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Home My WebLink About01-0130 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 The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as Custodian 4708 Mercantile Drive. North Forth Worth, Texas 76137-3605 Plaintiff - COURT OF COMMON PLEAS : CIVIL DIVISION : CWnberland County v. Loretta J. Myer 10 Kings Arms a/k/a AI0 Kings Arms Mechanicsburg, PA 17055 Defendant(s) :NO.Ot- 130 C,o~LY~ 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 aga~nst you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE 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 AYIS~Q 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 1a demanda y la notificacion. Hace 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 1MMED1ATAMENTE, S1 NO T1ENE ABOGADO o S1 NO T1ENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1C10, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVER1GUAR DONDE SE PUEDE CONSEGU1R AS1STENC1A LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013-3387 717-249-3166 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 assnme that the debt is valid. If you do notify ns 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 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 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 mail it to you. Once we have mailed to you the required information, we will then continne the collection ofyonr debt. TWs 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 Isl Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 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: Fairbank Mortgage Corporation Assignments of Record to: The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as Custodian Recording Date: Lodged for Recording 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: 10 Kings Arms a/k/a A10 Kings Arms MUNICIPALITY/TOWNSHIP/BOROUGH: Hampden Township COUNTY: Cumberland DATE EXECUTED: 3/26/99 DATE RECORDED: 4/12/99 BOOK: 1533 PAGE: 473 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 breach and _cfailure 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 1/04/01: Principal of debt due and unpaid Interest at 11.49% from 12/01/00 to 01/04/01 (the per diem interest accruing on this debt is $8.67 and that sum should be added each day after 01/04/01) $27,553.06 3,478.09 Title Report Court Costs (anticipated, excluding Sheriff'S Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $0.00 and that sum should be added on the first of each month after 01/04/01) 250.00 280.00 0.00 Late Charges (monthly late charge of $13.73 should be added on the fifteenth of each month after 01/04/01) 151.03 Miscellaneous 180.00 Attorneys Fees (anticipated and actual to 5% of principal) 1. ~ 77 .65. TO'I'AL $33,269.83 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 9l of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and~xegular 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 $33,269.83 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ./" ,. ,/ fl/ /' Mark J. d en, ESQUIRE MARK\ ,J. UDREN & ASSOCIATES Atto~ney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN property in lheTownship of Hampden, County of Cumberland, Commonwealth ofPCllIl.ylvania, Tax Parcel # 10-] S-1323-Q3Z-UA-IO, boing more fully described in Deed dated 1/25/94 and recorded IIZ8194 in the land records of tho County and State .et forth above in Deed Book T36, Page 1045. , . , -- -"j March 15, 2000 DATE: . ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thisjs an official notice tlud the mortgage on ~Jr home is in default, anel the lender intends to foreclose. Specific information about the nature ofthe...default is prQYided in the attached pages. The HOMEOWNF.R'S MORTGAGR ASSISTANCE PRO~ay be ablll tn..h.elp to save your home. This Notice explains how the proeram works. To see ifHEMAP ean help,..s:ID1 must MRF,T WITH A CONSlJMRR CRRDIT COlJNSEI,ING AGRNCV WITHIN 30 DA VS OF THE DATR OF THIS NOTWR Take this Notice with you when you meet with the Counseling Ae~ The name, address and phone number of Consumer....C1:edii Counseline Aeenei.es..s.eJ:ring ;\LQur County a"te listed at the end o(this Notice. If you have an:lUlues..tinns~.illUIl3JL..cal.U:he , Pennsylvania Honsine Finance Age.w:y toll free at 1-800-342-2397. (persons with impaired hearine can call (717) 780-1869). This Notice contains important legal information. If yon 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 imd a lawyer. LA NOTIFICACION 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 (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGillLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Page 1 of6 EXHIBIT fig HOMEOWNER'S NAME(S): In:RE:ITA.J..M.YER PROPERTY ADDRESS: 10 KlNC.S ARMS LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: MF.CHA.NTr~RTTRG, PA 17n~!=; _0111006RR FA mRA NK MORT~AGF. rORPOR A TION .sA. XON MORTC.AC.R HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOlTMAVRE ELIGIRI"E FOR FINANCIAL ASSISTANCE WHICH CAN SA VR VOTJR HOME FROM FORECI,OSlJRE AND HEI,P YOlT MA KR FTJTTmE MORTGAGE P A YMRNTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S ~MERGENCYMORTGAGEASSISTANCEACT OF 1983 (fHE "ACT"), YOU MAYBE ELlGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY cmCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PA~NTS, AND . IF YOU MEET OTHER ELIGffiILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARYST A V OF FORECT ,OSTmE - Under the Act, you are entitled to a temporary stay offoreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MTJST OCCTm WI I HIN" THE NEXT (30) DA VS. IF VOl) DO NOT A 1'1'1 YFOR EMERGENCY MORTGAGE ASSIST A NeE, YOU MHST RR.lNG YOUR MORTGAGE UP TO DATE THE PART OE...IHIs...NOJ:1CE CALLED "HOW TO CURE YOUR MORTGAGRDEFAULT', EXPLAINS HOW TO BRING YOUR MORTGAGE TJP TO DATE CONSlTMER CREDTT COTTNSELING AGENCTES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numhers of rlesienaterl consnmer credit cOllnseling aeencies for the cOllnty in which the property is located . are set forth at the enrl ofthis Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender imme.diatcly of your intentions. APPLICATION FO.F MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting. YOU MIIST FTI.,E YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOU~ HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. Page 2 of6 . AGRNCY ACTIOlS: - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETmON IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have tiled bankruptcy you can still apply for Emergeney Mortgage Assistance.) HOW TO CYTRE YOITR MORTGAGE DEF A lILT (Bring it lip to date).. N A TTJRR OF TRF. nRF A IJI .T - The MORTGAGE debt held by the above lender on your property located ,i't: 10 Kin~s Arms Mechanic~hnrg, PA 1705~ IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONIHL Y MORTGAGE PAYMENTS for the following months and the following amounts are now past due: -.Mo~ent.. of $274.60 fm:.Ianua.ry...2ll00 throneJl M:u:.ch,.2illlO = $1l2~.1l0 -.Mo.nthIy T,ate Charges of$1~.7~ for .Iannary, 2000 thron~h March, 2000 = $41 19 Other charges (explain/itemize): Other Fee = $50.00 PropeI:ty: Inspection = $15.00 TOTAL AMOUNT PAST DUE: $929 99 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (00 not ,,,e ifnot appli~.ahle): , ~A HQW TO CTJRF. THF. DRF A IJI .T - You may cure the default within TIllRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $..!!22.9..!L, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Faymf'!nt~ mnst h~ m~rle eifhP.T hy c:~~h; C':::lRh-ip.r's r:np.c:.K:) c:ertitlf"fl r:h~k or money order made payahle ann ~ent to' Mark .1. 1lJb:en..& Associates 1040 N...Kings.lIig:h:l!l'ay, Snite 500 Cherry Hill, NJ 01l0~4 You can cure any other default by taking the following action within TIllRTY (30) DAYS of the date of this letter: (Do not" se if not.applicable..) N/A IF YOU no NOT CI!RR THR nRF A IJI ,T - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exerdse its rights..to..accelerate the..mm:tga~e deht.. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the cbance to pay the mortgage in monthly installments. IffuII payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to fID:ed.ose upon J1ll-nr mortea.gJ:Jip.r.op.e$ Page 3 of6 . TF Tfffi MORTGAGR IS FO.RECLQSRD IJPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, iflegal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. Ifyo,' cllre thl:..defa.ulUrithill the THTRTY (."10) DA V p.erio.d;you will notDJUe.quh:e.d .to..pay attorn~ OTlrnR I,RNORR RRMR1lIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO CITRR THF, DRF AUI ,T PRIOR TO SfffiRIFF'S SAI,R - If you have not cured the default within the TI:IIRTY (30) DAY period and foreclosure proceedings have begun, YOII ,;till have the rir;ht to curn J:h.e..d!:fault..an.~..alany time up to on" hourhefo,." Ih" Sh"riff's Sal" Vou may do so by payinp- the..to.t::Jl amnnnt fhffll pa~t cine) plu~ any late or other c:h::n:ge~ thP.Tl dne, rea~onahlf': attorn.ey'~ fee~ ann c..o.sts conn"cled..3Y.ith.Jhe.Jilre.c1usure sale and..any olher costs connected with the Sheriff's SaIs: as sp"cified..in Jmiling.h~nde~ and hy p"rfonninp- any oth"r re.qui=nts nnrl"r th" mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. RART,TF.ST POSSIBLR SfffiRTFF'S SAT,R DATR - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date oithis Notiee. A notice of the actuaI date of the Sheriff's Sale will be sent to you before the sale. Of course, the ~ount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT Tfffi 1 ,RNO~ Name of T lenilerIServir.er~ Aildres~: Meritech MQd:gag.c..S.endces, Tnc. One RidgeJllllr Center 6500 West Freeway, SlIite 400 FortWortb, TX76116 800/874-9516 N/A Cnldnrner Service Dept Phone Nnmher: l::l'l' Nnmhp.r. Contsct Pe~on. RFFRCT OF SfffiRIFF'S SAT ,R - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSlTMPTfON OF MORTGAGR - You _ mayor -----X- may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, 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. Page 4 of6 NOTICE The amount of your debt is as stated in the attached document. The name ofthe creditor to whom the debt is owed is as named in the attached docnment. 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 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 jndgment against you, and mail it to yon. 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 mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. TWs 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 Page 5 of6 YOUMAV AT,sORAVRTRF.RTGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTIIER LENDING INSTITUTION TO PAY OFF TIllS DEBT. . TO HA VB TIllS DEFAULT CURED BY ANY TIllRD PARTY ACTING ON YOUR BEHALF. . TO HA VB THE MORTGAGE RESTORED TO THE SAME POSmON AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE TIllS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTIlER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . . . TO SEEK PROTECTION UNDER TIlE FEDERAL BANKRUPTCY LAW. C:ONSTJMF.R C:RF.nrr C:OTJNSF.T .TNG AGF.Nc:ms SF.RVTNG VOlm COIJNTV (Ej/1111J1JisLojJlJLCmJ11Sf!liItg-AgendesJi<ded in Ap]1J!ndix..C, FOR THE COrlNTYin which the. jlII1pCI/Jlis.1o.J:D1eJl,JIsjllg.additiDnal.p.agexJ~SSJU)!) .cnMRF.RT ,A NJ) COnNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 17102 (717) 541-1757 FAX (717) 541-4670 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, P A 17104 (717) 232-9757 FAX (717) 234-2227 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Page 6 of6 .." ,':,'-"" s~o ~e~'cW~ fo,,>,>'O'>iro "",00 ,po,p,o ..o."",,,<!f.S;fo"""'<-~"S~ .,. -f!J ,*,-,/!>-S ~~'>~~O ~O~ <</;0 ~.,p'l'~" 0 ~$-(J ""S~~\.~&"',"NJ';\\\~O .~?"..:<<J1 ~~..~~",~~@-". <fI><b"~"<!f." , ~ . .~ .., I 3~ I~', . . 'Ci. ~~ D ~. ~ I ~ ~ ,l ~- .r-::,~ V', ~ ~ ~ ~ ~ ~ ~. 1-, l....Q; ~ ' ~ -~~ "- ~ - \;~ i '" . r i I " ~ ~ ~ \<:::::, -~ ~ (J' \ ....r\ ""'-.,;;; ;1i..",::JIt '" !I, L:'i ~~~<'S~f i:i'" ;> " ,,:Jl{ll ~ ~~al: :~ \J "",..>/i'I \j ;g :> () ~:D ~ g^ J:J a:=-. II ;2:Cr- <(J)AOJ:;> ~~zfR~ r-iCi)ZC' rmCf) -tj 01 J2':I ~-;;1 t:g*~H o G>gsrn '" ~ow a <0 i: ?(;;:; '-l m en ~l ..II ..II C1 C1 C1 .... ..r= w In ..r= ..II .... ..II c::J 1!;11 ',j,l. .'~~ I~"g . .~~ \(~ UJ- 00 ~ .,*,~, NeoN t..'.JV1C\ *' ~tN ,ia l}Z:. ~ OU"J"', "' ..' ."U' :tJ""''.I_~d'..'-: i N ~'U' "~...\'; .-- ",I ~ 0 l." ~ ;0.<::> ~ i~ ~~l 0: ~~i:i 0) VI oll!! o C>> ~l <N Cl co II ~aN g . . V F. R 1FT CAT T O-N 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. ('rrL/// Mark J MARK J Udren, ESQUIRE DOREN & ASSOCIATES '" /.- 'J,!,'i<40 ~ j::: z :-3~ :1~ . '_"ilj] ;:-ncl.... "'.; '5 u = (.) ~~ ~~ Q I , ~ 3 8 ~.;f "",- "'.1 cr:; .:>..... :~; ;.;. . . ';:I, :,:;,-~ _ e;.~:;.:.. ~.,..) -',,;- ! ~: ~ . . ~"T ". - ~ -" ~ - "'-= "'---',~ ~.i . . ~ 2t e; ~ <) fY) '- &~ SHERIFF'S RETURN -_REGULAR CASE NO: 2001-00130 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN BANK THE VS MYER LORETTA J ROBERT L. FINK Sheriff or Deputy Sheriff of Cumberland County,Pennsy1vania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MYER LORETTA J the DEFENDANT at 0019:30 HOURS, on the 18th day of January 2001 at 10 KINGS ARMS A/K/A A 10 KINGS ARMS MECHANICSBURG, PA 17055 by handing to LORETTA MYER a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service,.. Affidav1i Surcha-rge 18.00 7.44 .00 10.00 .00 35.44 So Answers: ~~1~e R. Thomas Kline 01/19/2001 MARK J. UDREN Sworn and Subscribed to before me this ;{'i't day of (jrlA..':."r )..en I A.D. 't Q - ~ C -/t.. _~ .. P othonotary . By: ~~r/~~~ Deputy herif \. ,~;. .. 't 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 The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as Custodian . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE 4708 Mercantile Drive. North Forth Worth, Texas 76137-3605 Plaintiff v. Loretta J. Myer 10 Kings Arms Mechanicsburg, PA 17055 Defendant(s) : NO. 01-130 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND-AS.sESS.MENT OF-DAMAGES. TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest per Complaint From 1/5/01 to 3/5/01 Late charges per Complaint From 1/15/01 to 3/5/01 Escrow payment per Complaint From N/A to N/A $33,269.83 520.20 27.46 o 00 TOTAL .$33.817 49. I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy o~which is attached hereto. MARK {- \t E~~ES Mark J. dren, ESQUIRE Attor~ey for Plaintiff \ DAMAGES ARE HEREBY ASSESSED AS IND~TED DATE: 3- ( It - 01 '-_~~~ PRO PROTHY RLeJ ? ",.' . 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 The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as Custodian 4708 Mercantile Drive. North Forth Worth, Texas 76137-3605 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. DATED: TO: Loretta J. Myer 10 Kings Arms Mechan~csburg, PA 17055 Defendant(s} February 12, 2001 Loretta J. Myer 10 Kings Arms Mechan~csburg, PA 17055 NO. 01-130 civil Term .r~RTANT NOTZ,CE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 NOTIFICACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA~DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFlCACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFlCACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DlNERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. - SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,t_-"'__ . 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 The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as Custodian ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE 4708 Mercantile Drive. North Forth Worth, Texas 76137-3605 Plaintiff NO. 01-130 Civil Term v. Loretta J. Myer 10 Kings Arms Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF SS COUNTY OF THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Loretta J. Myer Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Over 18 As captioned above Unknown r~ Sworn to and subscribed before me this 5'l-h day of fY'I6rC-h ,2001 . & () JtJfYn t DARLENE SHELLENBERGER ". ~1L~ ' ~ --e-1bj c....-NOTARY PU8UC OF NEW JERSEY Notary PubJ!ic (\ COmm!sslon Exph8$l2fl/2005 '-i Name:, t,e-Vrv . uet f\ \ t:S(~p;,e Title: i-\~()..e.y" -f'o{'- \)1'0\<\11 M Company: ~\\t..... v:Oc(jcen CI- !:t$::,OC';o}es . . " 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 The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/kja Texas Commerce Bank, NA as Custodian 4708 Mercantile Drive. North Forth Worth, Texas 76137-3605 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Loretta J. Myer 10 Kings Arms Mechanicsburg, PA 17055 Defendant(s) : NO. 01-130 Civil Term TO: LORETTA J. MYER 10 Kings Arms Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. -X- Judgment by Default Prothonotary Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings . r> IF YOU HAVE..,ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J~e At this telephone number: 856-487.-6900 " ~ -~~'- ~ ~ C") ~ - r. "'- }- Z r', N ~ !.J"::~-<. ~< ~,?~~. 07 ;:c ~;o~ C- -L)~ C">t; ~~ 6,.. -' u..,L'- w:~!d = a::z ~-: """ ~~~u ::c ~_.~- u.. 2: 0 <::> :::> Cl ~ ~ ~ -:} \'- .f) J I, ~ t-1 \~ ,;8 \i ~ ~. c. '<>":- ~~"\ ~'9 ~ 'J' ~C8 1 V' - ..... -l l:: 3 0- ~ I;;,., i:>o Cl -- \1 ,; ;;1 ~ ,~ -:v r \ '0 III lD ~\I ~\ 'CI' , ~ :,\ ~ ~l.., \ ? 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 The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as CUstodian . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County 4708 Mercantile Drive. North Forth Worth, Texas 76137-3605 : MORTGAGE FORECLOSURE Plaintiff v. Loretta J. Myer 10 Kings Arms Mechanicsburg, PA 17055 : NO. 01-130 Civil Term Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: AI0 KINGS ARMS MECHANICSBURG, PA 17055 Amount due $33,8J7 49. Interest From March 6.~.1 RO.6......3.1. to Date of Sale ~ 6 ?OOl Per diem @$8.67 (Costs to be added) $ MARK J. UDREN ES n(} Mark \J. IPd en, ESQUIRE ATTO\EY FOR PLAINTIFF ( , ., , ALL that certain unit in the property known, named' and Identified in the Declaration Plan referred to below as King's Arms Condominium, S!t~~!,.!D ih!,! YJJi~ge o!- Westover, .Hampden Township, Cumb~rland County, PeMsylv~nri(; which ha~ .been' s'ubmltted to the provisions 01 the Unit Property Act of PElrtnsylvania, Act of JiJly 3, 1963. P.L 196 (68 P.S. '~00101, et seq.), by recording In.t(1e Office of the Recorder of Deeds In and. for Cumberland County, Pennsylvania, of a Declaratlon'dated May 21, 1975 and recorded in Miscellaneous Book 214, Page 836. and a Ii Declaration Plan dated May 21, 1975, and reGarded In Plan 800k .26, Paga 70, and a Code 01 'Regulations, Exhibit "8" .of said Deolaration dascribed as follows: . BEING and designated on the Decleretion Plan as Unit A10, with detached garage, said garage designated on the Declaration P.ian ,as U!1it A10G, together with an undivided interest .appurtenant to the unit In all Common Elements (as defined In the Declaration) of 5.26%. The unit is municipally numbered as A10 King's:Arrt:'s, Village of West.over, Mechanlcsburg, Pennsylvania. BEING tha same premises which Frederick D. Fischer and Marianne M. Fischer, husband and wife, by their Deed dated May 6, 1983 and recorded in the Office aforesaid, In Deed Book "E", Volume 30, Page 294, granted and conveyed unto Richard R. Townsend and Lucille O. Townsend. husband and wifa. The said Richard A. Townsend having died October 31, 1988, thereby vesting tee simple title, by .operation of law, in his surviving widow, Lucille O. Townsend, Grantor herein. - II UNDER AND SUBJECT. to ce~~in restrictions, rigbts-of-way, easements and agreements' ot record. " BEING KNOWN AS PROPERTY ID# AlO KINGS ARMS, MECHANICSBURG, PA 17055 10-18-1323-032 TITLE TO SAID PREMISES IS VESTED IN LORETTA J. MYER, MARRIED PERSON BY DEED FROM LUCILLE Q. TOWNSEND, WIDOW DATED 1/25/1994 AND RECORDED 1/28/1994 IN DEED BOOK-T-36 PAGE 1045 ( \j\ "'~J , ... .. - . ... ~ 1':::; ~ t't~~ '.l~--- C? \-~) ~:~ u_ o ~ - ~ ~ &:, r . " 3:C ~ 1'0 1.0 ~ O=-"<""<J -::::r- ~ 8:2.: Il o?3 3~~\ ;--Z \ "'- will _ ::ide.. -,J..::; ~1: ~ 3d c<:; N - 0-- -"1' cc """ :::c o ~ ~l ..z:- r.:::J '--- ~ ~ ~:::S j > , 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 4708 Mercantile Drive. North Forth Worth, Texas 76137-3605 . . COURT OF COMMON PLEAS : CIVIL DIVISION : CUmberland County : MORTGAGE FORECLOSURE The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as Custodian Plaintiff v. Loretta J. Myer 10 Kings Arms Mechanicsburg, PA 17055 : NO. 01-130 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. :/#-\~ .'" ~~_~ w J I MARK JI' i , Mark Jj. ATTORNEY ~ IATES dren, ESQUIRE FOR PLAINTIFF ~~ >- ..::l" C 0:: C":1 Z <r:: ,-- N ::J<: c-. 0- "-'-::="-;' O~ ~t\ :c c.. ~>; ~0 - ~~ 6:5 ::Jz L:.-~ <--- G::L "~ UJLU J~;~: <<:C CD a.. :c :z ~ l!~ ~ C) 0 Q , " f . ~ J. UDREN & ASSOCIATES ,JlY':' 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 The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as Custodian . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County 4708 Mercantile Drive. North Forth Worth, Texas 76137-3605 : MORTGAGE FORECLOSURE Plaintiff v. Loretta J. Myer 10 Kings Arms Mechanicsburg,'PA 17055 :NO. 01-130 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as Custodian , Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 10 Kings Arms, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address LORETTA J. MYER 10 KINGS ARMS, MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. DOVENMUEHLE MORTGAGE CO. 1501 WOODFIELD ROAD, SCHAUMBURG, IL 60173- 4982 5. Name and address of every other person who has any record lien on the property: Name Address .. NONE~ . ~, 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address REAL ESTATE TAX DEPT. 1 COURTHOUSE SQUARE, CARLISLE, PA 17013 Domestic Relations Section l3 N. HANOVER STREET, CARLISLE, PA l70l3 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA l7128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address KING'S ARMS CONDOMINIUM VILLAGE OF WESTOVER, HAMPDEN TOWNSHIP, CUMBERLAND COUNTY Tenants/Occupants lO Kings Arms, Mechanicsburg,PA l7055 DATED: March 5, 200l I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are tnade subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J., NnifN!\ ASSO;;---Al'ES (llV ~ Mark J.I ~~ren, ESQ. Attornev ~or Plaintiff i ! :....;> ,~: "' ... ,,/ ~~ . t "'>- ...:1' ;:- G_:; co-o' ~ ~~ N :::>< ',-. ~~ 0- ""'- O~ I, .-'- :0- 0:::1 ;f'~ '0'>- -:;1' ~CI) ~:Z u__; O~ o::z a:~F 0=:: UJW """ roD... ,~~ :z: ~ t.t_ :::> C) 0 U - u-,. I" ..!, , 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 The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as Custodian ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County 4708 Mercantile Drive. North Forth Worth, Texas 76137-3605 : MORTGAGE FORECLOSURE Plaintiff v. Loretta J. Myer 10 Kings Arms Mechanicsburg, PA 17055 : NO. 01~130 Civil Term Defendant(s) NQ.T.I.C~~~LE-OF REAL PROPERTY TO: LORETTA J. MYER 10 Kings Arms Mechanicsburg, PA-17055 Your house (real estate) at 10 Kings Arms, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 6, 2001 , at 10:00 AM in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $33,817.49, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NO.TICE-QF OWNER' S-UGlITS, YOU MAY ~CLEF.EVEN'T THTS SHERTF'F" S SlILE To prevent this Sheriff's Sale, you must take ~~~_~_tL~ ~~ The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees~ To find out how much you must pay, you may call, (8S61 4~~ 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other_legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) , Ij _.J; YOJ:! MAY S'I'IL~.E-AB.LEJ_O--SA:\lE-XO.J:!l.L..ERODRTY AND----YQ~QTHER RIGlU'S E~N IF THE SHERIFF'S~E-DOES TAKE ~LAC~ 2. If the Sheriff's Sale is not stopped~ your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the_amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (lO) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. J:F YOU DO NOT RAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFJ:CE LJ:STED BELOW TO FJ:ND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVJ:CE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA l70l3-3387 7l7-249-3l66 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA l70l3-3387 7l7-249"3l66 ,. ~,-..,... ).<.~.>-,' .\~. ~ >:: ..:r ;:: ~ 'C"i Z ~- 3~ r. N W'~::' h:~ :;;::. oS: "'"" c... ::::3::;:; ~;;~!. ~ ::::;&1 .:12 ,:,cL.: i2:: = I,ULU :~ CD 0- ~o ~- "'" 1-;- ::::l 0 0 '0 " , \<, 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 The Chase Manhattan Bank, s/b/m/t Chase Bank of Texas, N.A. f/k/a Texas Commerce Bank, NA as Custodian 4708 Mercantile Drive. North Forth Worth, Texas 76137-3605 Plaintiff v. Loretta J. Myer 10 Kings Arms Mechanicsburg, PA 17055 Defendant' (s) ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. Ol-BO Civil Term flUI,ECIl;'E TO WITHDRAW .:rDDGMENT AND D;rsCONTINUE WITHOUT PREJUD~.E TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. . 'h. DATED: J.Jl1 ();113;:' 2.0Jll /JVf~!/c~, Mark J. Udren, Esquire Mark J. Udren & Associates Attorney for Plaintiff ~ >- r--. 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