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HomeMy WebLinkAbout00-05301 ';,' ~ , '" , l , 1 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Realty Corporation 961 Weigel Drive, P.O. Box 8634 Elmhurst, IL 60126 v. Jacob A. Quatrara 20 Subdivision Road Newville, PA 17241 and Carol A. Quatrara 20 Subdivision Road Newville, PA 17241 """'- '.;~"", '''' --~~"'" >,,,;~ ,., '=.,.~ " :,> ,.' "",to': i, " " ' "";;, ~7}"-'<-;:' '",~ '~"",;; ,"-"'."',"-",, ;;~~ ' ,,', Attorney for Plaintiff Cumberland County Court of Common Pleas Number 00 - 5'.101 (!'U~ lTeRJf CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE AVISO 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 defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered aga i nst 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TI!E OFFICE SET FORTI! BELOW TO FIND OUT WHERE YOU CAN GET HELP. Cumberland County Bar Association 2 Liberty Avenue Carl isle, PA 17013 (717) 249-3166 Le han demandado a usted en La corte. Si usted qui ere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas'o sus objeciones a Las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, La corte puede decidir a favor del demandante y requi ere que usted cumpLa con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos import antes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SINO TIENE ELDINERO SUFICIENTE DE P AGAR TAL SERVICO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRlTA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ---;-~.'- f - '"'- 0 0 ,'"",^,' ,"'So".__' , ~, .',"" C ~o ~ 0 ~~""j, ^"& ~ Cc ',4 d^ ;"';'J~;'",,;'~ 'V"',,,",,__ ':^,p,~g., "o"'~ '0' _";.."--,-<-';~,, ~:;-~" ",.0;1 'ri""] McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Household Realty Corporation 961 Weigel Drive, P.O. Box 8634 Elmhurst, IL 60126 Cumberland County Court of Common Pleas v. Jacob A. Quatrara 20 Subdivision Road Newville, PA 17241 and Carol A. Quatrara 20 Subdivision Road Newville, PA 17241 Number CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Household Realty Corporation, a corporation duly organized under the laws of Delaware and doing business at the above captioned address. 2. The Defendant is Jacob A. Quatrara, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last-known address is 20 Subdivision Road, Newville, PA 17241. 3. The Defendant is Carol A. Quatrara, who is one of the mortgagors and real owners of the mortgaged property hereinafter :; '. '. c '.. " ,,~ '" ~,' --, ,<'.' 'c, ''^''' =.';;">"<'.F.~O:""':"'i,""'~" "',' '~";", "~", ,-' ,', . ~' ,0,.-,)1 . described, and her last-known address is 20 Subdivision Road, Newville, PA 17241. 4. On 8/4/94, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1227, Page 381. 5. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as Box 102A Rural Route 2, Newville, PA 17241. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/1/99 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 month, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage: Principal Balance Interest 10/1/99 through 6/15/00 (Plus $8.70 per diem thereafter) Attorney's Fee Cost of Suit Appraisal Fee Title Search $21,331. 39 $ 3,685.45 $ 1,500.00 $ 225.00 $ 125.00 $ 200.00 GRAND TOTAL $27,066.84 8. 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 ,L' , . ,~,. '''' "-";,~" . 0/, ~-'_'.,' "'.~' """.",,'0 """ '--,--' ','~.>ioI"',"--~i',,:_,,;:'_';;,,,,~:,"',,;; ;;,:,~ i",.. f;; -',!;'~ , Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.G. ~403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by certified mail on the date set forth in the true and correct copies of such notices attached hereto as Exhibit liB. II WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $27,066.84, together with interest at the rate of $8.70 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgage property. ~N\~mco~mc.~ TERRENCE J. cCABE, ESQUIRE Attorney for Plaintiff ~,'" /i..,'?''f1l~~' - '. - ~.- I , ,~.' ......, =~ i~JUN 15 '00 11 :50 FR HFS-CPJ/CI I SERVICING530 515 7398 TO 912157901274 , " -S-J.S ~; 11 ~ ?o~ ~ n-?q~<6D:? MORTGAGE ~~:ti::t'~ P.03/15 QJ IF IlOX IS CHEa;:Il)). T}JIS MORTGAGE IS AN OPEN-END MORTGAGE AND SECURES FUTURE ADV ANCBS THIS MORTGAGE is made this 4TH day of AUGUST 19 ~. between the Mortgagor. JACOB A. aUATRARA ANO CAROL A. QUATRARA HUSBAND AND WI FE \hemn "tlorrower"), and Mortgagee HOUSEHOLD REAL TV CORPORAT I ON a corporation organize<! and exist5ng under the laws 01 DELAWARE 25 GATEWAV DRIVE. SUITE 101. MECHANI CSBURG. ~A 11055 \heretn "Lender" I. The following poragtaph p~ed by . checked box is applicable. n WHEREAS. llorrower is indebted to Lender in the principal sum 01 $ . e.rnienee4 by Borro....r's Loan Repaymmt and See\Jrity Agreement or Seoon<lary Mortgage J.,oan A&recment dated and any el<lensions or renewals theceol (herein "Note"), providing for monthly installments 01 prmolpal ana interest, including any adjustments to the amount of payments Or the contract rate if that rate is variable. with the balance of the indebtedness, if not sooner paid, dut ana payable on [JJ WHEREAS, Borrower i~ ind.ebted to Lender in the principal sum of $ 21 .600 . CO . 0' so much thoreof as may be advanced pUrsuant to llorrower's Revolving Loan AglWment datea AUCUST 4 , 1994 and extensions and renewals thereof (herein "Note"), providiD& for monthly installments, and IOterest at the rate and under the terms spo<;ified in the No..., tnol\lding any adjustments in the interest ",te if that rate is variable, and providin& for a credit limit stated in the principal S1Jm above and an initial advanee of $ 11.151. 00 TO SECURE to Lender the repayment of (l) the indebudne3S evidenee4 by the Note, with interest thereon, includin& any increo.... jf the contract rate is variable; (2) future aavances under any Revolving Lo.n Agreement; (3) the payment of all other sums, with interest thereon. advanced in accordance hetewith to protect the seourity of this Mortgage: and (4) the performance of the covenants and agreements of Borrower herein wntained,. Borrower aoos he,eby mortgage, grant and convey to Lendor and Lender's suc<:ossors and assigns tho following described property located in the County of CLMSeRLANO Commonwealth of Pennsylvania: BRIEF LEGAL DESCRIPTION: ALL THAT CERTAIN pROPERTY SITUATED IN THE TOWNSHIP DF UPPER MIFF"IN IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA. BEING MORE FULLY OESCRIBEO IN A OEEO DATED 01/09/92 AND RECORDED 01/09/92. AMONG THE LANO RECORDS OF THE COUNTY AND STATE SET ~ORTH ABOVE. IN OEED VOLUME ~~T AND PAGE 004. . CO ~ .::r! d:= ~ ""-- TAX MAP OR PARCEL 10 NO, 44-05-0031-060A ..." ::a . ....: 'N l'N C> ., 06-30-$4 ~tgilge PA ....':, (:RIGINAl " q':" .1. I 800';1227 PACE 381 \\ )1 (X\-II!?:,lTA . ,Who.se address is CD c"> c:: 3::"'", .,,"'0 ",<'>." ","""" ....""'" )>~-4 2: ,0 .~ '" . <,>ON 0-"- c:<:>'"' zm'" -trnr.;:; 0<0;<> , <J> ." ". PAOOU~f ~ ' "', "~=' '>",",",'" , " __.""'"O"''';'L;",''~ " '~, ",'.", ,,'';;;''''',i,', ',0";,,,,, ~:x.:,",'r':~;#,',io-,,;,;;_.;.;,;"...,~.o:~;'; <,"_ "'", '.'"", ., ''';:'i,[i';;~1 February 22, 2000 Jacob Quatrara 20 Subdivision Road Newville, PA 17241 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose. Specific information about the nature ohhe default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEAP) mav be able to help to save vour home. This Notice explains how the program works. To see if HEAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counseling Agencv. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end ohhis Notice. Ifvou have any questions, you mav call the Pennsvlvania Housing Finance Agencv toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869. This Notice contains important legal information. 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 fmd a lawyer. LA NOTIFICATION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUBS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASE. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUBDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUBDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: ORIGINAL LENDER: CURRENT LENDERlSERVICER: Jacob and Carol Ouatrara 20 Subdivision Road Newville. P A 17241 713303-17-8938037 Household Finance Corporation .\ "EXHiB IT 5 '~ ,--" '"" , ,,':,.':,;;~' , , ,'.'~, ",~ ;.;''''~,",-:.;~~",'"~,,,':.," "'d""" ,",'"",,,,,,, -''''",.~''-"", '.';;"_'",,''-' ~ ""0' ,,' c;i<",i.,."," "^,: ,,-,',..;-\i;iJ HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE 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 MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: - IF YOUR DEF AUL T HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, - IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND - IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end ofthis Notice. THIS MEETING MUST OCCUR WITHIN THE 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 TO CURE YOUR MORTGAGE DEFAULT." EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end ofthis Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-- Y our 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 financial 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 the 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. YOUMUSTFILEYOURAPPLICATIONPROMPTLY. IF YOU FAIL TODOSOORIFYOUDONOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION--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 Finance Agency of its decision on your application. ;;-. ,''_''' . ',',' "c' -' ,,^, '", , ' , .~,~, '_' "0 " "'",,'li;' ~' ;:",:Z..;~T"',~"c,,''''-____'' ?;,,'"'",,; ie"';'"' , ,; ~,i "c."~"';;~ NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to date). NATURE OF THE DEF AUL T --The MORTGAGE debt held by the above lender on your property located at 20 Subdivision Road Newville. P A 17241 IS SERIOUSLY IN DEF AUL T because: YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the following amounts are now past due: $300.00 for the months of November 1999 through February 2000 Other charges: TOTAL AMOUNT PAST DUE: $1267.82 HOW TO CURE THE DEF AUL T -- Y oumay cure this default within THIRTY (30) DAYS of the date ofthis Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1267.82. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or money order made payable and sent to: Margaret Smith Household Finance Corporation P.O. Box 4153 Carol Stream, IL 60197-4153 IF YOU DO NOT CURE THE DEFAULT--Ifyoudo 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 attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, 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, iflegal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. Ifvou 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--Ifyou have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and prevent the sale at anv time up to one hour before the Sheriffs Sale. You mav do so bv paving the total amount then past due. plus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure ',",. '" ",; ,'.'"',',"',,,;..','--,',;, ,',"~^',f,' ' ;o";;,~',, 'n~" ' ~,_ " E'''.' '-'..."T:~; "~ -,,' ,~'" ,,' ,,', _; ';,.,;:;,>..;~','< 'O-:"',,;G;~ __" -,-,.c~~_"'__~ _"" , ,,;,:,,<-,-,,,> sale and anv other costs connected with the Sheriff's Sale as specified in writing bv the lender and bv performing anv other requirements 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 POSSffiLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately from the date of this Notice. A notice of the actual date of the Sheriff's 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 fmd out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Household Finance Corporation Address: P.O. Box 4153. Carol Stream. IL 60197-4153 Phone Number: 1-800-609-4278. Ext. Fax Number: 630-617-7744 Contact Person: Margaret Smith EFFECT OF SHERIFF'S SALE-- Y ou 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-- Y ou mayor X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: - TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. - TO HAVE TIDS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. - TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE TIDS RIGHT TO CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) - TO ASSERT THE NONEXISTENCE OF A DEFAULT 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. FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE THE ATTACHED LIST. NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the validity ofthis debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain _ ",; \0 ~" <' ,"",~,', , , :' , ',';, ~,'-- '""~',,,,,:, "', -",,~.:;,,; "', "',i-";..'d_" '~.".';'''':':~',d-,-, ";"<,', ';>"'~[;,,: ,M'C" :',;:;"''-',;,,, ;..:: r ',:: ',,".V;;_.'':'''';, " ;.~;.lib;~, . a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the original creditor. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE. SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER Z 290 359 325 RETURN RECEIPT REQUESTED ,".",",''''' ^^'^ ^^'^ ,''''0 "c,""' .,,,.,';0",',,, <',,~' 0",' .' '~'",,,,,, ~,~, ,:,::",>-,__,,,,,,,,-,, ;,"";.;;",, " -c;:;" ;",,-~;,,,,J,'::,,' ~,__ :2,~j . February 22, 2000 Carol Quatrara 20 Subdivision Road Newville, P A 17241 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to save your home. This Notice explains how the program works. To see ifHEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when yOU meet with the Counseling Agencv. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions. you may call the Pennsvlvania Housing Finance Agencv toll free at 1-800-342-2397 (J.'ersons with impaired hearing can call (717) 780-1869. This Notice contains important legal information. 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 NOTIFICACIO EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASE. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGffiLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Jacob and Carol Ouatrara 20 Subdivision Road Newville. P A 17241 713303-17-8938037 Household Finance Corporation .,,'; ".,~ ' ."-. ;, ~" ,",.." C,",,,,, '''''0,'"',, ,~__,>;;"""~:,-,,,;:,--~,"",'~'';';'_,i ,--,," ~" '" '___C' ""~",~..;',~"j,W "/,;'~~,""",,:,, ",0",':;;;,,11 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE 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 MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: - IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, - IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND - IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end ofthis Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF TillS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT." EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers of designated consumer credit counseling agencies for the county in which the property 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 ASSIST ANCE-- 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 financial 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 the 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 APPLICATION PROMPTL Y. IF YOUF AIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION--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 Finance Agency of its decision on your application. ',>~~"~'~''''''l'',-, ~"'.,,~<~C"__'--i- """b',~, ",'''-- ",~ ::"'--''~'d,--,','_'~,'.;"j',,,,('i;,\;'._--",',~.' :"0Od c,>',,;,,c; '";,, :,,;c";:\<:'~";;"',:',l>; ;:;", "",,,,,''i ,"~ ",c',_ :;':;,~~,j NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEF AUL T --The MORTGAGE debt held by the above lender on your property located at 20 Subdivision Road Newville. P A 17241 IS SERIOVSL Y IN DEFAULT because: YOVRA VB NOT MADE MONTHL YP A YMENTS for the following months and the following amounts are now past due: $300.00 for the months of November 1999 through February 2000 Other charges: TOTAL AMOUNT PAST DUE: $1267.82 HOW TO CURE THE DEFAULT--You may cure this default within THIRTY (30) DAYS ofthe date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1267.82. PLUS ANY MORTGAGEP A YMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cash. cashier's check. certified check or monev order made pavable and sent to: Margaret Smith Household Finance Corporation P.O. Box 4153 Carol Stream, IL 60197-4153 IF YOU DO NOT CURE THE DEFAULT--Ifyoudo not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortl[!:age 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 attorneys to start legal action to foreclose UDon vour mortgaged proDertv. IF THE MORTGAGE IS FORECLOSED UPON-- The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, 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 attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe 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 Dav 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--Ifyou have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and . - ,..',c,,,.-'- "~,~,,--, , ~ ',~ ' ,,:~ " ",;'C"',' >c\;-- , ~'",', :c:"",i ;,-'. :'i', ,;"'.,;:..~ """,kl""'~ ".' '" ,"~ ..,\,~, ')",i "'-["rn prevent the sale at anv time UP to one hour before the Sheriffs Sale. You may do so by paving the total amount then past due. Vlus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as specified in writing bv the lender and by performing any other requirements 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 POSSffiLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 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: Name of Lender: Household Finance Corooration Address: P.O. Box 4153. Carol Stream. IL 60197-4153 Phone Number: 1-800-609-4278. Ext. Fax Number: 630-617-7744 Contact Person: Margaret Smith EFFECT OF SHERIFF'S SALE-- You should realize that a Sheriffs 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-- Y ou mayor X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements ofthe mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: - TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. - 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. FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE THE ATTACHED LIST. ,;,-<'d,,--: ~, "..,' -,;--~' '"' '''--' ',,"'~' ,.. ~"o' ",,,,,,,,",--,. ,~,C" '. ,,',",>"-',;, "'o'~'." "'i'--,! NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the original creditor. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT ADEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE. SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER Z 290 359 326 RETURN RECEIPT REQUESTED " 'J .. ",~ '"'',..'''" 0,'.," ';""","'6,~"",,, ~,,,', ~.., ,,,-,,.',\~'.a~','i"c'~'" :,,~,'o"_ ")',"A''''''-'~'..":;"""",,--,,,'L,,,,-' , '''',"' :':~.! PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, Pa 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, Pa 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, Pa 17101 (717) 234-5925 FAX # (717) 232-4985 YWCA of Carlisle 301 G Street Carlisle, Pa 17013 (717) 243-3818 FAX # (717) 243-3948 .',"'iii;;:lli~l;f .!d..l>~-""" , .~ ,', ," - .. r:' . . June 16, 2000 Occupant( s) Box 102 A Rural Route 2 Newville, PAl 7241 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortqaqe on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paqes. Tne HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the proqram works. To see if HEMAP can help, YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with yOU when you meet with the Counselinq Aqency. The name. address and phone number of Consumer Credit Counselinq Aqencies servinq your County are listed at the end of this Notice. If you have any questions. you may call the Pennsylvania Housinq Finance Aqency toll free at 1-800-342-2397 (Persons with impaired hearinq can call (717)" 780-1869. This Notice contains important legal information. 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 NOTIFICACIO EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASE. SI NO COMPRENDE EL CONTENIDODE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Jacob and Carol Ouatrara Box 102 A Rural Route 2 Newville, PA 17241 713303-17-893803 Household Realty Corporation Household Realty Corporation ~~ ,-, ~ ">~' . , ~ 'c. ~ '"'<'~.1'1-">t1; . HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE 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 MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: - IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF 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. TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange 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 THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR M€JRTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGA@E DEFAULT." EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of desiqnated consumer credit counselinq aqencies for the county in which the property 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 immediately 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 financial 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 the 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 APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE -",'~ ~~-- """\ilIilililiilii;.~' v ,~~ "~""I_J~ M~~",'i , . 'MAY ~ROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility cri teria 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 Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (BrinG it UP to date) . NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at Box 102 A Rural Route 2 Newville. PA 17241 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the following amounts are now past due: $342.00 for the months of November 1999 throuqh June 2000 Other charges: TOTAL AMOUNT PAST DUE: $2,518.82 HOW TO CURE THE DEFAULT--You may cure this default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,518.82, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cash. cashier'S check. certified check or monev order made pavable and sent to: Arely Calderon Household Realty Corporation P.O. Box 8604 Elmhurst, IL 60126 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 ,',,"..J..~----.i,J;,,"J,II~' 1l<i~1liIIIil"'i-"~"~ , nMffj;/ , i ~aym~~t of the total amount past due is not made within THIRTY (30) DAYS, the lenqer also intends to instruct its attorneys to start legal action to forebloseupon Your mortqaqed property. IF ~HE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the :1?n.eriff to payoff the mortgage debt. If the lender refers your case to its 'attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attO'lmey'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 attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the THIRTY (30) DAY period. YOU will not be required to pay attorney'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, vou still have the riqht to cure the default and prevent the sale at anv time UP to one hour before the:Sheriff' s Sale. You mav do so bv pavinq the total amount then past due. plus anv late or other charqes then due. reasa,nable attornev's fe~s and costs connected with the foreclosure sale and anv other costs connected with the :Sheriff's Sale as specified in writinq bv the lender and bv performinq anv'other requirements under the mortqaqe. Curing your default in the manner s.et forth in this notice will restore your mortgage to the same position as if you had neyer defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately fiye months from the date of this Notice. A notice of the actual date of the Sheriff's 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: Name of Lender: Household Realtv Corporation Address: P.O. Box 8604. Elmhurst. IL 60126 phone Number: 1-800-959-3482. Ext. 7695 Fax Number: 630-617-7744 Contact Person: Arelv Calderon 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. ,hiolYii.""'~. """""""""'';:' .~ ........bJ". "~-t. ) ~ ~ASSUMPTION OF MORTGAGE--You mayor X may not sell or transfer your home to a buyer or transferee who will assume the mortgage aebt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. 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 DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YODR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) - TO ASSERT THE NONEXISTENCE OF A DEFAULT 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, FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY~ PLEASE SEE THE ATTACHED LIST. NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the original creditor. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE. SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7000 0600 0025 7949 1565 RETURN RECEIPT REQUESTED "", ~~ ""-.J><:rlI!. ~~ ' ,"""', ."'-""""t"'j"j . .' PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, Pa 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, Pa 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, Pa 17101 (717) 234-5925 FAX # (717) 232-4985 YWCA of Carlisle 301 G Street Carlisle, Pa 17013 (717) 243-3818 FAX # (717) 243-3948 ,'" , ~'" ,~ , " ~ ~ ~ . .' . VERIFICATION The undersigned, Renee Turner, hereby certifies that she is the Foreclosure Specialist of the Plaintiff in the within action, Household Realty Corporation, and that she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. ~4904 relating to unsworn falsification to authorities. ~~ .V\OO ~ RENEE TURNER ~~~!ihJi,1lili;\j~""'i'iili!i~,"!i!'i<!-d!ko-!d;,.""'I'i'''-,i;;;:<I!<i';-''Illi..ilffi."".RW'-.jOIIit~~jf;i;'-= 'iHI~.' .L'-,-, - ,'~ ~"" ~~~jiilJJil.lliiiIIiSif~' ". l? (:J .r ~ '"' h ~ ~ ~ (j 8 P '" I -., -..t ,..J I ~ -- r Pi;J ~t J:... ", ^" ~ ,~ _" ~,__~,~" ~,' ,>c' " , -- ,~ __0,' ", {Q. ~ Irt 0' """"""'''i:&d(_~jj" -~"1' ) [! ~<--- :'! ~'-i -.;. o !:; : ..~ 0"1, r:) " ('.'!.:; ~ '~) t. ..:.. ~...tI -<: ',." , , .. . n ~, ,,-OJ 8 ;:: C', ~-~~~'" ~ . ;.;i SHERIFF'S RETURN - REGULAR CASE NO: 2000-05301 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD REALTY CORPORATION VS QUATRARA JACOB A ET AL BRIAN M BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon QUATRARA JACOB A the DEFENDANT , at 1025:00 HOURS, on the 3rd day of Auqust , 2000 at 20 SUBDIVISION ROAD NEWVILLE, PA 17241 LANITA EICHELBERGER, GIRLFRIEND by handing to 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 18.00 8.68 .00 10.00 .00 36.68 So Answers.,: .", ~'''''''''t~ ::;;9" ~ ~j~Jr'<; ," 1":'" ,r<<:4'" R. Thomas Kline Sworn and Subscribed to before ~ me this 36 - day of 08/28/2000 MCCABE WEI/S;~ERG CONWAY By: ( Deputy Sheriff 0, 't'....Y oZcv-o cA. D. g&h~nCJt?:; Pf), . ) J f ~'5 cW ~-~,~ ,~ "" ~ -~ ,';;) SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-05301 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD REALTY CORPORATION VS QUATRARA JACOB A ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: QUATRARA CAROL A but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of BLAIR County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On August 28th , 2000 , this office was in receipt of the attached return from BLAIR Sheriff's Costs: Docketing Out of County Surcharge BLAIR COUNTY 6.00 9.00 10.00 29.50 .00 54.50 08/28/2000 MCCABE WEISBERG S~ ..~? ;./~?/ R 'Thomas Kline Sheriff of Cumberland County & CONNELY Sworn and subscribed to before me this 3(Jb day of ()u~ dlH-O A.D. n_ . nu 0- 7kl.ft'J ~ '---'M Prothonotary' r- ,,"> DATE RECEIVED DATE PROCESSED O.lb7 '< \V SHlE~~~~~~~~~:~ENT 1- 5~- ~ SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN INSTRUCTIONS, Print legibly, insuring readability of all copies. Do not detach any copies. BCSD ENV. # 1. PLAINTIFF I S I eJo~ 3. DEFENDANT I S I SiE{ AT 5. ud. ,VA /7 ~41 PERSON IN CHARGE DOE oCERT.MAILoAEGISTEREOMAIL oPOSTEO oOTHER BLAIR . COUNTY, f>A., do hereby deputize the Sheriff of County to execute this Writ and make return thereof according to law. This deputation being made at the request and risk of the plaintiff. 6. NOW, _, I, SHE IFFOF SHERIFFiOF BLAIR COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any depUly:sheriff levying upon or attaching any property under within writ may leave same without a watchman, in cwslody of whomever is found in possession, after I')olifying person 01 levy or a,t~~chment, without liability on the part of such deputy or the sheriff 10 any plaintiff herein for any loss, destruction or removal of any such property before sheriffs' sale thereof. 9 SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: 10. TELEPHONE NUMBER 11. DATE I acknowledge receipt 01 the writ 12. or complaint 'I.S indicated above. URE of A~thorized B,C~DI\Deputt or Clerk. and Title I 13. ,Date Received l'\ \ ,:)~t:lU"~-(<...o~ 15. I hereby CERTIFY and RETURN that 1 have personally served, Dhave served person in charge, D have legal evidence of service as shown in "Remarks" (on reverse) o nave posled the above described property with the writ or complaint described on Ihe individual, com'pany, corporation, etc., at the address shown above or on the individual, company, corporation. elc" at the address inserted below by hand ing/or Posting a TRUE and ATTESTED COPY lhereof. HERIFF ONLY - DO NOT WRITE~ELOW THIS LINE I 14. Expiralion/Hearing date 7J:"';n-()O 16. O! hereby certify and return a NOT FOUND because I am unable to locate Ihe individual. company, corporation, etc., named above. (See remarks below) 17 Name and title of indivIdual served 18. A.person of suitable age and discretion ~ ,- '--A r-.'. then residing in thedefendanfs usual:place """",o.....:t"(' fo..oP"'"lo"'-" of abode. D Read Order o 19. Address of where served (complete only if different than shown above) (Streel or RFD. Apartment No.. City, Boro. Twp.. Slale and ZIP Code) 20: Date 01 Service 21. Time -$' Afi'I€. '&/;n}/)o I ~oOV5 22. ATTEMPTS Date Miles Date Miles Dep. Int. Tot,1 Co"" c!l9.5() C8G'!cl 0:50 30. REMARKS SO ANSWER. Not lal Seal , Notary Public OTAAY 0.., My Commis\IIO" Expiras Feb. 3, 2003 Dale if (}(}.!t:O Dale MY COMMISSION EXPIRES. " I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE OF AUTHORIZED ISSUING AUTHORITY AND TITLE. 39. Dale Received - ,-- ., '~', .', ....~'.........leE () (1) The within upon defendant ,by mailing to , by prepaid a trueant:l attested copy thereof at . the within named mail, return receipt requested, postage 0foi'ffiii ( ) . (2) The return receipt signed by defendant on the mad~part of this return. Outside the Commorlwealth, pursuant-to Pa. R.C.P. 405 attested copy thereof at'" eo' " is hereto.altached and (c) (1) (2). by mailing a true and in the following manner. ( ) (a) To the defendant by ( ) registered ( ) certified mail. return receipt requested, postage prepaid, addressee only on the ; said receipt being returned NOT signed by defendant. but with a notation by the Postal Authorities that defendant refused to accept the same. The returned receipt and envelope is attached hereto and made part of this return. And thereafter: ( ) (b) To thedefel'ldant by ordinary mail addressed to defendant at same address. with the return address of the Sheriff appearing thereon, on the ,__ I further certify that after fifteen (151'days fmm 1hemailing date, I have not r~ceived said envelope back from1he Postal Authorities. fA .certificate of mailing is hereto atlachedas a proof o/mailing. - ( ) . (3) By pUblication in a daily publication of generill circulation in the County of Blair Commonwealth of Penosylvania,-1iffle (s) wilp publication appearing , , The affidavit from said publication is hereto attached. () (4) By mailing to by mail. return receipt requested, postage prepa.id, on the a true and attested copy thereof at _ returned by the Postal The Authorities marked is hereto attached. () (5) Other ... ~- . """H_.~, " ~ . 'I rJlml!ll!llIfInlllle!~1 / .In The Court of Common Pleas of Cumberland County, Pennsylvania .Household Realty Corporation VS. Jacob A. Quatrara, et. al. Serve: Carol A. Quatrara ., . ~" _" r.~ . . "-Ok No: 70-')101 rivi 1 Now, 8/14/00 ,200 (j , T, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Blair County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. L/:XII! . .. . ~~~~~-" ,Sheriff of Cumberland County, P A Affidavit oi Service Now, ,20_, at o'clock M. served the within upon at r by handing to a copy ofthe original and made lmown to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ 'J.~MWJiil/i;~'> - ~ ,~ . ~ !~" -, " McCABE, WEISBERG AND CONWAY, P. C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Realty Corporation vs. Jacob A. Quatrara and Carol A. Quatrara CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 00-5301 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $27,066.84 Interest from 6/16/00-9/25/00 $ 878.70 TOTAL $7,945.54 ~ .[ l ------ TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff AND NOW, this 1t).;It day of 001- , 2000, Judgment is entered in favor of Plaintiff, Household Realty Corporation and against Defendants, Jacob A. Quatrara and Carol A. Quatrara and damages are assessed in the amount of $27,945.54, plus interest and costs. BY THE PROTHONOTARY: .RI a/JL "e~ .-,,~, ~"''''<~1i~~~~~~'Ii'~~~~:il&"&.J''j~o&il''''-'- i.JJ~~iiMr .fiiIIIliiltP"'~~II''(j ... -= "~~.'~~~1iiii!f'''' --. ...." o c <: -or: rn6~ Z:T) ~~i- J;::C: ~8 >r-': ~ .' ,- 0.- o o " --1 () -n c :~~; ~~~ ~~~~ '- 5J -< ..... ~~ I"" (:I; ~. "'e-..,'Th'''' ~-~~,--,.-,_, , ,.,~.. =, -~ .,.,,,~. ".-,"-~..""'\c<>'~'-oi-"""'1"" ""'~"~'"""'- . ~,,--o-., .',"".<r"",".=;'".\"~--0,V~~"""_', ~ - ,_ _ ....-'. t. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Realty Corporation vs. Jacob A. Quatrara and Carol A. Quatrara CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 00-5301 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendants are 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; and that the Defendants, Jacob A. Quatrara is over eighteen (18) years of age, and resides at 20 Subdivision Road, Newville, PA 17241 and further Co-Defendant, Carol A. Quatrara is over eighteen (18) years of age, and resides at 1216 Pleasant Valley Blvd., Altoona, PA 17241. SWORN TO AND SUBSCRIBED BEFORE ME THIS J..tj""'DAY OF ~. , 2000. U LL -/ TERREN J. McCABE, ESQUIRE Attorney for Plaintiff iii . O.~ !OT~IC . NOTARIAL SEAL . GLORIA D. MiTCHELL, Notary Public City 01 Philadelphia, PhUa. Coun\V Commission Ex ires June 2, 2003 ,-- > .",...'~ " =-~'" c "'~ ..:...","" '" ~ ~ ~ - (') c,) C CJ <" C) uC:,~ n [lIL .-1 Z..'. Zc-. 0),.'.- a -<..< r:::CJ ~8 >c: ~ Z ~ :.< U1 "". ,0 Ii 1'1 ~! :1 i ;; Ii \:.... ., :-1If - ~ " ;;- .. " McCABE, WEISBERG AND CONWAY, P. C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Realty Corporation vs. Jacob A. Quatrara and Carol A. Quatrara CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-5301 CERTIFICATION I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the Complaint and is calculable as a sum certain from the Complaint. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. A true and correct copy of the notice pursuant to pennsylvania Rule of Civil Procedure No. 237.1 is attached hereto and marked Exhibit "Au. SWORN TO AND SUBSCRIBED S-H, DAY U tz '-- TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff BEFORE ME THIS OF De+ 2000. o I [ L GLORIA O. MITCHElL, Notary PubRc City 01 Philadelphia. Phila. CounlY M Commission Expires June 2, 2003 ~:-, _-", ,',1 ......~I_li;; >, _.~~__.",' ;,.",".~~" 0- 'Le.~il:I;,o:;-~~..Li!fl.-tliiJj .IIIIiiiIii. Cl c:: s::: iJrtl n"I'1- ~ 5~~~ ~e ~t} '> ZG ~~~ Z -, -< " .. o C) C::> C) ..-j f-} "11 c' ... (Jl " 'I II .. I , I I I I i ., ,~~,~- "', ' <,., - ,,'-, -,-. --", .^..",". -",- ',' ."-""""J<-""'=;y;",,, ",w"'_~_.,,,-."', ",;,,', '__~~_'_,~~,'~_;'. ,',"K''''''';,-.'_n_ ., :"wi! .. '. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Realty Corporation vs. Jacob A. Quatrara and Carol A. Quatrara CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 00-5301 CERTIFICATION Terrence J. McCabe, Esquire, attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail letters notifying the Defendants that judgment would be entered against them within ten (10) days from the date of said letters in accordance with Rule 237.5 of the pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibi t "7"' /J '-- [L.[t TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 6l:S ~AY ~. /um~~{} ~ !OTARY PUBLIC OF , 2000. NOTARIAL SEAL GlORIA D.MITCHEll, Notary Public "City of Philadelphia, Phila. County Mv Commission Exoires June 2, 2003 ~, ^ -,~. " ~~ ,. ~. ^,^,',- o s;;; -wf:': rn,--.. ~5': ~~~: s>~ ..-;:.-. ~ c') C) o C) --j Cl .,\'; ..~ o -"....., ~ <=- (j'" ,.., ! ! ! I. i i I , I f.'; ~- . --, ... ".~ ~ '-".'--.. ..- _''',.0 ,_,,___ ,.j~',," "-'--'-'~,' - 1!';';'''-",,- ,__ -.-;-"0- ,.."-"-,,,","'- .-'"~"":'b;o'-'\-:i.,",c _ -,;, ; -~, ^-'<-ii. :', - '. VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. CrA ~ ~~ TERRENCE J. McCABE, SQUIRE "'" -- ~........ ,. ~ "!.*,,~' OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, September LAWRENCE E. WELKER Prothonotary To: Jacob A. Quatrara 20 Subdivision Road Newville, PA 17241 Household Realty Corporation V. Jacob A. Quatrara and Carol A. Quatrara PA 13, 17013 2000 CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-5301 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT 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 set 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: Court Administrator Cumberland county Courthouse Carlisle, PA 17013 (717) 240-6200 NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber presentado una comparecencia escrita, ya sea personal mente 0 por abogado y por no haber radicado por escrito con sete Tribunal sus defensas u objeciones a los reclamos formulados en contra suyo. Al no tomar la accion debida dentro de diez (10) dias de la fecha de sata notificacion, el Tribunal podra, sin necesidad de comparecer usted en corte u oir preuba alguna, dictar aentencia en su contra y usted pOdria perder bienes u otros derechos importantes. Debe llevar esta notificacion a un abogado inmediatamente. Si usted no tiene abogado, 0 ai no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a Ia Oficina, nombrada para averiguar si puede conseguir asistencia legal. Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CONWAY, P.C. First Union Building 123 South Broad Street, Suite 2080 Philadelphia, pennsylv.....an..ia 19109 1i this telephone number: ~~~,~~ , at TJM/cj "fi\' OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COUNTY COURTHOUSE, CARLISLE, September i.-6'>>"..,,,~,,, --~ ~ ,~ -... .. CUMBERLAND LAWRENCE E. WELKER Prothonotary To: Carol A. Quatrara 1216 Pleasant Valley Blvd. Altoona, PA 17241 Household Realty Corporation V. Quatrara and Quatrara Jacob Carol A. A. flI!ltii' PA 13, 17013 2000 CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-5301 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT 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 set 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 proper~y 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: Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia par no haber presentado una comparecencia escrita, ya sea personalmente 0 par abogada y par no haber radicado por eacrito con este Tribunal sus defensas u objeciones a loa reclamos formuladoa en contra suyo. Al no tamar la accion debida dentro de diez (10) dias de 1a fecha de eata notificacion, e1 Tribunal pedra, sin necesidad de comparecer usted en corte u oir preuba alguna, dictar sentencia en au contra y usted pedria perder bienes u otros derechos importantes. Debe Ilevar eata notificacion a un abogado inmediatamente. Si usted no tiene abogado, 0 ai no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina, nombrada para averiguar si puede conseguir asistencia legal. Court Administrator CUmberland County Courthouse Carlisle, PA 17013 (717) 240-6200 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CONWAY, P.C. First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 this telephone n~exHi)Bif10,,~ at TJM/cj ,.-.... ' ~~~'Mlif~~:"ffiriI;1&'im,W1..~1~1,1.II~~~,,.,"i~j;,,',,i:,'lli:illii;'<I}:lM\"$>iloo'$ll!!1!I~A~a~b!~]j!l!l!W~~o~." . ~~"_.;...' , iIIloii~ -'lJ-"'........'n--~- ;I i .' - t , ~ ';l~ ~ \. 0 C..1 r..., , ~ ~ c: C) "-I -j "- '0_ ~ 0'-. a 10 , ~!r:::~ C) , ...... "T"J 9-.J ~ ~ 6}~; 71 "- ~ (~ :~~,~ ~~ ~ ....;~ ..:::... :i(-.; ~~ ~CI )~"".. _~~ =..-e: eC) :-:t;;: 6f~~ ~cj Pc Z C- ;;;! -' -< ()1 :xJ -< . . ... ''" "~ ._" _0 " .w_,. .,.,..,,-, ""'-'., k',. , ",".A" "'.""",& """""""''''',.",,;,.,., "'J..' '11 ..."",..". OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Jacob A. Quatrara 20 Subdivision Road Newville, PA 17241 Household Realty Corporation vs. Jacob A, Quatrara and Carol A, Quatrara CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 00-5301 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Curtis R. Long Prothonotary XX Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe. ESQUire at (215) 790-1010. ",-- ~'-~ ~_,o -"..,.,"~~.-~^,. '.";;:-<--~.-.'-""'"<-~'<"'~".,'<_'---'oic'12&.~~-o,.",,,;,,,."""'~_""-".'-'~">-'-i;",", -".."-'1 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Carol A. Quatrara 1216 Pleasant Valley Blvd. Altoona, PA 17241 Household Realty Corporation vs. Jacob A. Quatrara and Carol A. Quatrara CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 00-5301 NOTICE pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Curtis R. Long Prothonotary XX Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe, ESQuire at (215) 790-1010.