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Home My WebLink About00-05278 ,,~ -.-.- " ~ ~ ~<1"~ ~., LAW OFFICES OF GREGORY JA V ARDIAN BY: GREGORY JA V ARDIAN, ESQUIRE ATTORNEY LD. #55669 44 Second Street Pike, Suite 101 Southampton, P A 18966 (215) 942-9690 Attorney for Plaintiff HOMECOMINGS FINANCIAL NEWTWORK 8275 SKY PARK COURT 3RD FLOOR SAN DIEGO, CA 92123 Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION CUMBERLAND COUNTY No. 00- S~1P Cu~lYUuj vs, PAULA H. STAHL 2101 LAMBSGAP ROAD ENOLA, P A 17025 Defendant( s) COMPLAINT - CIVIL ACTION NOTICE You have been sued in Court If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense or objections to the claims set forth against you, You we wamed that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Cwlisle, P A 17013 717-249-3166 .'0&, ************************************************************************ NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT ************************************************************************ 1, This is an attempt to collect a debt and any information obtained will be used for the purpose. 2, Unless you dispute the validity of this debt, or any portion thereof, within thirty (30) days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within thirty (30) days ofreceipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the judgment against you, and a copy of such verification or judgment will be mailed to you by our offices, 4. If you notify our offices in writing within thirty (30) days of receipt of this notice, our offices will provide you with the name and address of the original creditor, if different from the current creditor. --. "-S" LAW OFFICES OF GREGORY JA V ARDIAN BY: GREGORY JA V ARDIAN ID# 55669 44 SECOND STREET PIKE SUITE 203 SOUTHAMPTON, PA 18966 (215) 942-9690 Attorney for Plaintiff HOMECOMINGS FINANCIAL NETWORK: COURT OF COMMON PLEAS 9275 SKY PARK, COURT : CUMBERLAND COUNTY 3RD FLOOR SAN DIEGO, CA 92123 Plaintiff( s) VS, No, PAULA H. STAHL 2101 LAMBSGAP ROAD ENOLA, PA 17025 Defendant( s) COMPLAINT IN MORTGAGE FORECLOSURE CIVIL ACTION MORTGAGE FORECLOSURE L Homecomings Financial Network, Inc., (hereinafter referred to as "Plaintiff') is an Institution, conducting business under the Laws of the Commonwealth of Pennsylvania and brings this action to foreclosure the mortgage between Paula H. Stahl, Mortgagor( s) (hereinafter referred to as "Defendant") and itself as Mortgagee by assignment which is being simultaneously filed with this complaint.. Said Mortgage was dated June 30, 1998 and was recorded in the Office of the Recorder of Deeds and Mortgages in Cumberland County in Mortgage Book 1465, page 401 . A copy of the Mortgage is attached and made a part hereof as Exhibit' A' . 2, The Mortgage is secured by Defendant(s) Note dated June 30, 1998 in the amount of $83,200.00 payable to Plaintiff in monthly installments with an interest rate of 11.50%. 3, The land subj ect to the mortgage is: 2101 Lambsgap Road, Enola, PA 17025, 4. The defendant(s), Paula H. Stahl is the real owner(s) of the land subject to the mortgage and the Defendants' address is: 2101 Lambsgap Road, Enola, P A 17025. = ,- ~iti, 5. The Mortgage is now in default due to the failure of the Defendant(s) to make payments as they become due and owing. The following amounts are due: Principal Balance: Interest to 7/31/00 $82,803,39 $ 8,570.14 $ 370.80 $ 2,003.00 $ 3,700.00 Late Charges Escrow deficit Attorney Fee/costs TOTAL: $97,447.33 plus interest from 8/1/00 at $26.45 per day, costs of suit and attorney fees. 6, In accordance with the provisions of the Act of January 30,1974, P.L. 13 No.6, Section 403 (41 P.S. 403), a Notice of Intention to Foreclose and A Notice of Homeowners' Emergency Mortgage Assistance was sent to defendants January 26, 2000, The Defendant(s) have not cured the default, WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale of the mortgaged property in Plaintiff's favor and against the Defendant(s), in the sum of $97,447.33 together with the interest from 8/1/00 at $26.45 per day, costs of suit and attorney fees. Law offices of Gregory Javardian C,I=w-"'---- - ~" ~> jIrg'. ',' 30,'98 Tl'E 10:37 FAX '10 29,~,15<8 CENT, MONEY MORT, ,~ ~ ,,)1' .,~ /' , (I ()1 ()O\S D\)1> @012 NOTE "i', '''\ , 1" ", June 30,1998 {Oau' Enala {City] 2101 Lambsgsp Road, Enola, PA 17025 Pennsylvania rSlutcl {PMpc1'ly Addrenl b\ \OY~l~ ~. 1. BORROWER'S PROMISE TO PAY In retumfor a loan that I have received, I promiscto pay U.S. $ 83,200.00 (this amount is called "principal"), plus interest. to the order of the Lender. The Lender is Central Money Mortgage Co. (IMe), Inc. ;,: I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by trnnsfer and who is "ntitled to receive payments under tbis Note iG called the "Note Holder," 2. INTEREST Interest will be charged on unpaid principal until the full amount of principal has bCCn pud. 1 will pay interest at a yearly rateaf 11.5000%. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 'I'" 3. P;\YMENTS (A) Time and Place of Payments I will pay principal and interest by making payments: every month. [ will make my monthly payments on the 6th day of each month beginning on August 06. 1998 J will make these payments every montb until I have paid all of the principal and interest and any other chatg~s described below that I may owe under this Note. My monthly paym"nts will be applied to interest befoTC principal. If, on July 06, 2028 I { still Owe amounts under this Note, I will pay those amOllnts in full on that date, whieh is. called the "maturity dalC." J will make my monthly payments at 8840 Stanford Blvd, Suite 2200, Columbia, MO 21045 .r,'> '",. or at a different place if required by the Note Holder. l! (B) Amonnt of Monthly Payments My monthly payment wiD be in the amount of U.s. $ 823.93 ".t. 4. BORROWER'S RIGHT TO PREPAY I )lave the right to make payments of principal at any time before they arc duc. A paymellt of principal only is known as a "prepayment." When I make a prepayment, I will teU tbe Note Holder in writing that I am doing so. I may make a full prepayment or partial prepayments. without payin&; any prepayment char&;e. The Note Holder will use all of lIlY prepayments to reduce the amount oC principal that I owe under this Note. If I lll3ke a partial prepayment, t.lu..TC will be nO changes. in the due date or in the amount of my monthly payment Ilhless Ute Note Holder agrees in writing to those changes. ~"LTlSTATE FIXED RATE NOTE - Siogle Fumily. FNMAIFHLMCtJnifal1U Imtrumcnt lTfM18<18L1(95111 (Pagi!/ofJJXJ8i!.sJ Fom 3200 12113 GR&ATLA~ . TcOjdOfC~II, 1-B(lo)o53o.t3t3DF~.616<791'1131 -"0/' --""" - ---~ .: i: CENT. MONEY MORT. e '. Ii1J013 ('I, .30"98 TFE 10:37 F.U .ull}~.O_ 1548 5. LOAN CHARGES If a law. which applies 10 this loan and which lie{S maximum loan charges, is finally interpreted Jl\O that the interest Qr other loan charges coIlccled Or lo he collected in connection with this loan exceed the permiUed limits, Chen: (i) any sllch loan charge shall be reduced by lhc amount necestar)' to reduce the charge to the penniucd 1imit~ and Hi) any sums already collected from me which exceeded penniUed limits will be refunded to me. The Note Holder may choose to mllke this refund by reducing the principal I owe u~der this Nole or hy making a direct payment to me. If a refund reduces principal, the reduction will be treared a$ a partial prepayment. i', "i,~ \ t '. , ;~' 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge fOr Overdue Payments If the Note Holder has. J'tot received the full amount of MY monthly payment by the end of fifteen calendar days after the date it is d\.le, I will pay a late charge to the NOle Holder. The amount of 1he charge wHl be 5.0000% of my overdue payment of principal and interest. I will pay this late charge promptly but only Once On each late payment. (B) Default If I do not pay the full amount of each monthly payment On the date il is due, I wtll be in default. (e) Nollee of Default If 1 am in default, tbe Note Holder may send me it written notice teUing me that if 1 do not pay the overdue amount hy a cerlllin date, the Note Holder mKY require me to pay immediately the f\.ln amo\.lnt of principal which has not been paio. md all the interest that I owe on that amount. That date must be at least 30 days artet the date on which the notice is delivered or mailed to me. (0) No Waiver By Note Holder Even if, at a time: when I am in default, the Note Holder does not require me to pay irrunediately in full as described above, the Note Holder will still have the right to do so if [ am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required.me to pay iGunediately in full as described above. the Note Holder wil11uve the right to be paid back by me for all of its costs. and expcmscs in enforcing this Note to the extent not prohibited by applicable Jaw. Those expenses include, for example, reasonable attorneys' fees. 7, GIVING OF NOTICES Unless applicable law requires a different method, any notice that m\.lst be given to me under this Note will be !ivcn by delivering it or by mailing it by fiTSt ela.o:;s mail to me al the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by mailing il by first class mail to the Note Holder at the address stated in Section 3(A) ahovc OT at a different address if I am given a notice of that different address. 8, OBLIGATIONS OF PERSONS UNDER TIDS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who tabs over these obligations. including the obligations of a guarantor. surety at endorser of this Note. is also obligated 10 keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that anyone of us ma.y be requited to pay aU of the amounh owed under tbis Note. 9, WAIVERS I and any other person who has obligations under this Note waive tbe rights of prescnl.rnent and notice of dishonor, "Presentment" means the right to require the Note Holdt..-r to demand payment of amountS due. "Notice of dishonor" means the right to require the Note Holder to give notice to other petsons that amounts due have not been paid. 16. UNlFORMSECUREDNOTE This Note is a uniform instn.1ment with limited variations in $Ome j\.lrisdictions. In addition to the protc.."Cuons given to the Note Holder under (his Note, a Mortgage, Deed of Trust or Security Deed (the "Security Instrument"), dated the same .date as this Note. protects the Note Holder from possible Josse., ",Wcb might result if 1 do not keep \he promise$ which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amOunl\; I owe under this Note. Some of those conditions are described as follows: :TEMl848L2(9iJ,11} (Page 2 ~O pat;u) Fonn 3200 I11BJ BFlEATlANO. TOOrd61c.:.1:1-80D-S!(I-'l393CF36111-791-1131 " U" ,.-= - ~. "~. 1111 30/98 TtTE 10: 38 FAX -I1Q-.~9.c), 15.18 CENT, MONEY MORT. ~ o ~014 Transfer of the Property or a Beneficlallntere.d in Borrower. If all or any part of lhe Property or any' interest in it is sold or transferred (or if tl beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by ihis Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the dale of this Security InSlrUment. If Lender exercises this option, Lender shall give Borrowt..'T notice of acceleration. The notice shall provide a period of not le...~ lhan 30 days from the date the notice is delivered or mailed within which Borrower mu~t pay all sums secured by this Security Instrument. If BOrrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies penniued by this Security Instrument without further notice or demand on Borrower. " '\ '\ ( " , ),;.- , . Borrower has executed and acknowledges receipt of pages I through 3 of this Note. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED ~~^ Q_J ,.2:;!! 9~7;:s:S f7~ (Seal) -Bum)Wl!r (Seal) -Borrower (Seal) -BulTOwer (Seal) -Borrower (Seal) -80lTowcr [Silln Original Only] PAY TO THE ORDER OF WllHOUT RECOURSE 8~~~~J!jr BflIAN D, HOlMAN. PR EHT ITEM 164(u($511) {Patel qf3 ptlilC~1 Form 3ZOO 12Jlll GREATLANO. ToOt~I~II: 1.SO"53G-W9!DFII616-'r91-119t IIH 30/98 TUE 1u:38 FAX 410 290 1548 C~i<T,MONE\ MORT, .. ,~ "W ~OlS I hereby certify tllal this is a ~r~e and correct copy of the onglnal document. 9~/ /7 f~ .1', "\ ISpAce Above This Line For RcconlinR DlltIl] MORTGAGE TIllS MORTGAGE ("Security Inslrumenn is given on June 30, 1998 The mortgago{ is Paula H, Stahl, unmarried Central Money Mortgage Co. (1M C), Inc. wbich is orga.nized and existing under the laws of the State of Maryland 8840 Stanford Blvd, Sulle 2200, Columbia, MD 21045 . ("Borrower"). This Security Instrument is given to , , and whose address is :tr Eighty Three Thousand Two Hundred and no/100 Dollat'$ (U.S. $ 83,200.00 ). This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt. if not paid earlier, due and payable on July 06, 2028 . This Security Instrument secures to Lender; (a) the repayment of the debt evidenced by the Note, wiUt interest. and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest. advanced under paragraph 1 to protect the security of this Security Instrument; and (0) the performance of Borrower's covenants and agreements under this Security Inslrumenl and the Note. Por this purpose, Borrower does hereby moJlgage, gIant and convey to Lender the following described property located in Cumberland ("Lender"). Borrower owes Lender the principal sum of See Exhibit A attached hereto and made a part hereof. County I Pennsylvania: Pennsylvania 17025 (Zip Codel 2101 Lambsgap Road tS"=I} ("Property Address"); enola ICity} which has the address of PENNSYLV ANlA -- Sinll'e Family.. 'FDnn~e MuclFrcddle Mac \JN1FQRM INSTRUMENT ITeM19~1 (9611} (Paf.'I::1 IJf6puj;:c.l"J l'onn 3039 9J9Q, OA!A~. ToOrllorCall:l.6OIl-$301ISt3C'n616-1II1.1131 ";! ~ .:'" :1" " , , , ~, -.,[ ,,: -.... ..! ,.... .'\ ;.. - n!:ll'I<<t'" ."1 3u/uf:! TUE 1U:36 VAl ~10 290 1546 tENT,MONEI' ~IORT. . .Qi Iij]016 ~ \,. \ , " " . rOOBnIBR WITH all the ~mprovements now or hereafter erected on lhe property. and all easements, appunenar,.ees, and fixtures now or hereafter a part of the property. All replacements and additions sholl also be covered by this SecUrity instrument. All of the foregoing is referred to in dlis Security Instrument as the "Property. II BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record, Borrower wanants and will defend genl...nlly the title to tlie Property against all claims and demmds, subject to any encumbrances of record. TInS SECURITY INSTRUMENT combines uniform eovenanls for national use and non.uniform covenanls with limited variations bylurisdiction to constitute a uniform security instrumenl covering real property. UNIFORM: COVENANTS. Borrower and Lendercoven3.nt and agree as follows: 1. Payment of Prindpal and Iutere!Ctj Prepayment and Late Charges. Borrower shall promptly pay when due the principal of lInd interest on tlle debt evidenced by the Note and any prepayment and late charges due under tbe Note. 2. Fund~ for Taxes IInd 1l16Urance. Subject to applicable law or to II wriuen waiver by Lender, Borrower shall pay tu Lender on the day montWy payments are due under the Note, until the Note is paid in fuU. a sum ("Funds") for: (a) yearly taxes and assessments which may attain priority over this Security lnstrument as a lien on the Property; (b) yearly le:u;ehold payments or ~round rents on the Property, if any. (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums, if MY: (e) ycarlr mortgage Insurance premiums, if any: and (0 any sums payablc by Borrower to Lender, in accordance. with tbe proviSions of patagr:wh 8, In lieu or the p,"ymeJlt of mortgage insurance premiums. These iLcmsllJ'c caUed "Escrow Items_~ Lender may. at any time, conect and hold Fund", in an amount not to exceed the maximum amount a lender for 8 federally related mortgage loan may require for Borrower's escrow account under the federal Rca1 Estate Settlement Procedures Ad oC 1974 as amended from time to time, 12 U,S.C. 8 2601 et seq. ("RESPA"), unless another law that applies t6 the Funds sels a lesser l\Dlount.1f so, Lender may, III any time, collect and hold Funds in an amount not to exceed lhe lesser amount. Lender may estimate the amoUnt of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with .applicable law. The Funds shall be l1eld in an institution whose deposits :u;e insured by a federal agency. instrnmentality, or entity (including Lender, if Lender is such an institution) or in any Fedcral Home Loao Bank. Lender shall apply the Funds to pay the Escrow Items. Lender may not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items. unless Lender pays Borrower interest-on the Funds and applicable law pennits Lender LO make 6uch a charge. However, Lender may require Borrower to pay a one-time charge for an indl...-pendent real e$tatc tax reporting service used by Lender in connection with t1ti~ loan, unless applicable law provides othcrwisc. Unless an agreement is made or applicable law requires interest 10 be paid, Lender shall not be required to pay BOlTowcr any interest. Or earnings on the Punds. Borrower and Lender may agree in writing, however, that interest shall be paid on the Fund5. Lender sball gi"4o to Borrower. without charge, an annual accounting of the Funds. showing credits and debits to the Funds: WId the PUrp06C for which each debit to tbe Funds was made. The Punds are pledged as additional security for all 5ums sccured by this Security Instrumcnt. If the Funds held by Lender cxceed the amounts permitted to be held by applicable law, Lendcr shall account to Borrower for the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Lender o.t any time is not sufficient to pay the Escrow Items when due. Lender may so notify Borrower in writing, and, in such case Borrower shall pay to Lender the amount necesslll)' to make up the deficiency. Borrower sball make up the deficiency in no more than twelve monthly payments. at Lender's sole discretion, Upon payment in full of all sums secured by this Securily I~SlrUment. Lender shall promptly ~efl1nd to Bo:~r any Funds held by Lender. n. under paragraph 21, Lende, shall acqulre or sell the Property. Lender, pnor to the acqUUluon or sale oC the Property, shall apply any Fl1nds held by Lender at the time of acquisition or we as a credit against the sums secured by this Security Instrument. 3, Application of Payments. Unless applicable law provides otherwise. all payments received by Lender under paragraphs 1 and 2 shall be applied: fust. to any prepayment charges due under the Note; second, to amounts payable under paragraph 2; third, to interest due: fourth, to frlncipal ducj and last, to any late charges due under the Note. 4. Chargesj Liens. Borrower shal pay all laxes. assessments, charges, fines and impositions a~butable to the Property which may a~tain .priority over this ~ecl1~ty InstrUment, and.l.easeho~d ~ayments or ground rents, If any. Borrower shaU pay these obligal1ons 10 the manner proVlded m paragraph 2. or Ii not pud m that manner,.Borrower shall pay them on time directly to the person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this paragraph. It' Bonower makes these payments directly, Borrower shall promptly fumisb to Lender receipts evidencing thc payments. ' Borrower sball promptly discharge any Hen which has priority ovcr this Security Instrument unless Borrower: (a) ~8rces in writing to the paymentlof the obligation ~ured by the lien in a manner acceptable to Lender. '(b) contests in goQd f81th the lien by. or defends againsl enforcement of the lien in, legal proceedings which in the Lendei'1 opinion operate to preveat Ihe enforcement of the lien; or (e) secures from the hulder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines thai any part of the Propert)' is subject to a lien whieh may allain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall ,satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. : S. Hazard or Property Insurance. Borrower SrboJI keep Ihe improvement5 now existing or hereafter erecled on the Property insured againslloss by fire, hazards included within the term "extended coverage" and. any olher hazards, including 'Ooods or flooding. for which Lender requires insurance. This insurance shall be maintained in the amounts and lTEMtO!0L.2(96111 (f'age2nj"t1pages) Fonn 3039 9190 OREATl,ANO. ToOfftf~I:1-600-530-a3t3afpat8-79j.ml - " " Jiritf,,; Pi ":}OdI8 TlIE 10:39 FAX HO 290 15.(6 "c~i<T,MONE~ MORT, R4 ,I'"'" ~017 ': for the periods tbat Lender requires. The insurance: camer providing the insurance shall be chosen by Borrower subj~t to Lender's r.pprOval wbich shall OO( be. ",nreasonably withheld. If Borrower faits to maintain coven,go described abcwc, Lender may. at Lender's option. obtain coverage to protect Lender's rights in the Property in accordance Willi paragraph 7. '. All insur3llcc. policies and renewals shall be acceptable 10 Lender and shall include a standard mortgage clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give 10 Lender all receipls of paid premiums and renewal notices. In the event of loss. Borrower shall give prompt notice to the insuranc~ carrier and Lellder. Lender may make proof of Joss if nol made promptly by Borrower. Unless Lender ilnd Borrower otherwise agree in woting, Insurance proceeds shall ~ applied to restoration or repair of the Property damaged. if the restonl.tion or repair is economically feasible and Lender's ~eurity is not lessened. If the rcslorabon or repair is not economieaUy feasible or Lender's security would be lessened. the insurance proceeds llhall be applied to the sums secured by this Security lnstrumenl, whether or not then due, with any ex.cess paid to BOllowc!. If Borrower abandons the Propeny, or does not answer within 30 days a notice:: from Lender that the insurance carrier has offered to settle a claim, Ihen Lender may cotlect the insurance proceeds. Lender may use the proceeds to repair or restore the Proptrty or to pay sum:'> secured by this Security Instrument, whether or not then dut. The 30-day period will begin when the notice is given, Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of the payments. If under/,aragraph 21 the Property is acquired by Lender, Borrower's right to any insurance policjes and proceeds resulting from amage to the Property prior to the acquisition shall pass to Lender to the extent of the sums secured by this Security Instrument imme4ialdy prior to the acqnisition. 6. Occupancy, Preservation, MalutenQnce Ilod Protection of the Property; Borrower's Lo~JI Application; Leaseholds. Borrower shall occupy, establish. and use the Property as Borrower's principal residence within sixty days after the execution of Chis Security Instrument and shall continue to o~upy the Properly as Borrower's principal rCMdence for At least one year after \he date o[ oc.c.upancy, unless Lender otherwise agrees in writing.. which consent sball not be unreasonably withheld, or \lole!;."! extenuating circutm:tances exist which are beyond Borrower's control. Borrower shall not destroy. dadlage or impair the Propeny, allow the Property to deteriorate. or commit waste on ttle Property. Borrower shall be In default if any fodeiturc action or proceeding, whether civil or criminal. is begul1 that in Lender's good faitb judgmeat could result in forfeiture of the Property or otherwise materially impair the lien created by thi,; Security IrtSlrument or Lendcc's security interest. Borrower may cure .\uch a default and reinstate. as provided in paragraph 18. by causing the action or proceeding to be dismissed with a ruling that. in Lender'S good faith determination, preclude!!. forfeiture of the Borrower's interest in the ProperlY or other material impairment of the lien cr~ated by this Security In!itrument or Lender's security intt:reGl. Borrower shall also be in default if Borrower, during the loan application process. gave materially false or inaccurate information or statement!'> to Lender (or failed to provide Lender wil.h any material information) :in connectioCl witb the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security InslrUmenl is on a leasehold, Borrower shall comply with all the provisions of the Jease.1f Borrower acquires fee tiUe to the Property, the lellsehold and the fee title shall not merge unless Lender agree.~ to the merger in writing. 7. Protection of Lender's Rights in the Prnptt'ty. If Borrower fails to per(onn the covenants and agreements contained in this Security Instrumc:nt, or there is a legal proeeedirlg that may significantly affect Lender's right 'I in the Property (such as a proceeding in bankruptcy, probate. for condenutation or forfeiture or to enforce laws or regulations), then Lender may do and pay for whatever is necessary to protect the value of lhe Prope11y and Lender's rights in the Property, Lender's actions may include paying any sums secured by a lien which has priority over lhis Sec;urity Instrument. appearing in court, paying reasonable atlorncys' fees and entering on the Property to make repairs. Although Lender may take action under this p;uagraph 7, Lender does not have to do so. . Any amOUnts disbursed by Under under this paragraph 7 shall become additional debt of Borrower secured by this Security lnstnlmenl. Unless Borrower and Lender agree to other terms of payment, thesc amounts shall bear intere5l from the dale of disbursement at the Notc rate and shall be payable, with interest, upon nolice from Lender to Borrower rcquestil1t payment. 8. Mortgage Iasurante. If under required mortgage insurance as a condition of making the loan scoured by this Security Instrument, Borrower shall pay the premiums rcq,uired to maintain the morlgage insurance in effect. If, for arty reason. the mort$age insurance coverage required by Lender lapses or eeases to be in effect, Borrower shall pay the premiums required to obtam coverage substantially equivnlent to the mortgage insurance previously in effect, at a cost substantially equivaienllo the cost to Borrower of the mortgage insurance proviously in effect, from Itn llItcrna.te mongage insurt.T approved by Lender. If sJbstantialty equivalent mortgage insu{ance coverage is: not available, Borrowt:r shall pay to Lender each month a sum eqIJal to one-twelfth of the yearly mortgage insurance premium bell'lg paid by Borrower when the insurance co"erage lapsed or ceased to be in effect. Lender win accept, use and retain these payments as a loss reserve in lieu of mortgage Insurance. Loss reser\'e payments may no lon~er be require~ at the option of Lender, if mortgage insurance coverage (in the amounl and for the period that Lender reqUltes) provided by an insurer approved by Lender again becomes anilable and \$ oblaincd. Borrowet sn~l pay Ihc premiums required \0 maintain mortgage insurance in effect, at to provide a. .10$$ fe.o;ervc, untillhe requirement for morlgage insurance ends in accordance with any written agreement between Borrower and Lender or applicable law. , 9. Inspection. Lender or its agent may make reasonable entries upon and inspections or the Properly. Lender shall give Borrower notice Ilt the time or Of prior to an inspection specifyjng reasonable cause for the jn~pec:tion. 'j' , '\ , '. " , ,~' * 'i. ,',., IrEM1!16Ol.3 (ll511) (PaGt 3 (1/6 palled Form 303' 'hO OAEATl.ANO. To Ood,rCed: 1.800-5>>9J93CFuM6.nl.1131 'toy " ,-~ ~~ ~ ~ ~ jj':!L. ,;,: 30/98 TUE 10:-10 FAX ..UO 290 1548 ~, CENT,MONEY MORT. ~I , t~ , '.;;;;J ~018 10. Condemnation. The proceeds of any award or claim for damages, dir<.:et or consequential. in conn(:etion.',with any condemnation or other taking of any part of the Property. or for conveyance in Heu of condemnation, arO hereby assigned and ~hall be paid to Lender. In the event of a tolal taking of the Properly. the proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, witb any exccss .paid lo Borrower. In the event of a partial tllking of the Property in whieh the fair market value of the Property immediately before the taking is equal to or greater thll1\ the amount of the sums secured by this Securily Instrument immediately before the taking. unless Borrower and Lender otherwise agree in writing. the sums secured by this Security Instrument sha.lI be reduced by the amount of the proceeds multiplied by the [ollowing fraction: (a) the total amount of the sums secured immediately before the taking, divided by (b) lhe fair market value of the Properly iuunediately bcfore the taking. Any balance shall be paid to Borrower.. In the event of a partial taking of lhe Pmperty in which thc fair market value of the Pmpercy immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provide.... the proceeds $hall be applied (0 the slims secured by this Security Instrument whelher or not tbe sums are then dUe. If the ProperlY is abandoned by Borrower, or if. after notice by Lender to Borrower that the condenmor offen to make al1 award or settle a daim for damages. Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option. either to restoration or rcpair of the Property or to the sums secured by this SCC\lricy Instrument, whether or not then due. Unless Lender and Borrower other:wise agree in writing, any application of procceds to principal shall not extend or postpone the dub date of the monthly payments referred to in paragraphs 1 and 2 or changc lhe antounl of such payments. 11. Borrower Nol Released; l?orbearoDce By Lender Not A Waiver. E.xtension o( the time for payment or modification of amortization of the _sums sceured by this Security Instrument granted by Lenderfto any successor in interest of Borrower shall not operate to release the liability of the original Borrower Or Borrower's successors in interest. Lender shall not be required to commence proceeding!; against any successor in interest or refuse to c:x.tend time for payment or otherwi~e modley amOrllulion of the sums secured by this Security InSlIUment by reason of any demand made. by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of Or preclude the exereise of any right or remedy. 12. Successors pnd Assigns Bound; Joint and Several Liability; Co.slgners. The covennnls and agreements of this Securily Instrument shall bind and benefit the successors and assigns of Lender and Borrower, :subject to the provisions ot paragraph 17. Borrower's covenants and agrcemenlS shlll1 be joint and several. Any Borrower: who co-signs this SecurilY Insltument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and con\'cy that Borrower's interest in the Properly under the terms of this Security Instrument; (b) is not personally obligated to pay the ....sums secured by this Security Instrument; and (c) a&l'ees that Lender and any other Borrower may agree to extend, modify. forbear or make any accommodations with regard to the lenns of this Security Instrument or the Note without thal Borrower's consent. 13. Loan Charges, If the 10m sccured by this Security Instrument is subject to a law which sets maximum loan charges. and that law is finally interpreted $0 that the interesl or other loan charges collected or to be collected in connection with the loan ex.ceed the permitted limits, then: (a) any such Joan charge shall be reduced by the amount necessary to reduce the charge to the permitted limiti and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a pariial prepayment without any prepayment charge under the Note. . 14. Notices. Any notice to Borrower provided for in this Security Instrumenlxhall be given by delivering it or by mailing it by first class mail unlc.."s applicable law requjrt:$ use of another method. The notice shall be directed to Ihe Property Address or MY other address Borrower designates by notice to Lender. Any notice 10 Lender shall be given by first class mail lo Lender's address stated herein or any other address Lender designate.'l by notice to Borrower. Any notice provided for in this Secwity Instillment shall be deemed to have been given to Borrower or Lender when given as ptovided in this paragraph. 15. Go\'ernlng Law; SeverabUlty. This Security Instrument shall be govented by fcdcrallaw -and the hlW of the jurisdiction in which the Property isloc3ted. In the event tbat any provision or clause of thi" SL"CUrity Instrument or the Note conflicts with applicable law. such confliet shDlI not affect othcr- provisions of this Security {nsttument or the Nole which ean be given effect without the conflicting provision. To this end the provision" of this Security Instrument and the Note ute declared to be severable. 16. Borro"ec's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 11. Transfer ofthf Pro~rtyor a Benefidallnterest in Borrower. H al10r anYJ'art of the Property or any interest in it is sold or trnnsferred (or if a benefi~ia1 interelit in Borrower is sold or lransfctTCd un BottOwer is not a natural person) without Lendcr's prior written consent, Lender may, at its option, require: immediate payment tn Cull of alIliOms $CCured by this Security In"lrumenl However. thjs option shall not be exercised by Lender if exercise is prohibited by federal law 3.0; of the date of Ibis Security lnstrullll.-nt If Lender exercises this option., Lender shall give Borrower notiCE: of acceleration. Ule notice shall provide a period of not less than 30 days from the date the notice is dellvered or mailed within wbjcb BotTowcr must pay all sums se<:ured by Ibis Security Instrum~nt. If Borrower fails to pay these sums prior to lhe expiration 01 this period, Lender may invoke any remedles perntined by thiS Sc:cunty InslrUmenl without further noUce or demand on Borrower. 18. Borrower's Right to Reinstate. II Borrower meet& celtain conditions. Borrower shall have the rigbt to have enforcement of this Security Instrument discontinued At any time prior to the carlier of~ (a) 5 days (or such othec period as Form 3039 9190 GRl!ATl.AND. lTEM1950lA (941i) (Pa,e4rJJ6paR~,f' 10 O<<!lrCa!1: 1-aGO.m-tmD''.S16-1t101131 .i' e, \ i, " , ~.: lllj .~_TlIE 10:..10 FAX ..110 290 1548 'CENT . MONEy lI0RT. . ~ ,@f ~019 ;,-, applicable law may specify for reinstatement) before sale of tbe Property pursuant (0 any power of sale contained in this Security Instntmel1t; or (b) entry of a judgment enforcing this Security Instrument Those condilions are that Borrower: (a) pays Lcnder all sums which then would be due under this Security [nstrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all e'l.pcn~es incurred in enforcing this Security lnslnlment, including. but not limited to. reasonable attome)'s' fees; and (d) takes such action as Lender mllY reasonably require to assure that the lien of this Security Instrument. Lende(s rights in the Properly and Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon rein~talcment by Borrower, this Security Instrument and the obligationi'; secured hereby shall remain fully effective as if no acceleration had occurred. However, this right [0 reinstate shall not apply in tlie case of acceLeration under paragraph 11, 19. Sale of Not.e; Change nf Loan Servicer. The Note or a partial interest in the Note (together with this Security Instrument) may he sold one or more times withoUl prior notice to Borrower. A sale may result in a change in the entity (known as the "Loan SerVicer") that collects Olonlhly payments due under the Note and this Securit)' Instntmenl There also may be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer. Borro.....er will be given written notice of the change in accordance with paragraph 14 above and applicable law. The notice will state the name and address of the new Loan Servieer and the address to which payments should be made. The notice will also contain an)' other information required by applicable law, 20. Hazardous Substanctll, Borrower shall not cause or permit the presence. use. disposal. storage, or release of any Hazardous Substances on or in the Property. Bonower shall not do. nor allow anyone e1ltC to do, anything affecting the Property that Is id vlolation of any Environmental Law. The preceding two sentences shaH not apply '0 the presence. use, or storage on the Property of small quantities of Hauardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender writtcn notice of any investigation, claim, demand, lawsuit or oth.et action by any governmental or rcguJ.tory agency or private party involving the Property and any Hazardous Substance or BnvuomnenW Law oC which Borrower has actual knowledge. If Borrower leOlns, or is notified by any go\'emmental or regulatory authority, that arty removal Dr other remediation ()f any Hazardous Substance affecting the Property is nece5sary, Borrower ~hall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragrP.Dh 20. "J.l3.Ztlrdous Substances" are tho!\c substances defined as toxic or hilr.ardous substances by Environmental Law and the fonawing substance..',;; gasoline. kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, \lolatile solvents, material6 containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 20, "Environmenlal Law" means federal laws and laws oC the jurisdiction where the Property is located that relate to health. safety or environmental protection, NON~UN1FORM COVENANTS, Borrower and lender further covenant and agree as follows: 21. Acceleration; Remedies. I"ender shall give notice to Borrower prior to accelerll.tion tollowins; Borrower's breach or any covenant or agreement in this Securit.y Instrument (but. not prior to acceleration under paragraph 17 unless applicable law provides otherwise). Lender shall noUty Borrowtlr of, among other things: (n) the default; (b) the action required to cure the default; (c) when the defawt must be cured; and (d) tbat failure to cure the default as specified may result in aceeleratlon oS tbe sums secuTed by this Sec.uTity Instrument, [otu\o~nre by iudicial prot.e:ed\\\R and sale ot the Properly. Lender shall further Inform Borrower of the right to reinstate afier acceleration and the right to assert in the foreclosure proceeding the non-existence or a default or Ilny other defense of lIorrowcr to acceleration and foreclosure. If the default is Dot ,cured as llpecified, Lender at. its option may require Immediate payment in full ot aU sums secured by this Security Instrument without further demand and mOlY foreclose this Security Instrument by judicial proceeding. Lender 5hall be entitled to 4.:ollect. all expenl)f!l incurred in pursuing the renlcdie." pro\'idcd In this paragraph 11, Including. but not limited to, attorneys. fce~ and COjlts of title evidertce to the extent permitted by applicable law. 2.2. Release. Upon payment of all sums secured by this Security Instrument. this Security Instrument and lhe estate conveyed shall terminate and become void. After such occurrence. lender shall dischuge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay :my recordation costs, 23. Waivers. BOlTowcr, to the extent permitted by apDlicable law. waives and releases an)' error or defects in proceedings to enforce this Security Instrument, and hereby w,jve~ [he benefit of any present or f~ture laws providing for stay of e'l.ecution. extension of time. exemption from attaehmenllevy and sale. and homestead exemption. 2.4. Reinstatement Period. Borrower's Lime to reinstate provided in paragraph 18 shall ex.lend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pUf:\uant to this Security Instrument. 15. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent k:J Borrower to acquire title to the Property. this Security instrument shall be a purcha,e money Dlongage. 16. lnterest Rate Afier Judgment. Borrower agrees that the interest rate payable after a judgment is entered On the , Note or in an action of mortgage foreclOllurt: shall be Ihe rate payable from time to time under the Note. " \,. \ i, " !~. ,i_. ..,.. r lTEMl9!OUi (1l6111 (Puglj S (lf15ptJlIlr6J Form 3019 '190 GREATLAND . lo0Ido,t~W: I-ooGoSJn-l13t3Dh~BlI1-1gH131 - i' ~ o Othcr(s) [specify] .~.'" BY SIGNING BELOW, Borrower accept.~'and agrees to the terms and covenants conWned in pages 1 through 6 of this 'ty Instcument and in :my rider(s) executed by onower and recorded with it. !:,\ (Seal) .Bormw~r (Snal) .Bottnv,= (Seal) .Burrower (Snal) .HOITOWer (Seal) .B<,)fl'Owcr (Soal) .Qunowcr Witness: Witness: ~n-1~ COMMONWEALTH OF PENNSYLVANIA. Countys:s; ~~ (a A.'" Onthis:.thn 3iJ"fh dayo! a....'-<.- /Y7~bn!ornmc. J.!SS/f: N. ,('6YC.~ the undc~ned officer, personally appeared Paula H. Stahl proven) to be the person whose name Is that he executed the same ror dle purpose herein contained. known tQ me (or satisfactorily subscribed to tho within jnstrument and acknowledged IN WITNESS WHEREOF, 1 hereuntQ set my hand and official seal, My Commi:l;s. NoIarialSII81 n.......-:..~ '--no NRoyfIrNolaI)'Pub\lc ~ ,....J'~~lerTwp:. lancaslerCOU,...'" N "J , ~c;;;,;iSsIonExplreIlJuly29. _~ Member, nsytvanlllASSOClallonolNCltartes D ~ Th!~l)j'Offil:CT CERTlI'lCATE OF RESIDENCE !, :JESS IE I'll. 'l6yPr do hereby certify that the correct address of the within narned lender is . 8840 Stanford Blvd, Suit. 2200, Columbia, MD 21045 Witness my hand this 30th day of June 1998 fOld ~ Pu:b-& ~~ ~ n, 1r Agent of Lender ltEMt~61~5tl1 (Page 6 of 6 plJges' Farm JOJ9 91'90 GREA'l'LAWD . loOtdlrc.lI:1.!lOO-5:lOo93t3ChIl81l1-701.1131 ,!,~;' ~, ~ -_OJ ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE January 26, 2000 TO: PAULAH. STAHL 2101 LAMBSGAP ROAD ENOLA, P A 17025 THIS FIRM IS A DEBT COLLECTOR A TIEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATIEMP'f TO COLLECT TIIE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HA VB PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official notice that the mortgllj(e on vour home is in default and the lender intends to foreclose. Specific infonnation about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to help to save vour home. This Notice explains how the prol!l1lll1 wOlks. To see IfHEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF TIIE DATE OF THIS NOTICE. Take this Notice with vou when vou meet the Counseling Agencv. The llaI11e. address and phone number of Consumer Credit Counseling Agencies serving vour County are listed at the end of this Notice.lrvou have anv auestions. vou mav call the Pellnsvlvania Housing Finance Agencv toll free at 1-800- 342-1397. (Persons with impaired hearinl! can call (717) 780-1869). This notice contains important legal1nfonnation. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. IS NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIA TAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADA ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDA SAL V AR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HlPOTECA. ~'''' ~ ~.,,~" >, ~ , -, - , "I STATEMENTS OF POLICY HOMEOWNER'S NAME(S): PAULA H. STAHL PROPERTY ADDRESS: 2101 LAMBSGAP ROAD, ENOLA, PA 17025 LOAN ACCT. NO.: 2104412 ORIGINAL LENDER CENTRAL MONEY MORTGAGE CO. (IMC),INC. CURRENT LENDERlSERVICER: CITIFINANCIAL MORTGAGE COMPANY FIKIA IMC MORTGAGE COMPANY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELIGmLE FOR EMERGENCY MORTGAGE ASSISTANCE. . lJ1 YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . lJ1 YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMJ>ORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on you mortgage for thirty (30) days from the date of this Notice. During that time you must ~e and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN TIm NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW Tb CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -Ifvoumeet with one of the consumer credit counseline: ae:encies listed at the end of this notice the lender mav NOT take action lIl!ainst vou for thirtv (30) davs after the date of this meetine:. The names. addresses and teIe\ljlone numbers of desie:nated consumer credit counseIine: .lIl!encies for the county in which the Drooertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for fmancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICA TION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETIER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. ,," " ~ '. . ^'r; AGENCY ACTlON- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that 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 the Pennsylvania Housing Agency of its decision on you application, NOTE; IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLWWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT (Uyou have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to date) NATURE OF THEDEF AUL T- The MORTGAGE debt held by the above lender on your property located at: 2101 LAMBSGAPROAD, ENOLA,PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 9/7/99 thru 1/7/00 at $823.93 per month, Monthly Payments Plus Late Charges Accrued: $4,284.45 NSF: $0.00 Property Inspection: $0.00 Other: $0.00 Insurance: $0.00 Attorney fees: $50.00 (Suspense) ($0.00) TOTAL AMOUNT TO CURE DEFAULT $4,334.45 B. YOU HA VB FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable): N/A HOW TO CURE THE DEFAULT- You may cure the default within THIRTY (30) DAYS of the date of this Notice BY PA YlNO TItE TOTAL AMOUNT PAST DUE TO THE LENDER, WIllCR IS $4,334.45 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WIllCR BECOME DUE DURING THE THIRTY (30) DAY PERIOD.l'avment must be made either bv cashier's check. certified check or monev orderm.de oavable and sent to: CITIFlNANCIAL MORTGAGE COMPANY. 4501 ERSKINE ROAD. SUITE 50. CINCINNA TL OR 45242-4713. AITN: ROLLY CARROLL. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not apolicable) N/A. IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to foreclosure uoon vour mortgage oropertv. ~' "~'-, IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorney, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00, Any attorney's fees will be added to the amount to the lender, which may also include other reasonable costs, If vou cure the default within the THIRTY (30) DAY period. vou will not be reQuired to pav attornev's fees. OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage, RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- 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 time UP to one hour before the Sheriff s Sale. You mav do so by paving the total amount then past due. plus anv late or other charges then due. reasonable attornev's fees and costs C<:Jnnected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing bv the lender and bv performing any other reauirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DA TE- It is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriffs 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 any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER- CITIFINANCIAL MORTGAGE COMPANY 4501 ERSKINE ROAD, SUITE 50 CINCINNATI, OH 45242-4713 ATIN: HOLLY CARROLL TEL. NO. 1-877-222-1140 EXT. 6680 EFFECT OF SHERIFF'S SALE- You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You _ mayor XX may not (check one) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charge and attorney's fees and cost are paid prior to or at the sale that the other requirements of the mortgage are satisfied. _':.o!' ,,-' YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED, ~[yyours, . i ~<;-.""'-7c"~~,~,,,"'L0.-- f , ' - .. ' ATTORNEY FOR I::ENDER ~- - -^ - NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT ************************************************************************ 1. This is an attempt to collect a debt and any information obtained will be used for the purpose, 2. Unless you dispute the validity of this debt, or any portion thereof, within thirty (30) days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within thirty (30) days ofreceipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. 4. If you notify our offices in writing within thirty (30) days of receipt of this notice, our offices will provide you with the name and address of the original creditor, if different from the current creditor. F"' '. .'-~ Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) Lt:mit;g~linton Counties 213:B:::"~ J:e~ommunity Action (STEPI P. O. Box 1328 (Wi5~i:unspo",,, PA 17703 ,0) 326.0587 FA."C (5701322.2197 CCCS oO!ortheastetn PI\. 201 Basin Street . W"illiama (5~01 3 port, PA 1 i703 , 23-6627 FA."C (5701 323-0626 ' CLINTON COI:JNTY CCCS of Northeastern Po,. 1631 S AthertOn Se . Suite 100 State College, PA 16301 (8141 238-3668 FA."!: (814) 238-3669 COLUMBIA COUl'<n CCCS ofNortheastem Pennsvlvania 1400 Ahington Exe<:".1tive Park Suite 1 Claru Swnmitt PA 18411 (5701587.9163 or (8001 922-9537 FA."!:(5701587-91~135 31 W. Market Street PCB 1127 W"Ukes.Barre, P.... 18702 (5701 821.0837 or (8001 922.9537 FA."C (5701821-1785 Commission on Economics Opportunity of Luzerne County 163 .-\mOOr Lane W"Ilkes-Barre, P.... 18702 (5701 826-0510 or (8001 822-0359 FA."C (5701 829-1665-CALL BEFORE FA."ClNG (5701 455-4994 HAZELTON FAX (5701 455-5631-CALL BEFORE FAXING (5701 836-4090 TUl'lKHAI'!"NOCK Booker T. Washington Center 1720 Holland Street Erie, P.... 16503 (814) 453-5744 FAX (814) 453-57"9 John F. Kennedy Center, tnc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX (8141 898-1243 CCCS of Western Pennsylvania. tnc. 2000 Linglestown Road Ramsburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6th Street Ramsburg, PA 17101 (717) 234-5925 FA."{ (7171 234-9459 CollUllunity Action Co= of the Capital Region 1514 Derry Street Ramsburg, P....l7104 (717) 232.9757 FA."C (7171234-2227 CRAWFORD COUNTY Greater Erie Co=unity Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 , SlienaII&o Valley Urban League, Inc 601 tt..:I;""ft"" Avenue Farrell. PA 16121 (412) 981-5310 . CUMBE1U.A4"lD COUNTY Fin,n,,;,1 Counseling Services of Franklin 31 West 3rd Street , Waynesboro, PA 17268 (7171 762-3255 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (7171243-3818 FA."C (7171731.9589 Adams County Housing Authorit'J 139-143 Carlisle St Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 PENNSYLVANIA BULLETIN. VOL 29. NO. 23. JUNE 5, 1999 .~ - ...:><;" . VERIFICATION The undersigned hereby states that the statements made in the foregoing Pleadings are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. d!PUA--f!~~ Doris P. Smith Foreclosure Specialist 'Cl' ';;,$":'''''" _~~ili!j;;-""-;1iliir~tHl"";,~illI.%";jiM'1"iill.l&"<r!01i,*~,,,...~,,c,h':c,<rj,_,,~",~;_",iH"",,"HHtg~ ~~c= "'. _. ,',..-, ',~-, , _c ^=, ~. ,.""" , ' '~ J.1~ ~-m~illIV ffi R t /l .- { ~ ~ ~ C3 Q ......~. () ~ 'U I -- ~~ J- ~,... -~-'"-"'-Ill.~w~- ,. . . ~ 0 ~~) c3 c:: ; -0 , '-- .--, G IT' , ~ . ~. .) ~ .. u:: (:;:.:., r-~ '. ; 'Je. ,".. .- .. < .' " -.. , ),-~ Cj ;'-i"1 C:-.= ~--~ 2': " ; --- :.0 " r ...:} -< ~I~~ "."~--" ~- _.-.,n" -- ',-, SHERIFF'S RETURN - REGULAR CASE NO: 2000-05278 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMECOMINGS FINANCIAL NEWTWORK VS STAHL PAULA H ROBERT L. FINK , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STAHL PAULA H the DEFENDANT , at 1745:00 HOURS, on the 10th day of Auqust , 2000 at 2101 LAMBS GAP ROAD ENOLA, PA 17025 by handing to PAULA STAHL a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 7.44 .00 10.00 .00 35.44 ~~~ R. Thomas Kline 08/11/2000 GREGORY JAVARDIAN a.- me this /'1 ~ day of By: 6?i!ii~~;/J;- eputy S eriff Sworn and Subscribed to before a.Q;.';'~ A.D. rothonotary ~ - ...........'" " -- -,... ," , LAW OFFICES OF GREGORY JAVARDlAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO, 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (2 I 5) 942-9690 HOMECOMINGS FINANCIAL NETWORK 8275 SKY PARK COURT, 3RD FLOOR SAN DIEGO, CA 92123 COURTOFCO~ONPLEAS CUMBERLAND COUNTY No.: 00-5278 CIVIL vs, PAULA H. STAHL 2101 LAMBSGAP ROAD ENOLA, PA 17025 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against PAULA H. STAHL, Defendant, for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As Set forth in Complaint Interest 8/1/00 to 9113/00 $97,447.33 1.163.80 TOTAL $98,611.13 I hereby certifY that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached, Damages are hereby assessed as indicated. V ARDIAN, ESQUIRE laintiff DATE: 9- (J..-~ ~ Q J~AD'_ PRO PROTHY v,-# '0 ~ _~il>(iUt;~~"!!ll;#!~'j~Ul!~%\'.'''t~,";Wf0,;;4V.wi-",,~WlW-~ "..'.' ~-. .'m<u 1 "iIl1lii~ "'-<, -'-"""""l_ll!!lL ,^" ~. .,~ u , .....- 0 C:.:: ~ r'~'. ,- ? U) " -oCT.,\ \~..., -, fil n: -0 Z:T: "7r-- c.) ~~:.~' r:;' l.:-" ....] '< ~:~~, ~) PC''': --, :::~. --,-". ::s -< cO -, - ~ ~"~~ ""~-' - ~, - _L _~m""~~" - c' , 'k.\i ,~ , HOMECOMINGS FINANCIAL NETWORK In The Court of Common Pleas Plaintiff Cumberland County v. No. 00-5278 CV PAULAH. STAHL Defendants TO: PAULAH. STAHL DATE OF NOTICE: 9/1/00 NOTICE, RULE 237.1 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims se forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. Cumberland Bar Association Lawyer Reference Se~ r" 2 Liberty Aven?n~ ~ Carlisle, PA 1701 (717) 249-3166 Gregory Javardian, Esquire 44 Second Street Pike, Suite 101 Southampton, Pa 18966 (215) 942-9690 Attorney for Plaintiff Usted se encuentra en estado de rebeldia por no haber tornado la accion requiida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de esta notificacion, el tribunal podra, sin necesidad de compararecer usted en corte 0 escuchar prueba alguna, dictar sentencia en su contra, usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatemente si usted no tiene abogado, 0 si no tiene dinero suficiente para tal servicio, vaya en persona 0 llame por telpfono ala oficina, cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assistencia legal. "NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE" -~""'~'''' . -....~ , - ~' '" .- _ 'l\.. LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (2 I 5) 942-9690 HOMECOMINGS FINANCIAL NETWORK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No,: 00-5278 CIVIL PAULA H. STAHL VERIFICATION OF NON-MILITARY SERVICE GREGORY JA V ARDIAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) Defendant, PAULA H. STAHL, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) Defendant, PAULA H. STAHL, is over 18 years of age, and resides at 2101 LAMBSGAP ROAD, ENOLA, P A 17025. (c) Plaintiff, HOMECOMINGS FINANCIAL NETWORK, is an institution conducing business under the Laws of the Commonwealth of Peunsylvania with an address of 8275 SKY PARK COURT, 3RD FLOOR, SAN DIEGO, CA 92123. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. J ARDIAN, ESQUIRE .;;,~" - ".....""'~iW.l1bt:'ililME<if~-!@)fi.~,~M~lL~~'W'.l&1'!MW~.\'(;~~l;f~'Lil!lll'&ili",,4l:,_LWjJ)r!" -~ . - ~- .., .~ ~ -- '~ 't" r 2, .;:), ::J--., ~~ -~~ . ',,;I - ~ - - ",,~, () D --.J 1 - ."""-;,~,~- ~R~tu .~ ~ fell <I) c.v ~ ;f fib - r r ~\ ...... CN i -rJ iJ-:~ rllU; Z._, zt.- co ,. -< ~ d~C> ?,-,--, >c':: ~ jlilli'~" , C'") c:: .,c_ c~~ (.::=-- " "'" "' u <. -. :f) t'ij "''0 c,:; r:"? '0 -'--""' S,,) -< . ,-"".-.~ ,-,- ,~ ... - \ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HOMECOMINGS FINANCIAL COURT OF COMMON PLEAS NETWORK 8275 SKY PARK COURT, 3RD FLOOR CUMBERLAND COUNTY SAN DIEGO, CA 92123 No.: 00-5278 CIVIL vs, PAULA H. STAHL 2101 LAMBSGAP ROAD ENOLA, PA 17025 PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due $98,611.13 ..; Interest from 9/13/00 to Date of Sale @ $16.21 per diem Subtotal (Costs to be added) $ $ ~ "i- -"11I .. "-..... -, ~ ~ . ALL THAT CERTAIN tract or parcel ofland and premises, situate, lying and being in the Township of Hampden, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the center line of intersection of Legislative Route No. 21001 (Wertzville Road) and Legislative Route No. 21051 (Lambs Gap Road); thence along the center line ofLR 21001 South 85 degrees 30 minutes West, 214.94 feet to a point on line of lands now or late of Mary and Elizabeth Bretz; thence along lands of same North 10 degrees 30 minutes 18 seconds West, 469.26 feet to a point in the right-of-way ofL.R. 21051; thence through the right-of-way ofL.R. 21051 North 73 degrees 33 minutes 14 seconds East, 20.59 feet to a point; the center line ofL.R. 21051; thence along the center line ofL.R. 21051 South 27 degrees 21 minutes East 43.70 feet to a point; thence along same South 35 degrees 16 minutes East, 360 feet to a point; thence along same South 26 degrees 14 minutes East, 117.70 feet to a point in the center line ofIntersection ofL.R. 21051 and L.R. 21001, the PLACE OF BEGINNING. HAVING THEREON ERECTED a stone and frame dwelling house, small cottage, garage, and other small buildings, BEING KNOWN AS 2101 Lambsgap Road, Enola, PA. BEING THE SAME PREMISES which Gary L. Stahl and Paula H. Stahl, his wife, by Deed dated June 20,1985 and recorded July 22,1985, in the Recorder's Office of Cumberland County, Pennsylvania, in Record Book J 31, page 567, granted and conveyed unto Paula H. Stahl. ""'-' ;It.!iWri'i."iii,ii@ji~itlt~.l'~..Jill'.iEi";;f;'liWl,;,)d,,,i.,""!;J,,)"j~"'~iL~iJi~'" .j,;.",-.','" - --, .L.~", '" - ~ C- ~ (:) c --:z 't: c1 - ~ ~ ~~ - ~~ ~ ' \ ~ Q; :t '(j -- \.:) .-0' (', ~;; ~~t (j))"- -,/ -- 1}~ -=1 -< -u_~< S~~? ~ ':--:;. --n (J) "1 -1) (..J -n ~: r;~ .;:; ~ :::--1 ~ =< '0 "' .l" . ;:i ~ [i " II II i ~ .~ '"'J,,,,,~"""""""'_> "- -~~ ~<iil~,:- . ... HOMECOMINGS FINANCIAL NETWORK COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY PAULA H. STAHL No.: 00-5278 CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 2101 LAMBSGAP ROAD. ENOLA PA 17025: 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PAULA H. STAHL 2101 LAMBS GAP ROAD ENOLA, P A 17025 2, Name and address of Defendant(s) in the judgment: PAULA H. STAHL 2101 LAMBSGAP ROAD ENOLA, P A 17025 3, Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. _'~I~O~ """ . ~ 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5, Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None, 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale, Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Rela1ions 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 2101 LAMBSGAP ROAD ENOLA, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. September 12,2000 r AN, ESQUIRE ..: '_.i" c~"'!k':""_'n,,,,,",,__""_'w.,,,,_,,,,,,,,,,....... -= .,_ ,_.""'"_~_-<> "ON < -'" ,~'" ~ --~ ,~-^-'","",~. ,. ,- ".........~- ="'~ .-~~~ q ~- ~~ C:) cl n ::./) r-'-' :-'1 " [1-: "T1 ~~ U1 _.. , r: ~-~ u i~i? J> ~ t:';.) c ~-, ....::... ''V ~ ::;:! ('~ 5.; < ~-~- ~ " # '. '!." ~ "~ " LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICA nON NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 HOMECOMINGS FINANCIAL NETWORK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 00-5278 CIVIL PAULAH. STAHL CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY AS TO THE SALE OF REAL ESTATE I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action and further certify this Property is: () FHA () Tenant Occupied () Vacant ( ) Commercial ( ) As a result of Complaint in Assumpsit (X) Act 91 complied with . ur!:p-ff~V""~:~OOi[ffilffi:l,~~:liil\ftj~;i>2'lio-!tr~~""'illi<t:,'"'l"'!'I'll"-'~~' .,'"" -"', ,,~~ -~ .~-, " ~- ~ ["'-- --~~ ~, ='-~"""" ~l.'ilIf' it . ._. iimilti i 1liI1ID'~'~~" - -ml&'""' ~..... - 'jjWlJ ~ti:~""'-"; ", ~..", ~&/. "i . j i 1 I ij 0 c;:; () c: c:) , I ~~;-. UJ ! U [',_'I ,71 " ,; fl'i L; , '''0 Z , 7 ,.:::..i C1:i . L-J " -< t , Cj s:::: -U -11 -, =~J (.~ -,,~ . C) ...-:;.,. , , , ['n '5 /'-' ~" ,- .,.-, / C'0 -.,...,. =:~ C"" -<. <::J " m . , .' . LA W OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO, 55669 44 SECOND STREET PIKE, SUITE JOJ SOUTHAMPTON, PA 18966 (215) 942-9690 HOMECOMINGS FINANCIAL NETWORK COURT OF COMMON PLEAS vs, CUMBERLAND COUNTY PAULA H. STAHL No.: 00-5278 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PAULAH.STAHL 2101 LAMBSGAP ROAD ENOLA, PA 17025 Your house (real estate) at 2101 LAMBSGAP ROAD. ENOLA. PA 17025, is scheduled to be sold at Sheriffs Sale on DECEMBER 6. 2000 at 10:00 A.M., in the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of$98,611.13, obtained by HOMECOMINGS FINANCIAL NETWORK, against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay, you may call: (215) 942-9690, 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 more chance you will have of stopping the sale, (See notice on page two on 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690, 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 ifthis has happened, you may call Gregory Javardian, Esquire at (215) 942-9690. 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 the 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, 6, You may be entitled to a share of the money which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days, 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale, YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 - ~.- " "lfi! ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Hampden, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the center line of intersection of Legislative Route No, 21001 (Wertzville Road) and Legislative Route No, 21051 (Lambs Gap Road); thence along the center line ofL.R, 21001 South 85 degrees 30 minutes West, 214,94 feet to a point on line of lands now or late of Mary and Elizabeth Bretz; thence along lands of same North 10 degrees 30 minutes 18 seconds West, 469.26 feet to a point in the right-of-way ofL.R. 21051; thence through the right-of-way ofL.R. 21051 North 73 degrees 33 minutes 14 seconds East, 20,59 feet to a point; the center line ofL.R, 21051; thence along the center line ofL.R, 21051 South 27 degrees 21 minutes East 43,70 feetto a point; thence along same South 35 degrees 16 minutes East, 360 feet to a point; thence along same South 26 degrees 14 minutes East, 117,70 feet to a point in the center line of Intersection of L.R. 21051 and L.R. 21001, the PLACE OF BEGINNING. HAVING THEREON ERECTED a stone and frame dwelling house, small cottage, garage, and other small buildings, BEING KNOWN AS 2101 Lambsgap Road, Enola, PA. BEING THE SAME PREMISES which Gary L. Stahl and Paula H. Stahl, his wife, by Deed dated June 20,1985 and recorded July 22,1985, in the Recorder's Office of Cumberland County, Pennsylvania, in Record Book J 31, page 567, granted and conveyed unto Paula H, Stahl. _MIlti!ll'j!"~ . ~~""'i!lil!;ii~jiHMili:I,~~~:;i;t't..'M'-'i.l'"'~;"'i<-l!li,,'&;1ill;)1iI':M:iilIM' - J~ ~.--I ~'._ -.lIIt'. :JlI~""""Oi;!;""""";<;';""""'j"iT-~}t~; ~'liM'ii!llHiil''':';:"" --",--~"",," -~, 0 ~ C) ~,' c:: C:J -i'J :s: u') "'[) ",'-- c., n-I ,'" -0 -- .Z L~ : 2' ;Ti (JJ " G.) '..-' , -< ", t""', ~::-' '...' '.::.-! " ~'\'i - ;.j -, > ..0:':'" " ) :> C 1'..) C; tn (= :;:l -"\,,) ;:;:~ -~ -<, (::J -< ~ ~'".--- ,<I. . " , ~ , , Homecomings Financial Network -vs- Paula H. Stahl In The Court of Common Pleas of Cumberland County, Pennsylvania No, 2000-5278 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff s c.osts: Docketing Poundage Advertising Posting Bills Law Library County Mileage Certified Mail . Levy Postpone Sale Surcharge Share of Bills Law Journal Patriot News 30,00 342.52 15.00 15.00 ,50 1.00 14,88 ,69 15,00 20,00 20,00 23.15 293,30 252.45 $ 1,043.49 Paid by atty 12/01/00 Sworn and subscribed to before me ~4-, R. Thomas Kline, Sfleriff This ;13 Ml,day of9w,-v""j 2000, A.D, ~lt... Q 'nn, fhJ, ~ P othonotary By~1::~.t4 )/eritr Real Estate Deputy ~ \ \, 3.\\"1 I ut", ()t.- c."" ,0 \?;u. .--- " ~ .. - ~ , --~ . HOMECOMINGS FINANCIAL NETWORK COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY PAULAH, STAHL No,: 00-5278 CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the teal property located at 2101 LAMBSGAP ROAD. ENOLA. P A 17025: 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PAULA H, STAHL 2101 LAMBSGAP ROAD ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: PAULA H, STAHL 2101 LAMBSGAP ROAD ENOLA, PA 17025 3, Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None, " . 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5, Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None, 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale, Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, P A 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O, Box 599 Carlisle, PA 17013-0599 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 2101 LAMBSGAP ROAD ENOLA, P A 17025 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief, I understand that false statements herein are subject to the penalties of 18 Pa. C,S,A. 4904 relating to unsworn falsification to authorities, t1l r GRE Att AN, ESQUIRE September 12,2000 .:..,; .,,"" LA W OFFICES OF GREGORY JA V ARDlAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO, 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 HOMECOMINGS FINANCIAL NETWORK COURT OF COMMON PLEAS vs, CUMBERLAND COUNTY PAULA H, STAHL No,: 00-5278 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PAULAH.STAHL 2101 LAMBSGAP ROAD ENOLA, PA 17025 Your house (real estate) at 2101 LAMBSGAP ROAD. ENOLA. PA 17025, is scheduled to be sold at Sheriffs Sale on DECEMBER 6; 2000 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, l"A 17013, to enforce the court judgment of$98,611.13, obtained by HOMECOMINGS FINANCIAL NETWORK, against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 942-9690. 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 more chance you will have of stopping the sale, (See notice on page two on 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690, 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 the 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, 6, You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 '~ ~ 'fili """ ~ .. ALL THAT CERTAIN tract or parcel ofland and premises, situate, lying and being in the Township of Hampden, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the center line of intersection of Legislative Route No, 21001 (Wertzville Road) and Legislative Route No. 21051 (Lambs Gap Road); thence along the center line ofL.R. 21001 South 85 degrees 30 minutes West, 214,94 feet to a point on line of lands now or late of Mary and Elizabeth Bretz; thence along lands of Same North 10 degrees 30 minutes 18 seconds West, 469.26 feet to a point in the right-of-way ofL.R. 21051; thence through the right-of-way ofL.R. 21051 North 73 degrees 33 minutes 14 seconds East, 20,59 feet to a point; the center line ofL.R. 21051; thence along the center line ofL.R, 21051 South 27 degrees 21 minutes East 43,70 feet to a point; thence along same South 35 degrees 16 minutes East, 360 feet to a point; thence along same South 26 degrees 14 minutes East, 117,70 feet to a point in the center line of Intersection of L.R, 21051 and L.R, 21001, the PLACE OF BEGINNING, HAVING THEREON ERECTED a stone and frame dwelling house, small cottage, garage, and other small buildings, BEING KNOWN AS 2101 Lambsgap Road, Enola, PA, BEING THE SAME PREMISES which Gary 1. Stahl and Paula H, Stahl, his wife, by Deed dated June 20, 1985 and recorded July 22,1985, in the Recorder's Office of Cumberland County, Pennsylvania, in Record Book J 31, page 567, granted and conveyed unto Paula H, Stahl. 0' ~ ~ -. . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 00-5278 Civil Term CIVIL ACTION - LAW TO THE SHERIFF OF Cwnberland COUNTY: To satisly the debt, interest and costs due Homecomings Financial Network PLAINTlFF(S) Irom Paula H. Stahl, 2101 Latnbsqap Road, Enola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property 01 the delendant(s) and to sell See LEcral Description ')""'""" ,n',; '" I' (2) You are also directed to attach the property 01 the delendant(s) not levied upon in the possession 01 ",. I,. ",":l' ( ',~'. . ~,: '~~ ',' ' GARNISHEE(S) as lollows: and to notny the garnishee(s) that: (a) an attachmanthas been issued: (b) the garnishee(s) is/are;~njcilned lrom paying any debtici or lor the account 01 the delendant(s) and Irom delivering any property 01 the delendant(s) or otherwise disposing thereOI; (3) II property 01 the deleridal1t(s) not levied upon an subject to attachment is lound in the possession 01 anyone other than a named garnishee, you are directed to notilyhim/tierthat he/she has been added as a garnishee and is enjoined as above stated, L.L. Due Prothy Other Costs $.50 Amount Due $98,611.13 from 9/13/00 to date of Sale Interest e $Hi :21 p€lr di_ Atty's Comm % Attypaid 5107.44 $1 nn Plaintiff Paid Date: September 13, 2000 Curtis R. Long Prothonotary, Civil Division ao..-... P - /1f-J?-'?'-. J Deputy by' REQUESTING PARTY: Name Gregory Javardian, Esq. Address: 44 Second Street Pike, suite 101 SouthaIlI>ton, PA 18906 Attorney lor~ Plaintiff Telephone: 215-942-9690 Supreme Court 10 No, 18966 bi,w"',w. ---.i~lIiIIifMii~~~~!il;Mi~g&\t;WWUihijf -~ .,I.,vi tIfjJ II"~ -~ - , ~- ;'~,,,. "--'[ REAL ESTATE SALE No.)/ on~ Jf, 'HnJ the sheriff levied upon the d8fendams Interest in the real property situated in .~L_ /'~ ~^""'~ Cumberland County, Pa" known and numbered as:~...Io J I!.. .4.!L..~~ ,(:.Illk- and more fuli\JBscribed on Exhibit "A" flied with ~ ~ ~ this writ and by this reference incorporated herein. ~7.: .I.. Jf,~ ~# 'j,XI I ~--i . 'i'j VI,:' '~I ",-,''''1,'\ ( ".'d "1, __" ,,1' (" Ii " b\ J3$ AUil,'- .,,(10 4JIlUH ; il\'.: JMAO < - "~,"~, , '- ,. ,<--.. <= .