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Home My WebLink About98-04540 \ )1 i\ ~~ ! ...... ...... , ~ ~ . ~ \.:) ~ ... U : (;j .. "~ II 1).,., It. ~I I.. 'I (;I' ~' ~ ~ .., ~ t '> ~ ~ .:> ~ ~ o ::r \-1 ::r , , 0.' cr- Mortgage Book Record Book 954 page 47, secured on premises 1050 West Willow street, Coal TWp., FA 17866, a true and correct description of which is attached hereto as Exhibit I. 4. On December 13, 1996, Corestates Bank, N.A., Successor by Merger to Commonwealth Bank, a division of Meridian Bank assigned the said mortgage to Eastern Mortgage services Inc., the plaintiff herein, by written assignment which is recorded in the Office of the recorder of Deeds of Northumberland county in Record Book 1091 page 459. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that the defendants, mortgagors and real owners have failed to make payment of the monthly installments of principal and interest,in accordance with the terms of the mortgage, for the month of December, 1996 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon ,are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: principal Interest from 11/01/96 to 07/20/98 at $ 5.61 p/d Accrued late charges from 12/15/96 to 07/15/98 $ 27,316.36 $ 3,517.47 $ 156.60 Accrued escrow deficit (taxes and insurance) from 12/01/96 to 07/01/90 Montbly inspections from 12/01/96 to 07/01/90 at $0.00 Reasonable attorney's fee Title information certificate Pbotostats and postage Notarizations Total $ 209.07 $ 160.00 $ 1,400.00 $ 335.00 $ 35.00 $ 10.00 $ 33,220.30 9. Plaintiff sent to defendants, mortgagors and real owners a Notice of Warning of Intention to Foreclose dated April 27, 1998 by certified mail and also by regular mail (copies attached hereto as Exhibit II). To date, defendants have not made payment as required. 10. Plaintiff sent to defendants Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising them of their rights under the statute (copies attached as Exhibit III). To date defendants have neither made payment nor indicated that they have taken any steps to avail themselves of the financial assistance made available through this legislation within the time established by this statute. WHEREFORE, plaintiff demands judgment for $33,220.30, plus per diem interest at $5.61 from 07/21/98 to the date of judgment, plus monthly late charges of $7.83 from 08/15/98 to the date of judgment, plus monthly inspection charges of $8.00 from 08/01/98 ,to date of judgment and escrow advances of $8.49 pe~ month from 08/01/98 to the date of judgment, foreclosure mortgaged premises plus costs thereon. Martha E. Von Rosen tiel Attorney for Plaintiff . .. . 1833644630, Our File #6130AB STATE OF ~(./ COUNTY OF OR.'.IlCE (../J;o}(.4.J ':10- {/'Vv- AFFIDAVIT SS LARRY Fry . of full age, being duly sworn according to law deposes and says that he is th~~Vice President of Eastern Mortgage Services Inc., plaintiff herein; that he is duly --r;..- authorized to take this affidavit on behalf of the plaintiff; that he is fully familiar with the facts in this matter; that he has read the foregoing Complaint in Mortgage Foreclosure, and that the facts contained therein are true and correct to the best of his knowledge, information and belief. ~c:' Larry Fry Sr. Vice Pres~dent Eastern Capital Markets Sworn to and Subscribed Before me this ,3 day Of f\\J C ('\ , 19 8 , Notary Public ,~ Notarial Seal Lawrence R, Kintner. Notary Public Manheim Twp.. Lancastor County My Commission Expires Jan, 9, 1999 Member, Pennsylvania Association of Notaries ACT '.II NOTICE IMI'OItL\NT: NOTICE OJlIIOi\lEOWNEI{S' EMEIH;ENCY MOI{T(;A(a: ,\SSISTANCE l'IUlGItAM I'I.EASE I{EAI) TillS NOTICE. yOU MA Y III~ EI.lGIIIJ.E JlOI{ FINANCIAL ASSISTANCE WIII<:II C,\N SA VE YOIlI{ 1I01\U: 1,'ltOl\I FOIU:CI.OSUnE ANI) IIELI' YOU MAKE JlIITlJIU; I\IOlrrGAGE \',\ YMENTS You l\1ay bc eligiblc IiII' lillallcial assistancc that will prevcnt Ihrt:closurt: on your llIollgagc if you cOl\1ply with thc provisiolls of thc 1101llt:owners' Emergency Mortgagc Assistancc ActoI' IlJMJ (the "Act"), Youl\1ay be eligiblc lur t:lIIergency tClllporary assistancc if your dclaolt has bccn causcd by circumstanccs bcyond your control, you havt: a rcasonablc prospcctof resuming yuur mortgagc paYlllcnts, and if yuu llIeet other eligibilily rcquirements cstablishcd by the Pcnnsylvania I lousing Finance Agcncy, Plt:ase read all of this Noticc, It cuntains im cxplanation ufyuur rigbts, Undcr thc Act, you arc cntitlcd tu a tClllpurary stay uf lurcclosure 011 your mortgage for thirty (.10) days Ihlln the datc of this Nllticc, Dllring tbat timc you must arrange and attend a "Iacc-tu-nlcc" meeting with a rcpresenlative of this lender, or with a designated consumer crcdit counseling agency, Thc purposc of this mceting is to attempt to work out a repayment plan, or to otherwise settle your delinquency, This meeting must occur in the next (30) days, If you attend a lacc-to-thce meeting with this lender, or with a consumer credit counseling agency identitied inlhis notice, no furthcr proceeding in mortgage foreclosure may take place for thhty (30) days allcr the date of this meeling, The name, address and telephone number of our rcpresentativc is: Telephone: Contact: Eastelll Capital Markets 2700 Westhall Lane Suite #240 Maitland, FL 32751 I-M88-225-<J<J II Patricia A. Weston Company Name: Address: Thc namcs alld addr csscs ur dcsignalcd CllllSIUllcr crcdit cllllnsclillg agcncics arc shown IIn thc allachcd shccl II is IInly nCCCSSillY III ,,:hcdlllc III1C I1ICC.tu,IiII:C IIIcclillg You shlluld mtvisc this IClldcl illllllcdiately Il'Y"11I illlcnlilllls \'lIm mllilgagc is in dclhult hcCilusc Y"U havc Iililcd tll pay PllllllPlly insta:hncnts or prillcipaland inlercst, as Icquilcd, lill a pClilld orat least sixty (C>O) days, Thc lolal alllounlllf the dclinquency is __~,:L.Ic>7J.7..,..,_.., A(:I") I NOTICE 1l\II'OIUANT: NOTICE OF 1I0MEOWNEns' EMEIU;ENC\, MOIU<,A<a: ASSISTANCE PIWGI~AM i>LEAS~; nEAI> TillS NOTICE. VOU 1\-1 A Y BE ELIGIBLE Fon FINANCIAL ASSISTANCE WHICII CAN SA V~: youn HOME FnOM FORECLOSURE AND HELl' YOU MAI\E FlJTlJIU: 1\I0HTGAGE PAYMENTS You may be eligible for financial assistance that will 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 default has been caused by circumstances beyond your control, you have a reasonable prospect of n:suming your mortgage payments, and if you meet other eligibility requirements established by the I>ennsylvania !lousing Finance Agency, Please read all of this Notice, It contains an exphmation of your rights, Under the Act, you are entitled to a tcmporary stay of foreclosure on your mortgage for thirty (30) days from the dale of this Notice, During that time you must arrange and attend a "face-to-face" meeting with a representative of this lcndcr, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to 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 eounseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days alter the date of this meeting, The name, address and telephone number of our representative is: Telephone: Contact: Eastern Capital Markets 2700 Westhall Lane Suite #240 Maitland, FL 32751 1-888-225-9911 Patricia A. Weston Company Name: Address: The names and addresses of designated consumer credit counseling agencies are shown on the altached sheet. It is only necessary to schedule one face-to-face meeting, Y 011 should advise this lender immediately of your intentions, 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 $ 4.467,97 '>- ex I "' (>~ <', ';1. - ~:) ~~ U.l.- -- 1....) , c.:.: (. . .. ~L , -, , C> , I , u..~ -. i , ',J [t t , , (: '.... j.'.~ "-'- ;. u, O~ :.5 0 0" U ) ~~ ~~\ ~~ ~ \\ \ ~~ ~ ~ \ \ \~ ~"1 ~ ~ ~ ':-J ~ ~ \J~ "." .~ .~ 'lti ~~ " ('~J ~~ C''- - j:-"': ",=.:; , (- u.:~., ~,~t', " ~;::: .. I C)~"'.' '.. \..'J ; - ...L.., . , L-.,j ".; " 1 ,- , U.l '.,. -' ~.. , " i .., " ; _:! u: :~t LC j.::' d u_ OJ ::J a 0-", (.)