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GOLDBECK McCAFFERTY
BY: Joseph A. Goldbeck,
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
& McKEEVER
Jr.
WELLS FARGO BANK MINNESOTA NA AS
TRUSTEE
c/o GRP Loan Corp.
444 Park Avenue South, 8th Floor
New York, NY 10016-7321
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
VS.
1610 Orrsbridge Road
Enola, PA 17025
Defendant(s)
ClUlCT~
CIVIL ACTION: MORTGAGE
FORECLOSURE
Term
NO'OI_ S/'t
MELVIN F. AUCKER JR. AND
MICHELLE L. AUCKER
(Mortgagor(s) and Real Owner(s))
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V ISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION.
ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS
LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD
U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
S I NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVI CE" (SERVI CIO DE REFERENCIA DE ABOGADOS) ,
215-238-6300.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
a Irvine Row, Carlisle, PA 17013
(717) 243-9400
Jt5.
.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is WELLS FARGO BANK MINNESOTA NA AS TRUSTEE,
c/o GRP Loan Corp., 444 Park Avenue South, 8th Floor, New York, NY
10016-7321.
2. The name(s) and address(es) of the Defendant(s) is/are
MELVIN F. AUCKER JR., 1610 Orrsbridge Road, Enola, PA 17025 and
MICHELLE L. AUCKER, 1610 Orrsbridge Road, Enola, PA 17025, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter de~cribed.
3. On June 28, 1999, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
AMERIQUEST MORTGAGE CO., which mortgage is recorded in the Office
of the Recorder of Deeds of Cumberland County in Mortgage Book
1555, Page 759. By Assignment of Mortgage dated July 6, 1999, the
mortgage was assigned to Plaintiff, which Assignment is lodged for
recording. These documents are matters of public record and are
incorporated herein by reference in accordance with Pennsylvania
Rule of Civil Procedure 1019('1).
4. The premises subject to said mortgage is described as
attached.
5. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due May 1, 2000, and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible fo~thwith.
6. The following amounts are due on the mortgage:
Principal Balance
Inte~est from 4/ 1/00
through 1/31/01 at 10.500%
Per diem interest rate at $18.28
Atto~ney's Fee at 5%
of Principal Balance
Late Charges 5/ 1/00- 1/31/01
Monthly late charge amount at $34.99
Costs of suit and Title Search
$
63,540.97
5,575.40
3,177.05
314.91
560.00
$ 73,168.33
Escrow Balance
Monthly Escrow amount $
$ 73,168.33
7. 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
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Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. Notice of Intention to Foreclose and a Notice of
Homeowners' Emergency Mortgage Assistance has been sent to
Defendant(s) by Certified and regular mail, as required by Act 160
of 1998 of the Commonwealth of Pennsylvania, on the date(s) set
forth in the true and correct copy of such notice(s) attached
hereto as Exhibit "A". The Defendant(s) has/have not had the
required face to face meeting within the required time and
Plaintiff has no knowledge of any such meeting being requested by
the Defendant(s) through the Plaintiff, the Pennsylvania Housing
Finance Agency, or any appropriate Consumer Credit Counseling
Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $73,168.33, together with interest at the rate of
$18.28, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises.
By:
GOLDBECK Mc
BY: Joseph A. Goldbeck,
Attorney for Plaintiff
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01117/2001
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VERIFICATION
I,
, as the representative of the
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Plaintiff corporation within named do hereby verify that I am
authorized 1:0 and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief, I understand that false statements therein
arc m~de subject to the penalties of 18 Pa. C.B. 4904 relating to
unsworn falsification to authorities.
Date:
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#6735 - AUCKER JR.,MELVIN F.
01/17/01 WED 12:02 [TX/RX NO S521]
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I\1.L eha e ",erea1n piece or parcel cf land .t.taullee in JllUl\Pden
TGw~$hip, e~mbe...land County, ~cnn.yl~ania, being more pareicularly
bounc:\ed aod deGcrlbed as fo~ows, eo vie:
e~Gt~NING at a point on the eastern .ide of errs 8rt-dge Road, at a
~oin~ on t~e no~thweGt corner of and now or formerly of Bl1en
Desc~eoes; then",.. by game North 150 East One 8un~ec:\ zLghty-three
and "ive 'renth>l(183.5) feet, more or less to a poine 0." the
southeast corner of land noW or form~...ly o~ Ga~ z. Walker; thenco
by s...... Soutll 790 05' East TwO Hunclreci Twenty-1:.WC (22.2.1 feel: moz;e or
l~ss to a point at land now Or formerly o~ 1~r.1 G. Moore et a1;
thence by s~ South go East ~orty-oight (48') feet, moz;o or. les8,
to e ~oint; thence by same Soutb 150 wost One Hun~ed Tw.n~-~WO ano
Two ~enth8 (122.2') faet ~o:e or less to a poln~ ~t tbe no~b.ast
~oJr""",c!!,~,the afor,!B8.ic:\ land. "ow or fol:J\\erly of Ellen beschan..s; the
oy sa,... IlQl:~h B20 weilt Two -Huriaf'EilFW:t1:y""'tvo (242 ') foet:,1It9re, or,
lesQ, to a point. the ?lace of BEG1NNING.
CON~IN1NG two (2) Acres, more or less.
BF-XIlG part of that same fl:~i.c. whieh wayne 2. Baker ana 8~elyn n.
8ake~, his wife, by their dead datea :.b~ary 6, 1953 and reCOrded
in ~he office of the Cwmb$rland County Recoraer of Deeds in Record
Book "K", v01.- 15, 5'o.ge 120, gx-anted and con-1" unto Harold E.
Kra11lor and E1..1. !t.rall\er, his wi::e. ElCOai't.!.n9 and reeorving
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Certified Article Number
Certified Article Number
7Jdlb IfS75 12"11fD1f1"1 1f1S"I
71Db IfS7S 12"14 '0111"1, Iflobb
SENDERS RECORD
SENDERS RECORD
ACT 91 NOTICE
EX~f~OF NOTICE: 12/11/00
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default. and the
lender intends to foreclose. Specific information about the nature of the default is
provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may
be able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take
this Notice with you when you meet with the Counseling Agency.
The name. address an 1Jhone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice. If you have anv questions. you
mav call the Pennsylvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons
with impaired hearing can call (717) 780-1869.)
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain
it. You may also want to contact any attorney in your area. The local bar association
may be able to help you find a lawyer.
La notificacion en ad junto es de suma importancia, pues afecta su derecho a
continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga
una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance
Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo
por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual
puede salvar su casa de la perdida del derecho a redimir su hipoteca.
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Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
Fax (215) 627-7734
Date: December 11, 2000
Homeowners Name: MELVIN F. AUCKER JR. and MICHELLE L. AUCKER
Property Address: 1610 Orrsbridge Road, Enola, PA 17025
Loan Account No.: 6735
Original Lender: AMERIQUEST MORTGAGE CO.
Current LenderlServicer: GRP FINANCIAL SERVICES CORP.
HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND
YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary
stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During
that time you must arrange and attend a "face-to-face" meeting with one of the designated
consumer credit counseling agencies listed at the end of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING
YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO
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CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the
consumer credit counseling agencies listed at the end of this notice, the lender may NOT take
action against you for thirty (30) days after the date of this meeting. The names. addresses and
telephone numbers of designated consumer credit counseling agencies for the county in which
the property is located are set forth at the end of this Notice. It is only necessary to schedule one
face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for
the reasons set forth later in this Notice (see following pages for specific information about the
nature of your default.) If you have tried and are unable to resolve this problem with the lender,
you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies
have 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 fact-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS
LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY
AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the Agency under the eligibility criteria established by the
Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it
receives your application. During that time, no foreclosure proceedings will be pursued against
you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
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HOW TO CURE YOUR MORTGAGE DEFAULT (Brinl!: it HI> to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your
property located at: 1610 Orrsbridge Road. Enola. PA 17025 IS SERIOUSLY IN DEFAULT
because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following
months and the following amounts are now past due:
(a) Monthly payment from 51 1/00 thru 12/11/00
(8 mos. at $583.15Imonth)
(b) Late charges from 51 1/00 thru 12/11/00
(8 mos. at $34.99/month)
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF TillS DATE
$ 4,665.20
279.92
$ 4,945.12
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS
of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE
LENDER WHICH IS $4,945.12, PLUS ANY MORTGAGE PAYMENTS AND LATE
CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments
must be made either bv cash. cashier's check. certified check or monev order made I>avable and
sent to:
GRP FINANCIAL SERVICES CORP.
444 Park Avenue South
8th Floor
New York, NY 10016-7321
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default
within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ril!:hts
to accelerate the mortl!:al!:e debt. This means that the entire outstanding balance of this debt
will be considered due immediately and you may lose the chance to pay the mortgage in monthly
installments. If full payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose HI>On your
mortl!:al!:ed I>rOl>ertv.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by
the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you
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cure the delinquency before the lender beings legal proceedings against you, you will still be
required to pay the reasonable attorney's fees that were actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees
will be added to the amount you owe the lender, which may also include other reasonable costs.
If vou cure the default within the THIRTY (30) DAY period. vou will not be required to
pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid
principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured
the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou
still have the right to cure the default and prevent the sale at any time UP to one hour before the
Sheriffs Sale. You mav do so bv paving the total amount then past due. plus anv late or other
charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and any
other costs connected with the Sheriffs Sale as specified in writing bv the lender and bv
performing any other requirements under the mortgage. Curing your default in the manner
set forth in this notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that
such a Sheriffs Sale ofthe mortgaged property could be held would be approximately four (4)
to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs
Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly what the required payment
or action will by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: GRP FINANCIAL SERVICES CORP.
Address: 444 Park Avenue South
8th Floor
Phone Number: 212-951-2400
Fax Number: 212-686-7018
Contact Person: Albert Nolberto
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your
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ownership of the mortgaged property and your right to occupy it. If you continue to live in the
property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other
belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may 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 POSITION AS IF
NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN
ANY CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY
FORECLOSURE PROCEEDING OR ANY OTHER LA WSUlT 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.
Contact Person: Albert Nolberto
Phone Number: 212-951-2400
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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
URBAN LEAGUE OF MElROPOLITAN HARRISBURG
2107 N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
r!
COMMUNITY ACTION COMM OF 1HE CAPITAL REGION
1514 Derry Street
Harrisburg, P A 171 04
(717) 232-9757
FAX 234-2227
FINANCIAL COUNSELING SERVICES OF FRANKLIN
31 West 3rd Street
Waynesboro, P A 17268
(717) 762-3285
YWCA OF CARLISLE
30 I G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
ADAMS COUNTY HOUSING AUTHORITY
139-143 Carlisle Street
GettysbUrg, PA 17325
(717) 334-1518
FAX (717) 334-8326
GRP FINANCIAL SERVICES CORP.
444 PARK AVENUE SOUTH, 8TH FLOOR
NEW YORK, NEW YORK 10016-7321
TELEPHONE 212 951-2400
FACSIMILE 212636-7013
December 26, 2000
Goldbeck, McCafferty & McKeever
111 S. Independence Mall E. St. 500
Philadelphia, P A 19106
Attention: Laura Bryans
In Re: Original Assignment
GRP Loan # 6735
Dear Laura:
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As per your request, enclosed is the original document for the above referenced loan. Please record the
original assignment. After you record this document, kindly return the original recorded assignment back to
my attention.
If you have any questions, please do not hesitate to contact me at 212-951-2479.
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aren Hemmmgs 0-
Paralegal
GRP
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SHERIFF'S RETURN - NOT SERVED
CASE NO: 2001-00514 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WELLS FARGO BANK MINNESOTA NA
VS
AUCKER MELVIN F JR ET AL
R. Thomas Kline
, Sheriff
, who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT
, to wit:
AUCKER MELVIN F JR
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOTICE
NOT SERVED , as to
the within named DEFENDANT
, AUCKER MELVIN F JR
DEFT FILED CHAPTER 13 BANKRUPTCY ON 1/18/01 BY
ATTY JAMES BACH. CASE NO. IS 01-00288.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
8.06
.00
10.00
.00
36.06
R. THOMAS KL ~/
SHERIFF OF CUMBERLAND COUNTY
GOLDBECK MCCAFFERTY & MCKEEVER
01/29/2001
Sworn and subscribed to before me
this /..<Vf' day oJ~.. "'J
OLfJ.-O/ A.D.
(l . Q. ~"D;.J, ~ '
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SHERIFF'S RETURN - NOT SERVED
CASE NO: 2001-00514 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WELLS FARGO BANK MINNESOTA NA
VS
AUCKER MELVIN F JR ET AL
R. Thomas Kline
, Sheriff
, who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT
, to wit:
AUCKER MICHELLE L
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOTICE
NOT SERVED , as to
the within named DEFENDANT
, AUCKER MICHELLE L
DEFT FILED CHAPTER 13 BANKRUPTCY ON 1/18/01 BY
ATTY JAMES BACH. CASE NO IS 01-00288.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
~
R. THOMAS KLI - '
SHERIFF OF CUMBERLAND COUNTY
GOLDBECK MCCAFFERTY & MCKEEVER
01/29/2001
Sworn and subscribed to before me
this /..tVf- day of )'~
~I A.D.
r;:tt~ c. '111-,;1,_, ~~A~
Pro h notary )
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GOLDBECK McCAFFERTY
BY: Joseph A. Goldbeck,
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
& McKEEVER
Jr.
IHEREBYCERnFYTHATTH~
IS A TRUE AND CORRECT COpy
OF THE ORIGINAL FILED
WELLS FARGO BANK MINNESOTA NA AS
TRUSTEE
c/o GRP Loan Corp.
444 Park Avenue South, 8th Floor
New York, NY 10016-7321
Plaintiff
IN THE COURT QF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
VS.
MELVIN F. AUCKER JR. AND
MICHELLE L. AUCKER
(Mortgagor(s) and Real Owner(s))
Term
No. 6/- S/4 /? .( ~
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1610 Orrsbridge Road
Enola, PA 17025
Defendant(s)
CIVIL ACTION: MORTGAGE
FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM .YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in \.:iting with the court your defenses or objections to the
claims set forth sgainst you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be eptered 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 LEGA~ HE~P.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V ISO
LE HAN DEMANDADO A USTED EN LA CORTE. S I DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECSSSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN E8TA DEMANDA.
RECUERDE: 81 USTED NO REPONDE A ESTA DEMANDA, 8E PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION.
ENTONCES, LA COUTE' PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS
LAS PROVISIONES De ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED POEDA PERDER DINERO, PROPIEDAD
U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
81 NO CONOCE A UN ABOGADO, LLAME AL "LA'tlYER REFERENCE SERVICE" {SEKHCIO DE REFERENCIA DE ABQGADOS) ,
215 238-6300.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
TRUE COpy FROM RECOPO
III TootlmooywherllOf. I here unto set r" ,. ~l
ai'ld tOO _ ~ said Court at Carlltk
T~~~~~~~~g"
I'lWdlij\*!'1I
Legal SeIvices Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243.,9400
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II-IEREBY CERTIFYTHATTHIS
IS A TRUE AND CORRECT COpy
COMPLAINT IN MORTGAGE FORECLOSURIPF THE ORIGINAL FILED
,
1. Plaintiff is WELLS FARGO BANK MINNESOTA NA AS TRUSTEE,
c/o GRP Loan Corp., 444 Park Avenue South, 8th Floor, New York, NY
10016-7321.
2. The name(s) and addressees) of the Defendant(s) is/are
MELVIN F. AUCKER JR., 1610 Orrsbridge Road, Enola, PA 17025 and
MICHELLE L. AUCKER, 1610 Orrsbridge Road, Enola; PA 17025, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On June 28, 1999, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
AMERIQUEST MORTGAGE CO., which mortgage is recorded in the Office
of the Recorder of Deeds of Cumberland County in Mortgage Book
1555, Page 759. By Assignment of Mortgage dated July 6, 1999, the
mortgage was assigned to Plaintiff, which Assignment is lodged for
recording. These documents are matters of public record and are
incorporated herein by reference in accordance with Pennsylvania
Rule of Civil Procedure 10l9(g).
4. The premises subject to said mortgage is described as
attached.
5. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due May 1, 2000, and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 4/ 1/00
through 1/31/01 at 10.500%
Per diem interest rate at $18.28
Attorney's Fee at 5%
of Principal Balance
Late Charges 5/ 1/00- 1/31/01
Monthly late charge amount at $34.99
Costs of suit and Title Search
Escrow Balance
Monthly Escrow amount $
$ 63,540.97
5,575.40
3,177.05
"'-,. 314.91
560.00
$ 73,168.33
$ 73,168.33
7. 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
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Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. Notice of Intention to Foreclose and a Notice of
Homeowners' Emergency Mortgage Assistance has been sent to
Defendant(s) by Certified and regular mail, as required by Act 160
of 1998 of the Commonwealth of Pennsylvania, on the date(s) set
forth in the true and correct copy of such notice(s) attached
hereto as Exhibit "A". The Defendant(s) has/have not had the
required face to face meeting within the required' time and
Plaintiff has no knowledge of any such meeting being requested by
the Defendant(s) through the Plaintiff, the Pennsylvania Housing
Finance Agency, or any appropriate Consumer Credit Counseling
Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $73,168.33, together with interest at the rate of
$18.28, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises.
By:
GOLDBECK Mc
BY: Joseph A. Goldbeck,
Attorney for Plaintiff
01/17/2001 WED 11:57 FAX
_ f_e,_ -fr"_
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I4J 005/007
VERIFICATION
I,
as the representative of the
Plaintiff corporat.ion within named do hereby verify that. I am
authorized 1:0 and do make this verification on behalf of the
Plaintiff corporation and the facts set forth \i.n the foregoing
complaint are true and correct to t.he best of my knowledge,
information and belief. I understand that false statements therein
arc made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to aut.horities.
Date:
/. 17'01
ddK~.-21 ~~O/
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#6735 - AUCKER JR. ,MELVIN F.
01/17/01 WED 12:02 lTX/RX NO 8521J
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~ that ce~taLn ~iece or pareel ef lapd .L~uate in Hampden
Tcwn6hip, Cumberland County, Penn~yl~4n14, baing more par~i~ul.rly
bounded and doucribed as fo~ow., ~o wie:
eeGtNNING at a point on the eastern uids of Qrrs Bridge Poad, at .
~oint on the noy.thweG~ corner of and now or formerly of Bllen
DeSchenes; th~noe by oame Noreh 150 east One Hundred Eigbty"three
and Five TBnth~ (183.5) feet, more or les8 to a point at tbe
eou~hB.st corner of land noW or for~~rly 0: Gary E. Walker; thenco
by sa.... South 7,0 05' East ~""'e Hundrecl Tw..nty-ewe (2221 feet _rc or
1~9a to a point at land no~ er formerly a! 1~~ G, Hoare et al;
thence by same South go East Forty-eight (48') feet, ~ or. less,
to 4 point; thence by same South 150 Woe~ one H~ndred Twenty-two and
Two Tenth8 (122.2') f~et mo:e or less to e pOin~ ~t tpe north.ast
co.",..r o~"the afore..aid land now or fornworly of Ellen J>eschEIlJeSI the
DY sallie WQrth B~o West. Two Ilunat'..<i"~y-two (2.42') feet', lIIore, or,
less, to a poLnt, the Place ot BEGXNNING.
CONTAINXNG two (2) ~or.s, more or less.
BEING part of that s...... flr-L...., wl>!eh W..yne 2. Balcer lll~d Evelyn n.
841<.0l.', hie wifa, by their deed dated S'eb~lU'Y 6, U5J ...nd recorded
in t.he Office of the cum~erland eounty Reoor~er of Deeds in Record
Book "K", vol.' 15, PAge 120, grant~ and conve1ed \Into Harold E.
Kramar and 21.i. Kramer, his w1ie. Exo.pt.~n9 end reserving
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Certified Article Number
7106 4575 1294 041~ 415~
Certified Article Number
SENDERS RECORD
7106 4575 12~4 D41~ 4166
SENDERS RECORD
ACT 91 NOTICE
EX~T~OF NOTICE: 12/11/00
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default. and the
lender intends to foreclose. S~ecific information about the nature of the default is
provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav
be able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take
this Notice with you when vou meet with the Counseling Agency.
The name. address an phone number of Consumer Credit Counseling Agencies
serving vour County are listed at the end of this Notice. If vou have any questions. YOU
may call the Pennsylvania Housing Finance Agency 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 any attorney in your area. The local bar association
may be able to help you find a lawyer.
La notificacion en ad junto es de suma importancia, pues afecta su derecho a
continuar viviendo en su casa. Si no comprende el contenido..de esta notificationohtenga
una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance
Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo
por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual
puede salvar su casa de la perdida del derecho a redimir su hipoteca.
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Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
Fax (215) 627-7734
Date: December 11, 2000
Homeowners Name: MELVIN F. AUCKER JR. and MICHELLE L'AUCKER
Property Address: 1610 Orrsbridge Road, Enola, PA 17025
Loan Account No.: 6735
Original Lender: AMERIQUEST MORTGAGE CO.
Current LenderlServicer: GRP FINANCIAL SERVICES CORP.
HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGmLE 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
ELIGmLE 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 ELIGmILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYL VANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the, Act, you are entitled tQ..aJemporary
stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During
that time you must arrange and attend a "face-to-face" meeting with one of the designated
consumer credit counseling agencies listed at the end of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING
YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO
2
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CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the
consumer credit counseling agencies listed at the end of this notice, the lender may NOT take
actiou against you for thirty (30) days after the date of this meeting. The names. addresses and
telephone numbers of designated consumer credit counseling agencies for the county in which
the property is located are set forth at the end of this Notice. It is only necessary to schedule one
face-to-face meeting. Advise your lender immediatelv of your intentions.
APPLICATION FOR MORTGAGE 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 fact-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS
LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY
AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the Agency under the eligibility criteria established by the
Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it
receives your application. During that time, no foreclosure proceedings will be pursued against
you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
,;,,,;;,:,,,;,.,,,;,,,;,,,,,;.,,;,;,.:.;,;;.:,,.;,:,,.;.:.;.;-:.:,:::,:.;::-:.:-;-:,;,;,:;::;;:,;::.,:"",.::";",
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HOW TO CURE YOUR MORTGAGE DEFAULT (Brim! it UP to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your
property located at: 1610 Orrsbridge Road. Enola. PA 17025 IS SERIOUSLY IN DEFAULT
because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following
months and the following amounts are now past due: .
(a) Monthly payment from 5/1/00 thru 12/11/00
(8 mos. at $583.15/month)
(b) Late charges from 51 1/00 thru 12/11/00
(8 mos. at $34.99/month)
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE
$ 4,665.20
279.92
$ 4,945.12
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS
of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE
LENDER WHICH IS $4.945.12, PLUS ANY MORTGAGE PAYMENTS AND LATE
CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaYments
must be made either bv cash. cashier's check. certified check or money order made Davable and
sent to:
GRP FINANCIAL SERVICES CORP.
444 Park Avenue South
8th Floor
New York, NY 10016-7321
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default
within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ril!:hts
to accelerate the mortl!:a~e debt. This means that the e!lti!;~,!l)ltstanding,,~lanceof thi{;,,gebt
will be considered due immediately and you may lose the chance to pay the mortgage in monthly
installments. If full payment of the total amount past due is not made within THIRTY (30)
PAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your
mortl!:al!:ed property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by
the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you
4
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cure the delinquency before the lender beings legal proceedings against you, you will still be
required to pay the reasonable attorney's fees that were actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees
will be added to the amount you owe the lender, which may also include other reasonable costs.
If vou cure the default within the THIRTY (30) DAY period. vou will not be required to
pav attornev's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid
principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured
the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you
still have the right to cure the default and prevent the sale at anv time UP to one hour before the
Sheriffs Sale. You may do so by paving the total amount then past due. plus any late or other
charges then due. reasonable attorney's fees 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 bv
performing any other requirements under the mortgage. Curing your default in the manner
set forth in this notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that
such a Sheriffs Sale ofthe mortgaged property could be held would be approximately four (4)
to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs
Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly what the required payment
or action will by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: GRP FINANCIAL SERVICES CORP.
Address: 444 Park Avenue South
8th Floor
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Phone Number: 212-951-2400
Fax Number: 212-686-7018
Contact Person: Albert Nolberto
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your
5
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ownership of the mortgaged property and your right to occupy it. If you continue to live in the
property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other
belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or
trallsferee 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 POSITION AS IF
NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN
ANY CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY
FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE
MORTGAGE DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO
SUCH ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Contact Person: Albert Nolberto
Phone Number: 212-951-2400
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PENNSYLVANIA HOUSING FlNANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
CCCS OF WESTERN PENNSYLVANIA INC.
2000 Linglestown Road
Harrisburg, P A 17102
(717) 541-1757
URBAN LEAGUE OF METROPOLITAN HARRISBURG
2107 N. 6tb Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
COMMUNITY ACTION COMM OF THE CAPITAL REGION
1514 Derry Street
Harrisburg, P A 17104
(717) 232-9757
FAX 234-2227
FINANCIAL COUNSELING SERVICES OF FRANKLIN
31 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
YWCA OF CARLISLE
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
ADAMS COUNTY HOUSING AUlHORITY
139-143 Carlisle Street
Gettysburg, P A 17325
(717) 334-1518
FAX (717) 334-8326
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OfFICE Of THE SHERIFf'
CUMBCt{Ll.~W COUNTY
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GOLDBECK McCAFFERTY
BY: Joseph A. Goldbeck,
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for plaintiff
& McKEEVER
Jr.
I HEREBY CERTIFY THATTHIS
IS A TRUE AND CORRECT COpy
OF THE ORIGINAL FILED
WELLS FARGO BANK MINNESOTA NA AS
TRUSTEE
c/o GRP Loan Corp.
444 Park Avenue South, 8th Floor
New York, NY 10016-7321
Plaintiff
IN THE COURT QF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
vs.
Term
Ct~;( ~
MELVIN F. AUCKER JR. AND
MICHELLE L. AUCKER
(Mortgagor(s) and Real Owner(s))
NO.Ol-S/Y
CIVIL ACTION: MORTGAGE
FORECLOSURE
1610 Orrsbridge Road
Enola, PA 17025
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
a Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V ISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, RBGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMAMDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SD PARTICIPACION.
ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TQDAS
LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD
U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS),
215-238 6300.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-910a
TRUE COpy FROM RECORD
In T estiloony whereof. Il1efilllillo sat my hand
...~.. .... ~ Carl"". Pa.
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a Irvine Row, Carlisle, PA 17013
{717} 243-9400
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i HEREBY CERTIFYTHATTHIS
IS A TRUE AND CORRECT COpy
FORECLIJSqw;:THE ORIGINAL FILED
COMPLAINT IN MORTGAGE
1. Plaintiff is WELLS FARGO BANK MINNESOTA NA AS TRUSTEE,
c/o GRP Loan Corp., 444 Park Avenue South, 8th Floor, New York, NY
10016-7321.
2. The name(s) and address(es) of the Defendant(s) is/are
MELVIN F. AUCKER JR., 1610 Orrsbridge Road, Enola, PA 17025 and
MICHELLE L. AUCKER, 1610 Orrsbridge Road, Enola; PA 17025, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On June 28, 1999, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
AMERIQUEST MORTGAGE CO., which mortgage is recorded in the Office
of the Recorder of Deeds of Cumberland County in Mortgage Book
1555, Page 759. By Assignment of Mortgage dated July 6, 1999, the
mortgage was assigned to Plaintiff, which Assignment is lodged for
recording. These documents are matters of public record and are
incorporated herein by reference in accordance with Pennsylvania
Rule of Civil Procedure 10l9(g).
4. The premises subject to said mortgage is described as
attached.
5. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due May 1, 2000, and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 4/ 1/00
through 1/31/01 at 10.500%
Per diem interest rate at $18.28
Attorney's Fee at 5%
of Principal Balance
Late Charges 5/ 1/00- 1/31/01
Monthly late charge amount at $34.99
Costs of suit and Title Search
Escrow Balance
Monthly Escrow amount $
$ 63,540.97
5,575.40
3,177.05
314..91
560.00
$ 73,168.33
$ 73,168.33
7. 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
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Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. Notice of Intention to Foreclose and a Notice of
Homeowners' Emergency Mortgage Assistance has been sent to
Defendant(s) by Certified and regular mail, as required by Act 160
of 1998 of the Commonwealth of Pennsylvania, on the date(s) set
forth in the true and correct copy of such notice(s) attached
hereto as Exhibit "A". The Defendant(s) has/have not had the
required face to face meeting within the required-time and
Plaintiff has no knowledge of any such meeting being requested by
the Defendant(s) through the Plaintiff, the Pennsylvania Housing
Finance Agency, or any appropriate Consumer Credit Counseling
Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $73,168.33, together with interest at the rate of
$18.28, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises.
By:
GOLDBECK Mc
BY: Joseph A. Goldbeck,
Attorney for plaintiff
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01/17/2001 WED 11:57 FAX
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VERIFICATION
I,
as the representative of the
Plaintiff co:t-poralion within named do hereby verify that I am
authorized co and do make this verification on behalf of the
Plaintiff corporation and the facts set forth \j.n the foregoing
Complaint are true and correct to t,he best of my knowledge,
information and belief. I understand that false statements therein
arc made subject to the penalties of 18 Pa. e.s. 4904 relating to
unsworn falsification to authorities.
Date:
/. 17' 0 /
dt:/"-t'Vr 21 &h:~O~
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#6735 - AUCKER JR. ,MELVIN F.
01/17/01 WED 12:02 lTX/RX NO 8521]
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~ chac ceECaln piece or pa~cel cf Lana 11~~ate i~ Hampden
TGwnahip. Cumberland County, Pann.yl~an1a, being more par~icularly
bounded ,,,,d dellcribad aa foU......., 1:0 wit.
seGINNING at a poinC on the eastern ciao ot arrs &~idge Road, at a
~oin~ on ~he noy.thV9Gt corner of and now Or formerly of Bllen
Deschenes; thence by gamo North 150 East One Hundred Eighty-three
and rive '1'Bn...b" 1183.5) feet, mora or less to a poin\; .1: the
ooutnease corner of land noW or form~rly o~ Gary E. Walker; thenoe
by same 501.11:1\790 OS' East TwO Hllndreci Twenty-two (2.2.2) feel: more or
l""o to a poi~t at l.meS no... or formerly o! 1~::l:'/ G, MOOll1B at all
thence by s~ South gO East Forty-eight (48') feet, ~ ~ less,
co a poin~~ e~anee by same Soutb 150 woa~ One Rund~ed TWenty-eMo ana
Two Tenth'll (122.2') elOet 1Il0~" 0:1: less to a poin'!; at t.be .no:I;;'II..8t
COlmer of...,the aforosaid land "ow or formarly of Ellon Descllene..; ehe
oy SaI\Ia North sao Wast TWo Ill.lrlilt'ea""l'6':tty-two (2.42') feetiAlore or,
less, to a poin~. the Place of 8EGINNING.
CONTAINING two (2) Acres, more or less.
JlEXNG part of that "'...... pr_1..... vlU.eh Wayne 2. Baker &1\4 Evelyn n.
8eke:r;, hi" wifB, by their d'eed dated ~el:l"ary 6, 1953 and recorded
1n the Office of t.he C;~erland Count.y Recora.er of Decd. in a....ora
Book "K", vol.- 15. Page l20, granted and con_~red unt.o Barold E.
Kra~Qr and El..~e Kramer, hts wife. Exo..pt~ng end xe.erving
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Certified Article Number
710b 4575 1294 0419 4159
Certified Article Number
SENDERS RECORD
710b 4575 1294 0419 41bb
SENDERS RECORD
ACT 91 NOTICE
EX~Ti\OF NOTICE: 12/11/00
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default. and the
lender intends to foreclose. Specific information about the nature of the default is
provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may
be able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, YOU must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take
this Notice with YOU when YOU meet with the Counseling Agencv.
The name, address an phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice. If you have any questions. you
may call the Pennsylvania Housing Finance Agency 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 any 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
continuar viviendo en su casa. Si no comprende el contenido.de-..esta notification obtenga
una traduccion immediatamente lIamanda esta agencia (Pennsylvania Housing Finance
Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo
por el programa lIamado "Homeowner's Emergency Mortgage Assistance Program" el cual
puede salvar su casa de la perdida del derecho a redimir su hipoteca.
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Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
Fax (215) 627-7734
Date: December 11, 2000
Homeowners Name: MELVIN F. AUCKER JR. and MICHELLE L."AUCKER
Property Address: 1610 Orrsbridge Road, Enola, PA 17025
Loan Account No.: 6735
Original Lender: AMERIQUEST MORTGAGE CO.
Current Lender/Servicer: GRP FINANCIAL SERVICES CORP.
HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGffiLE 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
ELlGffiLE 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 ELIGffiILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE.-.Under the Act,~QlI are entitledto_aternporary
stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During
that time you must arrange and attend a "face-to-face" meeting with one of the designated
consumer credit counseling agencies listed at the end of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING
YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO
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CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the
consumer credit counseling agencies listed at the end of this notice, the lender may NOT take
action against you for thirty (30) days after the date of this meeting. The names. addresses and
telephone numbers of designated consumer credit counseling agencies for the county in which
the propertv is located are set forth at the end of this Notice. It is only n,ecessary to schedule one
face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for
the reasons set forth later in this Notice (see following pages for specific infomiation 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
counseiing 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 fact-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS
LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY
AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the Agency under the eligibility criteria established by the
Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it
receives your application. During that time, no foreclosure proceedings will be pursued against
you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
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HOW TO CURE YOUR MORTGAGE DEFAULT (Brin!! it UP to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your
property located at: 1610 Orrsbridge Road. Enola. PA 17025 IS SERIOUSLY IN DEFAULT
because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following
months and the following amounts are now past due: .
(a) Monthly payment from 51 1/00 thru 12/11/00
(8 mos. at $583.15/month)
(b) Late charges from 51 1/00 thru 12/11/00
(8 mos. at $34.99/month)
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE
$ 4,665.20
279.92
$ 4,945.12
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS
of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE
LENDER WHICH IS $4.945.12, PLUS ANY MORTGAGE PAYMENTS AND LATE
CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavrnents
must be made either bv cash. cashier's check. certified check or monev order made payable and
sent to:
GRP FINANCIAL SERVICES CORP.
444 Park Avenue South
8th Floor
New York, NY 10016-7321
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default
within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ri!!hts
to accelerate the mort!!a!!e debt. This ll\e,ans thatthellntire outstanding~i.\l~, oLthis debt
will be considered due immediately and you may lose the chance to pay the mortgage in monthly
installments. If full payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your
mort!!a!!ed property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by
the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you
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cure the delinquency before the lender beings legal proceedings against you, you will still be
required to pay the reasonable attorney's fees that were actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees
will be added to the amount you owe the lender, which may also include other reasonable costs.
If YOU cure the default within the THIRTY (30) DAY period. YOU will not be required to
pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid
principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured
the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU
still have the right to cure the default and prevent the sale at anv time UP to one hour before the
Sheriffs Sale. You may do so by paying the total amount then past due. plus any late or other
charges then due. reasonable attorney's fees and costs connected with the foreclosure sale and anY
other costs connected with the Sheriffs Sale as specified in writing by the lender and by
perfonning any other requirements under the mortgage. Curing your default in the manner
set forth in this notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that
such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4)
to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs
Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly what the required payment
or action will by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: GRP FINANCIAL SERVICES CORP.
Address: 444 Park Avenue South
8th Floor
Phone Number: 212-951-2400
Fax Number: 212-686-7018
Contact Person: Albert Nolberto
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your
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ownership of the mortgaged property and your right to occupy it. If you continue to live in the
property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other
belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may 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 POSITION AS IF
NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN
ANY CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY
FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE
MORTGAGE DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO
SUCH ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Contact Person: Albert Nolberto
Phone Number: 212-951-2400
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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 17102
(717) 541-1757
URBAN LEAGUE OF ME1ROPOLITAN HARRlSBURG
2107 N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
COMMUNITY ACTION COMM OF TIIE CAPITAL REGION
1514 Derry Street
Harrisburg, P A 17104
(717) 232-9757
FAX 234-2227
FINANCIAL COUNSELING SERVICES OF FRANKLIN
31 West 3rd Street
Waynesboro, PA 1726&
(717) 762-32&5
YWCA OF CARLISLE
30 I G Street
Carlisle, PA 17013
(717) 243-3&1&
FAX (717)731-95&9
ADAMS COUNTY HOUSING AUTHORITY
139-143 Carlisle Street
Gettysburg, P A 17325
(717) 334-151&
FAX (717) 334-&326
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GOLDBECK, McCAFFERTY & McKEEVER
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
BY: MICHAEL T. MCKEEVER, ESQUIRE
Attorney I.D. #56129
Attorney for Plaintiff
WELLS FARGO BANK MINNESOTA NA AS
TRUSTEE
c/o GRP Loan Corp.
444 Park Avenue South, 8th Floor
New York, NY 10016-7321
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Term
vs. No. 01-514 CIVIL TERM
MELVIN F. AUCKER JR. AND
MICHELLE L. AUCKER
(Mortgagor (s) )
(Record Owner(s))
1610 Orrsbridge Road
Enola, PA 17025
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon
payment of your costs only.
R., ESQUIRE
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FllEDO!"FICE
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01 SEP - 7 PM 2: 25
CUMBERU,,\lD COUNTY
PENNSYLVANIA
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