HomeMy WebLinkAbout01-1489 FX
,
STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55.
Robert P Ziegler
I, ______________________________________________________________________________Recorderof
Deeds in and for said County and State do 'hereby certify that the Sheri{{'s Deed in which ________________
_________A~~=l?.:_':._~.::~~~_ ~.?___________________ __________________________________':._ is the grantee
the same having been sold to said grantee on the _____..s_t:.~_____________________________~~~_______ day of
Dee 01
_____________________________________;..__ A. D., r _____, under and by virtue of a writ______________
Execution . 11th
______________________________________ _____ _____ ISSUed on the _ _____ ______ ______ _____'- _____________
day of ____!..':~L_______________ A. D.,
Civil
______________________________.._______ _____ _____ __ _______ _______ ______ _.:________ _ Tenn, :
1489 Altegra Credit Co
Number ______________, at the suit of _________________________________________________L____________
Jeannetta Rudy
___________________________________against_______________~_________________________j__________ ~
249 4820
duly recorded in Sheriffs Deed Book No. ____________, Page ____________.
01 '
_____, out of the Court of Cornman Pleas of said County as of
01
of __
IN TESTIMONY WHEREOF, I have hereunto
and and seal of said office this _j!'~__ day
-______________~~~ ~c?-~~
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Recorder of Deeds, Cumberland County, Carlisle, P~_L
My Commission Expires tlJe first Monday of Jan. 2UllP
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Altegra Credit Company
VS
J eannetta Rudy
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-1489 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
made diligent search and inquiry for the within named defendant, to wit: Jeannetta Rudy,
but was unable to locate her in his bailiwick. He therefore deputized the sheriff of Perry
County, Pennsylvania, to served the within Real Estate Writ, Notice and Description,
according to law.
Perry County Retutn: Now, September 12, 2001 at 2:50 o'clock P.M., served the
within Real Estate Writ, Notice and Description upon Jeanette Rudy, at 12-B Pfautz Rd.,
Penn Township, Duncannon, P A 17020 by handing to Jeanette Rudy a true and attested
copy of the original Writ, Notice and Description and made known to her the contents
thereof. So Answers: James C. Wilson, Deputy Sheriff of Perry County, Pennsylvania.
Kenneth E. Gossert, Deputy Sheriff, who being duly swom according to law,
states that on Sept, 28, 2001 at 3:45 o'clock P.M., E,D.S.T., he posted a true copy ofthe
within Real Estate Writ, Notice, Poster and Description, in the above entitled action,
upon the property of Jeannetta Rudy, 10cated at 515 Herman Ave., Lemoyne, PA,
according to law,
R. Thomas Kline, Sheriff, who being duly swom according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: J eannetta Rudy, by regular mail to her last known address of 13 B
Pfautz Rd., Duncannon, P A 17020. This letter was mailed under the date of October 2,
2001 and never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, who being duly swom according to law, states that
after due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania,on December 5,2001 at 10:00 A.M., EST. He sold the same for the sum
of$1.00 to Attorney Richard Stem for Altegra Credit Company. It being the highest bid
and best price received for the same, Altegra Credit Company of 150 Allegheny Center,
Pittsburgh, PA 15212, being the buyer in this execution paid SheriffR. Thomas Kline the
sum of$649.51, it being costs,
Sheriffs Costs:
Docketing
Poundage
Advertising
Posting Bills
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
$30.00
12.74
15.00
15.00 30.00
10.00
.50
1.00
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Out of County
Perry County
Mileage
Certified Mail
Levy
Surcharge
Postpone Sale
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
II
9.00
30.35
10.40
4.56
15.00
20.00
218.90
188.25
25.66
25.00
27.50
$688.86
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Swom and subscribed to before me So AnS~ ~ .
rl ~ z;.o~?v:."'<-1"~
This 1,/'3:-'dayof~~ .
Q. R Thomas Kline, Sheriff
20~A.D._"..~ 0 ~ nPL
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Prothonotary riI ,I (' , e n~
BY q D~ " 'WVll:!2't
Real Estate Deputy
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F. STERN, ESQUIRE
STERN AND STERCHO
410 The Pavilion
Jenkintown, PA 19046
(215) 572-8111
LD. # 03315
ALTEGRACREDIT COMPANY
VS.
NO. 01-1489 CIVIL
JEANNETTA RUDY
AFFIDAVIT PURSUANT TO RULE 3129.1
RICHARD F. STERN, attorney for Plaintiff in the above caption, sets forth as of the date the
Praecipe for the Writ of Execution was filed, the following information concerning the real
property 10cated at 515 HERMAN AVE., LEMOYNE, PA 17043,
1, Name and address of Owner(s) or Reputed Owner(s):
Jeannetta Rudy
13 B Pfautz Road
Duncannon, P A 17020
2, Name and addres~ of Defendant(s) in the judgment:
Jeannetta Rudy
13 B Pfautz Road
Duncannon, PA 17020
3, Name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
N/A
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4. Name and address of the last recorded holder of every mortgage of record:
Farmers Trust Co,
P.Q, Box 220
Carlisle, PA 17013
A VCO Financial Services, CDC
3542 Gettysburg Pk.
Camp Hill, PA 17011
5. Name and address of every other person who has any record lien on the property:
N/A ..
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:
N/A
7. Name and address of every other person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Commonwealth of Pa.
Inheritance Tax Division
1400 Spring Garden Street
Phila., PA
Intemal Revenue Service
Federated Investors Tower
13th Fl., Ste. 1300
1001 Liberty Ave.
Pittsburgh,PA.15222
Tax Claim Bureau
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Domestic Relations
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
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Occupant
515 Herman Ave.
Lemoyne, PA 17043
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 made subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
Date: 5/30/0 I
STERN AND STERCHO
BY: /&a6C~
RfCHARD F. STERN,
Attorney for Plaintiff
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LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland
and State of Pennsylvania, more particu1arly bounded and described as follows, to wit:
BEING western section of Lot No. 41, Section "D" in a Plan of Lots known as Plan No.1 Riverton,
PennsylvaWa; said plan being recorded in the Recordei:'s Office in and for Cumberland County,
PennsylvaDia;:,at C:ll'lisle, Pennsylvania, in Deed Book "J", Volumn 4, Page 40. The said western section
of lot starting at a point on the northern line of Herman Avenue in the center of Lot No. 41 and thence
through the center walls or partitions of double house known as 513-515 Herman Avenue on a parallel,
line with Fifth Street, formerly known as Clinton Street, one hundred :fIfty (150) feet to the southern line '
of Peach Alley; thence westwardly seventeen feet six inches (17' 6"), thence southwardly one hundred fIfty
(150) feet to northern line of Herman Avenue; thence eastwardly seventeen feet and six inches (17'6")
to point of BEGINNING.
ERECTED THEREON dwelling house No. 515 Herman Avenue.
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PlAINTIFF'S
EXHIBIT
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW.
RICHARD F. STERN, ESQUIRE
STERN AND STERCHO
410 The Pavilion
Jenkintown, PA 19046
(215) 572-8111
I.D. # 03315
ALTEGRA CREDIT COMPANY
VS.
NO, 01~1489 CIVIL
JEANNETTA RUDY
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: JEANNETTA RUDY
13 B PFAUTZ ROAD
DUNCANNON, PA 17020
Your real estate at 515 HERMAN AVE., LEMOYNE, PA 17043 is scheduled to be sold at
Sheriff's Sale on DECEMBER 5,2001 at 10:00 A.M., in the Cumberland County Courthouse,
Carlisle, PA, to enforce the court judgment of $51,505,43 obtained by Altegra Credit Company
against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be cancelled if you pay to Stern and Stercho the back payments, late charges,
costs and reasonable attorney's fees due. To fine out how much you must pay, you may call Stern
and Stercho, telephone (215) 572-8111.
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.
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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.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder: Youmay
find out the price bid by calling Stem and Stercho, telephone (215) 572-8111.
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 Vlill go through only if the buyer pays the Sheriff the full amount due in the sale. To
fmd out if this has happened you may call Stern and Stercho, telephone (215) 572-8111.
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 a 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 on a date specified by the
Sheriff no later than 30 days after the sale date. 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 (10) days
after the date of fIling of said schedule, You should check with the Sheriff's Office by calling
(717) 240-6390 to determine the actual date of fIling of said schedule.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
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 LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
LAWYER REFERENCE SERVICE
COURT ADMINISTRATION
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
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LEGAL DESCRIPTION
AlL THAT CERTAIN piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland
and State of Pennsylvania, more particularly bounded and described as follows, to wit:
BEING western section of Lot No. 41, Section "D" in a Plan of Lots known as Plan No. 1 Riverton,
Pennsylvariia; said plan being recorded in the Recorder's Office in and for Cumberland County,
Pennsylva:nia;,at C:rrlisle, Pennsylvania, in Deed Book "J", Volumn4, Page 40. The said western section
of lot starting at a point on the northern line of Herman Avenue in the center of Lot No. 41 and thence
through the center wails or partitions of double house known as 513-515 Herman Avenue on a parallel,
line with Fifth Street, formerly known as Clinton Street, one huildred fIfty (150) feet to the southern line '
of Peach Alley; thence westwardly seventeen feet six inches (17' 6"), thence southwardly one hundred fIfty
(150) feet to northern line of Herman Avenue; thence eastwardly seventeen feet and six inches (17'6")
to point of BEGINNING.
ERECTED THEREON dwelling house No, 515 Herman Avenue.
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PLAINTIFF'S
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 01-1489 CIVIL.ftf TERM
CIVIL ACTION - LAW -
TO THE SHERIFF OF
Cumberland
COUNTY
Al tegra Credit Canpany
To satisty the debt, interest and costs due _
PLAINTIFF(S)
from Jeanetta Rudy. 515 Hennan Ave.. Lemoyne. PA 17043
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Descriptions
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notrty the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the accounf of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property of thedefendant(s) not levied upon an subject to attachment is found in the possessioriof anyone other
than a named garnishee, you are directed to notify him/her that he/she has been added as agarnishee and is enjoined as above
stated,
Amount Due $51,505.43 LL
,- -,fran date of judgment at the per diem
Interest LdL", uf $ $10.14 Due Prothy
$.50
$1.00
AttY's Comm
Atty Paid
Plaintiff Paid
'10
Other Costs
$149 OR
Date:
July 11. ?001
Curtis R. Long
Prothonotary, Civil Division
,Qy:
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Deputy
REOUESTING PABTY' '
Address:
Richard F. Stern. Esg.
410 The Pavilion
JAnkintown. PA 19046
Attorney for: PlAintiff
Telephone: ?l ';-';72-8111
Supreme Court 10 No, O:U15
Name
,~~i~lllt(ijl!illlt;~i&!i;!iJ!:41lki~Iill!It\-%jtlt&1!l""'~f$l!.irl"'.O'
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REAL ESTATE SALE No. S
On sc.pJ _ (0) ;)00 I the sheriff levied ut)onthed6Tendam:l.
Interest In the real property situated In 6~(Ol/~ d P J~fY)(ffj nil
Cumberland County. Pa.. known and numbered as: ,1}/ '1 # rt'{Ji)J'l flye.-
~j r'LL and more fully described on exhibit "A" flied with
this writ and by this reference incorporated herein.
Date:SepL!IJ, ,DO ( - ay!ik(f}.; ~5f:~7
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OFPENNSYLVANlA :
55.
COUNTY OF CUMBERLAND :
Rog~r M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Joumal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of alllegal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the ~ame as was printed in the regular editions and issues ofthe said Cumberland Law
Journal on the following dates,
VIZ:
October 12, 19,26,2001
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
(i~
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Rog r M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
26 day of OCTOBER. 2001
NOTARIAL SEAl
LOIS E, SNYDER, No!aIY Public
Carlisle BOlO, CumOOlland Coun20Q5ty
My Com/lIiSSIOIl ExpireS March 5,
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REAL ESTATIt SALE NO, 5
Writ No. 2001-1489 Civ1l
Altegra Credit Company
v!\l.
Jeannetta Rudy
Atty.: Richal-d F, Stern
EXHIBIT A
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or
parcel of land situate in the Bor-
ough of Lemoyne, County of Cum-
berland, and State of Pennsylvania,
more particularly bounded and de-
scribed as follows, to wit:
BEING western section of Lot No.
41, Section "D" in a Plan of Lots
known as Plan No.1 Riverton, Penn-
sylvania, said plan being recQrded
in the Recorder's Qillce in and for
Cumberland County, pensylvania, at
Carlisle, Pennsylvarlta, in Deed Book
"J," Volume 4, Page 40. The said
western section of lot starting at a
point on the northern line of Herman
Avenue in the center of Lot No. 41
and thence through the center walls
or partitions of doulple house known
as 513-515 Herman Avenue on a
parallel line with ruth Street, for-
merly known as Clinton Street, one
hundred fifty (150) ieet to the south-
ern line of Peach Alley; thence west-
wardly seventeen feet six inches (17'
6"), thence southwardly one hun-
dred fifty (150) feetlto northern line
of Herman Avenue; thence east-
wardly seveI,lteen fe~t and six inches
(17' 6") to point ,of BEGINNING,
ERECTED THEiREON dwelling
house No. 515 Herman Avenue.
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THE PAtRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
UnderAct No.1587, Approved May16,1929
Commonwealth of Penhsylvania, County of Dauphin) ss
James L. Clark being duly sworn accordi'\g to law, deposes and says:
I
That he is the Acounts Receivable Manager 01 The Patriot News Co" a corporation organized and existing
under the laws of the Commonwealth of PennsylvaT1ia, with its principal office and place of business at 812 to 818
Market Street, in the City of Harrisburg, County of gauphin, State of Pennsylvania, owner and publisher of Th e
Patriot-News and The Sundav Patriot-News newsp~pers of ,general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesai~; that The Patriot-News and The Sunday Patriot-News were
established Match 4th, 1854, and September 18th, 1 949, respectively, and all have been continuously published
ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and pUblished in
their regular daily andlor Sundayl Metro editions which appeared on the 23rd and 30th day(s) of October and the
6th day(s) of November 2001. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
:=,~::~:","g " Do~. '" "" ''''.'C~=.~"P"'~"kU~''",:~mm
COpy Swo n to an su scn . 19th da of ber 2001 AD,
NotartalSaal ~
5 ALE #5 Te.rry L. R. ussan, Notary Pub
Hanisburg, Dauphin Cou. .
My Commission Expires June
, NARY PUBLIC
Mamber, Pennsylvania ASSOCiation at i'lo/artes
My commission expires June 6, 2002
I
CUMBERlAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
186,75
1.50
188.25
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
By....,.,.,.,.,.,.,.,.,...,.,...,.,...,.........,.,.,.",.,.,.,.,.,.,.
REAL ESTATE SALE No.5
Writ No.2001-1489
ClvflTerm
Allegra Credit Company
vs
-Joannetta Rudy
L 'c_~- Ally: Rlcha-d F. Stern
DESCRlPTIDN
=ALL THAT eEB.TA-r..r, piece or parcel of land
di~tG.. jp Jh~ototl ,h oE. Lemoyne, County of
-Cumberland and State of Pennsylvania, more
_j!articu!arly bounded and described as follows, to
Wit: .
F-'Rf1:NG weslerp. section"of Lot No. 41, Section
.;fj1"'-;n <1- Plan, of Lots kno:wp. as, Plan No, 1
Wv.eri011;"Penrisylvania, said plan being recorded
mjhe.Recorder~s Office in and for Cumberland
~ eolm~Peni1sylvania, at Carlisle, Pennsylvania,
~~dJlQ~J", 'VoLl1f!1e ~4. Page :1-0: .The said
EWS~rn seCI1011.m, lot ,~g_ala pam! on the
-l1,grtUem line of Herman Avenuein the center of
- Lot No.4! and thence through the center walls or
partitions-of double house known as 513.515
- Herman Avenue on a parallel line with Fifth
-S~~ formerly known as Clinton Street, one
hundred fifty (150) feet to the southern line of
_ P~cb Aijey:;_thenc,e westwardly, seventeen feet
~fijGhes (1'i~6"), ,t&ence sciuthW3Jd1y one
~]jqndri:.d, fUth (ISO) feet to northern line of
~cnnan. AvCJIu~ ,lh, 'l1ce eastwardly ~eventeen
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F, STERN, ESQ.
STERN AND STERCHO
410 The Pavilion
Jenkintown, PA 19046
215-572-8111
LD. #03315
ALTEGRA CREDIT COMPANY
116 Allegheny Center
Pittsburgh, PA 15212
VS.
NO. 01- f'lf7
CIULL ~~
JEANNETTA RUDY
515 Herman Avenue
Lemoyne, PA 17043
CIVIL ACTION- MORTGAGE FORECLOSURE
This is an attempt to collect
a debt and any information obtained
will be used for that purpose.
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NOTICE
You have been sued in Court. If you wish to defend the claims set
forth in the following pages, you must take action within twenty
(20) days after this Civil Action and notice are served, by entering
a written appearance persona11y or by attorney and filing in writing
with the Court your defense 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 Civil
Action or for any other claim or relief requested by the plaintiff.
You may 10se money or property of other rights important to you.
YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE.
IF YOU DO NOT HAVE ALA WYER, 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, PENNSYLVANIA
1-800-990-9108
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F, STERN, ESQ.
STERN AND STERCHO
410 The Pavilion
Jenkintown, PA 19046
215-572-8111
I.D. #03315
ALTEGRA CREDIT COMPANY
116 Allegheny Center
Pittsburgh, PA 15212
VS.
NO.
JEANNETTA RUDY
515 Herman Avenue
Lemoyne, PA 17043
CIVIL ACTION- MORTGAGE FORECLOSURE
1, Plaintiff is Altegra Credit Company, with registered offices located at 116 Allegheny
Center, Pittsburgh, PA 15212.
2. Defendant is JEANNETTA RUDY, individuals residing at 61 Village Court,
Mechanicsburg, PA 17055.
3. Under date of July 19, 1996, Defendant and WALTER RUDY executed and delivered
to American Mortgage Reduction, Inc. a mortgage upon the premises 515 Herman Avenue,
Lemoyne, PA 17043 to secure the payment of the sum of $48,825,00. The said mortgage is
recorded in the Department of Records in and for the County of CUMBERLAND in Mortgage
Book 1335, page 723, and is incorporated herein by reference. A copy of the legal description
of the premises is attached hereto and made a part hereof as Exhibit "A" .
4. By Assignment dated July 19, 1996, the said mortgage was assigned to ALTEGRA
CREDIT COMPANY. The said Assignment is recorded in the Office for the Recording of Deeds
in and for CUMBERLAND County in Mortgage Book No. 527, page 516, recorded August 9,
1996, and is incorporated herein by reference.
5. And the said WALTER RUDY has since departed this life,
6, Defendant is the real owner of said premises.
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7. In accordance with Section 403 of Act No.6 of 1974, thirty days notice of intention to
foreclose was sent by certified mail, return receipt requested, A copy of said notice is attached
hereto as Exhibit "B".
8. In accordance with Act 91 of 1983, notice was sent to Defendant and no response was
made in the appropriate period of time. A copy of said notice is attached hereto as Exhibit "C".
9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C, 91692 et seq. (1977),
Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in
writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and
provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be
valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for
Plaintiff will send Defendant(s) the name and address of the original creditor if different from
above.
10. The said loan is in default as a result of the failure to pay the montWy installments of
$442.67 due on December 24, 1998, and on the 24th day of each month thereafter.
11. The following is due on the loan:
PRINCIPAL BALANCE
$35,100.00
INTEREST (accrued thru 2/26/01 at the per diem rate of
of $10,14. Interest shall continue to accrue at said per diem rate
after 2/26/01 until judgment is paid in full.)
12,262,75
LATE CHARGES (accrued thru 2/01 at the montWy late
of $22.13, Late charges after 2/01 shall accrue at the
said monthly late fee,)
420.47
OTHER FEES DUE
612.80
COSTS
300.00
ATTORNEY'S FEE
1.800.00
TOTAL
$50,496.02
The attorney fees set forth above are in conformity with the mortgage documents and
Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale.
If the mortgage is reinstated prior to Sale, reasonable attorney fees will be charged based on work
actually performed.
WHEREFORE, Plaintiff, ALTEGRA CREDIT COMPANY requests this Court to enter
judgment for foreclosure of the mortgaged property for the sum of $50,496,02 plus interest
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thereon of $12,262,75 plus $10,14 per IdaX from February 26,2001, until judgment is paid in
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full, late charges of $420.47, plus late charges of $22.13 per month from February, 2001, until
i
judgment is paid in full, fees of $612.~0, costs of $300.00, attorney's fees of $1,800.00 and
,
record costs. I
BY:
RI HARD F. STERN,
Attorney for Plaintiff
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LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel ofland situate in the Borough of Lemoyne, County of Cumberland
and State of Pennsylvania, more particularly bounded and described as follows, to wit:
BEING western section of Lot No. 41, Section "D" in a Plan of Lots known as Plan No.1 Riverton,
Pennsylvania, said plan being recorded in the Recorder's Office in and for Cumberland County,
Pennsylvania, at Carlisle, Pennsylvania, in Deed Book "J", Volumn 4, Page 40. The said western section
of lot starting at a point on the northern line of Herman Avenue in the center of Lot No. 41 and thence
through the center walls or partitions of double house known as 513-515 Herman Avenue on a parallel.
line with Fifth Street, formerly known as Clinton Street, one hundred fifty (150) feet to the southern line
of Peach Alley; thence westwardly seventeen feet six inches (17' 6 "), thence southwardly one hundred fifty
(150) feet to northern line of Herman Avenue; thence eastwardly seventeen feet and six inches (17'6")
to point of BEGINNING,
ERECTED THEREON dwelling house No. 515 Herman Avenue.
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EXHIBIT
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Allegra-Credit Company
P,O. Bax 1838
l'ittsb01<gh. PA 15Z30-183&
April 2, 1999
I
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Jeannetta Rudy
61 Village Court
Mechanicsburg, PA 17055
Dear Mrs. Rudy:
The MORTGAGE held by AL TEGRA CREDIT COMPANY (hereinafter "we", .us., or
"oursi on your property lOcated at 515 Herman Avenue, Lemoyne, PA 17043 is in
SERIOUS DEFAULT because you have not made the monthly payment of $442.67 for
December, 1998, January, February, and March, 1999.
Late charges (and other charges) have also accrued to this date in the amount of
$88.52. Total amount now required to cure this default, or in other words, to get caught
Up on your payments, as of the date of this letter, is $1,859.20.
You mav cure the default 'Uithin thirty (30l..davs of the date of this letter bv Davina to us
the above amount of $.1.-859.20 Qlus any additional inonthlv cavmentsand late chames
which mav fjllI due dunna thi8 oeriod. Such payment must be made either by cash,
cashier's check, certified check or money order and made payable to Altegra Credit
Company, IDC 23-571,150 Allegheny Center Mall, Pittsburgh, PA 15212.
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right
to accelerate the mortgage payment. This means that whatever is owing on the original
amount borrowed will be considered due immediately and you may lose the chance to
payoff the original mortgage in monthly installments. If full payment of the amount of
default is not made within THIRTY (30) DAYS, we also intend to instruct our attomey to
. ..__ .,.~ta!'!.~ ~\Iit~9. fo!'Elclose your ~orts1!iged propert}'.. If the "!ortga~e is_fo~C?~~~ .y~ur '."
mortgaged property will be sold by the shenff to payoff the mortgage debt.
If we refer your case to our attorneys, but you cure the default before they begin legal
proceedings against you, you will still have to pay the reasonable attomey's fees
actuaRy incurred, up to $50.00. However, if legal proceedings are started against you,
you will have to pay the reaQOnable attorney's fees to whatever you owe us, Which may
also include our reasonable costs. If you cure the default within the thirty (30) day
peiiod. you will not be required to pay attorney's fees.
We may also sue you, personall
due under the moriQage.
. '~pal balance and all other sums
if
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EXHIBIT
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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 any time up to one hour before the sheriffs foreclosure sale. You may do so by
paying the total amount of the unpaid monthly payments plus any attorney's fees and
costs connected with the foreclosure sale (and perlorm any other requirements under
the mortgage). A notice of the date of the sheriff 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 will be by calling
us at 80Q..745-1787. This payment must be made by cash, cashier's check, certified
check or money order and made payable to us at the address stated above.
You should realize that a sheriffs safe will end yciur ownership of the mortgaged
property and your right to remain in it. If you continue to live in the property after the
sheriff's sale, a lawsuit could be started to evict you.
You have additional rights to help proteQt your interest in the property. YOU HAVE THE
RIGHT TO SELL THE PROPERlY TO OBTAIN MONEY TO PAY OFF THE
MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING.
INSTITUTION TO PAY OFF THIS DEBT (YOU MAY HAVE THE RIGHT TO SELL OR
TRANSFER THE PROPERlY .SUBJECT TO THE MORTGAGE 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
UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER
WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST.) YOU ALSO HAVE THE
RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARlY ACTING ON YOUR
BEHALF. YOU HAVE THE RIGHT TO ASSERT IN THE FORECLOSURE
PROCEEDINGS, THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE
YOU MAY HAVE TO ACCELERATION OR FORECLOSURE.
If you cure the default, the mortgage will be restor~ to the same status as if no default
had occurred. However, you are not entitled to this right to cure yQur default more than
three times in any calendar year. '
rAYOU ,
Eileen Gonzal
Collections Manager
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'Alt2gra"Credit Company
P.O. 'BOll; 1838
Piltsburgh. P A 15230,1838
April 2, 1999
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Jeannetta RUdy
515 Herman Avenue
Lemoyne, PA 17043
Dear Mrs. Rudy:
The MORTGAGE held by ALTEGRA CREDIT COMPANY (hereinafter "we., .us., or
'ours") on your property located at 515 Herman Avenue, Lemoyne, PA 17043 is in
SERIOUS DEFAULT because you have not made the monthly payment of $442.67 for
December, '1998, January, February, and March, 1999. .
Late charges (and other charges) have also accrued to this date in the amount of
$88.52: Total amount now required to cure this default, or in other words, to get caught
Up on your payments, as of the date of this letter, is $1,859.20.
Youmav cure the default within thirty (SO) days of the date of this. letter bv Davina to us
the above amount of $1.859.20 plus any additional monthlY Davments and late char12es
ythich mav fall due during this Deriod. Such payment must be made either by cash,
cashier's check, certified check or money order and made payable to Altegra Credit
Company, IDC 23-571, 150 Allegheny Center Mall, Pittsburgh, PA 15212.
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right
to aceelerate the mortgage payment. This means that whatever is owing on the original
amount borrowed will be considered due immediately and you may lose the chance to
payoff the original mortgage in monthly installments. If full payment of the amount of
default is not made within THIRTY (30) DAYS, we also intend to instruct our attomey to
start a laws,""it to forecloSE! youtlT!ol!9~ge(t~~pe~ !f th~ort9age is fo~~.!_~~!.. ..,.
mortgaged property will be sold by the sheriff to pay offlhe mortgage debt
If we refer your case to our attomeys, but you cure the default before they begin legal
proceedings against you, you wl1l still have to pay the reasonable attomey's fees
actually incurred, up to $50.00. However, if legal proceedings are started against you,
you will have to pay the reasonable attomey's fees to whatever you owe us, which may
also include our reasonable costs. If you cure the default within the thirty (30) day
period, you will not be required to pay atltomey's fees.
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We may also sue you, personally, for the unpaid principal balElnce and all other sums
due under the mortgage.
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If you have not cure<J 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 any time up to one hour before the sheriff's foreclosure sale. You may do so by
paying the total amount of the unpaid monthly payments plus any attorney's fees and
costs connected with the foreclosure sale (and perform any other requirements under
the mortgage). A notice of the date of the sheriff 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 will be by calling
us at 800-745-1787. This payment must be made by cash, cashiers check, certified
check or money order and made payable to us at the address stated above. '
You should reatize that a sheriffs sale will end your ownership of the mortgaged
property and your right to remain in it. If you continue to live in the property after the
sheriffs sale, a lawsuit could be started to evict you.
You have additional rights to help protect your interest in the property. YOU 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 (YOU MAY HAVE THE RIGHT TO SELL OR.
TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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
UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER
WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST.) YOU ALSO HAVE THE
RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF. YOU HAVE THE RIGHT TO ASSERT IN THE FORECLOSURE
PROCEEDINGS, THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE
YOU MAY HAVE TO ACCELERATION OR FORECLOSURE.
If you cure the default. the mortgage will be restored to the same status as if no default
had occurred. However, you are not entitled to this right to cure your delfault more than
three times in any calendar year.
... .. -fi1f-------
Eileen GonzaleS
CoHections Manager
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IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983.
PlEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE TOWARDS YOUR MORTGAGE PAYMENTS.
RE: 6019590146708
Apri/2, 1999
Jeannetta Rudy
61 Village Court
Mechanicsburg, PA .17055
Allegra Credit Company
IDe 06-571
150 Allegheny Center Mall
Pittsburgh, PA 15212
YOUR MORTGAGE IS IN SERIOUS DEFAULT because you have failed to pay
promptly installments of principal and interest as required. for a period of at least sixty
(60) days. The total amount of delinquency is $1,859.20. This sum includes the
following: Four (4) payments at $442.67 each plus late charges of $88.52.
FROM:
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE THAT WILL PREVENT
FORECLOSURE ON YOUR MORTGAGE, if you comply with the provisions of the
Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be
eligible for emergency temporary assistance if your default has been caused by
circumstances beyond.your control and if you meet the eligibility requirements of.the
Act as determined by the Pennsylvania Housing Finahce Agency. PLEASE READ ALL
OF THIS NOTICE. IT CONTAINS AN EXPLANATION OF YOUR RIGHTS.
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 this lender or with a consumer credit work out
repayment plan, or to otherwise settle your delinquency. THIS MEETING MUST
OCCUR WITHIN THE NEXT THIRTY (30) DAYS. .
'.......... .._.___..M____..'.._..__, .._~. ....._ ...._._.. _........ ,..___,.. ,.__._.._...... . . , "._."_'
If you' attend a face-to-face meeting with this lender or with a consumer credit
counsefing agency identified in this notice, no further proceedings in mortgage
foreclosure may take place for thirty (30) days after the date of this meeting.
PLA~'tIFF'S
EXHIBIT
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The names, addresses and phone numbers of our representative are:
REBECCA BEACOM
IDC 23-571
150 ALLEGHENY CENTER MALL
PITTSBURGH, PA 15212
1-80Q.,745.1787
662 NORTH MAIN ST.
GREENSBURG, PA 15601
412-838-1290
HOUSING ACTION COALITION, INC.
WESTMORlANO COUNTY ONLY
714 PHiLADElPHIA ST.
INDIANA, PA 15701
HOUSING OPPORTUNmES, INC.
623 VERSAIlLES AVE.
MCKEESPORT, PA 15134
MON-VALLEY UNEMPLOYED COMMITTEE
600 WALNUT ST_ .
MCI<EESPORT, PA 15134
URBAN LEAGUE OF PITTSBURGH, INC.
ALLEGHENY COUNTY ONLY
BUILDING FOR EQUAL OPPORTUNITY
, , 200 ,ROSS STREET
pmSBURGH, PA 15219
412.261.1130
CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY
1211 CHESTNUT STREET
SUITE 411
PHILADELPHIA, PA 19107
215-563-5665
125 NORTH JEFFERSON ST.
NEWCASTLE, PA 16101
412-652-8074
URBAN LEAGUE OF HARRISBURG, INC,
28 NORTH SECOND STREET
HARRISBURG. PA 17101
717-234-5925
CONSUMER CREDIT COUNSELING SERVlCE OF LEHIGH VALLEY
1031 LINDEN STREET
ALLENTOWN, PA 18102
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It is extremely important that you file your application promptly. If you do not do so or if
you do not follow the other time periods set forth in this letter, foreclosure may proceed
eligibility for assistance.
Available fUnds for emergency assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act.
It is extremely important that your application is accurate and complete in every respect.
The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after
it receives your application. During that additional 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 that Agency of its'decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O.
Box 8029 in Harrisburg, Pennsylvania 17105. Their telephone number is 717-780-3800
or, you may call toll free at 1-800-342-2397.
In addition, you may receive another notice from this lender under Act 6 of 1974. This
notice is called a "Notice of Intention to Foreclose Mortgage". You must read both
noti~, since they both explain rights that you now have under Pennsylvania law.
However. if you choose to exercise your rights described in this notice, we cannot
foreclose ilpon you during that time. Also, if you receive financial assistance from the
Pennsylvahia Housing Finance Agency, your home cannot be foreclosed upon while
you are receiving that assistance.
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Eileen Gonzales
Collections Manager
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IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983.
PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE TOWARDS YOUR MORTGAGE PAYMENTS.
RE: 6019590146708
April 2, 1999
Jeannetta Rudy
515 Herman Avenue
lemoyne, PA 17043
Altegra Credit Company
10C 06-571
150 Allegheny Center Mall
Pittsburgh, PA 15212
YOUR MORTGAGE IS IN SERIOUS DEFAULT because you have failed to pay
promptly Installments of principal and illlterest as required, for a period of at least sixty
(60) days. The total amount of delinquency is $1,859.20. This sum includes the
following: Four (4) payments at $442.67 each plus late charges of $88.52.
FROM:
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE THAT WILL. PREVENT
FORECLOSURE ON YOUR MORTGAGE, if you comply with the provisions of the
Homeowners' Emergency Mortgage ASsistance Act of 1983 (the "Acf'). You may be
eligible for emergency temporary assistance if your default has been cau$ed by
circumstances beyond your control an~ if you meet the eligibility requirements of the
Act as determined by the Pennsylvania Housing Finance Agency. PLEASE READ ALL
OF THIS NOTICE. IT CONTAINS AN EXPLANATION OF YOUR RIGHTS.
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 this lender or with a consumer credit work out
repayment plan, or to otherwise settle your delinquency. THIS MEETING MUST
OCCUR WITHIN THE NEXT THIRTY (30) DAYS.
- ., ..', n. ....__.....___,._ . _ ,'~._.,.'- _.._~_.
If you attend a face-to-face meeting with this lender or with a consumer credit
counseling agency Identified in this n~tice. no further proceedings in mortgage
foreclosure may take place for thirty (30) days after the date of this meeting.
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The names, addresses and phone numbers of our representatiVe are:
REBECCA BEACOM
IDC 23-571
150 ALLEGHENY CENTER MALL
PITTSBURGH, PA 15212
1-800-745-1787
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The names, addresses and phone numbers of designated consumer credit counseling agencies....;
ACTION HOUSING, INC.
TWO GATEWAY CENTER
PITTSBURGl-l, PA 15222
412-281-2102
CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYlVANIA, INC.
309 SMITHFIELD ST. P.O. BOX 278
SUITE 500 SllO-02 THIRD AVE,
PITTSBURGH. PA 15222 DUNCANSVlLLE. PA 16635
412471-7584 814-696-3546
002 NORTH MAIN ST.
GREENSBURG. PA 15601
412-838-1290
HOUSING ACTION COALITION. INC.
WESTMORLAND COUNTY ONLY
714 PHILADELPHIA ST.
INDIANA PA 15701
125 NORTH JEFFERSON ST.
NEW CASTLE, PA 16101
412-852-8074
HOUSING OPPORTUNmES. INC.
623 VERSAILLES AVE.
MCKEESPORT. PA 15134
MON-VALLEY UNEMPLOYED COMMiTTeE
600 WALNUT ST.
MCKEESPORT. PA 15134
URBAN LEAGUE OF PITTSBURGH, INC. URBAN LEAGUE OF HARRISBURG. INC.
ALLEGHENY COUNTY ONLY 28 NORTH SECOND STREET
BUILDING FOR eQUAL OPPORTUNITY HARRISBURG. PA 17101
-200RQSSSTREE:r---,..----. --..---..-- ,.. .. ,.,.717-234-5925
PITTSBURGH. PA 15219
412-261-1130
CONSUMER CREDIT COUNSELING SERVICE OF DElAWARE VALlE(
1211 CHESTNUT STREET
SUITE 411
PHIlADELPHIA. PA19107
215-563-6665
CONSUMER CREDIT COUNseUNG SERVICE OF LEHIGH VALLEY
1031 LINDEN STREET
ALLENTOWN. PA 18102
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It is extremely important that you file your application promptly. If you do not do so or if
you do not follow the other time periods set forth in this letter, foreclosure may proceed
eligibility for assistance.
Available funds for emergency assistance are very limited. They will be disbursed by
the Agenq under the eligibility criteria established by the Act.
It is extremely important that your application is accurate and complete in every ~pect.
The Pennsylvania Housing Finance ~ency has sixty (50) days to make a decision after
it recei'leli your application. During that additional 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 that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101 North Front street, P.O.
Box 8029 in Harrisburg, Pennsylvania'17105. Their telephone number is 717-780-3800
or. you may call toll free at 1-800-342-2397.
In addition. you may receive another notice from this lender under Act 6 of 1974. This
notice is called a "Notice of Intention to Foreclose Mortgage". You must read both
notices. since they both explain rights that you now have under PennsYlvania law.
However. if you choose to exercise your rights described in this notice, we cannot
foreclose upon you during that time. Also, if you receive financial assistance from the
Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon whne
you are receiving that assistance,
Eileen Gonzal '
Collections Manager
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2001-01489 P
. COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ALTEGRA CREDIT COMPANY
VS
RUDY JEANETTA
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
RUDY JEANNETTA
but was unable to locate Her
in his bailiwick. He therefore
deputized the sheriff of PERRY
County, Pennsylvania, to
serve the within COMPLAINT - MORT FORE/NOT
On April
10th , 2001 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs:
Docketing
Out of County
Surcharge
DEP. PERRY CO
18.00
9.00
10.00
40.08
.00
77.08
04/10/2001
STERN & STERCHO
S~/
R. Thomas Kllne
Sheriff of Cumberland County
Sworn and subscribed to before me
this J/~ day of ~__;d
.2..c-rJ1 A.D.
q.." -'- () ~ ~.;;; ,
f Prothonotary-
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.' III The Court of Common Pleas of Cumberland County, Pennsylvania
Altegra Credit Company
VS.
Jeanetta Rudy
No.
01-1489 Civil
Now,
4/2/01
, 20 0 (J , I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of Pe rry
County to execute this Writ, this
deputation being made at the request and risk ofthe Plaintiff. . .
. .. . ~1Jd"~~,
Sheriff of Cumberland County, P A
Affidavit of Service
Now, April 6,
, 20~, at 9: 40 0' clock
A M. served the
WitllID Complaint in Mortgage Forelosure
upon Jeanetta Rudy
& 13 B Pfautz Rd. Duneannon, Penn Township, PA. 17020
by h1Ul dill g to
J",,,n,,,tt:a Rudy
a
True & Attested
copy of the original Compo Mtg. Fore
and made known to
h",r
tl1e contents thereof.
So answers,
NOTARiAl SEAl
MARGARETE FlICKINGER,NOT~~
81.OOMAElD BORa" PERRY
MY COMMISSION EXPIRES f ,6
/
Deput Perry County, P A
COSTS
SERVICE 18.00 $
MILEAGE 1? OR
A.FFIDA VIT <.00
$ 40.08
Sworn and subscribed before
me this iN/., day of Apr, I ; 20 ~
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PRAECIPE FOR WRIT OF EXECUTIO:-: - (MONEY JUDG~tEN'I'S)
Pa. R.C.P. 3101 to 3H9
A1tegra Credit Company
In the Court at Common Pleas at'
CUMBERLAND . County, Pennsylvania.
.....................................................................................
..........................................................................................
1JS
No. .....QJ.:-.:!..4?9......,..................
Jeannetta Rudy
....u.......uu..........~....................................................... ........
.......................................................................a.................
PRAECIPE FOR WRIT OF EXECUTION
(MONEY JUDG?!ENT)
- ..
To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER.
(1) Directed to the Sheriff of .......CUrober.1oJJ.d............................County. Penna:.;
(2) against
..............................................................T..............................................................................................
...........................................~~!!Jw..~.t~~..Bg.9.Y..........................................,.................. Defendant (s) ;
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(~~ ............................................................................................................................ G~l(X);
(4). an.d index this .writ
(a) against ........................................................................ .................................... .......................................
...............................y.~gnn~j;j;a..ElJQ~....................................................... Defendant (s) and
(~..............................................................;...........................,...............:....:....................................
...a.~.... ................~. ..~.....~.~.~ ... ....~. .... .~............. .......~.a... .a.............. a... ................ .........
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asa lis pendens against the real property of the defendants (s) i
(Specifically describe property per attached property description) :
515 HerIilan Ave., Lemoyne, PA SEE ATTACHED LEGAL DESCRIPTION
(5)
Amount due
s...n,.5Q5.,~~......
Interest fromthe date judgment
at the per diem rate of $10.14.
Total
is entered.........................
Plus costs.
RICHARD F. STERN, Attorn.v tor Plain!ifj(s}
'. :-:OTE
tinder pa1"aff1"::J.on f II when the \\"TIt is directed to th~ snerut of :::.nother count)" :J.S :1uthon:eci by Rule ~:l0:J rh\. the
counc'!o" shouicl be inriic:.teri.
Unde:o Ruie 3103 (c} a. 9r."Tlt issued un a tr:msierred jucigment ma:: be directed oniy to the sh~riif oi the COl!n:r in
which issued.
Paragraph (3) abo'.e should be completed ontr if a named garnisnee' bftl"'b'e included in the w,it.
Paragraph (4) (a) should be completed onl}" if indexing oC ~he e:o-:ecution in the county Ot issuance. is desired as
authorized by Rule 3104 (:1). When the ","-rit issues to another count)" inde:dng is required :l.S of course in that count)' by
the prothonotar).. See Rule 3104 (bl:
P:uas-r3ph (4) (b) should be completed on1r if real P1"OpeoTt)"::1 ~he' namp- oC:J. R'arnisnt'e is :ltt:1C:nea :md inde~ing 3!1:
a. lis pendens is desired. See Rule 3104(1:).
Dated ................................................
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No. ....(lJ.~H89.....:....._.._........
In the Court of Cammon Pleas of
; Cl,lMBERLAND . County, Pennsylvania.
_._, 8Jt"gra. ("rliQit CEl!!lJilaFlY ....--.............
. .
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113
Jeannetta Rudy
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PRAECIPE FOR WRIT OF EXECUTION
(Money Judgments)
Pa. R.C.P. :n01 to 3149 etc:.
Premises: 515 Herman Ave., Lernoyne, PA
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F. STERN, A j",.pla.intil!r.)
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Address: FaV"il:!.on Suit:e 410
Jenkint:ovn. FA 19046
Where ps.pen may be served"':
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LEGAL DESCRIPTION
AlL THAT CERTAIN piece or parcel ofland situate in the Borough of Lemoyne, County of Cumberland
and State of Pennsylvania, more particularly bounded and described as follows, to wit:
BEING western section of Lot No. 41, Section "D" in a Plan of Lots known as Plan No.1 Riverton,
PennsylvaW,a; said plan being recorded in the RecorcIei:-'s Office in and for Cumberland County,
Pennsylvanla.;;atC:u-lisle, Pennsylvania, in Deed Book "J", Volumn4, Page 40. The said western section
of lot starting at a point on the northern line of Herman Avenue in the center of Lot No. 41 and thence
through the center walls or partitions of double house known as 513-515 Herman Avenue on a parallel,
line with Fifth Street, formerly known as Clinton Street, one hu:i1dred fIfty (150) feet to the southern line '
of Peach Alley; thence westwardly seventeen feet six inches (17' 6 "), thence southwardly one hundred fIfty
(150) feet to northern line of Herman Avenue; thence eastwardly seventeen feet and six inches (17'6")
to point of BEGINNING,
ERECTED THEREON dwelling house No. 515 Herman Avenue. .
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F. STERN, ESQUIRE
STERN AND STERCHO
410 The Pavilion
Jenkintown, PA 19046
(215) 572-8111
LD. # 03315
ALTEGRA CREDIT COMPANY
VS.
NO. 01-1489 CIVIL
JEANNETTA RUDY
AFFIDAVIT PURSUANT TO RULE 3129.1
RICHARD F, STERN, attorney for Plaintiff in the above caption, sets forth as of the date the
Praecipe for the Writ of Execution was filed, the following information concerning the real
property located at 515 HERMAN AVE., LEMOYNE, PA 17043.
1. Name and address of Owner(s) or Reputed Owner(s):
Jeannetta Rudy
13 B Pfautz Road
Duncannon, P A 17020
2. Name and address of Defendant(s) in the judgment:
Jeannetta Rudy
13 B Pfautz Road
Duncannon, P A 17020
3, Name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
N/A
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4. Name and address of the last recorded holder of every mortgage of record:
Farmers Trust Co.
P.O. Box 220
Carlisle, PA 17013
A VCO Financial Services, CDC
3542 Gettysburg Pk.
Camp Hill, PA 17011
5. Name and address of every other person who has any record lien on the property:
N/A
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:
N/A
7. Name and address of every other person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Commonwealth of Pa.
Inheritance Tax Division
1400 Spring Garden Street
Phila., PA
Internal Revenue Service
Federated Investors Tower
13th Fl., Ste. 1300
1001 Liberty Ave.
Pittsburgh, PA 15222
Tax Claim Bureau
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Domestic Relations
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
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Occupant
515 Herman Ave.
Lemoyne, P A 17043
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 made subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
Date: 5/30/01
STERN AND STERCHO
BY:~.~
RitHARD F. STERN,
Attorney for Plaintiff
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LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land sittJate in the Borough of Lemoyne, County of Cumberland
and State of Pennsylvania, more particularly bounded and described as follows, to wit:
BEING western section of Lot No. 41, Section "D" in a Plan of Lots known as Plan No. 1 Riverton,
PennsylvaWa; said plan being recorded in the Recorder's Office in and for Cumberland County,
Pennsylvania,;, at Carlisle, Pennsylvania, in Deed Book "J" , V olumn 4, Page 40. The said western section
of lot starting at a point on the northern line of Herman Avenue in the center of Lot No. 41 and thence
through the center walls or partitions of double house known as 513-515 Herman Avenue on a parallel
line with Fifth Street, formerly known as Clinton Street, one hundred :f1fty (150) feet to the southern line
of Peach Alley; thence westwardly seventeen feet six inches (17'6"), thence southwardly one hundred fifty
(150) feet to northern line of Herman Avenue; thence eastwardly seventeen feet and six inches (17'6")
to point of BEGINNING.
ERECTED THEREON dwelling house No. 515 Herman Avenue.
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PLAINTIFF'S
EXHIBIT
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F. STERN, ESQUIRE
STERN AND STERCHO
410 The Pavilion
Jenkintown, PA 19046
(215) 572-8111
I.D. # 03315
ALTEGRA CREDIT COMPANY
VS,
NO. 01-1489 CIVIL
JEANNETTA RUDY
CERTIFICATION UNDER RULE 237.1
I, the undersigned, attorney on the writ and attorney for plaintiff, hereby certify that a ten
day notice of intention to enter judgment by default was sent to defendant in accordance with Pa,
R.C.P.237.1. A true and correct copy of said notice is attached hereto,
STERN AND STERCHO
BY:~'.
RICHARD F, STERN,
Attorney for Plaintiff
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IN THE COURT uF COMMON PLEAS OF CUMBERLAND COUNTY
CML ACTION - LAW
RICHARD F. STERN, ESQUIRE
STERN and STERCHO
410 The Pavilion
Jenkintown, PA 19046
(215) 572-8111
I.D. #03315
ALTEGRA CREDIT COMPANY
VS,
JEANNETTA RUDY
:NO, 01-1489 CIVIL TERM
NOTICE OF INTENTION TO ENTER DEFAULT JUDGMENT
TO: JEANNETTA RUDY, 515 HERMAN AVENUE, LEMOYNE, PA 17043
IMPORTANT NOTICE
iIIliiIII "-
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YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY ORBY ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN
(10) 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 REFERENCE SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
2 LffiERTY AVENUE
CARLISLE, PENNSYLVANIA
1-800-990-9108
DATE: 4/27/01
STERN AND STERCHO
BY:~~
RIe ARD F. STERN,
Attorney for Plaintiff
I\Server\office documlAtUle MarlelTeD DayIRUDY.CUMBERLAND 10 DAY.wpd
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F. STERN, ESQUIRE
STERN AND STERCHO
410 The Pavilion
Jenkintown, PA 19046
(215) 572-8111
LD, # 03315
ALTEGRA CREDIT COMPANY
VS,
NO, 01-1489 CIVIL
JEANNETTA RUDY
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF MONTGOMERY
RICHARD F. STERN, being duly sworn according to law, deposes and says, to the best
of her knowledge, information and belief, defendant's:
1. Last-known address is:
515 Herman Ave" Lemoyne PA 17043
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2, Is over the age of twenty-one.
3. Is not now nor have been within the last six (6) months in the Armed Services of the
United States as defmed in the Soldiers' Civil Relief Act of 1940, as amended.
STERN AND STERCHO
By:,~2{1. a~.
RICHARD F. STERN,
Attorney for Plaintiff
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F. STERN, ESQUIRE
STERN AND STERCHO
410 The Pavilion
J enkintown, P A 19046
(215) 572-8111
I.D. # 03315
ALTEGRA CREDIT COMPANY
VS.
NO. 01-1489 CIVIL
JEANNETTA RUDY
CERTIFICATE UNDER ACT 91 OF 1983
It is hereby certified that the Sheriff's Sale scheduled in the above-captioned matter is not
protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L.
1688, No, 621 because notice, as required, was sent to defendant and no timely response
was made,
STERN AND STERCHO
BY:~/
if ARD F, STERN,
Attorney for Plaintiff
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F, STERN, ESQUIRE
STERN AND STERCHO
410 The Pavilion
Jenkintown, PA 19046
(215) 572-8111
I.D, # 03315
ALTEGRA CREDIT COMPANY
VS.
NO. 01-1489 CIVIL
JEANNETTA RUDY
CERTIFICATION OF ADDRESS
It is hereby certified that the last known addresses of the parties are as follows:
Altegra Credit Company
116 Allegheny Center
Pittsburgh, PA 15212
Jeannetta Rudy
13 B Pfautz Road
Duncannon, P A 17020
STERN AND STERCHO
BY: k
RICHARD F, STERN,
Attorney for Plaintiff
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F, STERN, ESQUIRE
STERN AND STERCHO
. 410 The Pavilion
Jenkintown, PA 19046
(215) 572-8111
I.D, # 03315
ALTEGRA CREDIT COMPANY
VS,
NO. 01~1489 CIVIL
JEANNETTA RUDY
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: JEANNETTA RUDY
13 B PFAUTZ ROAD
DUNCANNON, PA 17020
Your real estate at 515 HERMAN AVE" LEMOYNE, PA 17043 is scheduled to be sold at
Sheriff's Sale on DECEMBER 5,2001 at 10:00 A,M., in the Cumberland County Courthouse,
Carlisle, P A, to enforce the court judgment of $51 ,505.43 obtained by Altegra Credit Company
against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TmS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1, The sale will be cancelled if you pay to Stern and Stercho the back payments, late charges,
costs and reasonable attorney's fees due. To fine out how much you must pay, you may call Stem
and Stercho, telephone (215) 572-8111.
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.
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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.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
I, 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 Stern and Stercho, telephone (215) 572-8111.
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 Stern and Stercho, telephone (215) 572-8111.
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 a 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 on a date specified by the
Sheriff no later than 30 days after the sale date, 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 (10) days
after the date of filing of said schedule. You should check with the Sheriff's Office by calling
(717) 240-6390 to determine the actual date of fIling of said schedule.
7, You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale,
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 LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
LAWYER REFERENCE SERVICE
COURT ADMINISTRATION
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
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LEGAL DESCRlPI'ION
ALL THAT CERTAIN piece or parcel ofland situate in the Borough ofLemoyne, County of Cumberland
and State of Pennsylvania, more particularly bounded and described as follows, to wit:
BEING western section of Lot No. 41, Section "D" in a Plan of Lots known as Plan No.1 Riverton,
PennsylvaWa; said plan being recorded in the Recorder's Office in and for Cumberland County,
Pennsylv~,at Carlisle, Pennsylvania, in Deed Book "J". V olumn 4, Page 40. The said western section
of lot starting at a point on the northern line of Herman Avenue in the center of Lot No. 41 and thence
through the center walls or partitions of double house known as 513-515 Herman Avenue on a parallel
line with Fifth Street, formerly known as Clinton Street, one hundred fifty (150) feet to the southern line
ofPeachA1ley; thence westwardly seventeen feet six inches (17' 6"), thence southwardly one hundred fifty
(150) feet to northern line of Herman Avenue; thence eastwardly seventeen feet and six inches (17'6")
to point of BEGINNING.
. ERECTED THEREON dwelling house No. 515 Herman Avenue.
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PLAINTIFF'S
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RICHARD F. STERN, ESQUIRE
STERN and STERCHO
410 The Pavilion
J enkintown, P A 19046
(215) 572-8111
LD.#03315
ALTEGRA CREDIT COMPANY
:IN THE COURT OF COMMON PLEAS
DAUPHIN COUNTY
VS.
: NO. 01-1489 CNIL
JEANNETTA RUDY
CERTIFICATE OF SERVICE
I, RICHARD F. STERN, ESQ., attorney for the within Plaintiff, hereby certify
that notice of the Sheriff s Sale was mailed to the Defendant by regular and certified mail,
return receipt requested on October 30, 2001.
I further certify that notice of the Sheriff s Sale was mailed to each lienholder by
regular, first-class, postage prepaid mail on October 30, 2001 as evidenced by copy of
certificates of mailing attached.
STERN AND STERCHO
O~UJ.(~
BY: UY'1 #-$j Sy I
RICHARD F. STERN
Attorney for Plaintiff
10/30/2001
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Lemoyne,PA17043
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Thirteenth Floor, Suite 1300
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Plttsbureh PA1<;n?
PSFarm3817,M.,.1999
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1400 Spring Garden:',St.
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3542 Getty;;burg"Plke
Camp Hill, PA 17011
PSFomn:!:ll17.M...1999