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HomeMy WebLinkAbout00-06523 ~' ''',.,.,..~ '.-, -~~.. '..~ -......n.'jl~.."'~_4J_""'*;E" MARK J. UDREN. & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Scot A. Lytle 407 pine Road Mt. Holly Spring, PA 17065 Defendant(s) : NO. trJ ~ &5;)3 eu;J COMPLAINT IN MORTGAGE FORECLOSURE 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 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ~" ~"~ M_ ~ - 'iI'>";F'.&5:l>c._"c AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Race falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, 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 requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DlNERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF:ICINA CUYA D:IRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013-3387 717-249-3166 or 800-990-9108 ~~ - 'fl;O'i~,H'li.~iH,~~_, NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of II dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name llnd address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN Isl Mark J, Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 ~..~ ,'=,~ < ~ ~-'cl::~,_,'i'h0_ 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: GMAC Mortgage Corporation of PA Assignee: The Prudential Home Mortgage Company, Inc. Recording Date: 2/22/94 Book: 466 Page: 1036 Assignor: Assignee: Recording The Prudential Home Mortgage Company, Inc. Norwest Mortgage, Inc., a California Corporation Date: 8/26/96 Book: 528 Page: 495 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 407 pine Road MUNICIPALITY/TOWNSHIP/BOROUGH: South Middleton Township COUNTY: Cumberland DATE EXECUTED: 2/22/94 DATE RECORDED: 2/22/94 BOOK: 1197 PAGE: 980 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon -.~. ~-'" ~ '" L'L ~ "'_""__Jl"" breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 8/22/00: Principal of debt due and unpaid Interest at 7.5% from 3/1/00 to 8/22/00 (the per diem interest accruing on this debt is $14.83 and that sum should be added each day after 8/22/00) $71,167.52 2,523.54 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) 250.00 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $142.19 and that sum should be added on the first of each month after 8/22/00) 746.11 Late Charges (monthly late charge of $27.04 should be added on the fifteenth of each month after 8/22/00) 108.16 property Inspections Other Fees 45.00 185.00 Attorneys Fees (anticipated and actual to 5% of principal) 3.558.38 TOTAL $78,863.71 " ~,~~- ~ ~~~ 7. The attorney's fee 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 in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $78,863.71 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. U MARK J. Attorney Attorney ren, ESQUIRE REN & ASSOCIATES or Plaintiff I.D. No. 04302 """"~.~~ ~ ,<."'.~~ -~-" ., ~ ~~ ~, ~<,hJ:J;j~,;.,ri;,'<~- ALL THAT CERTAIN LOT OF GROUND WITH IMPROVEMENTS SITUATE IN SOUTH MIDDLETON TOWNSHIP, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED, AS FOLLOWS: BEGINNING AT A STAKE ON THE SOUTH SIDE OF THE PINE ROAD, SAID STAKE BEING 180 FEET WEST OF CORNER OF LAND NOW OR FORMERLY OF WILLIlIM L. SMITH, MEASURED ALONG THE SOUTHERN SIDE OF SAID ROAD; THENCE ALONG LOT NOW OR FORMERLY OF JOHN D. FEESER, ET OX, AND PERP$NDICULAR TO SAID ROAD 250 FEET, MORE OR LESS, TO A STAKE; THENCE BY LAND NOW OR FORMERLY OF LLOYD J. EDRIS, ET OX, SOUTH 84 DEGREES 3 MINUTES WEST 100 FEET TO A STAKE; THENCE ALONG LAND 01;' MARTIN F. BOYER AND WIFE AND PERPENDICULAR TO SAID ROAD 250 FEET, MORE OR LESS, TO A STAKE ON THE SOUTH SIDE OF SAID ROAD, NORTH 84 DEGREES 3 MINUTES EAST 100 FEET TO THE PLACE OF BEGINNING. AND BEING IMPROVED WITH A ONE-STORY RANCH TYPE DWELLING HOUSE. "'''~il.13 - - ,~~, ""~"-"''''''''''--",ifIIi!,,-' ~.'I..---,-.- -_~,_,... - Z 902 114 014 Wells Fargo Home Mortgage, Inc. P.O. Box 1225 Charlotte, NC 28201-1225 June 5, 2000 0514232 I000263/685AcI91 Scot A. Lytle 407 Pine Road Mt Holly Spring PA 17065 RF.: Wells Fargo Home Mortgage, Inc. Loan Number 0514232 Mortgagor(s): Mortgaged Premises: Scot A. Lrtle 407 Pine Road Mt Holly Spring, PA 17065 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortl!::ure on vour home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached Palres. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to save vour home. This Notice explains how the prOl!ram works. 'To see if HEMAP can help, vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHlN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counselin~ Aeencv. The name, address and phone number of Consumer Credit Counselin... A21mcies servinl!: your County are listed at the end of this Notice. If vou have anv auestions, vou mav call the Pennsvlvania Housim Finance Ag;encv 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 find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A COmINuAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENClA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRffiA. PUEDES SER ELEGffiLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDlDA DEL DERECHO A REDlMlR SU HlPOTECA. E)\nu;>>i f A JIIBoIIil -; 'ill. . J 'i1li1t!.!li '-~_llfi\r,,': '"OL.=- HOMEOWNER'S NAME(S): Scot A. T.ytle PROPERTY ADDRESS: 407 Pine Road Mt Holly Spring, PA 17065 0514232 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: WELlS FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE 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 VANTA HOUSING FINANCE AGENCY. ~MP~RARY ST A V OF FOR~.~E.. - Under the Act, you are entitled to a temporary stay o forec osure on your mortgage or . (30) days from the date of this Notice. Durmg that time you must arrangc and attcnd a "facc-to-face" meeting with onc of the consiuncr crcdit counseling agencies listed at the end of this Notice. THIS MRE~ MUST OCCUR WfTHTN THE NEXT ~' 11' YOU DO NOT AI'I'L Y POR EME~GENCY IORTGAGE ASSIST ANCE~ YOU __I'NG YOm MORTGAGE UPTODA"fi THE P~T OF THIS NOTIf:r:f:ATJ.ED "HOW TO CURE YOI JR MORT(~AGE DEIIAI JI1'''. EXPLAINS HOW TOBRIN(~ YOUR MORTGAGE UP TO DATE. CONSW,MER CR FWT fOI~SFT ~G ~GENr.TF~ - If you meet with one of the consumer credit counse ing a.&encies iste at t e end 0 thIS notice, t e lender may NOT take action against you for thirty (3u) days after the date of this meeting. The names addresses and tele hone numbers fin c nsum r cr' n lin n es t c . 'c r i . '. is on y necessary to sc e e one ace-to-face meeting. Advise your len er immediatelv of your intentions. AP~~ATION FOR MORTG~ ASSISTAN~E - Vour mortgage is in default for the reasons set 0 later in this Notice (see 0 owing pages or specific information about the nature of your default.) If you have tried and are unable to resolve tIiis problem with the lender, you have tlie right to apQly for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a comp'leted Homeowner's Emergency ASSIstance Program Application with one of the designatea consumer credit counseling agencies listed at the end of this Notice. Only consumer credIt counseling agencies have applications for the p~ogra!TI and they will assist you in s!lbmittin,ga cOIp-plete apphcation to ~h~ Pen!,\sylvania Housmg Fmance Agency. Vour apphcatlon MUST be fIled or postmarked WIthin thlJ'ty (30) days of your face-to-face meeting. YOUM1!SI FILE YOUR APPLICATION PROMPTLY., IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LElTERJ:ORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICA lION FOR MORTGAGE ASSISTANCE WILL BE DENTED. -~"""'. ~'"= ., ~ -~-I.b_1"',"" '.'"", , <O,~_ ' 000263/6B5 ~r:Y ~tTI~N - Available funds for emergency mortgage assistance are very limited. They will e IS. urs~ y t e Ageng un~er the eligibility criteria est~~IIshed by. the 1\ct. Tlie Pennsylvania HOl!smg Fma,nce Agency lias SIxty (60) d!1Ys to .make a deCISH)n a,fter It r~elves your applIcation. Durl!lg that tIme, no foreclosure proc.eedmgs wI.!1 be 'pursued agamst you If you have met the time reqUIrements set forth ahove. You wIll be notIfIed dIrectly by fhe Pennsylvania Housing l'inance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTI Y PROTECTED BY THE FILING OF A PETITION IN BANKRUPTC~]HE FOLLOWING PART OF TIIISNOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULU NOT BE CONSIDERED AS AN AmMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEF AUL T (Bring it up to date), ~~~~~ o:O~e~~~~m:!-.- TheMORTG.A~~debt held by_the. above 1ender on your property Mt Hnlh.SDn~ PA 1706<; IS SERIOUSLY IN OEFA T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the followin~ amounts are now past due: Apr;1 ?001l. Jnn. ?OOO $?,O?R 1? Late Char es 54.08 2 082.20 TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION ~OWT~ ClJ~E MFF')YHiE- You may cure the default within THIRTY (~O) DAYS of the ate of t is notice BY PYIN TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 2,082.20, PLUS ANY.MORTGAGE PAYMENTS AND LATE CHARGI1S WHICH BEcOME DUE DURING THE THIRTY (30) DAY PERIOD. paJments must be made either bv cash. cashier's check, certified check or money order made payable an sent to: WELLS FARGO HOME MORTGAGE, INC. 1 HOME CAMPUS X2501-olH DES MOINES, IOWA 50328 You can cure any other default by taking the following a<.:tion within THIRTY (30) DAYS of the date of this letter: T C. . . , AUL T - - If you do not cure the default within THIRTY (30) DAYS o t e ate 0 t s otlce, e en er mten t erci e its ri ts to accelerate th m t " e debt. Thi means that the entire out~tan mg a auee 0 t IS e t WI e consl ere, ue unm ate y an you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past duc is not madc wlthm THIRTY (30) DAYS, the lcndcr also intcnds to instruct its attorncys to start legal action to foreclose upon vour mortl!ae:ed proPertv. IF THE ~RTGAGE T~ ~OBi~;C~RSFD I~N - -The mortgaged propertr will be sold by the Sheriff to pay 0 e mortgage e t. I t e ender re ers your case to Its attorneys, liut you cure the delinquency before the lender begins legal p'roceedings againstyou1..You will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.vO. However, if legal proceedings are started. a,gainst you,you will have to pay all reasonable attorney's fees actually mcurred by the lender even If tliey =eed $50.00. Any attorney's fees will be added to the!11I!ount you owe the lender whi~h may also include other reasonable costs. If vou care the default WIth," the THIRTY 130l DAY oenod. vou will not be reaulred to pav attorney's tees. .Q)"HF,R T 'X~F.~ RFMFTS . - The lender may also sue you personally for the unpaid principal DilaiiCe an a ot er sums ue under the mortgage. -" - ~ J_ . ~~-=~ ",~.""'_M"b~ 000263/685 Name of Lender: Address: Phone Number: Fax Number: Contact Person: Wells Fargo Home, Mortgage, Inc. S024 Parkway Plaza Blvd. Charlotte, NC 28217 1-800-766-0987 704-423-4016 Jerry Wagner EFFECT OF SHF.RlFF'SSAI.E - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occul?Y it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ mayor _ 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 OBTAU'J MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSmON AS IF NO DEF AUL T HAD OCCURRED IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THl'> RIGHT TO (~URE 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. '" "' , '''~~ ~ " -'~,~ ,,.,,. APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAXIt (717) 541-4670 Financial Counseling Services of Franklin 31 Wesr 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAXIt (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAXIt (717) 731-9589 Community Action Commission of the Capital RegionH 1514 Derry Street Harrisbutg, P A 17104 (717) 232.9757 FAXIt (717) 234-2227 Adams County Housing Authority 139-143 ('.arlisle St. Gettysburg, P A 17325 (717) 334-1518 FAX (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. - "''iiI~~' ,,"', ~~~ '~ ",-, ,-y,~~! ,- -U<_ ,.~;. WeUs Fargo Home Mortgage, Inc. P.O. Box 1225 Charlotte, NC 28201-1225 June 5, 2000 Scot A. Lytle 407 Pinc Road Mr Holly Spring PA 17065 0514232 1000264/685Act91 RF.: Wells Fargo-Home Mortgage, Inc.-Lo~~N~mber0514232 Mortgagor(s}: Mortgaged Premises: Scot A. Lvtle 407 Pine Road Mt Holly Spring, P A 17065 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortaaae on your home is in default. and the lender intends to foreclose. Soecific information about the nature of the default is orovided in the attached oae:es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM(HEMAP) may be able to help to save vour home. This Notice explains how the orOl!ram works. , To see if HEMAP can help, yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30DA YS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counselina Aaencv. The name, address and phone uumber of Consumer Cre,dit Counselin17 Aaencies s,ervina vour Countv are listed at the end of this Notice. H you have any Questions. YOU may call the Pennsvlvania HousiIll! Finance Aaencv toll free at 1-800-342-2397. (Persons with imoaired hearina can call (717) 780-1869). This Notice contains important legal information. H 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 NOTIFlCACI0N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECT A SU DERECHO A COMTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICAOON OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCTA (PENNSYL VANTA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENOONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA UAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMlR SU HlPOTECA. ..1 ~ II. ~Jl ~ i,_ ~.- ~ ~ ~~, _ ," .a ':-~~M~~:.:i, HOMEOWNER'S NAM.E(S): Scot A. Lytle PROPERTY ADDRESS: 407 Pine Ro.d Mt Holly Spring, PA 17065 0514232 1.OAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: WEllS FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SA VEYQUR.HQME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH lHE 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 OlHER ELIGIBILITY REQUmEMENTS ESTABLISHED BY lHE PENNSYLVANIA HOUSING FINANCE AGENCY. ~RARY STAY OF FORE~~'iURE - Under the Act, you are entitled to a temporary stay o or osure on your mortgage or irtr (30) days from the date of this Notice. Durmg that time you must arrangc and attcnd a "facc-to-facc" mccting withonc of thc consumer crcdit counseling a encies listed at the end of this Notice. THIS MF.F.TING MUST OCClJR WlT:HTNTHE NEXT I DAYS . OU DO NOT APPLY fOR E '.' GENCY MORTGAGE ASS S "CE YOU "HOW TO (i~JRE YOIJR MORT(~AGE IWI'AIJLT" EXPLAINS HOWTO RRIN(~ YOIJR MORTGAG _:UP TO DATE. CONSEMER r.RF~IT fOl ~SF.LING AGENCI:I\~ - If you meet with one of the consumer credit counse ing agencies iste at t e endot this notice, t e lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and tele hone numbers f din n r cr it cou selin a e Cles or t e c n m i ,r e IS . '. is on y necessary to sc e e one ace-to-face meeting. Advise your len er immediately of your intentions. AP1LJrrATION IrR MORTG~ ASSISTAN{j,F' - Your mortgage is in default for the reasons set or ate! in is Notice (see fOt owing pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have die right to apmY for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a comj:lleted Homeowner's "Effi<;rgency ASSistance Program Application with one of the designatea consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the p~ogram and they will assist you jn s!lbmittinga co~plete applIcation to !he. Pen!1Sylvania Housmg FimlUce Agency. Your applIcation MUST be filed or postmarked wIthin thuty (30) days of your face-to-face meeting. YOUMllSI FILE YOUR APPLICA nON PROMPTLY. IF YOU FAll.. TO DO SO OR IF YOU DO N01'FDLLOW THE OTHER TIME PERIODS SET FORTH IN TInS LElTERJ:ORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICA J JON FOR MORTGAGE ASSISTANCE WILL BE DENIED. ,'''~..~<" ~'M^ _. '" < , ~ ,,- ilf'!ilIilllll!:~~" '. -. AG~~CY ~~Tl~N Available funds for ~,!,erge.ncy' mortgage assistance are very limited. They will be ". urs~ y t e Ageng un~er the ehglblllty crltena est~qhshed by. the A.ct. Tne Pennsylvania Ho~smg Fma.nce Agency lias Sixty (60) d!'ys to .make a declslC)n after It receives your apphcation. Durlpg that tune, no foreclosure proc!'ledmgs vy~ll 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.JHE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES 01~L Y AND SHOUL9.l~UT BE CONSIDERED AS AN ATTEMPT TO COLLE~ 1 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 OF.FAIIl.T - - Tbe MORTGAGE debt held by the above lender on your property located at: 407 Pine Rruln ,," , " "" ,.. " Mr HnlbLSvri'(ltPA 170", IS SERIOUSLY IN OEFA T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: April 100n - Jl1n. 1000 ~1 O?R 11 Other char Late Char es 54.08 TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION 2 082 20 ~OW TS, CURE m.DEEA~- You may cure the default within THIRTY (30) DAYS of the ate of t is notice B AYIN TOTAL AMOUNT PAST DUE TO THE LE1IIDER. WHICH IS $ 2,082.20, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Paxments must be made either bv cash. cashier's check, certified check or money order made pavable an sent to: WELLS FARGO HOME MORTGAGE, INe. 1 HOME CAMPUS X2S01-0lH DES MOINES, IOWA 50328 You can cure any other default by taking the following aLtion within THIRTY (30) DAYS of the date of this letter: NOTC . ..FAULT--I you. o.not.curethe au\twit in THIRTY (30 D~YS o t e ate 0 t is otlce, en ermten s to exera Its n h accelerate e m :b T mean$ that the entire out'ltan ng a ance 0 t IS e t WI e consl ere ue mune late y an you may lose the chance to pay the mortgage in monthly installments. . If full paY!llent of !he total amount past duc is not madc wlthm THIRTY (30) DAYS, ihc lendcr also mtcnds to mstruct It'l attorneys to start legal action to foreclose upon your mOr!l!lUZed 1ll'0Pertv. IF THE ~~RTGAGE ~ ~O~i'q,SED {~N - - The mortgaged propertr will be sold by the Sheriff to pay 0 t e mortgase ' e' t.' 'e ender re ers your case to ItS attorneys, liut you cure the delinquency before the lender begms legal p'roceedings againstyoubyou will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50. O. However, if lesal proceedings are started. a,gainst you you will have to pay all reasonable attorney's fees actually mcurred by the lender even If theyexceed'$SO.OO. Any attorney's fees will be added to the !,~ount you owe the lender, whi~h may also include other reasonable costs. If vou cure the default wlthm tbe THIRTY 130l DAY Denod, vou will not be reauired to pav attorneY's tees. ~R I.X~F.~ RF.MF~lF.~ - - The lender may also sue you personally for the unpaid principal a ance an a or er sums ue under the mortgage. ,",,-' - -- ~~{'-'ti!lfl@.'!!imr,,:, .. "---'-"''''"'..v-- 000264/665 F.I\RI.W~T 1'0~~ml.F. ~HF.RTF1"~ ~1\l.F DI\TF. - It is estimated that the earliest date that such a Sheriff's Sale ~Jf the !"ortgage~ property could be held would be approximately six (6) months from the date of this Nonce. A notIce of the actual date of the SherIff's Sale will be sent to you before the sale. of c01;ll'se, the amount needed t<? cure the default w~lI inc~ease the longer you wait. You may find out at any tIme exactly what the reqwred payment or action wIll be by contacting the lender. HOW 1'0 C.ONTACT THF I ENDER. Phone Number: Fax Number: Contact Person: ....--- ~. ------- Wells Fargo Home, Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 1-800-766-0987 704-423-4016 Jerry Wagner Name of Lender: Address: EFFEr.r' OF SHF.RlFF'S ~I\I.E - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and yonr right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ mayor _mal' 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 PAYOFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSmON AS IF NO DEFAULT HAD OCCURRED IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS RIGHT TO (~URE 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 B.ELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. -~ ,"iIJ rl.o ~" ~ ,--~ "~............"'-~- APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSEUNG AGENCIES CUMBERLAND COUNTY cecs of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FA}c#(717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Hartisburg N. 6th Srreer Hatrisburg, PA 17101 (717) 234-5925 FA}C# (717)234-9459 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FA}C# (717) 731-9589 Community Action Commission~of the Capital~Region- ~ 1514 Derry Street Harrisburg, P A 171 04 (717) 232-9757 FA}C#(717)234-2227 Adams-ConntyHousing Authority 139-143 C.arlisle St. Gettysburg, PA 17325 (717)334-1518 FA}C(717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. "l'-"'-'''''' " ~_.,,,,,,,,,,,,,,,~,,,,, V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of tne information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J MARK J ren, ESQUIRE UDREN & ASSOCIATES ~u, -', llUI1 ' "''''''~~ !lMllhi;ii~~l&~i:;' --1 ,;-~,_, ,:lliii ~'j - - C;'-h ';',_;,,-,,_ ,r~,~,J"",p,..~ ,<,>"?;~~Jl,,, . , '" J~ "" ,~ ~. ~ " ~ '" \ \lS ~ v "~"",.7~.,,,!J~? ' ".-,~--,I , '-'---- ~ ~~ ~ () ~ ~ ~ '\ . ., ~' ''''"'' -,",,-- .' '"'j ~ (') f; ;gfts ~~? ~~,:2:- t;:C' Ir !It )>Cd - ~ - .. ::::> ..., a C) (I) r" ''0 1'",) 0' o '" -:-:::! 61 ~~ry {"~~ g:~i f;;fi ".";; __)' '1 ,---i .::r::,.: :xJ -< '_~~~"'_-""llI.r-' - " ~ ~ i1~ &,:-: SHERIFF'S RETURN - NOT FOUND . CASE NO: 2000-06523 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS LYTLE SCOT A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT LYTLE SCOT A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , LYTLE SCOT A DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FORWARDING, PROPERTY IS VACANT. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 4.34 5.00 10.00 .00 37.34 So answW~ ~s Kline Sheriff of Cumberland County MARK J. UDREN 10/05/2000 Sworn and subscribed to before me this cv /b ~ day of (YeZ;L aZ-tnro A. D . [}t' Q 'nA.;g~ ~ Pr h notary , ,_ "I' ._ ~ . _. ~ , ", MJL~ MARK J. UDREN & ASSOCXATES BY: Mark J. Udren, Esquire ATTY X.D. NO. 04302 1040 N. KINGS HIGHWAY, SUXTE 500 CHERRY HILL, NJ 08034 856-482-6900 WE HEREBY CERTIFY THE WITHIN TO BE TRUE AND CORRECT COpy OF THE ORIGINAL ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff : COURT OF COMM:ON PLEAS : CIVIL DIVISION : Cwnberland County v. Scot A. Lytle 407 Pine Road Mt. Holly Spring, PA 17065 Defendant(s) ~ . :NO. &0/ ~0l3 ~ COMPLAINT IN MORTGAGE FORECLOSURE 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 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 CANMOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cwnberland County ~ar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 - "-" -""->&~1II>I-")'>!;'_i AV:ISO Le han demandado a usted en la corte. si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Race falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones ~ las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para- usted.-- n __u_ LLEVE ESTA DEMAJIDA A UN ABOGADO IMMEDIATAMENTE, S:I NO T:IUE ABOGADO o S:I NO T:IENE EL D:INERO StlFIC:IENTE DE PAGAll TAL SEltV:ICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF:IC:INA CtJYA D:IRECC:ION SE ENCtJENTRA ESCR:ITA ABAJO PARA AVER:IGtJAR DONDE SE PtJEDE CONSEGtJIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 L -",..,.~~ ~-= ~~~~ ~ ~ ,,-~ ~ " I\lwl~~hi NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice ana the attached document that the validity of the stated debt, or any portion ofit, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and~man it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and man it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARKJ. UDREN Is! Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 ~''''llillll'- "~ ~" ~I - " '~'iJ~,rc 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: GMAC Mortgage Corporation of PA Assignee: The Prudential Home Mortgage Company, Inc. Recording Date: 2/22/94 Book: 466 Page: 1036 Assignor: Assignee: Recording The Prudential Home Mortgage Company, Inc. Norwest Mortgage, Inc., a California Corporation Date: 8/26/96 Book: 528 Page: 495 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3 . On or al:Iout the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 407 Pine Road MUNICIPALITY/TOWNSHIP/BOROUGH: South Middleton Township COUNTY: CWnberland DATE EXECUTED: 2/22/94 DATE RECORDED: 2/22/94 BOOK: 1197 PAGE: 980 The legal description of the mortgaged premises is attached hereto and made part hereof. -4. . Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon 4~~'" i__""," .~ ~ .:.-lii;IJ[f~~__',,^ breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicat-ed- below~ 6 . The following amounts are due on the said Mortgage as of 8/22/00: Principal of debt due and unpaid Interest at 7.5% from 3/1/00 to 8/22/00 (the per diem interest accruing on this debt is $14.83 and that sum should be added each day after 8/22/00) $71,167.52 2,523.54 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $142.19 and that sum should be added on the first of each month after 8/22/00) 250.00 280.00 746.11 Late Charges (monthly late charge of $27.04 should be added on the fifteenth of each month after 8/22/00) 108.16 Property Inspections Other Fees Attorneys Fees (anticipated and actual to 5% of principal) TOTAL 45.00 185.00 3.558.38 $78,863.71 .-.' -~-"~ ~ - -~-"~....- ~ .~ ll>......'"""~,- 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvar.ia 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 in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the pennsylvania Homeowner's Emergency Mortgage Assistance program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendarit,- via - certified arid --regular mail, in accordance with the requirements of those acts, on the date appearing on the copr attached hereto as Exhibit nAn, and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $78,863.71 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ,ryyV Mark J. uciren, ESQUIRE , MARK J. UDREN & ASSOCIATES Attorney ~or Plaintiff Attorney I.D. No. 04302 TRlll:: COpy fROM RECORDh nd .. f I Iwre unto set my a - In Testimony whereo , . _ d h I of Said Court at Carlisle, Pa.J an tesea ~_ ~ . ,;:)'- .day of.. ~..... '''_~- !C....". This ........I,{'........ @.dMR1 K. . . .,. .... -- -- .................-;-. ..... ....P~1ho(\otarl . ~ ~, . ! , i i 7" " - -lll~'" ~ ALL THAT CERTAIN LOT OF GROUND WITH IMPROVEMENTS SITUATE IN. SOUTH MIDDLETON TOWNSHIP, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED, AS FOLLOWS: BEGINNING AT A STAKE ON TIlE SOUTH SIDE OF TIlE PINE ROAD, SAID STAKE BEING 180 FEET WEST OF CORNER OF LAND NOW OR FORMERLY OF WILLIAM L. SMITH, MEASURED ALONG THE SOUTIlERN SIDE OF SAID ROAD; TIlENCE ALONG LOT NOW OR FORMERLY OF JOHN D. FEESER, ET UX, ANDPERPlilNDlCULAR TO SAID ROAD 250 FEET, MORE OR LESS, TO A STAKE; THENCE BY LAND NOW OR FORMERLY OF LLO~ J. EDRIS, ET UX, SOUTH 84 DEGREES 3 MINUTES WEST 100 FEET TO A STAKE; THENCE ALONG LAND o'.F MARTIN F. BOYER AND WIFE AND PERPENDICULAR TO SAID ROAD 250 FEET, MORE OR LESS, TO A STAKE ON TIlE SOUTH SIDE OF SAID ROAD, NORTH 84 DEGREES 3 MINUTES EAST 100 FEET TO TIlE PLACE OF BEGINNING. AND BEING IMPROVED WITH A ONE-STORY RANCH TYPE DWELLING HOUSE. 'illillll" - ~,~.-- - ~ ~- ~ -~w,' Z 'l02 114 014 Wells Fargo Home Mortgage, Inc. P.O. Box 1225 Charlotte, NC 28201-1225 - - June 5, 2000 Seot A. Lytle 407 Pine Road Mt Holly Spring PA 17065 0514232 I000263J885Act91 RE: Well. Fargo Home Mortgage, Inc. Loan Number 0514232 Mortgagor(s): Mortgaged Premises: Scot A. Lytle 407 Pine koad . Mt Holly Spring, PA 17065 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mOrtl!a2e 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 PlIlZes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to . save vour home. This Notice explains how the PfOl!I'am works. . To see if HEMAP can help.vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vnn meet with the Connselinl! Al!encv. The name'. address and phone number of Consumer Credit CounseliD.. A2CDcies servin2 your County are listed at the end lihhis Notice. If yon have anv auestions. vou mav call the Pennsvlvanla Honsinl! Finance Al!encv toll free at 1-800-342-2397. (Persons with impaired hearinl! 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANOA, rUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICAOON OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AI. NUMERO MENOONADO I\RRlBA. PUEDES SER ELEGmLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMJR SU HlPOTECA. E.Ahn;>>l I A y="""~ -- - ~ . " _~jli!lli"lj,ii!lWK HOMEOWNER'S NAME(S): Scot A Lytle PROPERTY ADDRESS: 407 Pi:lf, Rnad Mt Ho y Spring, PA 17065 0514232 LOI\N I\CCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: WELlS FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM . wJig~ ~~~ELj~~tig~~~~~~1fiiEAND HELP YOU MAKE FUl'URF. MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE EUGmLE 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 ELIGmlLITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. ~RARY STAY OF FOR~~F. - Under the Act, you are entitled to a telI1.Porary stay o or osure on your mortgage or . (30) days from the date of this Notice. Durmg that time you must arrangc and attcnd a "face-to- acc" mcetin with onc of thc consiuncr crcdit counsclin agencies listed at the end of this Notice. ' " . 311 D YS ' YC ) (T ) I. 'OR' . GENe ' ORTG." 'S S . . . "HOW TO CIIRE YO\JR M()RTr~I\GE DEI'AI JJ .T", EXPLAINS HOW TO BR INri YO\JR MORTGAGE UP TO DATE. CON'iW,MER CRE~~01 ~SElJNG ~GF,Nr.ms.. - If you meet with one of the consumer credit counse ing _a.llencies i,st at t e endof thIS notice, the lender may NOT take action against you for ~ \30) days after the ~te of th,is meeting. The n es ad4r se~ a d tele ,hone I)umb rs n r r 1 n1 n 1 r I . " . ,,' . is 0 y necessary to see one ace-to-face meeting. Advise your lender Immediatelv of your intentions. A~'TlON 5PR MORTGAGE I\SSTSTAN~E - Your mortgage is in default for the reasons set 0 ,later in is Notice (see fiillowipg pages or specific information about the nature of your default.) If you have tried and are unable to resolve tliis problem with the lender, you have die right to apJl!y for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must flil out, sign and file a comp'leted Homeowner's Eritergellcy AsSistance Program Application with one of the designatea consumer credit counseling agencies listed at the end of this ~oticc:. Only.consum.er.credlt counseling agenc;ies have applications,for the pt:ogra!ll and they WIll aSSIst you !Il s!lbIDlttmg.a complete applIcation to ~he. Pen!lsylvanIa HOUSing Finance Agency. Your applIcatIon MUST be filed or postmilrked wIthin thIrty (30) days of your face-to-face meeting. yoii.Mi.rs:r FILE YOUR APPUCATION PROMPTLY., IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTERtlORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPUCA J JON FOR MORTGAGE ASSISTANCE WILL BE DENIED. -"'- "' ~" " lIll~,h' 000263/685 AG~~CY ~~~N - Available funds for emergency mortgage assistance are very limited They will be is. urs~ y t e Ageng' un~er the eligibility criteria est2.bhshed by the Act. Tlie Pennsylvania Ho~sIng FIn8:nce Agency lias SIxty (60) d,ays to .make a decisiQn after it receives your apphcation. Durl!lg that tIme, no foreclosure proc,eedmgs ~1.11 be pursued against you if y<?u have !"et the time reqmrements set forth above. You WIll he notified dIrectly by the I'ennsylvarna Housmg finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENn Y PROTECTED BY THEFllJNG OF A PETITION IN BANKRUPTC'XzJ'HE FOLLOWING PART OF TIllS NOTICE IS FOR INFORMATION PURPOSES Ol'lL Y AND SHOmQ NOT BE CONSIDERED AS AN ATIEMPT TO COLLECT THE DEBT. (If you have ffied bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEF AUL T (Bring it up to date). NI\TlJRE OF """:F. ORFAlJI.T-- - The MORTGAGE debt held by the above lender on your property located at:. 407 'PinE". ROAd --- - -' " -,,, -_., .._ _ __ MtHnIMri~PA 170~~ IS SERIOUSLY IN A T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the followillJt amounts are now past due: April '00ll- pmp '000 ~, O'R l' Other cha (ex lai1Jlitemi,ze: Late Char e$ 54.08 TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION 2 082.20 ~OW ~ ~E mWA~ - You may cure the default within THIRTY (30) DAYS of the ateofisnonceBYIN '. ' TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 2,082.20 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURiN'G THE THIRTY (30) DAY PERIOD. paJments must be made eitber bv cash. cashier's check, certified check or money order made payable an sent to: WELLS FARGO HOME MORTGAGE, lINe. 1 HOME ,CAMPUS X2501-01H DES MOINES, IOWA 50328 You can cure any other default by taking the following a~1:ion within THIRTY (30) DAYS of the date of this letter: T , A - -I you 0 not cure t e u t wit in HIRTY 30) DA S o t e ateo t s once, ,l9'm, ,,' eitsri, ,ccel a ",m ,'., , ' Thi means that the entire outstan ng" a ance 0 tiS' e t WI e COnsl ere ue unm te y an you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past duc is not madc wlthm THIRTY (30) DAYS, thc lcnder also intcnds to instrUCt its attorneys to start legal action to foreclose upon VallI mort1!lU!ed propertv. IF THFlflgRTGAGE T~ rRf~HSF:Pe ~;N - - The mortgaged propertr will be sold by the Sheriff to pay 0 e mortga,ge e t. e en er r ers your ca~e to Its attorneys, out you cure the delinCl.ueney before the lender begms legal p'roceedings, againstyou1.You will still be required to pay the reasonable attorney's fees that were actUally incurred, up to $50.vO. However, if legal proceedings are started. a,gainst YO~'you will have to pay all reasonable attorney's fees actUally Incurred bv the lender even If tliey exceM $'50.00. Any attorney's fees will be added to the ~ount you owe the 1enderJ.whi<;h may also include other reasonable costs. If vou cure the default WIth'" the THIRTY /301 DA I perIOd. vou will not be reauired to pav attorney's tees. ill"HF.U I f3?F~ RFMFT-!\ - - The lender may also sue you personally for the unpaid principal biUailce an a 0 er SWDS ue under the mortgage. "'" ~" ~- . . ,...,~, 000263/665 E 'SALE - If you have not cured the default orec OSUfe procee ings have oe un, '1 h . h . . do so h , a in the otal amount the,:! ast. uelus an late or ther ch r es then due reason ble a orne e san c stsc nnece WI t e orecosures ean an t ere c un e wi e Sheri's Sa e as S ecifie in writiIi e en erand b . erformill an ot er re uirements un er the mortl!:al!:e. uril1l\ your e a fin e nUllIner set or m 's notice w restore your mortgage to e same position as If you had never defaulted. EAR.}f'ST POSSTRl.E SHJI.R'!l:'S SAl.P. nATF, - It is estimated thai: the earliest date that such a Sheri's Sale of the mortgage property could beheld would be approximately six (6) 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 me 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 C,ONTACT THF.J ~NT),R,R~ Name of Lender: Address: Phone Number: Fax Number: Contact Person: Wells Fargo Home, Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 1-800-766-0987 704-423-4016 Jerry Wagner EFFF.r.r' OF SHERIFF'S SI\LE - You should realize that a Sheriff's Sale will end your ownership of the mortgagea property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ mayor _may not selI or transfer your home to a buyer or transferee who wtll 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 reqwrements 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 ~ ~~~m~ffrJ~g~J,lliWE~1HlltA~~~~fg&p&':i.~1HAVE CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . T-O ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. ~"''''"''''~'" \i "~ . ..^ . . ~~~ '"' It APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM , CONSUMER CREDIT COUNSEUNG AGENCIES CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, l' A 171 02 (717) 541-1757 F A}C# (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Streel Waynesboro,I'A 17268 (717) 762-3285 Urban League of Mcrropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FA}C# (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Community Action Commission of the Capital Region,-- 1514 Derry Street Harrisburg1 P A 17104 (717) 232-':1757 FA}C# (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (711) 334-1518 FA}C(717) 334-8326 The Pennsylvania Housing Finance Agency ean be reached TOLL FREE at 1 (800) 342-2397. ~i""" "~ . "~ ,,,,,,,",,"""',,,,;" Wells Fargo Home Mortgage, Inc. P.O. Box 1225 Charlotte, NC 28201-1225 - June 5, 2000 Scot A. Lvtle 407 Pine Road Mt Holly Spring PA 17065 0514232 1000284/685Ao191 RE: Wells Fargo Home Mortgage, Inc. Loan N~~h~;0514232 Morrgagor(s): Seot A. Lyrle Mortgaged Premises: 407 Pine Road . Mt Holly Spring, PA 17065 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mormaae on your home is in default. and the lender intends to foreclose. SDecifi.c inforlnation about the nature of the default is orovided in the attached pal!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save vour home. This Notice explains how the orOllraIn works. To see if HEMAP can help. vou .must MEET WTIH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when YOU meet with the C.ounselinl! Al!encv. . The name. address and phone number,of Consumer Credit Couns~Hn17 Al!encies servin2 vour gountv are listed at the end of this Notice. If van have anv anestions. yOU ,mav call the Pennsvlvania l:lonsine Finance Al!encv tollEree at 1-800-34~2397./Persons;with intoairedheariru!: 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 abl~ 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 NGTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL V I\NTI\ HOUSING FINANCE AGENCY) SIN CARGOS AI. NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE I\SSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDJDA DEL DERECHO A REDIMIR SU HlPOTECA. ;j->j~-~" ":l<l >~ M..~ HOMEOWNER'S NAME(S): Scot A I.ytle PROPERTY ADDRESS: 407 Pine Rood Mt Holly Spring, PA 17065 0514232 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: WBLL'l FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGffiLE FOR FINANCIAL ASSISTANCE wHICHGANSAVE Y9UR HOMEFROM';FORECLOSQREAND HELP YOU MAKE FUTURE MORTGAGEl'A YMJENTS IF YOU COMPLY WIIH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE EUGmLE 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 ELlGffiILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. ' ~~RARY STAY OF FOR~~ JRE - Under the Act, you are entitled to a temporary stay o forec osure on your mortgage or 'm' (30) days from the date of this Notice. Dunng that time you must arrange and attcnda "facc-to-fil.cc" mcctil!g with onc of thc consUD)cr crcdit counseling agencies listed ,at the end of this Notice. nns MEETING MlJST OC,c.lJR WITHIN THE NEXT rnllJ),' " AYS ~ fOU DB~OT MPL y FO~~GE~~ M()RTC~~~'SIS~~~f~ l()U .I\2lI1SI ,'gm'N :.. OUR RTG GRtli>"'i"i_ _ I___ART OF _____TI-"- ~tCJ...n "HOW TO CllRI'. YOIIR MORT(~I\(~EI)l1.I'I\IILT" EXPlAINS HOW TO RRING YOUR MORTGAGE UP TO DATE. CONS~R CRF.~lT f01~SE~AGENCII\~ - If you meet with one of the consumer credit counse ing agencies lste at t e end, Of 0 this notice, t' e lender may NOT take action against you for PtirtY (3U) days after the date of this meeting. The names addre se e one numbers f . r r i Jin n , I r' . . ' .. , . is on y necessary to e e one ace-to-face meeting. A vise your ertder immediatelv of your intentions. AP~~TION fR MORTGJ\GE ASSTSTI\N'i.E - Your mortgage is in default for the reasons set 0 ater in is Notice (see fOI\owirg pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have tne right to apI1-ly for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a coml?leted Homeowner's Bitergency AsSistance Program Application with one of the designateQ consumer credit counseling agencies listed at the end of this ~otice.. Only.conslllD:er. credIt counseling ~enc?es have applications .for the program and they WIll assISt you m submlttmg_a complete applicatIon to the PennsylvanIa Housill!tFinance Agency. Your application MUST he filed or pO~1marked within thirty (30) days of your 'face-to-face meeting. YOu. MiJST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME. PERIODS SET FORTH IN TInS LE'ITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. ''''-~" .._"".~- .." .. ~ - -,,,,,~,o,,, , .. . 000264/685 tG~~CY ~tJT~N - Available funds fa! ~ryterge.ncy' mortgage assistance are very limited. They will e I~ lIrSf! Y t e Ageng' under the ehgtbIlity Crttena esta bhshed by the Act. Toe Pennsylvania Ho~stng Fma.nce Agency lias sixty (60) d!lYs to .make a decisiqn after it r~eives your apphcation. Durl.ng that tIme, no foreclosure proc!ledmgs 1IYI:ll be pursued agamst you If you have met the time reqUlremel)t~ set f,?rth above. You :mH. be notIfied directly by fhe Pennsylvania Housing Finance Agency of Its decIsion on your apphcatlon. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION INBANKRUPTCY,zJ'HE FOlLOWING PART OF THIS NOn<'::E IS FOR INFORMA nON PURPOSES ONLY AND SHOULO..J:'l'OT BE CONSIDERED AS AN A 1TEMPT TO COLLE~ 1 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). NI\TURE OF THF DF,FI\lJ1,T- - The MORTGAGE-rlebt held by the above lender on your property lOcated at: 407 Pinf'! Rn~cI Mt Holk.SDrifft Pa, 17n,;~ IS SERIOUSLY IN I5EF A T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the foHowing months and the followillJ( amounts are now past due: April '000 - ['In" ,nnn ~, MR l' Other char es (ex lairyitemi.ze: Late Cha es 54.08 2 082.20 TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION ~ow't~ CEllI M~- You may cure the default within THIRTY.(30l DAYS of the ate ot t is notice BY.. . . TOTAL AMOUNT PAST DUE TO THE. LENDER WHICH IS $ 2082.20 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BEcOME DUE DURiNG THE THIRTY (30) DAY PERIOD. paJments must be made either bv cash. cashier's check. certified check or money order made payable an sent to: WELLS FARGO HOME MORTGAGE, JlNC. 1 HOME CAMPUS X2501-01H DES MOINES, IOWA $0328 You can cure any other default by taking the following al.1ion within THIRTY (30) DAYS of the date of this letter: - - I you 0 not cure t e u t wi in THIRTY 30) DAYS o t e tea IS. otice,' 'nib ercise its ri h .' . Thi means that the entire outstan 'a imce 0 t IS e t WI e consl e ue ImIne ate y an you may lose the chance to pay the mO!!Kage in monthly installments. If full payment of the total amount past duc is not madc WIthin THIRTY (30) DAYS. thc lender also intcnds to instrUct its attorncys to start legal action to foreclose upon vour mortl!aeed orODer1:V. IF THE ~~RTG.~GE I~~O~~ I~N - - The mortgaged property will be sold by the Sheriff to pay 0 t e mortga,lle e t. . e. en er t ers your case to ItS attorneys, out you cure the delinquency before the lender begms legal p'roceedings againstyoubyou will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50. O. However, if le,gal proceedings are started. a1l3inst you,you will have to pay all reasonable attorney's fees actually mcurred bv tlie \ende! even If tlley exceed $50.00. Any attorney's fees will be added to the !llI!ount you owe the lenderl,whi<;h may also include other reasonable costs. If von cure the default w,thm the THIRTY (31ll DA I nenod. vou will not be reouired to nav attorney's tees. , ~R T'a~F! RFM~S - - The lender may also sue you personally for the unpaid principal a ance an a 0 er sums ue under the mortgage. __,~ "H'. .<""'l(I""'~~"~ l" ~,~: 000264/685 IG TiC RE DEFA wit in t e TfIIRTY (30) DAY !lerio or .osure procee ings do so a :in the total amount then a t ue Ius an late Of 0 hef chaf es hen due feasonable attorn's '5 an costs connect' it e rec osure sa e an a er co ts c nne e wi e Sheri's Sale' as s eci ie in writin the lender and b erformin an at er re uirements un er the mortl!:al!:e. Gu~ your e a [,in' e lJ1ll1lDet set m' notice w restore your mortgage to e same positioh as If you had Dever defaulted. ' F.I\RI.ffiST PoSSffiT.F. SHERIFF'S SAT.F pATF. - It is estimated that the earliest date that such a Sheriff's Sale, ?f the !"ortgage~ propfFtr could be held would ~e approximately six (6) months from the date of ~s Notice. A notIce of the actual date of the Sherlff's-Sale will be sent to you before the sale. Of course, the amount needed to ~e t1te default will increase the longer you waiL You may find out at any time exactly what the required payment or action will be hy contactmg the lender. HOW TO ClONTACT THF.,] .RNnF.R- Name of Lender: Address: Phone Number: Fax Number: Contact Person: Wells Fargo Home, Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 1-800.:766-0987 704-423-4016 Jerry Wagner EFFEr.r' OF SHF.RTF1"S SI\ I.E - 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 furnismngs and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or _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 THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSmON AS IF NO DEPAUL T HAD OCCURRED IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THL~ RIGHT TO C~URE YOUR DEl<'AULT MORE THAN THREE TIMES IN I\NY 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 MA Y HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. . . . . . - .. '..~~ib.4!:{';>;-_ , .. APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 171 02 (717) 541-1757 F A}C# (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban Lcaguc of Mctropolilan Harrisburg N. 6th Street Harrisburg, P A 171 01 (717) 234-5925 FA}C#(717)234-9459 YWCA of Carlislc 301 G Street Carlisle, P A 17013 (717)243-3818 FA}C# (717) 731-9589 Community Action Commi;';;on of the C~pital Regio~-= 1514 Derry Street Harrisburg, P A 17104 (717) 232-9757 FA}C#(717)234-2227 AdamsCoun~ Housing Authority 139-143 C'.arhsle St. Gettysburg, P A 17325 (711) 334-1518 F A}C (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. . -~< ~~, V E R I FIe A T ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark MARK i~ J~ ren, ESQUIRE J ~ UDREN & ASSOCIATES \. ^".',-y" f1,'J~~ (!fJ2 ~ ~ .~ ~ ,~ lIJ1li!1!j11~._.~ '~ .'-, ~"~#""'- - <,~ ",0',," '^ ~-,-, .,~ .. ~ '-, .,-""~"- @ ~ ~ fiii ~D1IT~~\lRII,1fflfJi'i"__'1"'m.~'lW-1'@f.'iff'Wf!W\;m;-l\l';r'lt.~JfW~~~~i!iMi"''' "" [" _,JlO.'~ . JOHN ROBERT DEPUTY, Plaintiff v. JANICE F. DEPUTY, Defendant .~~ -. ':f'!!$!1!.i;hWsl~": , . . : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-6523 CIVIL : IN DIVORCE PRAECIPE PLEASE enter my appearance on behalf of the Defendant, JANICE F. DEPUTY, in the above-captioned action. DAlE: /0 (I'Ll 00 iane S. Baker, Esquire 27 South Arlene Street P.O. Box 6443 Harrisburg, P A 17112 (717) 671-9600 C" "., I' ,",',",,,. ,'.' ~ '- H _~~~ lllllilill " ~~n 1!fu.,it.~it:'>JW~~~~ti_:,~' -I U.lli.d._~~ . -. ,,~--. . ". II , , I I i - --. ~,',,'~ ~ ~, . Q ~; yft fI,.---, fEi ) c 5if; ~ "'~.~, - " . ~, c:! ',c:J ::--) -; C"j ,~ ';';" w " ~~~~- HARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff v. Scot A. Lytle 407 pine Road Mt. Holly Spring, PA 17065 Defendant(s) ~ ~ u_ c.: "'J~'> ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. 00-6523 CIVIL PRAECIPE TO HARK SETTLED. DISCONTINUED AND ENDED TO THE PROTHONOTARY: please mark the above captioned matter SETTLED, DISCONTINUED and ENDED, upon payment of your costs only. Dated: November 29. 2000 '" "'-,, ,~ -l," 1'-m~llldlJ-U[li1l1!l<<*~~i~m.:@[>iiE,~.@i~~'-' ,.. . ~, -' , "-" ".~,~.;;.",,-.;i"'~i.' ~ -,~..~--" ~~ ,.-- .'" ""h~ ' ". (') 0 0 0 'T1 c: ~ 0 ~:) '" ~,"-n rijOJ C) r-~~~ ;::::::~ z~ '"l-~-n :2"t- - (~~~, ~Z (;2G -0 rj('5 ~O :;l\: ~-- ~O r:- ;\1 ;pc: ~ ~ - 1;:' ::< '"