HomeMy WebLinkAbout00-06246
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FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANC AGENCY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. (J-O. t,;.1W... ~ T~
vs.
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON
Defendants
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOT ICE
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
the 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 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 PAPER 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 Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
S Irvine Row, Carlisle, PA 17013
717-243-9400
AVISO
LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE
ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
S Irvine Row, Carlisle, PA 17013
717-243-9400
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FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANC AGENCY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
vs.
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON
Defendants
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 31601:
The undersigned attorney is attempting to collect a
debt owed to the Plaintiff, and any information
obtained will be used for that purpose. The amount
of the debt is stated in this Complaint. Plaintiff
is the creditor to whom the debt is owed. Unless
the Debtor, within thirty (30) days after your
receipt of this notice disputes the validity of the
aforesaid debt or any portion thereof owing to the
Plaintiff, the undersigned attorney will assume
that said debt is valid. If the Debtor notifies
the undersigned attorney in writing within the said
thirty (30) day period that the aforesaid debt, or
any portion thereof, is disputed, the undersigned
attorney shall obtain written verification of the
said debt from the Plaintiff, and mail same to
Debtor. Upon written request by Debtor to the
undersigned attorney within said thirty (30) day
period, the undersigned attorney will provide
debtor with the name and address of the original
creditor if different from the current creditor.
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for plaintiff
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FIRST UNION NATIONAL BANK
AS TRUSTEE EOR PENNSYLVANIA
HOUSING FINANC AGENCY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01J - t..:l'-lG. ~ 't~
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON
Defendants
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
COM P L A I N T
1. Plaintiff, FIRST UNION NATIONAL BANK AS TRUSTEE FOR
PENNSYLVANIA HOUSING FINANCE AGNECY, pursuant to a Trust
indenture dated as of April 1, 1982 ("Trust"), is a national
Association with a servicing agent of Pennsylvania Housing
Finance Agency, with an address of 2101 North Front Street,
Harrisburg, Pennsylvania 17105.
2. Defendant, KIRK L. PATTERSON, is an adult individual
whose last known address is 125 EAST 15TH STREET, NEW CIMBERLAND,
PENNSYLVANIA 17070. Defendant, PATRICIA L. PATTERSON, is an
adult individual whose last known address is 125 EAST 15m
STREET, NEW CUMBLERAND, PENNSYLVANIA 17070.
3. On or about September 28, 1990, the said Defendants
executed and delivered a Promissory Note ("Note") in favor of
SOVRAN MORTGAGE CORPORATION ("Original Mortgagee") in the
principal amount of $63,837.00, the proceeds of which were used
to purchase a residential property located at 125 EAST 15TH
STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. A copy of the Note
is attached hereto and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to original
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Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds Office of the within County and
Commonwealth in Mortgage Book 992, Page 212 conveying to original
Mortgagee the subject premises.
The Mortgage was subsequently
assigned to CORESTATES BANK, N.A. and recorded in the aforesaid
County in Mortgage Book 387, Page 677 on October 1, 1990. The
Mortgage was subsequently assigned to MELLON BANK, N.A. and
recorded in the aforesaid County in Mortgage Book 531, Page 919
on October 7, 1996. The Mortgage was subsequently assigned to
PENNSYLVANIA HOSUING FINANCE AGENCY and recorded in the aforesaid
county in Mortgage Book 616, Page 722 on June 21, 1999. The
Mortgage was subsequently assigned to FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGNECY and will be
sent for recording. Said Mortgage and Assignments are
incorporated herein by reference.
5. The land subject to the Mortgage is: 125 EAST 15TH
STREET, NEW CUMBERLAND, PENNSYLVANIA 17070 and is more
pa.rticularly described in Exhibit "B" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. ,The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on April 1,
2000 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $
57,425.75
(b) Interest at $13.96 per day
from 3/1/00 to 10/1/00
(based on contract rate of 8.750~)
2,987.44
(c) Accumulated Late Charges
80.36
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(d) Late charges at $20.09
per month for 7 months
140.63
(e) Escrow Deficit
263.49
(f) 5% Attorney's Commission
2,871.28
$ 63,768.95
*Together with interest at the per diem rate noted in (b) above
after October 1, 2000 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
9. Notice of intention to foreclose and accelerate the loan
balance pursuant to pennsylvania Act No. 6 of 1974 is not
required in that the original principal balance exceeds
$50,000.00.
10. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers and Sailors Relief Act of 1940, as
amended.
11. The within Mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
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WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 8.750% ($13.96 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCE~~:~T po-_
By /'
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Attorney for plaintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
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FHA Case No.
Multistate
NOTE
441-416878-5 703
SEPTEMBER 28 ' 19 90
125 E. 15TH sr., NEJiI C1lMBERLAID, PA 17070
[Property Address]
APPLICATION # 162732
LOAN # 162732 /){
13:2-
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and .assigns. "Lender" means
SO\IRAN M:JR'IGAGE COREORATION. 201 EASI' c.!\Jrl STREEr. RIOMlNO. VIRGINIA 23219-3736
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of
SIXTY THREE THOUS1\ND. EIGlI1' HUNDRED THIRl'Y SS\IEN AND ID /100
Dollars (U.S. $ 63,837.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal,
from -the date of disbursement of the loan proceeds by Lender, at the rate of EIGffi' AND THREE QUARTERS
per cent ( 8.750 0/0) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same
date as this -Note and called the "Security Instrument." That Security Instrument protects the Lender from losses which might
result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
~ER 1 ,19 90 . Any principal and interest remaining on the first day of . OCI'OBER
20 20 , will be due on that date, which is call€;d the maturity date.
,
(B) Place
Payment shall be made at 201 EAST = STREE:I'. RIOMlNO, VIRGINIA 23219-3736
or at such other place as Lender may designate in writing.
(C) Amount
Each monthly payment of principal and interest will be in the amount of $ 502.21 . This amount
will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal. interest and
other items in the order described in the Security Instrument.
(D) Allonge to this Dote for payment adjustments
If an aUonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of
the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a
part of this Note. {Check applicable boxl
D Adjustable Rate Allonge
D Growing Equity Allonge
o Graduated Payment Allonge
o Other
S. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the
first day of any month.
6. BORROWER'S FAILURE TO PAY
(A) l.ate Charge for Overdue Payments
. If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C)
of this Note by the end of fifteen calendar days, after the payment is due, Lender may collect a iate charge in the amount of
FOUR per cent ( 4 %) of the overdue amount of each payment.
(8) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations
of the Secretary in the. case of payment defaults, require immediate payment in full of the principal balance remaining due
and aU accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent
default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment
in fun in the case of payment defaults. This Note does not -authorize acceleration when not permitted by HUD regulations.
As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs
and expenses including reasonable and customary attorneys' fees for enforcing this Note. Such fees and costs shall bear interest
from the date of disbursement at the same rate as the principal of this Note.
LYnlb it "A-"
G",-1FIB!ID61
Page I of2
VMPMOATGAGEFORMS' 13131293>8100' 18001521.1291
FHA Mullislale Fixed Rale Note. 6/89
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7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor.
"Presentment" means the right to require Lender to demand payment of amounts due, "'Notice of dishonor" means the right
to require Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be
given by delivering it or by mailing it by first class mail to Borrower at the .'property address above or at a different address
if Borrower bas given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated
in Paragraph 4(8) or at a different address if Borrower is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS 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 takes over these obligations, including the obligations of a guarantor,.
surety or endorser of this Note, is also obligated to keep aU of the promises made in this Note. Lender may enforce its rights
under this Note against each person individually or against all signatories together. Anyone person signing this Note may
be required to pay all of the amounts under this Note.
J
BY SIGNING BELOW, Borrower accepts and agrees to th:~~;:::thiS Note.
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(Seal)
-Borrower
(Seal)
-Borrower
(Seal)
-Borrower
Pay Without Recourse to the order of
MELl.ON BANk. '\I.A. AS TRUSTEE
under an Indenture of Trust with
the P"'nns\!\vania Housing
Finance Agency dated
s of Apr'1 j, 1982
,
(Seal)
-Borrower
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C:{ t:p:dV JO sa pa~:ep Jt:msS" SOUBU"}:! ~UlsnOH t:q:UB.tq.(SUU3a a-q:J JO a;tn:;Juapu!
;tspun aa:Jsn;[l S'E! C~U'E!g tBUOl:JeN 'E!lQdlspel1Qa aq:J O:J CaS;tn003;t 1noq:J~ ABel
Page2of2
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ALL TIlAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, (formerly
Lower Allen Township), Cumberland County and State of Pennsylvania, more particularly
bounded and described as follows, to wit:
BEGINNING at a point on the Northern line of Fifteenth Street at a distance of sixty-eight
(68) feet measured in a westerly direction from the northwest corner of Fifteenth Street
and Kathryn Street, said point being at the distance of One hundred and ninety-seven
(197) feet measured in a westerly direction from the line of lands of the Northern
Central Railway company (Front Street); thence in a westerly direction along the
northern line of Fifteenth Street thirty-four (34) feet to a point; thence in a
northerly direction along a line parallel with Kathryn street one hundred sixty (160)
feet to a point on the southern line of Charles Alley; thence in an easterly direction
along Charles Alley thirty four(34) feet to a point; thence in a southerly direction one
hundred sixty (160) feet to a point, the Place of BEGINNING.
HAVING thereon erected a single brick dwelling house known and numbered as 125 Fifteenth
Street, New Cumberland, Pennsylvania.
AND ALSO TRACT situate in the Borough of New Cumberland, Cumberland County, Pennsylvania,
bounded and described as follows:
BEGINNING at a point on the northern side of Charles Avenue, which point is sixty-eight (68)
feet west of the northwestern corner of Kathryn Street and Charles Avenue at the western
line of Lot No. 17; thence northwardly along the western line of Lot No. 17 a distance
of one hundred ten and seventy-six one-hundredths (110.76) feet to the southern line of
Fifteen and one-half Street; thence westwardly along the southern line of Fifteen and
One-Half Street a distance of thirty four and one tenth (34.1) feet to a point on the
eastern line of Lot No. 15; thence southwardly along the eastern line of Lot No. 15 a
distance of one hundred thirteen and thirty-five one-hundredths (113.35) feet to a point
on the northern line of Charles Avenue; thence eastwardly along the northern line of
Charles Avenue a distance of thirty-four (34) feet to a point, the Place of BEGINNING.
BEING Lot No. 16 on Plan of Lots of Charles H. Miller at Elkwood, Lower Allen Township,
Cumberland County, Pennsylvania, recorded in Plan Book 2, page 74.
UNDER AND SUBJECT, nevertheless, the easements, restrictions, reservations, conditions and
rights of way of record.
Being the same premises which Adele T. Hanna, widow by Indenture dated 12-15-86 and recorded
at Carlisle in the County of Cumberland on 12-16-86 in Deed Book J-32 page 453, granted
and conveyed unto Jeffrey A. Rudisill & Darlene M. Rudisill, his wife, in fee.
;lo6'K 992 PAGE 21F;
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VERIFICATION
I, Leon P. Haller, Esquire, hereby swear and affirm that the
facts
contained
in the
foregoing COMPLAINT
for Mortgage
Foreclosure are true and correct to the best of my knowledge,
information, and belief based upon information provided by
plaintiff FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY that said facts contained herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: September 11, 2000
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Leon P. Haller, Esquire
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-06246 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST UNION NATIONAL BANK
VS
PATTERSON KIRK L ET AL
DAVID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
PATTERSON KIRK L
the
DEFENDANT
, at 0015:35 HOURS, on the 27th day of September, 2000
at 125 EAST 15TH STREET
NEW CUMBERLAND, PA 17070
by handing to
PATRICIA L. PATTERSON
a true and attested copy of COMPLAINT - MORT FORE
together with
W/NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
10.54
.00
10.00
.00
38.54
So Ans,::;;~ ~,."
r>?;J:;#' ":/<1~ t
R. Thomas Kline
09/28/2000
PURCELL, KRUG & HALLER
Sworn and Subscribed to before
By:
~
"'- "'~.. t#;
~~ep~Sher~ff
me this 0'~
day of
() e..t;::L" O'-Ih/V A. D,.
9:,:. ,{2 /J4dJt7.~ -; ~
othonotary
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-06246 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST UNION NATIONAL BANK
VS
PATTERSON KIRK L ET AL
DAVID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
PATTERSON PATRICIA L
the
DEFENDANT
at 0015:35 HOURS, on the 27th day of September, 2000
at 125 EAST 15TH STREET
NEW CUMBERLAND, PA 17070
by handing to
PATRICIA L. PATTERSON
a true and attested copy of COMPLAINT - MORT FORE
together with
W/NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
S;:~~<
R. Thomas Kline
09/28/2000
PURCELL, KRUG & HALLER
Sworn and Subscribed to before
By:
~~~-
. Depu y Sherif ~
me this 6te:::.
day of
(p~ iJ--dy-() A.D.
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othonotary ,
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FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS.
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 6246
IN MORTGAGE FORECLOSURE
P RAE C I P E
TO THE PROTHONOTARY OF THE WITHIN COUNTY:
Please enter JUDGMENT "in rem" in favor of the Plaintiff and
against Defendants KIRK L. PATTERSON AND PATRICIA L. PATTERSON for
failure to plead to the above action within twenty (20) days from
date of service of the Complaint, and assess Plaintiff's damages as
follows:
Unpaid principal balance
Interest
(Per diem of $13.96
from 3/1/00 to 10/1/00)
Accumulated late charges
Late charges
($20.09 per month to 10/00)
Escrow Deficit
5% Attorney's Commission
$57,425.75
$ 2,987.44
$ 80.36
$ 140.63
$ 263.49
$ 2,871.28
TOTAL
$63,768.95**
** Together with additional interest at the per diem rate indicated
above from the date herein, based on the contract rate, and other
charges and costs to the date of Sheriff's Sale.
:~~ELL' ~ER
Leon P. Haller PA I.D. #15700
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS.
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 6246
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on OCTOBER 30, 2000 I served the Ten
Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this
matter by regular first class mail, postage prepaid, as indicated
on the attached Notice.
BY~
Leon P. Haller PA.D. #15700
Attorney for Plaintiff
Purcell, Krug & Haller
1719 North Front St.
Harrisburg, PA 17102
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!"'" ~ FIRST UNION NATIONAL BANK AS
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TRUSTEE FOR PENNSYL VANIA HOUSING
FINANCE AGENCY ,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYL VANIA
NO. 00-6246
VS.
KIRK L. PATTERSON AND PATRICIA L.
PATTERSON,
: CIVIL ACTION LAW
: IN MORTGAGE FORECLOSURE
Defendants
DATE OF THIS NOTICE: October 30, 2000
TO: KIRK L. PATTERSON
125 EAST 15TH STREET
NEW CUMBERLAND, P A 17070
PATRICIA L. PATTERSON
125 EAST 15TH STREET
NEW CUMBERLAND, P A 17070
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
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 FORIII AGAINST YOu. UNLESS YOU ACT WITIllN TEN (10)
DAYS FROM THE DATE OF TIllS NOTICE, A mDGEMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE TillS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER
OR CANNOT AFFORD ONE, GO TO TOR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
HWERE YOU CAN GET LEGAL HELP:
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA17013
717-249,3166
PURCELL, KRUG & HALLE
By
LEON P. HALLER, ESQUIRE
Attorney for Plaintiff
LD. # 15700
1719 N. Front Street
Harrisburg, PA 17102
(717) 234-4178
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FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS,
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 6246
IN MORTGAGE FORECLOSURE
NON-MILITARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
Personally appeared before me, a Notary Public in and for said
Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly
sworn according to law deposes and states that the Defendant(s)
above named are not in the Military or Naval Service nor are they
engaged in any way which would bring them within the Soldiers and
Sailors Relief Act of 1940, as amended.
Sworn to and subscribed
before me tl)is II day
of ile~ 20p-O
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LEON P. HALLER, ESQUIRE
~JOTf.\.Fi~AL SEAL
MARYLAt,JD K.. Fb'HETTI, Notary Public
LOWER PAXl'e'!\;wvP., DAuPHiN County
My Comml3siiJil ExpiresAlIGUST 8 2Q02,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
l CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
(. ) Confessed Judgment
(XX) Other IN MORI'GAGE FORECLOSURE
File No. 2000 6246
FIRST UNION NATIONAL BANK AS TRUS'IEE FOR
PENNSYLVANIA HOUSING FINANCE AGENCY,
PLAINTIFF
Interest 51"\ 'l/i /8; pm
10/1/00 to 3/7/01
Late charges 7~9.99
EscrON Deficit
Costs
$63,768.95
2,205.68
vs.
KIRK L. PATIERSON AND
PATRICIA L. PATIERSON,
DEFENDANTS
. ' Amount Due
"
100.45
2,000.00
$68,075.08
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of CUMBERLAND
for debt, interest and costs, upon the following described property of the defendant(s)
Real Estate:
County,
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachrnent against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
REAL ESTATE:
REAL CWNER: .
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real e
defendant(s) described in the attached exhibit.
\UC 11-
Signature:
Print Name:
of the
Date
Address:
Leon P. Haller, Esquire
Purcell, Krug & Haller
] 7'9 l\'Qrth FJ;OI:lt Stroet
Harrisburg, PA 17102
Attorney for:
Telephone:
Supreme Court ID No.:
PlAINTIFF
717-234-4178
US700
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ALL THAT CERTAIN PIECE or parcel of land situate in the Borough of
New Cumberland, Cumberland County, Pennsylvania, bounded and
described as follows:
BEGINNING at a point on the northern side of Charles Avenue. which
point is sixty-eight (68 1 feet west of t.he ,northwesternc;orner of
Kathryn Street and Charles Avenue at the western line Of .Lot, No. 17;
thence.northwardlyalong.the western line of Lot.No.,,17 .a distance
of one hundred ten and seventy-s.ixone-hundredths (110'.76 lfeet to
the southern line of Fifteen and One-Half Street; thence westwardly
along the southern line of Fifteen and One-Half Street a distance of
thirty four and one tenth (34.1) feet to " point on the eastern line
of Lot No.' 15; thence southwardly along the eastern line of Lot No.
75 a distance of one hundred thirteen and thirty-five one-hundredths
(113.35) feet to a point on the northern line of Charles Avenue/
thence eastwardly along the northern line of Charles. Avenue,a
diStance of thirty-four (34) feet to a point. the Plac,e,of.
BEGINNING.
BEING Lot No. 16 on Plan of Loti!' of CharlesH. Miller at. Elkwood,
'Lower Allen Township,. Cumberland County ,. Pennsylvania, recot:ded in
Plan Book ~. Page 74.
HAVING ERECTED THEREON A DWELLING KNOWN AS 125 EAST 15TH STREET,
NEW CUMBERLAND, PA.
BEING 'THE SAME PREMISES WHICH Jeffrey A. Rudisill et al by deed
dated 9/27/90 and recorded 10/1/90 in Deed Book M-34, Page 598
granted and conveyed unto Kirk L. Patterson and patricia L.
Patterson.
SEIZED IN EXECUTION AS THE PROPERTY OF KIRK L. PATTERSON AND
PATRICIA L. PATTERSON ON JUDGMENT NO. 2000 6246.
ASSESSMENT: 26-23-0541-124
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FIRST UNION NATIONAL BANK
AS TRDSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS.
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 6246
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
rhat the Sheriff's Sale of Real Property (real estate) will be
h~ld:
DATE:
WEDNESDAY, MARCH 7, 2001
rIME: 10:00 o'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
125 EAST 15TH STREET
NEW CUMBERLAND
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
2000 - 6246
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
is:
KIRK L. PATTERSON AND PATRICIA L. PATTERSON
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A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
recei ve part of the proceeds of the sale recei ved and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
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petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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ALL THAT CERTAIN PIECE or parcel of land situate in the Borough of
New Cumberland, Cumberland County, Pennsylvania, bounded and
described as follows:
BEGINNING at a point on the northern side of Charles Avenue, which
point is sixty-eight (68) feet we~t of t.he,northwesternc;orner of
Kathryn Street and Charles AVen~e at the western line Of ,Lot. No. 17;
thence,northwardly along. the western line of Lot,No...-l7 ,a distance
of one hundred ten and seventy-six ,one-hundredths (110.76) feet to
the southern line of Fifteen and One-Half Street; thence westwardly
along the southern line of Fifteen and One-Half Street a distance of
thirty four and one tenth (34.1) feet to ft point on the eastern line
of Lot No;' 15; thence southwardly along the eastern line of Lot No.
75 a distance of one hundred thirteen and thirty-five one-hundredths
(113.35) feet to a point on the northern line of Charles ,Avenue/
thence eastwardly along the northern line of Charles Avenue a
diStance of thirty-four (34) feet to a point. the Plac.eot,
BEGINNING.
BEING 'Lot No. 16 on Plan of Lots of Charles H. Miller at'Elkwood,
.'Lower Allen Township, Cumberland, County, Pennsylvania. recorded in
Plan Book, 2. Page 74.
.
HAVING ERECTED THEREON A DWELLING KNOWN AS 125 EAST 15TH STREET,
NEW CUMBERLAND, PA.
BEING THE SAME PREMISES WHICH Jeffrey A. Rudisill et al by deed
dated 9/27/90 and recorded 10/1/90 in Deed Book M-34, Page 598
granted and conveyed unto Kirk L. Patterson and Patricia L.
Patterson.
SEI ZED IN EXECUTION AS THE PROPERTY OF KIRK L. PATTERSON AND
PATRICIA L. PATTERSON ON JUDGMENT NO, 2000 6246.
ASSESSMENT: 26-23-0541-124
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FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS.
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 6246
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 125 EAST 15TH STREET, NEW CUMBERLAND, PA
17070:
1. Name and address of the Owner(s) or Reputed Owner(s):
Kirk L. Patterson
125 East 15th Street
New Cumberland, PA 17070
patricia L. Patterson
125 East 15th Street
New Cumberland, Pa 17070
2. Name and address of Defendant (s) in the Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW)
Secretary of Housing & Urban
Development of Washington, D.C.
451 7th Street - Southwest
Washington, D.C. 27410-8000
U.S. Department of Housing
and Urban Development
Albany Office, Region II
52 Corporate Circle
Albany, New York 12203-5121
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5. Name and address of every other person who has any record
lien on the property:
UNKNOWN
6.
interest
sale:
Name and address of every other person who has any record
in the property and whose interest may be affected by the
UNKNOWN
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:
TENANTS IF ANY ...
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject
to the penalties of 18 PA C.S. Section 4904 relating to unsworn
f"'eific"tion to "uthoritie". ,~
Leon P. Haller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: December 11, 2000
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FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS.
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 6246
IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
I hereby certify that I ha e de os'ted in the U.S. Mails at
Harrisburg, pennsyl vania on , a true and correct
copy of the Notice of Sale of eal state pursuant to PA R.C.P.
3129.1 to the Defendants herein and all lienholders of record by
regular first class mail (Certificate of Mailing form in compliance
with U.S. Postal Form 3817 is attached hereto as evidence), and
also to the Defendants by Certified Mail. Service addresses are as
follows:
Kirk L. Patterson
125 East 15th Street
New Cumberland, PA 17070
patricia L. Patterson
125 East 15th Street
New Cumberland, Pa 17070
Secretary of Housing & Urban
Development of Washington, D.C.
451 7th Street - Southwest
Washington, D.C. 27410-8000
U.S. Department of Housing
and Urban Development
Albany Office, Region II
52 Corporate Circle
Albany, New York 12203-5121
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
BY~
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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JOHN W. PURCELL
HOWARD B. KRUG
LEON P. HALLER
JOHN W. PURCELL JR.
BRIAN J, TYLER
JILL M. WINEKA
LAW OFFICES
PURCELL, KRUG AND HALLER
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
TELEPHONE (717) 234-4178
FORECLOSURE DEPT. FAX (717) 234-1206
JOSEPH NISSLEY (1910-1982)
ANTHONY DiSANTO
OF COUNSEL
HERSHEY
1099 GOVERNOR ROAD
(717) 533-3836
NOTICE TO:
Kirk L. Patterson
125 East 15th Street
New Cumberland, PA 17070
patricia L. Patterson
125 East 15th Street
New Cumberland, pa 17070
Secretary of Housing & Urban
Development of Washington, D.C.
451 7th Street - Southwest
Washington, D.C. 27410-8000
U.s. Department of Housing
and Urban Development
Albany Office, Region II
52 Corporate Circle
Albany, New York 12203-5121
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
NOTICE IS HEREBY GIVEN to the Defendants in the within action and
those parties who hold one or more mortgages, judgments or tax liens
against the real estate which is the subject of the Notice of Sale
pursuant to Pennsylvania Rule of civil Procedure 3129.1 attached
hereto.
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution
issued out of the Court of Common Pleas of the within county on the
judgment of the Plaintiff named herein the said real estate will be
exposed to public sale as set forth on the attached Notice of Sale.
By:
against the said
ou have an
'ng notified of
'7
YOU ARE FURTHER NOTIFIED that the lien you hold
real estate will be divested by the sale and that
opportunity to protect your interest, if any,
said Sheriff's Sale.
Leon P. Haller PA I.D.15700
Attorney for Plaintiff
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FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS.
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 6246
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE:
WEDNESDAY, MARCH 7, 2001
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
125 EAST 15TH STREET
NEW CUMBERLAND
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
2000 - 6246
THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property
is:
KIRK L. PATTERSON AND PATRICIA L. PATTERSON
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.
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
recei ve part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania l7013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you,
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause, This
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petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3, A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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ALL THAT CERTAIN PIECE or parcel of land situate in the Borough of
New Cumberland, Cumberland County, Pennsylvania, bounded and
described as follows:
BEGINNING at a point on the nor'thern side of Charles Aven'ue, which
point is sixty-eight (68) feet wellt of t.henorthwesternc;orner of
Kathryn Street and Charles Avenl!e at the western Hne of ,Lot, No. 17;
thence northwardly along, the well tern line of Lot No..d7 ,a distance
of one hundred ten and seventy-six ,one-hundredths (110.761 feet to
the southern line of Fifteen and One-Half Street; thence westwardly
along the southern line of Fifteen and One-Half Street a distance of
thirty four and one tenth (34.1) feet to a point on the eastern line
of Lot No.' IS; thence southwardly along the eastern line of Lot No.
75 a distanqe Of one hundred thirteen and thirty-five one-hundredths
(113.35) feet to a point on the northern line of Charles ,Avenue;
thence eastwardly along the northern line of Charles Avenue a
diStance of thirty-four (34) feet to a point, the Plac.e'of,
BEGINNING.
BEING Lot No. 16 on Plan of Lots' of Charles H. Miller at. Elkwood,
'Lower Allen Township" Cumberland County, Pennsylvania, recorded in
Plan Book ~, Page 74.
HAVING ERECTED THEREON A DWELLING KNOWN AS 125 EAST 15TH STREET,
NEW CUMBERLAND, PA.
BEING THE SAME PREMISES WHICH Jeffrey A. Rudisill et al by deed
dated 9/27/90 and recorded 10/1/90 in Deed Book M-34, Page 598
granted and conveyed unto Kirk L. Patterson and Patricia L.
Patterson.
SEIZED IN EXECUTION AS THE PROPERTY OF KIRK L. PATTERSON AND
PATRICIA L. PATTERSON ON JUDGMENT NO. 2000 6246.
ASSESSMENT: 26-23-0541-124
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Postage $ ..rS
Certifi€!d Fee 1.'10
Return 8eceipt Fee , },.z..,r
(Endorsement Required)
Restricted Delivery Fee 1..7S
(Endorsement Required)
Total Postage & Fees $ J"':1S'
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KIRK L PATTERSON
125 EAST 15TH STREET
NEW CUMBERLAND PA 17070............,....,,'
. Comp,eteh"lrlsi, 2; and 3.Ai~ complete
iter:n 411 Restricted Delivery'is desired.
. Print your name and address on the reverse
so:that we can return the card to you.
. Attach this card to the back of the mai/piece,
or on the front if ~ace permits.
1. Article Addressed to:
KIRK L PATTERSON
125 EA'ST 15TH STREET
NEW CUMBJRLAl'iD PA 1707Q',
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Certified Fee
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Return Receipt Fee
[Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
Total Postage & Fees $
PATRICIA L PATTERSON
1 25 EAST 15TH STREET
NEW CUMBERLAND PA
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17070
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3. Serv' ype
ertified Mail 0 Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra f:ee) 0 Yes
2, Arlicle Nu~r (Copy fro, m service labe, Q
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item 4 if ~estricted Delivery is desired.
. Print your-ilame and address on the reverse
SQ t,hat we'can return the card to you.
. Att~Ch this card to the back of the mailpiece,
or on the front if space penn its. '
1. Artidle Addressed to:
PATRICIA L PATTERSON
125 EAST 15TH STREET
NEW CUMBERLAND PA 17070
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D. Is delivery different from item 1?
If YES, enter delivery address below:
3. Se~pe
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o Insured Mail
o Express Mail
o Return Receipt for Merchandise
DC.D.D.
4.. Restricted Delivery? (Extra Fee) 0 Yes
PS Form 3811, July 1.999
Domestic Return Receipt
102595-00.M-0952
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Re: PHFA vs. Patterson
Cumberland Sale 3/7/00
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
Kirk L. Patterson
125 East 15th Street
New Cumberland, PA 17070
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
patricia L. Patterson
125 East 15th Street
New Cumberland, Pa 17070
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Secretary of Housing & Urban
Development of Washington, D.C.
451 7th Street - Southwest
Washington, D.C. 27410-8000
Postmark:
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U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
U.S. Department of Housing
and Urban Development
Albany Office, Region II
52 Corporate Circle
Albany, New York 12203-5121
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
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First Union National Bank: as Trustee
For Pennsylvania Housing Finance Agency
-vs-
Kirk L. Patterson and Patricia L. Patterson
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No.2000-6246 Civil
R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ
is returned STAYED.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Law Library
County
Levy
Postpone Sale
Surcharge
Certified mail
Mileage
Law Journal
Patriot News
Out of County
Share of Bills
30.00
141.10
15.00
15.00
.50
1.00
15.00
20.00
30.00
2.30
21.08
321.20
234.93
25.53
$ 872.64 Pd by atty 03/05/01
Sworn and subscribed to before me
so~~
R. Thomas Kline, Sheriff
This 7 ~ day of ~J
2000, A.D. ~a,~,~
Prothonotary
BJj;oN' ,jJJ;tt-
Real Estate Deputy
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FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS.
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 6246
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 125 EAST 15TH STREET, NEW CUMBERLAND, PA
17070 :
1. Name and address of the Owner(s) or Reputed Owner(s)
Kirk L. Patterson
125 East 15th Street
New Cumberland, PA 17070
patricia L. Patterson
125 East 15th Street
,New Cumberland, Pa 17070
2. Name and address of Defendant (s) in the Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every judgment credi tor whose judgment
appears of record on the real property to be sold:
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW) :
Secretary of Housing & Urban
Development of Washington, D.C.
451 7th Street - Southwest
Washington, D.C. 27410-8000
U.S. Department of Housing
and Urban Development
Albany Office, Region II
52 Corporate Circle
Albany, New York 12203-5121
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5. Name and address of every other person who has any record
lien on the property:
UNKNOWN
6.
interest
sale:
Name and address of every other person who has any record
in the property and whose interest may be affected by the
UNKNOWN
7. Name and address of
Plaintiff has knowledge who has
may be affected by the sale:
every other person of whom the
any interest in the property which
TENANTS IF ANY...
D~mestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject
to the penalties of 18 PA C.S. Section 4904 relating to unsworn
falsification to authorities. //'
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Leon P. Haller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: December 11, 2000
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FIRST UNION NATIONAL BANK
AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS.
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 6246
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be
hl=ld:
DATE:
WEDNESDAY, MARCH 7, 2001
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner'S Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
125 EAST 15TH STREET
NEW CUMBERLAND
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
2000 - 6246
THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property
is:
KIRK L. PATTERSON AND PATRICIA L. PATTERSON
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A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2, After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
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petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3, A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within 'County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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ALL THAT CERTAIN PIECE or parcel of land situate in the Borough of
New Cumberland, Cumberland County, Pennsylvania, bounded and
described as follows:
BEGINNING at a point on the northern side of Charles Avenue, which
point is sixty-eight (68) feet we$t of t.henorthwestern'C1orner of
Kathryn Street and Charles Avenlleat the western line of .Lot.No. 17;
thence, northwardly' along. .the western line of Lot No...17 ,a distance
of one hundred ten and seventy-s,ix ,one-hundredths 1110.76 ) feet to
the southern line of Fifteen and One-Half Street; thence westwardly
along the southern line of Fifteen and One-Half Street a distance of
thirty four and one tenth (34.1) feet to n point on the eastern line
of Lot No;' IS; thence southwardly along the eastern line of Lot No,
75 a distance of one hundred thirteen and thirty-five one-hundredths
(113.35) feet to a point on the northern line of Charles Avenue,
thence eastwardly along the northern line. of Charles, Avenue ..a
distance of thirty-four (34) .feetto a point. the Plae.e.of '
BEGINNING.
BEING 'LotNo. 16 on Plan of Lots of Charles H. Miller at. E1kwood.
.'Lower Allen Township, Cumberland County. Pennsylvania. recorded in
Plan Book 2, Page 74.
HAVING ERECTED THEREON A DWELLING KNOWN AS 125 EAST 15TH STREET,
NEW CUMBERLAND, PA,
BEING THE SAME PREMISES WHICH Jeffrey A. Rudisill et al by deed
dated 9/27/90 and recorded 10/1/90 in Deed Book M-34, Page 598
granted and conveyed unto Kirk L. Patterson and Patricia L.
Patterson.
SEIZED IN EXECUTION AS THE PROPERTY OF KIRK L. PATTERSON AND
PATRICIA L. PATTERSON ON JUDGMENT NO. 2000 6246.
ASSESSMENT: 26-23-0541-124
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF Cumb~r1and
NO. 00-6246 CIVIL 'f9{ TERM
CIVIL ACTION - LAW
COUNTY:
To satisfy the debt. interest and costs due FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY
from KIRK L PATI'ERSON AND PATRICIA L. PATI'ERSON; 125 East 15th Str~t,
PLAINTIFF(S)
N~w Cumb~land, PA 17070
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell
S~ L~qa1 D~scription
(2) You are also directe(ffd ait~thlhlljpropil'ifyofthe'defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defenda\'lt(s) or otherwise disposing
thereof;
(3) If property of thedefenda~t(s),notlevieq,\l'pon an subject to attacbr'nentis !ol,lnd inthe possession of anyone other
than a,named garnisH:lle,YQu are directed,to notffyhinilherthat he/she has been added as a garnishee and is enjoined as above
stated. ' .'. . '
Amount Due $63,768.95
I t t 10/1/00 to 3/7/01 $13. 96jdiem
n eres $?, ?Q5. fiR
Atty's Comm %
Atty Paid $. 126.511
Plaintiff Paid
L.L. :;]j Oil ,
Due Prothy $1. 00
Other Costs Late Charqes $20.09
Escrow ~ficit
$100L45 .
$2,000;00
Date: D~c<;:mb~r 1'3, 2000
by:
REQUESTING PARTY:
Name ~n P. Hall~r, Esq.
Address: 1719 North Front Str~t
Harrisburg, PA 17102
--
Attorney for:. Plff.
Telephone: 717-234-4178
Suprerne Court 10 No. 15700
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REAL ESTATE SALE No.;/. ~
this writ and oy tnlS re1erence
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On ;J ~ 1'(' ~ the sheriff leVied upon the defendant
interest in the real property situated in~h..J/L.,I..d.1 ~
Cumberland County, Pa., known and numbered as:J:Js E"f"'" ji;.../"
/J1J,JIL..LP...L ann more I"II'
':scflDed on Exhibit "A" moo witI'"
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FIRST UNION NATIONAL BANK, AS
TRUSTEE FOR PENNSYLVANIA HOUSING
FINANCE AGENCY,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
VS.
NO. 2000 - 6246 CIVIL TERM
KIRK L. PATTERSON AND
PATRICIA L. PATTERSON,
DEFENDANTS
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
P RAE C I P E
TO THE PROTHONOTARY:
Please Vacate the Judgment entered against the Defendants in
the above captioned matter, because the mortgage has been reinstated
and the default cured.
PURCELL, KRUG & HALLER
BYj~
Leon . Haller ID No. 15700
Attorney for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: June 13. 2001
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