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Home My WebLink About98-06321 I I I ~j i ,I . i ~ ~ .., ~ C) \ ~, , '" , :. ' ci ~ . .. .8 ~ ~, -~ '\ , ~ ~ ~ If. <> "< 'it III ~ ::s ~ ( '> \~ r- -.. ,:::l - ~ -.. ~i ~' I , I ~\ I I ,I :1 1. Plaintiff is Aurora Loan Services, Inc., 601 5th Avenue, II Scottsb1uff, NE 69)61. I 2. Defendant(s) is/are as follows: I' I A. Mortgagor (s): Stephen M. Kamowski and Joan E. Kamowski, who I reside at 1905 George Avenue, Carlisle, PA 170lJ. B. Real Owner(s): are the mortgagors. I' II ). The date of the mortgage is April 19, 1990. 4. A description of the land and property sUbject to the mortgage is set forth in Exhibit "A", incorporated herein by reference. 5. The mortgagee is Commonwealth Mortgage Company of America, LP. 6. The mortgage was recorded in the Department of Records of Cumberland County in Mortgage Book 974 page 612 et seq. and is incorporated by reference herein as though fully set forth at length. 7. The mortgage was assigned. 8. The most recent assignment was to the plaintiff herein, is in the process of being recorded in the Department of Records for Cumberland County, is incorporated by reference as though fully set forth at length. 9a. Written Notice of Intention to Foreclose under Act 6 of 1974 is not required because the original principal amount of the mortgage was in excess of $50,000.00. b. Written Notice of Homeowners I "Emergency Mortgage Assistance Act of 198)", pursuant to Act 91 of 198), is not required because the mortgage is insured by the Federal Housing Administration. 10. The mortgage is in default because monthly payments of principal and interest upon said mortgage due November I, 1997 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one (1) month, the entire principal balance and all interest due thereon are collectible forthwith. Tender of payment, if any, was rejected because the amount tendered did not represent the amount due at the time of tender. 11. The fOllowing amounts are due on the mortgage: Principal Balance Information Certificate Prothonotary - File Complaint Escrow Deficit Interest from 10/1 /97 to 10/)1/98 at $17.69 per diem Late Fees Accrued from 11/1 /97 to 10/)1/98 at $27.74 per month Attorney's Fees (5%) $6),700.99 )25.00 45.50 )26.47 6,987.55 )J2.88 1 'i67.39 $ 75,285.78 TOTAL ..... 12. The Attorney's fees 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 based on the work actually performed. WHEREFORE, Plaintiff requests the Court to enter judgment of mortgage foreclosure against the mortgaged property for the amount set forth above, interest and late charges at the contract rate until the date of Sheriff's Sale, foreclosure of said mortgage and a jUdicial sale of the mortgaged premises. KIVITZ & KIVITZ, P.C. 7\ , ~ C-(~ J~ E~IVITZ, QUIRE A orney for Plaintiff !j I'. ;,', '. ," . ,\::~ "'If. "-;,J ,~~ Y--..K.J1_l...~~.. ;!;.J; ..j~ ..~~~ J;_11._::1 '!'~HON li!lLLl!:U: lH~ing dltl~ tnlCl1,'n nrH~nl,'(.l.~.ng 1".n J.I~ll, (h~lJrll.it:ji 1.111' iW;[I: 1::1;". " - nm 1:110 Bunio);' Vico l'ruuiutlll't for the ullova nUll\ud 1lluin1:i~f, thm:. I c,lIl I I " l , uuthorbcti to tlll.e thJ.s Vl'lr.J.f:J.clltloll on halluH of the pJ.uintHl:, ;,:nd thl:'l: G4904 reluting to unaworn faloificutien to uu" the uti.tt:t.:m;.;nt:J 1lIi.~L1~ ill -l:hu furcgoiiJV pluL'.L~lng c..\~'U tl'l\~ u11d W)):;:l:,ul: ;:u ~:-a:. )Jeat 01: my ))"):~)(llll',l lmoll!,m:\gc or. j,1l1?m:lIlu\:ioll tllI<' !)\'l)),:'l);, :r. t\n(b;:~I;:'''lll~ '.:h' ,'" 1:t\lLi~ ~tt~~~:'::lil~lltij l1G).~~:tll i.\l.~~ mi..:(1~ ~.ml.J:l t:let .~l) '\:h~~ J.);JnuJ..i:i~~ o~ ~.U 1).:.. C.:~. ) I , -J -,~ . . " .;~ t "30Vd t{.t.IJt ((J3Ml 06, 6<' -,nr ,,' DESCRIPTION ALL THA T CERTAIN lot or ground, togcther with the improvements thercon erected, situate in North Middleton Township, Cumberland County, Pcnnsylvania, bounded and described as follows: BEGINNING at a point on a public strect, which strect parallcls State Highway Route No, 34 and which point is North 6 degrees 30 minutes East 100 feet from thc Northeastern corner of the intersection of two public streets, said corner being 505 feet East of the center line of State Highway Route No, 34 and 469 feet North of the Northern sidc of Fern A venue; thence by thc first mentioned street, North 6 dcgrees 30 minutes East 100 feet to a point at line of land now or formerly of George E. Henry and wife; thence by the latter land, South 83 degrees, 30 minutes East 150 feet to a point on line of land now or formerly of Russel Davis; thence by the latter land, South 6 degrees 30 minutes West 100 feet to a point on line of land now or formerly of Emmet L. Shullenberger and wife; thence by the latter land, North 83 degrees 30 minutes West, 150 feet to the place of BEGINNING, BEING known and numbered as 1905 George Avenue, Carlisle, Pcnnsylvania, PARCEL #29-17-1585-093 - ~ rtpv:r,v ~,(~ ~") ~ ~ ~ ~ ,"(\ ~ ~ J'-.-. " ~ , ~ ~(;5) ~ e) ,- ." ~ u ' '" "" .... .,). .,.. ';--. ~ ~ <~ " .t:. co' ," , ('1' . .. . , ,- ~~) c:\:. It.! ii' In l..:" C'; ,.. ,', .'. ~ , I L (.; c~ L ~ J I'. Ie [e. r:" (. "".,' F:^ p: