~~ CT> (.) , SHtRIFF'S RETURN - R~GULAR CASE NO. 1998,,01590 P COKKONWEALTH OF PENNSYLVANIA. COUNTY OF CUKBERLAND PNC BANK N It ETC VS. EVELIfOCH JAKES A JR ET AL DAWN L. KELL CUKBERLAND County, Pennsylvania, who to law, .ay., the within ~OKPLAINT - upon EVELHOCH JAKES A JR defendant, at 1353,U HOURS, on the ~, day of nArch 19~ at . 385 CROSSROADS SCHOOL ROAD NEWVILLE. PI. 17241 County, Penn.ylvania, by handing to JAKES EVELHOCH a true ond attested copy of the COKPLAINT - KORT FORE together with NOTICE and st the ..me time directing HiI attention to the contents thereof. . Sheriff or Deputy Sheriff of being duly sworn according KORT fORE .8. .erved the . CUKBERLAND -' .I Sheriff'. Co.ts, Docketing Servic.. Affidavit Surcharge 18.00 5.58 .00 6.00 So answer., ,/, d~ -~C.-) // i J~'rI~ _ ~ ~Thoma. KIlne, ~h.riff .29.~a KARK J. UDREN 03/30/1998 by ~o..(.\.rn ;t. ~ Oltputy Sher 1:1: Sworn and .ubscribed to before me ,to "'. this -3 {I .-- day of' U''-'-' '-',~ 19__2L A. D. ~ /1 h. ,,; ~ 4= u....~u._ 4.. / rLLL!J.L..... A 'I f Pf'othonotary