The URL can be used to link to this page

Home My WebLink About00-07177 -~....<.-." - , - I. ~ ~~ FEDERMAN AND PHELAN, LLP By: FRAJiKFEDERMAN,ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. 8201 GREENSBORO DRNE, SUITE 350 MCLEAN, VA 22102 Plaintiff TERM NO.Oc.- 7/77 O~l{~ CUMBERLAND COUNTY v. LEROYE. ARTZ 531 3RD STREET WEST FAIRVIEW, PA 17025 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE **TIDS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBt AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECErvED A DISCHARGE IN BANKRUPTCY AND TIDSDEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 19388317 . ~~ - . ~ , , I ,,-,1,,"::,- "_. . -"~~<"."'""'~O '-::;; 1. Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 2. Plaintiff, is or will be, the owner of legal title to the mortgage that is the subject of this action, and nominee for the entity indicated below, which is the owner of the entire beneficial interest in the mortgage: HOMESIDE LENDING, INC. 7301 BAYMEADOWS WAY JACKSONVILLE, FL 32256 3. The name(s) and last known addressees) of the Defendant(s) are: LEROY E. ARTZ 531 3RD STREET WEST FAIRVIEW, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 4. On 11/11/96 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PHH MORTGAGE SERVICES CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1351, Page 578. By Assignment of Mortgage recorded 7/19/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 619, Page 531. 5. The premises subject to said mortgage is described as attached. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 7/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." w.'; 7. The following amounts are due on the mortgage: Principal Balance Interest 6/1/00 through 10/1/00 (Per Diem $13 .42) Attorney's Fees Cumulative Late Charges 11/11/96 to 10/1/00 Cost of Suit and Title Search Subtotal $57,622.31 1,650.66 2,881.00 89.48 550.00 $62,793.45 Escrow Credit Deficit Subtotal 0.00 296.46 $ 296.46 TOTAL $63,089.91 8. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 10. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~ 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 11. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $63,089.91, together with interest from 10/1/00 at the rate of $13.42 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~:r~ /s/ Frank F ederrnan FRAJiKFEDER1{AN,ESQUIRE Attorney for Plaintiff ~-J ". I " ,;-',''''''-."-'' .">< ~'~"".-6~ .'~ je iJif~'i ~~ . HOMESIDE LENDING,INC. AUGUST 06, 2000 cY ~,~ LEROY E ART I 531 3RD ST ENOLA PA 17025-3132 RE' LOAN NUM6ER' 19366317 PROPERTY ADDRESS' 531 3RD ST WEST FAIRVIEW, PA 17025 ACT 91 NOT! CE TAKE ACTION TO SAVE YOUR HOME FROM FURECLOSURE THIS IS AN OFFICIAL NOTICE THAT THE MORTGAGE ON YOUR HOME IS IN OEFAULT, AND THE LENDER INTENDS TO FORECLOSE. SPECIFIC INFORMATION A60UT THE NATURE OF THE DEFAULT IS PROVIDED IN THE ATTACHEO PAGES. THE HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPI MAY 6E ABLE TO HELP TO SAVE YOUR HOME. THIS NOTlc!; t:XPLAINS flOW THE PROGRAM WURKS. TO SEE IF HEHAP CAN HELP, YOU MUST MEET HITH A CONSUMER CREDIT COUNSEL- ING AGENCY WITHIN 30 DAYS OF THE DATE OF TMIS NOTICE. TAKE THIS NOTICE WITH YOU WHEN YOU MEET WITH THE COUNSELING AGENCY. THE NAME, ADDRESS AND PHONE NUMBER OF CONSUMER CREDIT COUNSELING AGENCIES SERVICING YOUR COUNTY ARE LISTEU IN THE ENCLOSURE. IF YOU HAVE ANY QUESTlONSt YOU MAY CALL THE PENNSYLVANIA HOUSING dNANCE AGENCY TOLL FREE A I-BOO-342-2397. (PERSONS WITH IMPAIRED HEARING CAN CALL (717)760-1B69.) THIS NOTICE CONTAINS IMPORTANT LEGAL INFORMATION. IF YOU HAVE ANY QUESTIONS, REPRESENTATIVES AT THE CONSUMER CREDIT COUNSELING AGENCY MAY BE ABLE Tu HELP EXPLAIN IT. YOU 11AY ALSO WANT TO CONTACT AN ATTORNEY IN YOUR AREA. THE LOCAL BAR ASSOCIATION MAY BE ABLE TO HELP YOU FINO A LAWYER. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA PUES AFECTA SU DERRECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGAUNA TRADUCCION INMEDIAMENTE. LLAMANOO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUHERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAHADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM- ELCUAL PUEDE SALVAR SU CASA DE LA PEROI0A DEL DERECHO A REMIDIR SU HIPOTECA. STATEMENTS OF POLICY YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS FOR THE FOLLOWING MONTHS AND THE FOLLOWING AMOUNTS ARE NOW PAST DUE' MONTHS DELINQUENT' 2 PAYMENT AMOUNT' $517.31 LEGAL FEES' il LATE CHARGE BALANCE. 44.74 PROPERTY INSPECTIONS' 21.50 RETURN ITEH FEES: 50.00 TOTAL DUE. $1",270.B6 HOW TO CURE THE DEFAULT--YOU MAY CURE THE DEFAULT WITHIN THIRTY (301 DAYS OF THE DATE OF THIS NOTICE BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $1,270.B6 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DU~ DURIN~ THE THIRTY (30) DAY PERIOD. PAYMENTS MUST BE MADE EITHER BY CASH, CASHIER'S CHECK, CERTIFIED CHECK OR MONEY ORDER MADE PAYABLE ANO SENT TO: ATTN CASHIERING DEPARTMENT HOMESIDE LENOING, INC. 9601 MCALLISTER ~RWY SAN ANTONIO IX 76216 CL63 - 062000TG P.O. BOX 47524 SAN ANTONIO TX 78265-7524 I-B77-733-4200 PAGE 1 Of 4 EXHIBIT A ~ --- LENDER - ,. , , -,-'I -",~~,;;;;,;, ~~ . HOMESIDE LENDING, ING. LEROY ARTZ 19388317 / STATEMENTS OF POLICY fF YOU 00 NOT CURE THE OEFAULT--fF YOU DO NOT CURE THE DEFAULT WITHIN HIRTY 130) OAYS OF THE DATE OF HIS NOTICE THE LENDER INTENDS TO EXERCISE ITS RIGHTS TO ACCELERATE THE MORTGAGE DE8T. .THIS MEANS THAT THE ENTIRE OUTSTANDING 8ALANCE OF THIS DE8T WILL 8E CONSIDERED OUE 1~~V~tt~~hfS~NDI10~urtYp~~~~NfH5FC~A~Cfof~LP:~0~~Y ~~~fGaB~ I~ ~8o/T"k~E WITHIN THIRTY 1301 DAYS, THE LENDER ALSO INTENDS TO INSTRUCT ITS ATTORNEYS TO START LEGAL ACTION TO FORECLOSE UPON YOUR MORTGAGED PROPE RTY . IF YOUR MORTGAGE IS FORECLOSED UPON--THE MORTGAGED PROPERTY WILL BE SOLD BY THE SHERIFF TO PAY OFF THE MORTGAGE DEBT. IF THE LENDER REfERS YOUR CASE TO ITS ATTORNEYS. Bur YOU CURE THE DELINQUENCY BEFORE THE LENDER BEGINS LEGAL PROCEEulNGS AGAINST YOU, YOU WILL STILL BE REQUIRED f.O PAY THE REASONA8LE ATTORNEY'S FEES THAT WERE ACfUAlLY INCURR~B' UP o $50.00. HOWEVER, IF LEGAL PROCEEDINGS ARE STAR EO AGAINST Y ,YOU WILL HAVE TO PAY ALL REASONABLE ATTORNEY'S FEES ACTUALLY INCURR 0 BY THE LENDER EVEN IF THEY EXCEED $50.00. ANY ATTDRl<ey'S FEES HILL 6E ADOEO TO THE AMOUNT YOU OWE THE LENDER WHICH MAY ALSO INCLUDE OTHER REASONABLE COSTS. IF YOU CURE THE DEFluLT WITHIN THE THIRTY (301 DAY PERIOD, YOU WILL NOT BE REQUIRED TO PAY ATTORNEY'S FEES. OTHER LENDER REMEDIES--THE LENDER MAY ALSO SUE YOU PERSONALLY FOR THE UNPAID PRINCIPAL BALANCE AND ALL OTHER SUMS DUE UNDER THE MORTGAGE. RIGHT fO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--IF YOU HAVE NOT CURED HE DEFAULT WITHIN THE THIRTY 130 DAY PEKIOD AND FURECLOSURE PROCEEDINGS HAVE BEGUNt YOU STILL HAVE THE RIGHT TO CURE THE DEFAULT AND PREVENT THE SALE A ANY TIHE UP TO ONE HOUR BEFORE THE SHERIFf'S SALE. YOU MAY DO SO BY PAYING THE TOTAL AMOUNT THEN PA~T DUEl PLUS ANY LATE DR OTHER CHARGES THEN DUE REASONABLE ATTORNEY'S FEE~ AND COSTS CONNECTED WITH THE FORECLOSURE SALE AND ANY OTHER COSTS CONNECTED WITH THE SHERIFF'S SALE AS SPECIFIED IN WRITING BY THE LENDER AND BY PERFORMING ANY OTHER REQUIREMENTS UNDER IHE MORTGAGE, CURING YOUR OEFAULT IN THE MANNER SET FORTH IN THIS NUTICE RilL KESTORE YOUR HORT- GAGE TO THE SAME POSITION AS IF YUU HAO NEVER U~FAULTEO. EARLIEST POSSIBLE SHERIFF'S SALE DATE--IT IS ESTIMATED THAT THE EARLIEST DATE THAT SUCH A SHERIFF'S SALE OF THE MORTGAGED PROPERTY COULD BE HELD WBU\:D BE APPROXIHAIELYASIX 161 MONTHS FROM THE DAlE OF THIS NOTICE. A NT CE OF THE ACTU L 0 TE OF THE SHERIFF'S SALE W Ll.6E SENT TO YUU BEFORE THE SALE. OF COURSE, THE AMOUNT NEEOEO TO CURE THE DEFAULT WILL INCREASE THE LONGER YOU WAIT. YOU HAY FINO OUT AT 'ANY lIME EXACTLY WHAT THE REQUIREO PAYMENT DR ACTION WILL BE BY CONTACTING THE LENDER. HOW TO CONTACT THE LENDER' . NAME OF LENDER: HOMESIOE LENDING, INC. ADDRESS: COLLECTIONS UEPAKTMENT 9601 MCALLISTER FRWY SAN ANTONIO, TX 78216 PHONE NUMBER' 1-871-133-4~00 FAX NUMBER: (2101308-4499 EFFECT OF SHERIFF'S SALE--YOU SHOULO REALIZE END YOUR OWNERSHIP OF THE MORTGAGED PROPERTY IT. IF YOU CONTINUE TO LIVE IN THE PROPERTY A LAWSUIT TO REMOVE YOU AND YOUR FURNISHINGS COULD BE STARTED BY THE LENDER AT ANY TIHE. HOHEOWNER'S NAMECSI: LEROY E ARTZ PROPERTY ADDRESS: ~~h3~2I~hEW PA 11025 LOAN ACCOUNT NUMBER: 19386311 ORIGINAL LENDER: FEDERAL HLMC CURRENT LENDERISERVICER' HOHESIDE LENDING, INC. THAT A SHERIFF'S SALE WILL ANU YOUR RIGHT TO OCCUPY AFTER THE SHERIFF'S SALE, AND OTHER BELONGINGS CL63 - 062000TG P.O. BOX 47524 SAN ANTONIO TX 18265-1524 1-811-133-4200 PAGE 2 OF 4 EXHIBIT A @ --- tENOER "-.". ~.--~. ,,,,,,",,.-~._~_. >>0-' , I. ~" ~--I<~~;" ....~ . HOMESIDE LENDlNG,INC. LEROY'ARTZ 19388311 STATEMENTS OF POLICY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANC[AL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS [F YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASS[STANCE ACT OF 1983 [THE "ACT"), YOU MAY BE ELIGI8LE FOR EMERGENCY MORTGAGE ASS[STANCE: . * IF YOUR DEFAULT HAS 8EEN CAUSED BY CIRCUMSIANCES BEYOND YOUR CONTROL. * IF YOU HAVE A REASONABLE PROSPECT OF 8EING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEEl OTHER EL[G[B[LITY REQUIREMENTS ESTA8LISHED BY THE PENNSYLVAN A HDUS[NG F[NANCE AGENCY TEMPORARY STAY OF FORECLOSURE--UNDER THE ACI. YOU ARE ENTITLED TO A TEMPORARY STAY OF FORECLOSURE ON YOUR MORTGAGE FOR TH[RTY (30) DAYS FROM THE DATE OF TH[S NOTICE. DUR[NG THAr TIME YOU MUST ARRANGE AND ATTEND A "FACE-TO-FACE" HEET[NG WITH ONE OF THE CONSUHEfCCREDIT COUN- SELING AGENC[ES LISTED AT THE END OF TH[S NOT[CE. THIS HEETING HUST OCCUR WITH[N THE NEXT THIRTY (301 DAYS. IF YOU 00 NOT APPLY FOR EHERGENCY HORTGAGE ASSISTANCE, YOU MUST BR[NG YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLEu "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLA[NS HOW TO 8R[NG YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--[F YUU HEET WITIl ONE OF THt CONSUMER CRED[T COUNSELING AGENCIES L[STED AT THE END OF THIS NOT[CE THE LENDER MAY NOT TAKE ACT [ON AGAINST YOU FOR TH[RTY (30) DAYS AFTE~ THE DATE OF TII[S MEET[NG. THE NAMES, ADDRESSES AND TELEPHONE NUHBERS OF DESfGNATED CONSUHER CREDIT COUNSEL[NG AGENC[ES FOR THE COUNTY [N WHICH HE PROPERTY IS LOCATED ARE SET FORTH AT lIiE ENO Uf TIllS NOTICE. [T [5 ONLY NECESSARY TO SCHEDULE ONE FACE-TO-FACE MEET[NG. ADVISE YOUR LENDER IMMED[ATELY OF YOUR [NTENTIONS. APPLICAT[ON FOR MORTGAGE ASSISTANCE--YOUR MORTGAGE IS IN DEFAULT FOR THE REASONS SET FORTH LATER [N TH[S NOT[CE (SEE FOLLOW[NG PAGES FOR SPECIFIC INFORMAT[ON ABOUT THE NATURE OF YOUR OEFAULT). If YOU HAVE TRIED ANO ARE UNABLE TO RESOLVE THIS PR08LEM WITU THE LENDER, YOU I1AVE TUE RIGHT TO APPLY FOR FINANCIAL ASSISTANCE FROM THE HOMEOWNeR'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM. TO 00 SO. YOU MUST FILL OUT. SIGN AND FILE A COMPLETED HOMEOwNER'S EMERGENCY ASSISTANCE PROGRAM APPLICATION W[TH ONE OF THE DESIGNATED CONSUMER CREDIT COUNSELING AGENCIES LISTED AT THE END OF THIS NOTICE. ONLY CONSUMER CREDIT COUN- SELING AGENCIES HAVE APPL[CATIONS FOR THE PROGRAM AND TUEY WILL ASSIST YOU IN SUBMITTING A COMPLETE APPLICATION TO THE PENNSYLVANIA HOUSING FINANCE AGENCY. YOUR APPLlfATION MUST 8E FILED OR POSTMARKED WITHIN THIRTY (30) DAYS OF YOUR FACE"TO-FACE MEETING. YOU MUST F[LE YOUR APPL[CATION PROMPTLY. IF YOU FAIL TO 00 50 OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTIl IN TH[S LETtER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLI- CATION FOR MORTGAGE ASSISTANCE WILL BE DEN[ED. AGENCY ACT[ON--AVA[LABLE FUNDS FOR EMERGENCY MORTGAGE ASSISTANCE ARE VERY LIMITED. THEY WILL BE ylS8URSED BY fHE AGENCY UNDER THE ELIGI- 8 LITY CR[TERIA ESTABLISHED Y THE ACT. HE PE~NS LVANIA IlOUSING FINANCE AGENCY HAS SIXTY (bO DAYS TO HAKE A DECiSION AFTER IT RECEIVES YOUR APPLICATION. DURING THAT TIMEt NO FORECLOSURE PROCEEDINGS WILL Be PURSUED AGAINST YOU IF YOU HAVE ME THE TIME REQUIREMENTS SET FORTH ABOVE, YOU WILL BE NOTIFIED DIRECTLY BY THE PENNSYLVANIA HOUSING FINAN~E AGENCY OF ITS DEC[SION ON YOUR APPL[CATIUN. NOTE' IF YOU ARE CURRENTLY PROTECTED BY THE fiLING OF A PETITION IN BANKRUPTCY. THE F8LLOHING PART OF THIS NOT[CE is FOR INfURMATION PUR- POSES ONLY AND SH ULD NOT BE CONSIDERED AS AN TTEMPT TO COLLECT THE DEBT. (IF YOU HAVE FILED BANKRUPTCY YOU CAN STILL APPLY FO~ EMERGENCY MORTGAGE ASSISTANCE.) CLb3 - Ob20DOTG P.O. BOX 41524 SAN ANTON[O TX 1B2b5-1524 I-B 11-133-4200 PAGE 3 OF 4 EXHIBIT A 2 LENDER , _ u'"~_~_ -~ I.. , "-.,- <c',",. ,,"' ~ ~~ . HOMESIDE LENDING, INC. LEROY' ARTZ 193BB317 STATEMENTS OF POLICY HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATEI NATURE OF THE DEFAULT--THE MORTGAGE DEBT HELD BY THE ABOVE LENDER ON THE PROPERTY LOCATED ATI 531 3RD ST WEST FAIRVIEW PA 17025 IS SERIOUSLY IN DEFAULT BECAUSE YOU HAV~ FAILED TO PAY PROMPTLY 1~Sl~k~~E~I1r~F(~~IN6I~~~ AND INTEREST, AS REQUIRED, FOR A PERIOD OF ASSUMPTION OF MORTGAGE--YOU (++IMAY (++IMAY NOT (CHECK ONEI SELL DR TRANSFER YOUR HOME TO A BUYER OR TRANSFEREE WHO HILL ASSUME THE MORTGAGE DEBT. PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY" FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS OF THE MORTGAGE ARE SATISFIED. (+.1 PLEASE CHECK YOUR MORTGAGE DOCUMENTS OR CALL OUR SSUMPTION DEPARTMENT AT 1-877-944-9400 TO DETERMINE IF YOUR LOAN IS ASSUMABLE. YOU MAY ALSU MAVE THE RIGHT . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE OE8T 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. . fa HAVE THE MORTGAGE RESTORED TO TIlE SANE POSITION AS IF NO DEFAULT HAD OCCURRFD. IF YOU CURE THE DefAULT. (ItOWEVeR, YUU 00 NOT HAVE rHE RIGHT TO CUR. YOUR DEFAULT MORE TlUN T1iREt T1HtS IN ANY CALENDAR YeAR. I . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT NSTITUTED 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 FEUERAL BANKRUPTCY LAW. SINCERELY, R. AGUILAR COLLECTION SUPERVISOR ENCLOSURE CCI FIRST CLASS AND CERTIFIED MAIL NOI___________________ ADDRESSEE 531 3RD ST WEST FAIRVIEW, PA 17025 CL63 - D62000TG P.p. BOX 47524 SAN ANTONIO 1-877-733-420" MCI 2 PAGE 4 UF 4 EXHJBIT A ~ u:.r --- tENDER TX 78265-7524 ...... ;~~ PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY ~ Lycoming-Clinton Coup.ties Commision for Community Action (STEP) 2138 Lincoln Street P.O. aox 1328 Williams port, P A 17703 (570) 326-0587 FAX (570) 322-2197 CCCS of North eastern PA 201 Basin Street Williamsport, PA 17703 (570) 323-6627 FAX (570) 323-6626 31 W. Market Street POB 1127 Wilkes-Barre, P A 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 CCCS ofNonheastern P A 1631 South Atherton St, Suite 100 State College, PA 16801 (814) 238-3668 FAX (814) 238-3669 COLUMBIA COUNTV 1400 Abington Executive Park Suite 1 Clacks Summit, PA 18411 (570) 587-9163 or (800) 922-9537 FAX (570) 587-9134-9135 Commission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Barre, P A 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1 665-(Cal1 Before Faxing) (570) 455-4994 Hazelrown FAX (570) 455-5631-(Call Before Faxing) (570) 836-4090 Tunkhannock Booker T. Washington Center 1720 Holland Center Erie, P A 16503 (814) 453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East 20. Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N.6"'Street Harrisburg, P A 1710 1 (717) 234-5925 FAX (717) 234-9459 Community Action Corom of the Capital Region 1514 Derry Street Harrisburg, P A 171 04 (717) 232-9757 FAX (717) 234-2227 CRAWFORD COUNTY Greater Erie Community Action Committee 18 West 91h Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Shenango Valley Urban League, Inc. 601 IndianaAvenue Farrell, PA 16121 (412)981-5310 CUMBERLAND COUNTV Financial Counseling Services of Franklin 31 West 3" Street . Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 "G" Street Carlisle, P A 17013 . (717) 243-3818 FAX (717)731-9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, P A 17325 (717) 334-1518 FAX 334-8326 PENNSYLVANIA BULLETIN, VOL. 29, NO. 23, JUNE 5, 1999 EXHIBIT A . -, - ~'~"''"'''''''iIlJ~; ~LLTHAT CERTAIN portion, piece or parcel of land situate in the Borough of West .,a'd""Vdlew"bCodunt:: ollfCumberl~d and State ofPelU'lsy}vania, more particularly bounded escn e as.l:O ows~ to WIt: B~GINNING at a point in the eastern line of Third Strerot, ninety-sroven (97) feet south of the southeast corner of the intersection of Third Street and May Avenue; thence eastwardly along th.e southcn1 line of Lot No. 36. on the hereinafter Inentioncd Plan of Lots, one hundred and nine (109) feet to a point in the western line of a twenty (20) froet wide alley; thence southwardly along the western line of said twenty (20) feet wide .I1ey, thirty (30) feet to a point; thence westwardly along the northern line of Lot No. 38, one hundred and nine and five-tenths (109.5) feet to a point in the eastern line of Third Street; thence northwardly along the eastern line of Third Street, thirty (30) feet to a point, the place of BEGINNING. BEING Lot No. 37 in H.R. May's Second Addition to the Borough of \Vest Pairview; said Plan being recorded in the Office for the Recorder of Deed in and for' Curnbedand County in Plan Book I, Page 54. HA VING t.'lereon erected a single frame dwelling knovtn and numbered as No. 53] Third Streel~ West Fairview> Pennsylvania. BEING the sarne premises which Ralph A. Sheetz, Executor of the Estate of Wayne I;. Disney, by his Deed datee thc 4"' day of March, 1987 and recorded il1 the Office of the Recorder of' Deeds~ in Cllid for Cumberland County in Deed Book N. V01UIlll:: 32, Page 801, granted and conveyed unto DALE A. RYDER and JoANNA J. RYDER, Grantors herein. UNDER AND SUBJECT, NEVERTliELESS, to the conditions, n:strictions, agreements~ easements, rights of way I cncumbrances~ and all other matters of record. TOGETHER with all and singular hereditaments and appurtenances thereunto belonging or in anywise appertaining and the reversions -and remainders, renlS~ issues and profits thereoc; and all the estate, right~ title, interest, property claim and demand whatsoever of the said GRAN-rOR, in law, equity or otheI"\Nise of, in and to the saIne and every part thereof. TO Hi\. VE AND TO HOLD the above-described premises with the appurtenances unto the GRANTEE, his heirs and assigns, forever. AND THE GRANTORS do hereby covenant and agree with the GRANTEE, that the GRANTOR, their Executors and Administrators, Shall and Will Warrant and Forever Defend the herein above-described premises with the hereditaments and appurtenances, unto the GRANTEE, his heirs and assigns, against the GRANTOR, and against every other person lawfully clainlins, or who shall hereafter clailTI. the same or any pa.rt th~reof. "'- --........., ~. ....... , l,;;t~'"- VERIFICATION J- "' ",I, .*~r.J~'_ I, the undersigned hereby verify that I am a representative of the plaintiff and I am authorized to make this verification. I hereby verify that the facts set forth in the foregoing complaint are true and correct to the best of my information and belief and that this statement is made subject to the penalties of 18 P A C.S.A. 4904 relating to unsworn falsification to the authorities. ~~ . N \ . ame: Title: Company: Elizabeth A. Gibney Vice President HomeSide Lending, Inc. I10/13}00 '"",.., , ' ~d~~jjlili"~IliV~jQw*i.u-Ji!idill~~~~;,jjaiiillM~~IIllIIIIl!l.iIIIIlUl1f""-il;l:OO-t ".~~. ,~ 0:- J.) ~ 'g. ".~ ~ - . .~ ~~ () ~ ""oJ -.. ;t .lrt a I [t!t;.J ~1- ~ ~ "1"6 . . CCII y() 1< ~ '" Iiii' - o c <" ~f~f'( -? ..,'. 7:::':.: L7) '>;-: --:: ~._~ ,L~: c--: i-;E'~ z ::;! 1 U :1 o .~ o T;; ::::l n --; :...:,'B "V) ., . :~Sl I. i.) .._~ '.-0 c'jm ~ :0 -< -, -'0 -"- N ~..) (j") .. ,~ '''''' I q I" ~~.~_oll!Il~!: SHERIFF'S RETURN - REGULAR CASE NO: 2000-07177 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS ARTZ LEROY E HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ARTZ LEROY E the DEFENDANT , at 0019:30 HOURS, on the 18th day of October 2000 at 531 THIRD ST WEST FAIRVIEW, PA 17025 by handing to LEROY ARTZ a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.30 .00 10.00 .00 37.30 ~~:-~~i R. Thomas Kli~ . 10/19/2000 FEDERMAN & PHELAN Sworn and Subscribed to before By: 7.hAArU ~ 1f7~ Deputy Sheriff me this ol3 ~ day of (\) c y;.J u . d..-cnJO A. D . ~ () ~dP,.-, # r thonotary , ^",~Mi ~j , "- ..- "~~_;,~...._<_.u=,,~ " FEDERMAN ANlJ PHELAN By: Frank Federman, Esquire Atty. LD. No.: 12248 Qne Penn Center at Suburban Station Sllite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC. Plaintiff Court of Common Pleas CUMBERLAND County No. 00-7177 VS. LEROY E. ARTZ ;1:':' Defendant(s) PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PREJUDICE, AND DISCONTINUE AND END lip THE PROTHONOTARY: Kindly Withdraw the complaint filed in the instant matter, without prejudice, and mark this matter discontinued and ended, upon payment of your costs only. 1-4v~J--~ Frank Federman Attorney for Plaintiff )l--;t.9-~ Date ~'k ,::-ii:"; "~,,~o<<w_-^: J luJ.i J ~" '~.:lil",~.i >- en ~ 8~ If' ...;;. :z:: .. ::::;J<( ""'M ~~ C- i'- t;') >....U) ;-'-- I .:JZ ,'."Z ---1'" CtII-U _LL. ~L rYJo... ~ :>1 \..1.. ::::;J C) 0 (.)