HomeMy WebLinkAbout01-2397 FX
.10--.""-
-
,-;.;J;ci~ < "
"",,{;'L,_1[j-_
'..
, .
BENNETT & DOHERTY, P.C,
P A Bar I.D. No. 63352
By: Jeffrey A. Bennett
The Barness Office Plaza
975 Easton Road, Suite 102
Warrington, PA 18976
Tel. (215) 343-4100
Attorneys for Plaintiffs
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
vs.
No. Ol - .;J.ifi7
Ci0~l T~
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013,
Defendant(s).
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 this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with the Court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against you by the Court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE: GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP;
->r-~"~"'-~
'" ". ~
-
"' ~-
, "
.~'."
I,
~~"",
. -
.
COURT ADMOOSTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 240-6200
Dated: tt-Jo-O'
Jeffr A. Bennett, Esquire
Attorney for Plaintiff
2
....i ~ w-
~ ~.
. .
.-,,'
-'~"
BENNETT & DOHERTY, P,C.
PA Bar I,D. No, 63352
By: Jeffrey A. Bennett
The Bamess Office Plaza
975 Easton Road, Suite 102
Warrington, PA 18976
Tel. (215) 343-4100
Attorneys for Plaintiffs
LASALLE NATIONAL BANK, as
Trustee under the pooling and servicing
agreement dated 6/1198, series 1998-2,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff,
'71.c.O)-:1391 ~ /~
vs.
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, PA 17013,
Defendant(s).
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is
Lasalle National Bank
One Ramland Road
Orangeburg, New York 10962
2. The name (s) and last known address (es) of the Defendant (s) are
Maribeth Chudyk
26 Longstreet Drive
Carlisle, P A 17013
who is/are the mortgagor (s) and real owner (s) of the property hereinafter described.
:.- -"1~~ j j "
, ,
,
" ,~~
"1' l!!a-- - "^,,,,'
3. On June 10, 1998, mortgagor (s) made, executed and delivered a mortgage upon the
premises hereinafter described to Alliance Funding, a Division of Superior Bank FSB,
which mortgage is recorded in the Office of the Recorder of Cumberland County, in
Mortgage Book 1462, Page 350. See Exhibit A. PLAINTIFF is now legal owner of the
Mortgage and is in the process of recording said Assignment.
4. The premises subject to said mortgage is described as attached. See Exhibit B.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due July 15, 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
$32,854.00
$ 2,027.32
Through 2/1912001
(Per Diem $10.04)
Attorney's Fees/Costs
Inspection
NSF Fees
Cumulative Late Charges
$ 3,600.00
$ 165.00
$ 30.00
$ 433.18
TOTAL
$39,109.50
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 Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. On October 20, 2000, plaintiff sent defendant a notice of default by regular and certified
mail at defendant's last known address (and at the address which is the subject of the
residential mortgage, if different from defendant's last known address) in accordance with
the requirements of 41 Pa. Stat. S 403. See Exhibit C.
9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. S1692 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.
~'
"
d
-" , - ,~ ,
i,;j!<~ll1it~"';
WHEREFORE, PLAINTIFF demands Judgment against the Defendant (s) in the sum of
$39,109.50, together with interest from February 20,2001 at the rate of$10.04 per diem to the
date of Judgment, and other costs and charges collectible under the mortgage and for the
foreclosure and sale of the mortgaged property.
BENNETT & DOHERTY, P,C.
~
JEFF~ A. BENNETT, ESQUIRE
Attorney for Plaintiff
Dated: ~ - ;}'O -0 \
.
",I
""'''t----)-
,-,
~ "'~.'
VERIFICATION
Maureen Toal hereby states that she holds the position of foreclosure specialist for
Superior Bank, F.S.B., mortgage servicing agent for Plaintiff in this matter, that she is authorized
to make this Verification, and that the statements made in the foregoing Civil Action in
Mortgage Foreclosure are true and correct to the best of her knowledge, infOlmation and belief.
The undersigned understands that the statements therein are made subject to the penalties of 18
Pa. C. S. S4904 relating to unsworn falsification to authorities.
By:
~
UREEN TOAL, Foreclosure Specialist
Dated:
,..:C;Wh
,
.-1
-
""1!",,,,,,~",,,,,'ttlIM
EXHIBIT A
<
cJ- IJ.11!' u
': ;, :. :- . r. ''': ~ 'I, \. ;~~
; ~ 'J;:~;.::.I.' :'; \}~~:.DS'
. ' . 0 "\ (>1"\..,' ~ " - ", ...
~,;; r ~ i ~\ ,I,) ..' \' ., I ,
. ." ~'-' -
. 98JU\~ 2J ArllO 32
<~, ni
PI.EASE ReCORD AND REf""" JC)
PfONeE'R AGIHC'f
471 CAl.IF<MNIA ""~
GUAKllATOWH, M 1M1
~5S1'J'q
[Space Abo'v'e This l.ine For Rec:ordinl! DlltaJ
ACCOUNT #: 0800878969
Prepared by: JENNH'ER BOYER
Po..n::.e[#:-: ~I'Otc. - 0017 'o;;loA MORTGAGE
-----"*'
'--.;Q'~'~
,,",
17~
Afe.
:r :216
is
MARIBETH CHUDYK
THIS MORTGAGE ("Seeurity Instrument") is given on JUNE 10. 1998
. The mortgagor
("Borrower").
This Security Instrument is given to
Alliance Funding Company, Division of Superior Bank FSB
<;;iiicn IS organized ami'existlng-imder Ihe laws of The United States
1)5 CHE~}!IDT..BIDGE RQaP, ..I:lmlTVA\.~J N.J 07645
("Lender"). Borrower oweS Lender the principal suni'of ---
THIRTY-FOUR THOUSAND THREE HUNDRED SIXTY-ONE AlID ~0/100 Dollars
(U.s. $ 34,361. 00 ). This deht is evidenced by Borrower's note dated the same date as this
Security Inslrument ("Note"). which provides for monthly paymen:ls, with the full debt, ifno! paid earlier, due
and payable on JUNE 15, 2013 . This Security InslriJment secures 10 Lender: (a) the repayment
of the debt evidenced by the ~ote. with interest, and all renewals', exlens!nns and modifications of the Note;
(b) the payment of all other sums, with interest. advanced under paragraph 7 to protect the security of this
Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security
Instrument and the NOle. For this Purpose. Borrower does hereby mortgage, grant and convey to l.ender the
following described property located in CUMBERLAND. County', Pennsylvania:
.
. and whose address is
which has the address of 154 WEST MIDDLESEX DRIVE
[1!) If this box is checked see Schedule A annexed hereto and made a part hereof.
CARLISLE
(City]
[Stre"l
,Pennsylvania 17013
[Zip Cooc]
("Property Address");
PENNSYLVt\:"I;1,4A;ingle Famity.Fannle MaeIFrcdle 'Wac U~IFOR.l\t Vl'STll~~fE~T
lIC3039A.PA.'\1 (fIR. :zJ2J98)
BC1od4S2 rAGE .350
ALMU
.'OIlM ]039 9190 ~(! J of9 pi'J!,'t.~)
. ~
~ " on,
'~""\l$t!i"-~,i'o:'" ~
TOGETHER WITH all the improvements now or hereaner erected on the property, and all easements,
appurtenances, and fixtures now or hereafter a part of the propert). All replacements and additions shall also
be covered by this Sec,urity Instrument. All of the foregoing is re"erred to in this Security Instrument as the
lIProperty. "
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has
the right to mortgage, grant and convey the Property and that rhe Property is unencumbered, except for
encumbrances of record. Borrower warrants and will defend generally the tille to the Property against all claims
amI demands, subject to any encumbrances of record.
THIS SECL:RlTY INSTRUMENT combines uniform cc,venants for national use and non-uniform
covenants with limited variations by jurisdiction to constitute a uniform security instrument covering rcal
property.
UNIFORM COVENANTS. Borrower and Lender eovem,nt and agree as follows:
1. Payment of Principal and Jnterest; Prepayment and Late Charges. Borrower shall promptl)' pay
when due the principal of and interest on the debt evidenced by the' Note and any prepayment and latc charges
due under the Note.
2. Funds for Taxes and Insurance. Subject to applicable law or to a written waiver by Lender,
Borrower shall pay to Lcndcr on the day monthly payments are due under the :>rote, until the NOle is paid in
full, a sum ("!'unds") for: (a) yearly taxes and assessments which may attain priority over this Security
Instrument as a lien on the Property; (b) yearly leasahold payments or ground rcnts on the Propcrty, if any:
(c) yearly hazard or property insurance premiums; (d) yearly f1cod insurance premiums, if any; (e) yearly
mortgage insurance premiums, if any; and (f) any sums payable by Borrower to Lender, in accordance with
the provisions of paragraph 8, in lieu of the payment of mortgage insurance premiums. These items are called
"Escrow Items." Lender may, at any time, collecl and hold Funds in an amount not to exceed the maximum
amount a lender for a federally related mortgage loan may requir~ for Borrower's cscrow account under the
federal Real Eslate Settlement Procedures Act of 1974 as amcndcc, from time to tirae, 12 V.S.C. Section 2601
et seq. (''RESPA''), unless another law that applies 10 the Funds sels a lesser amount. If so, Lender may, at any
timc, collect and hold Funds in an amount not to exceed tho lesser amollnt. Lend"r ma)' estimate the amount
of Funds due on the basis of ourrent data and reasonable estimate:; of expenditures of fulurc Escrow Items or
otherwise in accordance with applicable law.
The Funds shall be held in an institution whose deposits are insured by a federal agency,
instrumentality, or entity (including Lender, if Lender is such an institution) or in any Federal Home Loan
Bank. Lender shall apply the Funds to pay the Escrow Items. Lender may no1 charge Borrower for holding
and applying the Funds, annually analyzing the escrow account, 0:' verifying the Escrow Items, unless Lender
pays Borrower Intere5t On the Funds and applieablc law permits Lender to make such a charge. However,
Lender may require Borrower to pay a one-time charge for an independent real estate tax reporting service used
by Lender in connection with this loan, unless applicable law provides otherwise. Unless an agreement is made
or applicable law requires interest to be paid, Lender shall nul be required to pay Borrower any intercst or
earnings on the Funds. Burrower and I.ender may agree in writing, however, that interest shaU be paid on the
Funds. Lender shall give to Borrower, without charge, an annual a;counting of the Funds, showing credits and
debits to the Funds and the purpose for which each debit to the Funds was made. The Funds are pledged as
additional security for all sums secured by this Security Instrument.
If the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shaU
account to Borrower for the excess Funds in accordance with the rl:quirements of applicable law. If the amount
of the F\mds held by Lender at any time is not sufficient to pay the Escrow Items when due, Lender may so
notify Borrower in writing, and, in such case Borrower shall pay to Lender thc ammmt necessary to make up
the dcficiency. Borrower shall make up the deficiency in no more than twelve monthly payments. at Lender's
sole discretion.
P":ri~S'\'L"AN1A.5tngle Fl1mil)'.Fannic MaelFrtdte Ml!l~ UNIFOR~ ISS'l'R1..,,)IE:'IIT
lTGJ0J9A.PAM (lIB ZJ:2J!;I8)
LOAN ID: 0800878969
AlMV 100llM 3039 9190 (pciR~ 1 r)j 9 PIIJ,CI!.fj
Bvud462rAcr .351'
-
. ,
"""IF.!ItW.1-'''!;;,i,",,~",'i' ,
Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund
to Borrower any F\mdS held by Lender. If, under paragraph 21, :Lender shall acquire or sell the Property,
Lender, prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at the time of
acquisition or sale as a credit against the sums secured by this Security Inslrurnent.
3. Application of Payments. Unless applicable law pro, ides otherwise, all payments received by
Lender under paragraphs I and 2 shall be applied: first. to any prepayment charges due under the Note; second,
to amounts payable lInder paragraph 2; third. to interest due; fOll:'lh, to principal due; and last, to any late
charges due under the Note.
4. Charges; Liens. Borrower shall pay all taxes, aSSI'ssments, charges, fines and impositions
attributable to the Property which may attain priority over this Se';urity Instrument, and leasehold payments
or ground rents, if any. Borrower shall pay these obligations in the manner provided in paragraph 2, or if not
paid in that manner, Borrower shall pay them on timc directly to the person owed payment. Borrower shall
promptly furnish to Lender all notices of amounts to be paid under this paragraph. 1 r Borrower makes these
payments directly, Borrower shall promptly furnish to Lender rccdpts evidencing the payments.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation ,ccured by the lien in a manner acceptable
, to Lender; (b) contests in good faith the lien by, or defends 19ainst enforcement of the lien in, legal
proceedings which in the Lender's opinion operate to prevent the enforcement ofllle lien; or (c) secures from
the holder of tbc lien an agreement satisfactory to Lender subordinating the lien to this Security Instrwnent.
If Lender detennines that any pari of the Pnlperty is sobjeet to a lien which may attain priority over this
Security Instrument. Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien
or take nne or more of the actions set forth above within 10 days of the giving of notice.
5. Hazard or Property Insuranee. Borrower shall keep tile improvements now existing or ilercafter
erected on the Property insured against loss by fire, hazard, includ'ld within the term "extended coverage" and
any other hazards, including floods or Hooding, for which Lender requires insurance. This insurance sball be
maintained in the amounts and for the periods that Lender requires. The insurance carrier providing the
insurance shall be chosen by Borrower subject to Lender's approval which shall nol. he unreasonably withheld.
If Borrower fails to maintain coverage described above, Lender may, at Lender's option, obtain coverage to
protect Lender's rights in the Property in accordance with paragraph 7.
All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage
clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Rnrrower shall
promptly give to Lender all receipts of paid premiums and renewal notices. Tn the event oftoss, Borrower shall
give prompt notice to the insurance carrier and Lender. Lender mE.y make proof of loss if not made promptly
by Borrower.
Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to
restoration or repair of1he Property damaged, if the restoration or repair is economica.lIy feasible and Lender's
security is notlcssened, If the restoration or repair is not eeonomit:ally feasible or Lender's security would be
lessened, the insurance proceeds shall be applied tu lhe sums secured by this Security Instrument, whether or
not then due, with any excess paid to Borrower, I f Borrower abanc:ons the Property, or does not answer within
30 days a notice from Lender that the insurance carrier has oITered to settle a claim, then Lender may collect
the insurance proceeds. Lender may use the proceeds to repair or restore the Prup':rty or to pay sums secured
by this Security [nstrument, whether or not then due. The 30-day period will begin when the notice is given.
Unless Lender and Borrower otherwise agree in writing, eny application of proceeds to principal shall
not extend or postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the
amuunt of the payments. If under paragraph 21 the Property is a';quired by Lender. Burrower's right to any
insurance policies and proceeds resulting from damage to the Pr,)perty prior 10 (he acquisition shall pass to
Lender to the extent of the sums secured by this Security Instrument immediately prior to the acquisition.
PI':NNSYLVA:"IlIA.Sinlilc Fllll1ily-FRRnie Malre/Fredlc )tile U:"IIJFOR." INSTRt:.\IEXf
:'v1HltlJlJ..\.rA)1 (Ira :Z111'98)
LOAN 1D: 0800878969
ALMi~ FORM 3039 9191) (pu~1l J q(9 ptJKu)
1l0u~1462rAG[ ~52
"'". ~
u-
'~"''''""
6. Occupancy, Preservation, MaIntenance and Protection of the Property; Borrower's Loan
Application; baseholds, Borrower shall occupy. establish, and lse the Property as Borrower's principal
residence within sixly days after the execution of this Security Im,trument and shall continue to occupy the
. Propert)' as Bortower's principal residence for at least one year after the date of occupancy, unless Lender
otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating
circumstances e"ist which are beyond Borrower's control. Borrow,,, shall not destroy, damage or impair the
Property, allow lhe Property 10 deteriorate, or commit waste on th" Property. Borrower shall be in default if
any forfeinlre action or proceeding, whether civil or criminal, is bl:gun that in Lender's good faith judgment
could resull in forfeiture of the Property or otherwise materially impair the lien created by this Security
Instrument or Lender's security interest. Borrower may cure SUl,h a default and reinstate, as provided in
paragraph 18, by causing lhe action or proceeding to be dismissed with. ruling that, in Lender's good faith
determination, precludes foneilIlre of the Borrower's interest in tho: Property or other material impairment of
the lien created by this Security Instrument or Lender's security interest. Borrower shall also he in default if
Borrower, during the loan application process, gave materially false or inaccurate information or stalements
to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced
by the Note, inClUding, but not limited to, representations concerning Borrowcr's occupancy of the Property
as a principal r~sidence. If this Security rnstrUment is on a le.sehold, Borrower shall comply with all the
provisions of the lease, If I:lorrower acquires fee litle to the Propelty, the leasehold and the fee title shall not
merge unless Lender agrees to the merger in writing.
7. Protection of Lender's Rights in tbe Property. If Be,rrower fails to perform the covenants and
agreements contained in this Security Instrument, or there is a Icgal proceeding that may significantly affcct
Lender's rights in lhe Propcrty (such as a proceeding in bankrupt"y, probate, for condemnation or forfeiture
or to enforce laws or regulations), then Lender may do and pay for whatever is necessary to protect the value
of the Property and Lender's rights in the Property. Lender's aetinns may include paying any sums secured
by a lien which has priority over this Security Instl'Ument, appearinll in court. paying reasonable attorneys' fees
and entering on the Prnperly to make repairs. Although Lender ma)' take action under this paragraph 7. Lender
does not have to do so.
Any amounts disbursed by Lender under this paragraph 7 shall becume additional debt of Borrower
secured by this Security Inslrument. Unless Borrower and Lend,:r agree to other terms of payment, these
amounts shall bear interest from the date of disbursement at the Note rate and shall be payable, with interest,
upon notice frolll Lender to Borrower requesting payment.
8, Mortgage Insurance. If Lender required mortgage imurance as a condition of making the loan
secured by this Security Instrument, Borrower shall pay lhe premiullls required to maintain the mortgage
insurance in effect. If, for any reason, the mortgage insurance coverage requircd by Lender lapses or ceases
to be in effect, Borrower shall pay the premiums required to obulin caverage substantially !?<jui"alent to the
mortgage insurance previously in effect, at a cost substantially equivalent to the cost 10 Borrower of the
mortgage insurance previously in effect, from an alternate mortgage insurer approved by Lender. If
substantially equivalent mortgage insurance coverage is not availab ,e. Borrower shall pay to Lender each month
a sum equal to one-twelfth of lhe yearly mortgage insurance prcmium being paid by Borrower when the
insurance coverage lapsed or ceased to be in effect. Lender will ae"ept, use and retuin Ihese payments as a loss
reserve in lieu of mortgage insurancc. Loss reserve payments may no longer be required, at the option of
Lender, if mortgage insurance coverage (in the amount and for tt.eperind Ihat If,nder requires) provided by
an insurer approved by Lender again becomes available and is (,btained. Borrower shall pay the premiums
reqoired to maintain mortgage insurance in effect, or to provid: a loss reserve, until the requirement for
mortgage insurance ends in accordance with any written agreement between Borrower and Lender or applicable
law.
9. Inspedion. Lender or its agent may make reasonable entries upon alld inspections of the Property.
Lender sball give Borrower notice attbe time of or prior to an imipection specifying reasonable cause for the
inspection.
n;:'!1XSYLYAr\IA-Slngle (Inmily.Fllnnill M:...cfFrctlle Mile UNIFOltJ\oIINSTRt'l\U:ST
:\lG303I)A.PA.:\1 (lIR 2/1/'JR)
LOAN 1D: 0800878969
ALMX. fO'RM 3039 9190 (PUw oJ rif 9 page!!;)
Boud462fAGE i353
--:
"--~~ "~.> ~.o~_~.~, 1 '1
"
-.'.
tJti\,;1lAAffi,-"
10, Cond~mnAtlon. The proceeds of any award or clair' for damages, direct or consequential, in
e,onneetion wilh any condemnation or other taking of any part of the Property, or for conveyance in lieu of
condemnation, are hereby assigned and snail be paid to Lender.
In the event of a total taking of the Property, Ule proceeds shall be applied to the sums seeured by this
Security [nstrument, whether or not then due, with any excess paid 10 Borrower. In the event of a partial taking
of ,he Property in which Ihe fair market value of the Property immediately before the taking is equal to or
greater than the amount of the sums secured by this Security Instrumcnt immcdiatoly before the taking, unless
Borrower and Lender otherwise agree in writing, the sums secured 'IY this Security '-nstrument shall be reduced
by the amount of the proceeds multiplied by the following fraetio:l: (a) the total amount of the SUITIS secured
immediately before the taking, divided by (b) the fair market value of Ihe Property immediately berore the
taking. Any bal.ance shan be paid \0 Borrower. III the event ofa partial taking of the: Property in which the fair
market value of the Property immediately before the taking is les:; than thc amonnt of the sums secured im.
mediatcly bcfore the taking, unless Borrower and Lender otherwi~e agree in writing or unless applicable law
otherwise provides, the proceeds shall be applied to the sums secued by this Security Instrument whether or
not the sums are then due.
If the Property is abandnned by Borrower, or if, afte', notice by Lender to Borrower that the
condemnor offers to make an award or scttle a claim for damages, Borrower fails to respond to Lender within
30 days after the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option,
either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or
not then due.
Unless Lender and Borrower otherwise agree in writing, alY application of proceeds to principal shall
not extend or postpone the due date of the monthly payments refe'cred to in paragraphs 1 and 2 or change the
amOUnt of such payments.
11. Borrower Not Released; Forbearance By Lender Not a Waiver. F.xtensinn ur the time for
payment CJT modilication of amortization of the sums secured by ':his Security Instrument granted by Lender
to any successor in interest of Borrower shall not operate to rclcf,se the liability of the original Borrower or
Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor
in imerest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this
Securit)' instrument by reason of any demand made by the original Harrower or Borrower's successors in
interest. Any forbearance by Lender in exere,ising any right or remedy shall not be a waiver of or preclude the
exercise of any right or remedy.
12. Sueeessors and Assigns Bound; Joint aud Several Liability; Co.slgners, The covenants and
agreements of this Security Instrument shall bind and benefit Ihe successors and assigns of Lender and
Borrower, subject to the provisions of paragraph 17. Borrower's covenants and agreements shall be joint and
several. Any Borrower who cn-signs this Security Instrument but docs not exec,ute the ,,"ate: (a) is co-signing
this Security Instrument only to mortgage, gram and convey that Borrower's interest in the Property under the
terms of this Security Instrument; (b) is not personally obligatec. to pay the SUITIS secured by this Security
Instrument; and (c) agrees that Lender and any other Borrower m,y agree tu exloml, modify, forbear or make
any accommodations with regard to the temlS of this Security lust'ument or the Note without that Borrower's
consent.
13, Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets
maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected
or to be collected in connection with the loan exceed lhe permittee limits, then: (a) any such loan charge shall
be reduced by the amount necessary to reduce the charge to the per mined limit: and (b) any sums already
collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose
to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower.
If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment
charge under the Note. .
PE~J"i5YI.\''\l'iIA-Single Fnmil)'-Fallnie MacIFredle Mile D.fFORM IT'iSTRt;J\.lENT
MG3l)39A,P,4.M (ilK 111198)
LOAN 1D: 0800878969
AIHY FORM J03~ 9190 (puf{e 5 vIi) f1U/f",rj
BOiJl1462r~[ ~54
~ c
~.
"!;;~,"<N>.l,_
14. Noti"e., Any notice to Borrower provided for in this Security Instrument shall be given by
delivering it or by mailing It by first class mail unless applicable law rcquires use of another method. The
notice shall be directed to the Property Address or any other addres~, Borrower designates by notice to [.ender.
Any notice to Lender shall be given by first class mail to Lender's address slated herein or any other address
Lender designates by notice to Borrower. Any notice provided for Inlhis Security lnstrument shall be deemed
to have been given to Borrower or Lender when given as provldee; in this paragraph.
15, Governing Law; Severability. This Security Instrument shail be governed by federal law and the
law of the jurisdiction in which the Property is located. In the event that any provision or clause of this
Securit), Instrument or the Nole conflicts with applicable law, such contlict shallllot affect other provisions
of this Security Instrument or Ihe Note which can be given effect without the conflicting provision. To this end
the provisions of this Security Instrument and the Note are declar"d to be severable,
16, Borrower'~ Copy, Borrower shall be given one confollncd copy of Ihe Note and of this Security
Instrument.
17. Transfer ofthe Property or a lleneficiallnterest in Horrower.lf all or any part of the Property
or any interest in it. is sold or transferred (or if a beneficial imerest in Borrower is sold or transferred and
Borrower is not a natural person) wilhout Lender's priur written (;onsent, Lender may, at its option, require
immediate payment in full of all sums secured by this Security Inslrument. However, this option shall not be
exercised by Lender if exercise is prohibited by fcdcrallaw as of 'I he date of this Security Instrument
If Lender exercises this option, Lender shall give Borro",er notice of accelcrat.ion. The notice shall
providc a period of not less than 30 days from the date the notice is lelivered or mailed within which Borrower
must pay all sums secured by this Securily Instrument, If Borwwer fails to pay thcse sums prior to the
expiration of this period, l.ender may invoke an)' remedies permitted by this Securily Instrument withoul
further nolice or demand on Borrower.
18. Borrower's Right 10 Reinstate. If Borrower meets certain conditions, Borrower shall have Ihe
. right to have enforcement of this Security Instrumem discontioued lIt any time prior to the earlier of: (a) 5 days
(or such olher period as applicable law may specify for reinstatem"nt) before sale of the Property pursuant to
any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security
Instrument. Those conditions arc that Borrower: (a) pays Lender all sums which then would he due under this
Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other
covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but
not limited to, reasonable .uorneys' fee~; and (d) takes such aclion as Lender may reasonably require to assure
that the lien of this ~ecurity Instrument, Lcnder's rights in the Property and Borrower's obligation to pay the
sums secured by this Security Inslrument shall continue unchan~;ed. Upon reinstatement by Borrower, Ihis
Security Instrument and the obligations secured hereby shall remain fully effectiye as if no acceleration had
occurred. However, this right to reinslale shall not apply in the c,sc of acceleration under paragraph 17,
19, Sale of Note; Chauge of Loan Servlcer, The Note or a partial interest in the Note (together with
this Security instrument) may be sold one or more times withoutllrior notice to Borrower. A sale ma)' result
in a change In the entity (known as the "Loan Servicer") that collects monlhly payments due under the Note
and this Security Instrument. There also may be one or more changes of the Loan Servicer unrelated to a sale
ofthe Note. If there is a change of the Loan Servicer, Borrower will bc given written notice of the change in
accordanc,e with pa,rat,,'raph 14 above and applicable Jaw. The nolic,) will state the name and address of lhe JleW
Loan Servicer and the addrcss to which payments should be made. The notice will also contain any other
infonnalion required by applicable law.
20. Hazardous Substances, BOlTower shall not cause or permit the prcsence, use, disposal, storage,
or release of any Hazarduus Substances on or in the Property. B<,rrower shall not do, nor allow anyone else
to do, anything affecting the Property that is in violation of any Environmema( Law. The preceding two
sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous
Substances that are generally recognized to be appropriate 10 norm II residential uses and to maintenance of the
Property.
PI,1":SSYLVANIA.Sinijlc Family-Fannie MaetFrcdl~ M:II: ['NIFORI\-IINSTRtlI\U~~T
MG3OJ9A.PAM (IlK 1JZi9M)
LOAN ID: 0800878969
ALMZ FORM ltJ:J9 9190 {flUMe IS of9 P<lXl1,t)
Bood462 PAGE.355
"~H~~
,,~
_--to: ,-
, '- ~ ~;;!~06~ '
I
Borrower shall promptly give Lender wrinen notice of any investigation, claim, demand, lawsuit or
other action by any governmental or regulatory agency or priv~te party involving the Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or
is notitied by any governmental or regulatory authority, that Iny removal or other remediation of any
Hazardous Substance affecting the Property is necessary, Borrowel' shall promptly take all necessary remedial
actions in accordance with Environmental Law.
As used in this paragraph 20, "Hazardous Substances" arc those substances defined as toxic or
hazardous substances by Environmental Law and the following subl,tances; gasoline, kerosene, other flammable
or toxic petroleum products, toxic pesticides and herbicides, vola\i1e solvents, materials containing ashestos or
formaldehyde, and radioactive materials. As used in this paragraph 20, "Environmental Law" means1'ed~ral
laws and laws of the j\lrisdiction where tile Property' is located that relate to health, safety or environmental
prutection.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
21, Acceleration; Remedies, Lender shaH gIve notice to Borrower prim' to aeeeleratloD following
Borrower's breach of any covenant or allreement in tbi. Seenrity lnstrnment (hut not prior to
acceleration under paragraph t 7 unless applicable law provides otherwise). Lender shaH notify Borrower
of, among otber things: (a) the default; (0) the action required to cnrc the default; (c) wben the default
must be cured; and (d) that failure to Cnre the default as specilled may resnlt in acceleration oC the sums
secured by this Security Instrument, forclasure b)' judicial proceeding and sale of the Property. Lender
shaH further inform Borrower of Ihe right to reinstate after acceleration and the right to assert in Ihe
foreclosure proceeding the non-exislence of a deCault or any other defense of Borrower to acceleration
and foreclosure. If the default is not cured as spctitied, Leneler at its option ma)' require immediate
payment in full of 011 sums secured by this Security Instrument without further demand and may
foreclose this Security Instrument by judlelal proceeding. unCler shall he entitled to collect all expenses
incurred in pursuing the remedieslJrovlded In this paragraph 2'1, including, but not limited to, attorneys'
fees and costs of title evidence to the extent permitted by applicable law.
22, Release. Upon payment of all sums secured by this S',curity Instrument, this Security Instrument
and the estate conveyed shalllerminate and become void, After s'Jch occurrence, Lender shall discharge and
satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation cosls.
23. Waivers. Borrower, to the extent pemlitted by applkablc law, waives and releases any error Or
defects in proceedings to enforce this Security Instrument, and hereby waives the henefit of any present or
future laws providing for stay of execution, extension of time, exemption from attlchment, levy and sale, and
homestead exemption.
24. Reinstatement Period. Borrower's time to reinstate provided in paragraph 18 shall extend to one
hour prior to the commencement of bidding at a sherifrs sale or other sale pursuant to this Security Instrument.
25. Purcbasc Moncy Mortgage. I f any of the debt see Jred by this Security Instrument is lent to
Borrower to acquire title to the J>roperty, this Security Instrumenl shall be a purchase money mortgage.
26. Interest Rate After Judgment. Borrower agrees that the inlerest rate payable after a judgment
is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under
the Note.
27, Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded
together with this Security Instrument, the covenanls and agreements of each such rider shall be incorporated
into and shall amend and supplementtbe covenants and agreement!,nfthis Security Instrument as if the rider(s)
were a part of this Security Instrument.
PEN~SllLVAril"-Singk famil)'.YaJlnit Matl[i'redle "be lII'HFOR)! INSTRUI\IE"'Y
:'\1GJ039A.PAM (IIR If.ZI9S)
LOAN ID:0800878969
ALNA FORM JOJ!' !ilNU {ptl/{t .. 0[9 f'(1~l?!I)
BOOK14621'AGE 0356
-
L '" ~
~'-',;- --,
,. ,
-~-~~j&",,,';<'
[Check applicable box(es)]
o AdjuSlable Rate Rider
o
o
IKJ
Balloon Rider
o Condominium Rider
o
~
o 1.4 Family Rider
Graduated Payment Rider
Planned Unit Developme:1t Rider 0 Biweekly Payment Rider
Rate Improvement Rider
o Second Home Rider
Other(s) [specify] ADDENDUM(S)
BY STGNING BELOW, Borrower accepts and agrees to the terms and l:ovenants contained in this
Security Ins1rument and in any rider(s) executed by Borrower and recorded with it.
Wq L( !lfef!ad:-
~B~~ f ~'I.
(Seol)
Bmmwer
(Seal)
Borrow!:'"
(Seal)
Dorrowcr
(Se.l)
BOrTowcl'
(Seol)
Rnmlwcr
(Seal)
Borrower
o
Witness my hand this
/0 ft
.
-
. do hereby certify t.hat the
9 '-I-Wh"'~ ~ """~ t"l.M~
.~~ . 1"'1<; rl. ~-(J~ I
~ cl",
;'1 '1$ .
'/~-'/~-'
9- Agent of Mortgagee
day of
J~
P'ENNSYLVAJ\;'IA-Single family-FAllnie l\Ia~redle )b~ UNIFORM INs"rRUI\IJ::N'1'
I\tG3U3'A.PAM (IIR 212198)
LOAN ID:0800878969
AUIB FORM Jon 9190 (Jl".~t ,y aff) ~,f)
,llouK1462 PAGE 1357
, ~-,-,.
"
," ...;-'
-'--'-~'lWr;-,
COMMON\'I1EALTH OF PEN~SYLVANIA, otlMllER'l::ltND ~fk. County 55:
..Qn this, thc f(')L. _ day of TulU G /CJ'18, before me,
-~ Y1 I? ~,..... J.. ~ lh, ullder_igned officer, personally appeared
jl4'7.1:~/b~ t.A tJ 14 ~t/r.t.'~. J
known to me (ur satisfactorily proven) to be the person(s) whose name(s) ~
sub5Cribed 10 the within instrument and
acknowledged that 5'U executed lhe same for the purpos~s herein conta.ined.
IN WI~ESS WHEREOF, I hereunto _et my hand a.nd official seal.
My Commission expires:
" NOlana' S.al
John R, aelnhsur, NoWJY Public
Hamp<lon Twp. Cum~rl8l'1d Coun1\!
My Comml"lon ilxpll.. March IS, 1999
~LiJ.fLJ:'p/AAA:.
~~~ (JJ....V..A.ht,
Title of' Orne
.\'......Jti~~,~" ~
.' -,....~, ",,:
.' ~;'~,~'Ii;;p".;.,,; ,
't-",."~ ~~"'iI .~,.
. 'v," 'J1.~""".., ...J.,. '..',
.;' ~:"'..~. ',~~"',1;':" ',\
< ,'>I ....,/;"",..(1,,,.. ",.' '..'
'",:: "-'~ .~..~,!ll\I'f..~~:...!;;~I,~'.....
,:';;;.:: "'lJ.:.~:':~::J;:.\.'$',....',;..." '",J+.'.
.. "' "J.~.,,, ..;:.. -~,~.); "i,,~',,'\'"'' .-,.~~.
. ~.r'.:~!.~f,;~~?";~:'::f~~~ f"
-.:.!;:' icrt;~~:: :~ .t/i'.~:( !;t ';,; (':1 .;:):
;, 1- " , .."I' ;;;-:;~"",-), 't' ""''l " ,
'S,,"~,,......,;.. ,i: ::tP.i\':'" 'U~,,(~.;
,'~ -"'1> '~"""~~1Itl~"I"''''~'' ::.tt;,;'.,:
'~'V' .."~' a 'tilt ~
..,:....\ 1f,J,' ,.11", ~' ~'\~'~. ..-\.'l!""'~~
...".,,,"~" '. iOl\"~
'~l,;~:/' ."" , ~.j'.
,#I,llH'p,t-JOo l'Ii" ,.
AFTER RECORDING RETUlm TO:
SUPERIOR BANK FSB
135 CHESTNUT RIDCE F:OAD
MONTVALE NJ 07645
ATTN: RECDRDED DOCUHF.NTS DEPT.
LOAN 1D:0800878969
~ T 't"",
JILL TIM CEI'fflUN piece or parcel of land with iIrprovanents thereon erected,
situated in the Township of Middlesex, County of CUlr!:>erland, Pennsylvania,
bounded and described as follCMEl:
BEGINNIN3 at a pin on the Southe;rn side of North Middlesex Drive ('1'-499) at
the dividing line between Lots Nos, 1 and 2, as shcMn on the hereinafter
mentioned Plan of Lots; thence aloog said dividing line between said IDts Nos,
., __-' '" 1f'l.....,..r..'L...,.,. .:1____ Ul'__'" _..t': ,..1-""........... ,..OF 1 ",;qc:;. -F~ i-,." eo ....-:. n .Q~ t-ho::.. 1; nA f"1-F
.".
,~"
" .
~' 'I~,: j,
"
, , ~
'-~~<,;
ALL THAT CERrAIN piece or parcel of land with iIrprovElIlimts thereon erected,
situated in the Township of Middlesex, COUnty 0:: CWdJerland, Pennsylvania,
bounded and desaribed as follows I
EEGINNThG at a pin on the SCRJthem side of North Middleaex Drive (T-499) at
the dividing line between lots Nos. 1 and 2, as shcMn on the hereinafter
mentioned Plan of IDtsi thence along said dividi.ng line between said lots Nos.
1 and 2, South 17 degrees West, a distance of 1:75 feet to a pin at the line of
lands of Ruth A. Clemson; thence along said lin9 of lands of Ruth A, Clemson,
South B2 degrees 42 minutes 20 secoods East a d;lst.ance of 100 feet to a pin at
line of lands of RayIoond Slqyseri thence along s,aid line of lands of Raynond
SlrJYser, North 11 degrees East, a distance of 17.5 feet to a pin on the Southern
side of North Middlesex Drive (T-499) first men:t.ioned above; thence along said
Southam side of North Middlesex Drive (T-499), North B2 degrees 42 minutes 20
se:::onds West, a distance of 100 feet to a pin on the'lOi!IIlEl at the dividing line
between IDts Noll. 1 and 2 as shcMn on the ha:rei,nafter l11E!I1ti.oned Plan of Wts,
the point and place of BE:GINNING. '
BEING Lot No, 1 as shcMn on the Subdivision plan of Property for Ruth Clemson
as prepared by Ernest J, Walker, Professional Engineer, on 4/24/1972 and
recorded in the Office of the Recorder of Deeds in and far CUmberland County,
Pennsylvania, in Plan Book 23 Page 109.
BEING ~ with a dwelling house kncMl1 as 154 West Middlesex Drive,
Carlisle, PennS1lvania,
P~~: 21-06-0017-020A,
BElING the sana premises which James F, GoocIrMn and Barbara A. Goodmah, husband
and wife by Indanture dated Janua:cy 31, 1996 and recorded in the Office of the
Recorder of DeedE; in and for the County of Cuni;erland in Deed Book 134 Page
753, granted and conveyed Wlto Mar.ibeth ChIldyk.
Bood462FAG( .359
to"
~~ _. J'
ACCOUNTjl :080087 8969
AQ,DENDUM T~ORTGAGE/DEED OF TRUSTI
DEED TO SE RE DEBT/SE<:;URITY DEED
This ADDENDUM TO MORTGAGEIDEr:.D OF TRUSTIDEED TO
SECURE DEBT/SECURITY DEED (also known as "Security Instrument") is made
this 10th day of JUNE , 1998 , and is incorporated into and
amends the Security Instrument of the same date given by the undersigned (the
"Borrower") to secure Borrower's Notc (the "Note") 10
Alliance Funding Company, Division of Superior Bank FSB
(the "I.ender") of the same dale and covering the Property described in the Security
I nstrument and loeatcd at:
154 WEST MIDDLESEX DRIVE, CARLISLE, FA 17013
(Property Addrc,s)
In addition to lhe covenants and agreements made in the Seeur'.ty Instrument,
Borrower and Lender further agrec as follows:
1. The paragraph of the Security lnstrument entitled, "Application of
Borrower's Payments" or alternately "Application of Payments," is
deleted in its entirety and the application of payments is governed by the
Note.
2. Unless prohibited by applicable Jaw, lhe paragraph of the Security Instrument
entitled, "Acceleration; Remedies" or alt~;mately "Lender's Rights if
Borrower Fails to Keep Promises and Ali:rcerncnts," is supplemented by
adding the following provisions:
"Additionally, Lender may require immediat~ payment in full of the entire
amount remaining unpaid under the Note and this Security Instrument, if:
(1) On application of Lender, two or more insurance companies
licensed to do business in the State in which the Property is located, refuse
to issue policies insuring the buildings and improvements on the Properly;
or
(2) Borrower fails to make any payment required by a senior
mortgage, deed of trust, deed to secure debt or other security instrument
encumbering or affecting Ole Property or fails to keep /lny other promise or
agreement in any senior mortgage, deed oftrLlst, deed to secure debt or olher
security instrument encumbering or affecting, the Property; or
(3) Any representation made or information given to Lender by
Borrower in connection with Borrower's api,lication for the loan evidenced
by the Nole is false or misleading in any m!.terial respect; or
(4) Borrower allows the Property to b. used in conn"ction with any
illegal activity."
MlJlTISTA1E ADDENDUM TO lST{2KD
Th'MAffHI.MC SECURITY lNSTRUMEN1
SUPERIOR (3/27198). SHORT fORM
MICN
AMGOl4a,USM
pAGE 1 OF5
BOud462PACE .JiSO
1.L:..,_ti,,,_
~"
"
~-', ~~'O""'""'-'l-r
:.J:j' """'-<,
3. for a loan ,ecured by Iowa real property:
a. The following sentence is added to the end of the paragraph of the Security
lnstrument entitled, "Release" or alternately ":Redemption Period:"
"Borrower shall pay any record"lion and/or official costs in connection with
this mortgage."
b. Language is added to the Security instrument as follows:
"NOTICE TO BORROWER
I UNDERHAND THAT HOMESTEAD PROPER1Y IS IN MANY CASES
PROTECTED fROM THE CLAIMS Of CREDITORS AND EXEMPT FROM
JUDICIAL SALE; AND THAT BY SIGNING THIS MORTGAGE, 1
VOLUNTARILY GIVE UP MY RIGHT TO THl~, PROTECTION FOR THIS
MORTGAGED PROPERTY WITH RESPECT TO CLAIMS BASED UPON Tl-HS
MORTGAGE."
4. The paragraph of the Security Instrument entitled, "Transfer of the
Property or a Benenciallntere.t In Borrower," j. amended by changing
the notice of default or aceeleration to be at least 60 days if the loan is
secured by a secondary lien 011 real property in the State of Conneeticut and
at least 3S days if the loan is secured by a lien on feal property in the State
of Oklahoma.
5. For a loan sccured by Kansas real property, if the Security Instrument is
form 30] 7, the last senlence ill the pllra8raph entitled, "Acceleration;
Remedies," is deleted and replaced with tlte following:
"Lender sball be entitled to collect all realonable expenses Incurred in
pursuing the remedies provided In this paragraph, including but not
limited to, reasonable attorneys' fees, to tltl: extent allowed by applicable
law."
In addition, the paragraph entitled, "Attorneys' Fees," is deleted in its
entirety.
6. for a loan secured by Ohio real property, the following language is added
after the legal description .ection of the Security Instrument:
"This mortgage is given upon the statutory ccndition'. "Statutory Condition"
is defined in Section 5302.14 of the Revised Code and provides generally
that if Borrower pays the indebtedness and performs the other obligations
secured by this mortgage, pays all taxes and a,;sessments, maintains insurance
against fire and other hazards and does not commit or permit waste" tlten this
mortgage will become null and void."
MULTISTATE ADDENDUM TO 1S'TI2NIl
FNMAlFllLMC SECURITY tNSTRUMENT
SUFERJOR (3/27198). SIIORT FORM
LOAN 10#:0800878969
PAllE 2 OF S A.'lCO AMG014B,USM
Bood462,.u .361
.~
"
.
1 , .',
7.
For a loan secured by SOllth Carolina real ~mpcrty:
If the Security Instrument is Form 3041, the second sentence uf tbe
paragraph entitled, "Waivers," is deleted. If the Security Instrument is
Form 3841 the paragraph entitled, "Waiver of Right of Appraisal," is
deleted.
8.
The paragraph of the Security T nstrument entitled, "Law That Govern. Thi.
Seeurity InstrumentlMortgage" or alternately "Governing Law;
Severability," is amended by deleting the fir,a sentence and replacing it with
the following language:
"This Sceurlty Instrument shall be governed by federal law and, to the extent
not inconsistent with or more restrictive t.1an federal law or regulation
governing Lender, the laws of the juri"diction in which the Property is
located. '
9.
T f the Security Instrument is a second or junior priority Security Instrument,
then a paragraph is added to the Security Instrument as follows:
"W AJVER OF RIGHT TO INCREASE PRIORMORTGAGElDEEDOF
TRUST. Borrower hereby waives Borrower's rights if any, to increase any
senior deed of trust, murtgage or other security instrument 0(1 the Property
under any provision contained lherein gove~ting optional future advances,
and, to the extent pennitted by law, waives Borrower's rights under any law
which provides for an increase of said prior d ~ed of lrllst, mortgage, deed to
secure debt or other security instrument to pay for repairs, impro\'ements,
replacements, taxes, municipal liens, assessments or other charges on the
Property. If, notwithstanding the foregoing \V,liver, such funds are advanced
to' or on behalf of Borrower, whether volulltalily or involuotarily, Borrower
agrees that Lender, at its option, may aceelerate the iodebtedness secured
hereby,"
10.
A provision is added to tI1e Security Instrument as follows:
'Borrower hereby acknowledges receipt. without charge, of a true copy of
the Security Instrument." nn
Escrow Waiver L.:J
If the box above has been checked, Lender waives tile requirement for
florrQwer to make payment to Lender for the escrow items referred to in tile
paragraph of the Security Instrument entit"~d. "Funds for TlI",es lInd
IlIsurance." Borrower shall pay these obligaions on time directly to the
person owed payment. Borrower shall promptly fumish to Lcntler all notices
of amounts to be paid under this paragraph, ,tnd receipts evidencing such
paymen\.
II.
MULTIST....TE AODEND1JM TO ISTnND
F~IFHLMC SBCIiR tTY INsrRUMENT
SlJPERJOR (JI2719l!) . SI-lORT FORM
LOAN ID#:0800878969
PAGE J OF 5 AMCP AMG014B.T:SM
Boud462 >>G[ ~
~ ~
,
,_!l~
,
Unless othcrwise prohibited by applicable la,", Lender reserv'~slhe right to
require Borrower to make payment 10 Lender for the escrow items referred
to in the paragraph of thc Security Instrument entitled, "Funds for Taxes
and Insurance," if Borrower defaults in the payment of such escrow items
and such default is not cured within the lime set forth in any notice senl to
Borrower by Lcndcr. Lender reserves such rig,ht even though Lender did nol
establish such escrow account as a condition ':0 closing the Inan. If Lender
requires Borrower to muke payments to Lender as provided herein, the
provisions or lhe paragraph ofthe Security l~strumcnt entitled, "Funds for
Taus and Insurance" will be in tilll force and effect.
12. A paragraph is added to the Security Instrument as follows:
"FORCE PLACED INSURANCE. Unless otherwise prohibited by
applicable law, if Borrower does not prov ide Lender with evidence of
insurance coverage (for any type of insurance that is required by Lender),
Lender may purchase insurance at Borrower's expense to pmtecl Lender's
intereS1S in Borrower's Property. This insurance may, but need not, protect
Borrower's interests. The coverage that Lender purchases may not pay any
claim that Borrower makes or any claim that is made against Borrower in
conncction with the Property. Borrower may later cancel any insurance
purchased by Lender, but only after providing Lender with evidence that
Borrower has obtained lhe required insurance. If Lender purchases insurEll1ce
fur the Properly, Borrower will be responsible for the costs ofthat insurance,
including the insurancc premium, interest at the rate provided by the terms
of the Note and any other eharges that the Lender or the insurer may impuse
in connection with the placement of the insUl'ance (for example, a fee from
the carrier for processiag tile force placed ins'lrance), until the c!lective date
of the cancellation or expiration of the insurance. The costs of the insurance
may be added to Borrower's total ourstandir,g balance and secured by this
Security [nstrument. The costs may be more than tbe cost of insurance that
Borrower may be able to oblain directly becT'use Lender will be purchasing
insurance under a general policy that docs not consider Borrower's individual
insurance situation."
13. A paragraph is added to the Security Instrument as follows:
"Verification or reverification nf the ProP"rly's valuation or any other
information normally contained in an appraisal may be required as part of
Lenders's ongoing quality control procedures. Borrower agrees to cooperate
tillly with Lender and/or its agents, successors or assigns in obtaining and
compleling a full appraisal in the future at 1.ender's sole option and
expense.'1
MULTISTATe ADDENDUM TO ISTI1ND
FNMAfFHI.MC SECURITY INSTRUME.'IT
SUPERIOR (3/27/98) - SHUKT FORM
LOAN IDU:0800878969
PAGE 4 OF S AMCQ ^MGOI4B.USM
Bood462 PAGE .3i63
" ',," '-'",- ",', ~ ~''ililillii.1Mi!H!!'0-{
-- "~-
,
-
",
~"
,-,
, J>","""",lj;~"':
14. If an Adjustable Rale Rider is executed in conjunction with the Security
Instrument, such rider is amended by deleting t~e Section entith:d, "Transfer
of the Property or a Benefieiallnterest in Horrower."
15. If the Security Instrument is assigned or tramferred, all Or a portion ot'thls
Addendum may be voided at the option of th,: assignee Or transferee. Any
terms and provisions of this Addendum whic!t are voided will be governed
, by the original terms of the Security InstfL,mllnt.
YUJui&L (314:-';-(
MARI,BETH CHUOYK
!:\Qrrowcr
harrower
Borr()wer
MULTtSTATaADDENDU~ TO ISTJ2ND
F~MAIFHL.\1C SECURITY INSTRIJMDlT
SUPERlOR (3/27/98) - SHORT FORM
.' ";',~.,'c..i.t
'~il:::"""'h
~.:rt4 ~\J_M-n '"', k. ,,'.~
.r'J'!<e,r;;""ff",."'~"r.,,' .."
~Y.:;f<(}..~~'~,i":;'" 'c"":. t ,..,
/N/~~~W1:~,r~'fo " ~"'t'I..
.:y:'.'": '~?;.',J , \1.'5~
, f!(i9..M~f! *':, ~~.~f\";1t~
.f.'....,fj!f,'f~. ~ ~"?~"'&.;' :A.\l'~t;:,:j
.if~~:t~1 !>'~~:~:t~t.;
'-''P:, ....:: )l':\)', .t!!s;~;;~.1i"n~.': :~'"', ,,'
(" :~"';.'" "\~~'"~' ~~' .. f:' 1;2'. -If:.~.~:,.'
i<ltii.t.l:~""r.~~' '.:.:1.,' -;:/~1J'!.I!
.-' ~~ \.~".. .:v.......,.. "J .~
(...ftt,!j);".;,~,. o.t.",~(:#.
.....:u..1-!"tj.l..:..4"/....." ~)!~~~f'I. ~ -~~~.
.~~~~ ",V,r..;;r, ~~:,~....
~1'l''' '.'~..I.;':.,"'" ;r,;......"'iJ
,'!O::""'-~:'l-",'''f.; "J~'
", "
Harrower
Borrower
Dorrowcr
LOAN 10#:0800878969
PAGE s OF 5 !\MCR AMGQ14B. USM
State of pennsylvania} 86
eounl'( of Cumberland
Recorded i~ the office fOT Ilia recording of Oesds
ec~. and 11~llilJ.lll.!lerland Counw.
in B~I~?wol.:::..- Pa n do
wit 55 y ha,od , A Of of II :-111
Carlis . PA Ihl day 0 19-
....
BOlJd462rAGE 1364
, ~' ~- d,o>> 1 - -
~~- ,,,,,",,,<-<I..",,,,,,,
, , ,
EXHIBIT B
<1
""'
,~-~-'
~"'~.@~iJ~t~' _
DESCRIPI'ION
ALL THAT CERTAIN piece or parcel of land with improvements thereon erected sitnated in the
Township of Middlesex, County of Cumberland, Pennsylvania bounded and described as follows:
BEGINNING at a pin on the Southern side of North Middlesex Drive (T-499) at the dividing line
between Lots Nos. 1 and 2, as shown on the hereinafter mentioned Plan of Lots; thence along said
dividing line between said Lots Nos. 1 and 2 South 17 degrees, West a distance of One hundred
Seventy-five (175) feet to a pin at the line of lands of Ruth A. Clemson; thence along said line of
lands of Ruth A, Clemson, South 82 degrees, 42 minutes, 20 seconds East a distance of One
hundred (100) feet to a pin at line of lands of Raymond Smyser; thence along said line of lands of
Raymond Smyser North 17 degrees East a distance of One hundred Seventy-five (175) feet to a pin
on the Southern side of North Middlesex Drive (T-499) first mentioned above; thence along said
Southern side of North Middlesex Drive (T-499) North 82 degrees, 42 minutes, 20 seconds West a
distance of One hundred (100) feet to a pin on the same at the dividing line between Lots Nos. 1
and 2 as shown on the hereinafter mentioned plan of Lots, the point and place of beginning.
BEING Lot No. 1 as shown on the subdivision plan of property for Ruth Clemson as prepared by
Ernest J. Walker, Professional Engineer, on April 24, 1972 and recorded in the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 23 page 109.
BEING improved with a dwelling house known as 154 West Middlesex Drive, Carlisle,
Pennsylvania.
^~~~~"
."
EXHIBIT C
"-.
~ "
liL'':;-,,:-
"iW----'---'------,---:;;."."
-
,
, j
-- ;~ -
1':'t"".',tit,,
, ,
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
October 20, 2000
TO: MARIBETH CHUDYK
154 WEST MIDDLESEX DRIVE
CARLISLE, P A 17013
MARIBETH CHUDYK
26 LONGSTREET DRIVE
CARLISLE, P A 17013
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVlOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
This is an official notice that the mortgage on vour home is in default and the lender intends to foreclose.
Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM !REMAP) mav be able to help to save
vour home. This Notice explains how the program works.
To see if HEMAP can help, vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when voumeet the
Counseling Agencv.
The name, address and phone number of Consumer Credit Counseling Agencies serving vour County are
listed at the end of this Notice. Ifvou have anv QUestions, vou mav call the Pennsvlvania 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 an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTlNUAR VIVIENDO EN SU CASA. IS NO COMPRENDE EL CONTENIDO DE EST A
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADA ARRlBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDA SAL V AR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
,
~ '~=---'-
. .
,II
'-"-"-'
.,~~
. .
STATEMENTS OF POLICY
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER
MARIBETH CHUDYK
154 WEST MIDDLESEX DRIVE, CARLISLE, PA 17ot3
0800878969
ALLIANCE FUNDING COMPANY, DIVISION OF
SUPERIOR BANK FSB
LA SALLE NATIONAL BANK
C/O SUPERIOR BANK, FSB
CURRENT LENDERlSERVICER:
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGffiLE FOR FINANCIAL ASSISTANCE WIDCH 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 MAYBE 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
forecl,osure on you mortgage for thirty (30) days from the date of this Notice. During that time you must
arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEETING 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 CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -Ifvou meet with one of the consumer credit
counseling agencies listed at the end of this notice the lender mav NOT take action against vou for thirty
(30) davs 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.
APPLJCA TION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set fortl~
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 [mancial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out
sign and file a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in submitting a complete
application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
.f
'!
'r
"
;'
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 IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
.''7,-,
'.
~
~,
~ illi_M~","",'
, ... l .
AGENCY ACTION- A vailab]e funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Peunsylvania Housing
Finance Agency has sixty (60) days to make a decisioji'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 Agency of its decision on you
application.
NOTE; IF YOU ARE CURRENTLY PROTECTED BY THE FILING
OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF'TIDS NOTICE IS FOR
INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT
TO COLLECT THE DEBT
(Uyou have filed baukruptcy you cau still apply for Emergency Mortgage Assistance)
HOW TO CURE YOUR MORTGAGE DEF AUL T (Bring it up to date)
NA TORE OF THE DEFAULT- The MORTGAGE debt held by the above lender on your property located
at: 154 WEST MIDDLESEX DRIVE, CARLISLE, P A 170] 3 ]S SERIOUSLY ]N DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due: 7/]5/00 thru 10/15/00 at $393.79 per month.
Monthly Payments Plus Late Charges Accrued:
Attorney fees:
Inspections:
Other:
NSF:
(Suspense)
TOTAL AMOUNT TO CURE DEFAULT
$1,929.58
$50.00
$169.00
$0.00
$30.00
($0.00)
$2,178.58
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable):
N/A
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 $2,178.58
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
UJE THIRTY (30) DAY PERIOD. Pavment must be made either bv cashier's check, certified check or
monev order made pavable and sent to: SUPERIOR BANK, FSB, ONE RAMLAND ROAD,
ORANGEBURG, NY 10962, AnN: VALERIE BARNES.
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter. (Do not use unot applicable) N/A.
]F 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 rights to accelerate the mortgage 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 installmeuts. Iffull payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to
foreclosure upon your mormage property.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay
off the mortgage debt. If the lender refers your case to its attorney, but you cure the delinquency before the
lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees
that were actually incurred, up to $50.00. However, if/egal proceedings are started against you, you will
have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount to the lender, which may also include other reasonable costs. If
YOU cure the default within the THIRTY (30) DAY period, vou will not be required to pav attornev's fees.
,;}
~< " ,~.
-
,I ; __~
L
'~ '
"~.'
, ... , "
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 nrevent the sale at any time un to one hour before the Sheriff's Sale. You may do so bv
naving the total amount then nast due. nlus any late or other charges then due. reasonable attorney's fees
and costs connected with the foreclosure sale and anvothercosts connected with the Sheriff's Sale as
snecified in writing bv the lender and bv nerfonning 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 Sheriff's
Sale of the mortgage property could be held would be approximately SIX (6) MONlliS from the date of
this Notice. A notice of the actual date oftbe 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 fmd out at any time
exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER-
SUPERIOR BANK, FSB
ONE RAMLAND ROAD
ORANGEBURG, NY 10962
(800) 451-1093
CONTACT PERSON: VALERIE BARNES EXT.2476
EFFECT OF SHERIFF'S SALE- You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the 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 _ mayor XX may not (check one) sell or transfer your
home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost are paid prior to or at the sale that the other requirements of
the mortgage are satisfied.
YOU MAY ALSO HA VB THE RIGHT:
. TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT.
. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF
. TO HA VB THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD
OCCURRED, IF YOU CURE THE DEFAUL T. (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 OlliER 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 lliE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED,
~ truly yours, ,
I
U2~ !
ATTt2J:l~:~:R
~,
, ... . ~
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
************************************************************************
1. This is an attempt to collect a debt and any information obtained will be used for
the purpose.
2. Unless you dispute the validity of this debt, or any portion thereof, within thirty
(30) days after receipt of this notice, the debt will be assumed to be valid by our
offices.
3. If you notify our offices in writing within thirty (30) days of receipt ofthis notice
that the debt, or any portion thereof, is disputed, our offices will provide you with
verification of the debt or copy of the judgment against you, and a copy of such
verification or judgment will be mailed to you by our offices.
4. If you notify our offices in writing within thirty (30) days ofreceipt of this notice,
our offices will provide you with the name and address of the original creditor, if
different from the current creditor.
-,~~~
- ,~
.
"
I -.: ^... ..
: I _~' ~
-" I ~.' >
".~'~fY'
. ,
PENl\i.... {L VANIA HOUSING FINANCE AL .CY
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
N. 6th Street
Harrisburg, P A 171 0 1
(717) 234-5925
FAX (717) 234-9459,
Cormnunity Action Comm of the Capital
Region
1514 Derry Street
Harrisburg, P A 17104
(717) 232-9757
FAX (717) 234-2227
Financial Counseling Services of Franklin
3! West 3rd Street
Waynesboro, P A 17268
(717) 762-3285
YMCA of Carlisle
301 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
PENNYLSVANIA BULLETIN, VOL. 29, NO. 23, JUNE 5,1999
~l!iil;Ji~r&1t~~~:,n":;"",,1!,.~'C,,>E;ol;H!HMirM;;ili>:}'fi","':'~*':)"jk
=~":':
"",&,;"',,:!~:;;,,,,,c;;,,~
- ~~,Wl:"Mli_'\C.r4iM~.ilil!i!i&-
_,;i,,:,illJ~~_L~~...t-lli
~ ~
~
~
'-J
"'-
C\
f'
~
t>,. '69.
~lrt&
~ ' ~
I ~ 0
if:'f-J
~~
'---...(
(')
r;;
<
'Uta
mr-n
;~:J")
2' '.,.
~{~:~
~CJ
>-
2~:,~
.;r>c~
~
?!
---l. f
~.~ ~
B
1L -'- ,~~
~ "
o
~fj
1'1<=-""
-q~l1
:ho
~,,,,J ':)
_-:1 _'w,
~"-'-,--'h
~_J.o
on,
~"l
:!>:
~
:.".
'"l:)
:;t:J
N
.f;:"
.):::<llo
:'l';~'
-
..
:...>
.;:-
"~-,:!;
I ~ ~'"
...--
J
'J-.."-" ,",,~b. ~,,"~,_ ,
"--~^'~-""';
^ '
0, 0
BENNETT & DOHERTY, P,C.
PA Bar I.D. No, 63352
By: Jeffrey A. Bennett
The Barness Office Plaza
975 Easton Road, Suite 102
Warrington, PA 18976
Tel. (215) 343-4100
Attorneys for Plaintiffs
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff,
vs.
NO,()I_~ Cu~(~
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013,
Defendant( s).
PRAECIPE FOR APPEARANCE
To the Prothonotary:
Please enter my appearance for the Plaintiff, Lasalle National Bank in the above case.
~.
P A Bar I.D, No. 63352
975 Easton Road, Suite 102
Warrington, PA 18976
(215) 343-4100
Dated: 4')0 -0 \
,g.I~r;iM;~i~~,";;[;...'i;;;;::_,;~,(",#j",ij\\i!t;{M:;;ll:''''''''';;'J\l,tr:,,,j;',_,,,"",':';di;,,,}],,~,,~;,),,'f~1j'of";;,,f..00--"';F!i,;t'<}f~jji;B:~~~ilIli.W;~i;l,!liilel;;!lt~jj-",+:1!'ilili_&.'4t-;illi!l'J:'~I~*'I~ii!!'~"-"-"'~
'~Illn "1""
"!!oi\
i
I
I
(") c.., C'
C --[1
-?
r ~ 2J
~ ;;:0
1'0 ",.m
, .S; ~- S~,~~
"
~O :I> ,,~~ "r'
:;-.t. ::d
ig ::;:: ~:O
orn
Z W ;g
=< ;:0
..".. -<
TJ
N_~ _~
n'~ .
"....
"' ,'~,~ _."-~.~--,- ,~,
,_~' ~ ,~u,," 0 _~'''''~~'~''_~ " ........
.' ~
r,,', ,',
",'or_
':l~.tt",
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02397 P
'COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK
VS
CHUDYK MARl BETH
CPL MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CHUDYK MARl BETH
the
DEFENDANT
, at 1629:00 HOURS, on the 1st day of May
, 2001
at 26 LONGSTREET DRIVE
CARLISLE, PA 17013
by handing to
MARIBETH CHUDYK
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31.10
So Answers:
.r~...~:/23u?
R. Thomas Kline
me this
~
day of
05/02/2001
BENNE::, ~ L-f:?
Deputy .A3Keriff
Sworn and Subscribed to before
, """"-..<."
"- -', ~', ' ;, -;.." --,
~~ H .,~
BENNETT & DOHERTY, P.C,
P A Bar I.D, No. 63352
By: Jeffrey A. Bennett
975 Easton Road, Suite 102
Warrington, PA 18976
Tel. (215) 343-4100
Attorneys for Plaintiffs
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
No, 2001-02397 P
vs.
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013,
Defendant(s).
PROOF OF RETURN OF SERVICE
Plaintiff, Lasalle National Bank, by and through its counsel, Bennett & Doherty, P .C.,
hereby files this Proof of Return of Service, and states that a true and correct copy of the
Complaint of Plaintiff, Lasalle National Bank, was served on the Defendant as set forth in the
accompanying Proof Of Service (Exhibit A).
Dated: S-' ~-O\
BENNETT & DOHERTY, P.C.
BY~
Jeffrey . Bennett, EsqUire
Attorney for Plaintiff
975 Easton Road, Suite 102
Warrington, PA 18976
Tel. (215) 343-4100
_~, -W,"
~
"~
"
L
~
"",0:..,""", -,
SHERIFF'S RETURN - REGULAR
.... ,\ ,. ~
'CASE NO: 2001-02397 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK
VS
CHUDYK MARIBETH
CPL MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CHUDYK MARIBETH
the
DEFENDANT
, at 1629:00 HOURS, on the 1st day of May
, 2001
at 26 LONGSTREET DRIVE
CARLISLE, PA 17013
by handing to
MARIBETH CHUDYK
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavi t
Surcharge
18.00
3.10
.00
10.00
.00
31.10
So Answers: '. ,_
:r~<e";(t>e' ,,~;::;~..,;>
R. Thomas Kline
me this
day of
05/02/2001
BENNETT & DOHERTY
BY:~ 4/J ~ V
z;."..~ -
. Deputy~eriff
Sworn and Subscribed to before
A.D.
Prothonotary
",,,,,t,-,,,,,,,,,,,,",-,,,,,,~~;~tr;i:~~M-:;~:;'\ii*t.,jh",~'_h"_"~,,,;>,,xkr'ii'" ""'lJ'A~M",';&:'.'~,j,~;~Jl'j~__~il;-,~liIf.lliif lt1 fi:1Ii'''''~
) 1
._P"~_', ',-r-<" ~"",'<'" ,,_<"';" ,~,",~," ",'-, .oc',
,"".
."-"",-,,
"-""
, '~~:~'" ~~~,-U
~Jr"'~ - ~o,~ lM"""'-
o
c
;;:
"TIc'.!]
rnn;
Z~J"
Zr-~
~:".
~C)
)>r~
~(~
C
Z
=<
CJ
o
-n
:3:
:<>-
-<
1-:::::;
~'r:
-- ~'''--
'~',~~ ~),
~~
--.,
>-
:xJ
-<
.-.J
"
~..;J>.
r:-
<:::>
"" ~
t 11, ,Y>-
...
~
I,il
; ~ ~~.. """,...";,,.,--
,,~~II
~ '
"'" ~-"
'~1!k~jM'i.
BENNETT & DOHERTY, p,c.
PA Bar I.D, No, 63352
By: Jeffrey A. Bennett
975 Easton Road, Suite 102
Warrington, PA 18976
Tel. (215) 343-4100
Attorneys for Plaintiffs
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
No. 2001-02397 P
vs.
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013,
Defendant( s).
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above-captioned Civil Action for an additional thirty
days.
BENNETT & DOHERTY, P.C.
Dated: S-)S....O (
~
By:
Jeffrey . Bennett, Esquire
Attorney for Plaintiff
975 Easton Road, Suite 102
Warrington, PA 18976
Tel. (215) 343-4100
~~~-i@j;~I"fu~{(<,j~~iii""Hlli:."")M'\'#.llilf"'>lI~lll"j*ltJ!i,;amk4~l\'"
-'-
\!-_,,,,"
l'iu"'~--'h;.::r.A*"a0!;#;ffii.,-"'~~l!t~~l!'alclil ".-,....J..;rtR:' :W!iill~' ilt"
o
~;
QJt~"
i?;.~-
2: ~E~,
'-
--:,:?-,",
~~g
2:,
-i
-'..
,-'
;>J
o
-a
:::::'
''''lIlIil''
, ~,
j'-.}
.,
:.Jl
tV
~
:,;~
~"""'~ .. ,
'.
. ,,~ '~ ~ ',b,_
l
BENNETT & DOHERTY, P.C,
P A Bar I.D. No. 63352
By: Jeffrey A. Bennett
975 Easton Road, Suite 102
Warrington, PA 18976
Tel. (215) 343-4100
Attorneys for Plaintiffs
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
No. 2001-02397 P
vs.
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, PA 17013,
Defendant(s).
PROOF OF RETURN OF SERVICE
Plaintiff, Lasalle National Bank, by and through its counsel, Bennett & Doherty, P.C.,
hereby files this Proof of Return of Service, and states that a true and correct copy of the
Complaint of Plaintiff, Lasalle National Bank, was served on the occupant of the premises as set
forth in the accompanying Proof Of Service (Exhibit A).
Dated: (P - (c,;-...(j I
BENNETT & DOHERTY, P.e.
By: 9i~
Jeffrey ~. Bennett, EsqUire
Attorney for Plaintiff
975 Easton Road, Suite 102
Warrington, PA 18976
Tel. (215) 343-4100
~,' ~,~ ' "'. -- "-"--'", ..I--!',,;,'_~-'c.~v,..l ' "'", ", ", ,I ~;;; ;~,'", ,j"',,,,' ,,,;, ''',"" '~<"i ',' ""_"'-0 '.,i ,:J;~;_",:> {, ;;:;;;:'-~:~';~-; , - - .c' 't'f.1
~h~K~~~'0 K~lUm~ - K~GULAK
).
. .
CASE NO: 2001-02397 P
Amended
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK
VS
CHUDYK MARIBETH
DEP RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CHUDYK MARIBETH
the
DEFENDANT
, at 1900:00 HOURS, on the 4th day of June
, 2001
at 154 W MIDDLESEX DRIVE
CARLISLE, PA 17013
by handing to
JAMES GOODMAN (FATHER)
a true and attested copy of COMPLAINT & NOTICE
together with
MORTGAGE FORECLOSURE
and at the same time directing His attention to the contents thereof.
Amended
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31.10
So A-Dswers: .
~~~~
, .,
R. Thomas Kline
06/13/2001
BENNETT &
Sworn and Subscribed to before By:
me this
day of
A.D.
Prothonotary
~<>,
=-~lIi ~~:~liiiOlil@l'.I'" i~~!i^' ,;,~~"';;"~-'"'
~ .~~
~~O,~_ ~,~ ~,~,
~^
~--
^~, , -" ,:"",,"
, ~"
~,=j;.",>-o:..;'~
"
'.
'.J.:~
, '
4
0 0 '".-'
C ~!
s:: ,
'--
-U G~, ,.'--
fT1r1-i '-,""
Z_" ~-
Z ,.- --...,,-,-"
~ ,- ,a ,
2: ) ,
, ()
r:::C_; ~ -,.
~~, ;:-3 --,----.
!-..' - r'5
--0 UJ :-::"::-1\'
>c :~)
--1
Z :::> ?D
::;! <:0 -<
,
,'~.'._~ '~r>A " ._ ,
j ,-,'
..J,'
'~ --"'~-
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02397 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK
VS
CHUDYK MARl BETH
RICHARD E. SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CHUDYK MARIBETH
the
DEFENDANT
, at 1900:00 HOURS, on the 4th day of June
, 2001
at 26 LONGSTREET DRIVE
CARLISLE, PA 17013
by handing to
JAMES GOODMMAN, FATHER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31. 10
s07~~
R. Thomas Kline
06/07/2001
BENNETT & DOHER
Sworn and Subscribed to before By:
me this :l1..J-- day of
~ / oJiu,1 A.D.
0P~hO~~~//;A " ~.
" d_
< ~
, ~
~ I,,,,
"
,1 "" "'~ lK ili.~l>il!iOMlll;I''':
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02397 P
Amended
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK
VS
CHUDYK MARIBETH
DEP RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CHUDYK MARIBETH
the
DEFENDANT
, at 1900:00 HOURS, on the 4th day of June
, 2001
at 154 W MIDDLESEX DRIVE
CARLISLE, PA 17013
by handing to
JAMES GOODMAN (FATHER)
a true and attested copy of COMPLAINT & NOTICE
together with
MORTGAGE FORECLOSURE
and at the same time directing His attention to the contents thereof.
Amended
Sheriff's Costs:
Docketing
service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31.10
?~:~~C~;
R. Thomas Kline
06/13/2001
BENNETT &
Sworn and Subscribed to before By:
me this ;l1.Ak day of
~, ~I A.D.
~o~t?r~.~
.--
I
_." .'f
.
,
BENNETT & DOHERTY, P,C,
BY: Jeffrey A. Bennett, Esq,
Attorney I.D. 63352
975 Easton Road, Suite 102
Warrington, PA 18976
(215) 343-4100
Attorneys for Plaintiff
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
vs.
No. 2001-02397 P
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013,
Defendant(s).
PRAECIPE TO ENTER DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter default judgment in favor of Plaintiff and against Defendant by default for
Defendant's failure to file an answer to the Plaintiff s Complaint against the Defendant.
Assess damages as set forth below:
As set forth in Complaint
Interest from 2/20/01 to 7/9/01
$39,854.00
$ 1,405.60
$41,259.60
TOTAL
* Interest continues to accrue at the rate of$10.04 per diem from July 10,2001 through the date
of execution.
~~",,;
'" ~ .' ~ , .,., ~~
""......-., "'~
-
",.
)' "_ 1-
'c,,, ~'h ~'-
,
.
I hereby certifY that written notice of the intention to take a default judgment was mailed
or delivered to the party against whom judgment is to be entered and to his attorney of record, if
any, after the default occurred and at least ten days prior to the date of the filing of this praecipe.
A copy of the Notice ofIntention to Enter Judgment by Default is attached hereto as Exhibit A.
Dated: 7-'~....0 t
By: ~
Jeffrey N.. Bennett, Esquire
Attorney for Plaintiff
975 Easton Road, Suite 102
Warrington, PA 18976
215-343-4100
Attorney LD. # 63352
ASSESSMENT OF DAMAGES
AND NOW \.. I.. f I ,2001, Judgment is entered in favor of the Plaintiff and
against the Defendan~ant of filing an Answer to Plaintiffs Complaint and
damages assessed at the sum of Forty One Thousand Two Hundred Fifty Nine Dollars and Sixty
Cents ($41,259.60), as per the above statement.
'"
c
BENNETT & DOHERTY, P.e.
PA Bar I.D. No.. 63352
By: Jeffrey A. Bennett
975 Easton Road, Suite 102
Warrington, PA 18976
Tel. (215) 343-4100
Attorneys for Plaintiffs
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1/98,
series 1998-2,
CIVIL ACTION - LAW
Plaintiff,
No. 2001-02397 P
vs.
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013,
Defendant(s).
NOTICE OF INTENTION TO TAKE DEFAULT
TO: MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013
VIA CERTIFICATED MAIL
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE
IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO
THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITHIN
TEN (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:
-
1.
';;.0 "
I
;},;,
,
COURT ADMINISTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
By:
Jeffrey . Bennett, Esquire
Attorney for Plaintiff
975 Easton Road, Suite 102
Warrington, PA 18976
(215) 343-4100
Attorney I.D. # 63352
d.
Dated: 5" - ,) )'....0 (
0", "{vt:;;7 ~ ~~'ed t~h (A ~ L( L
;) G I J)Yl'jbfree1 bnoe.
C()..Jtlw~ iY-l 17CLJ.
,
'I oj
o!
I .1
I.
i j
I,i
I I
l.J'1
U,S, POSTAL SERVICE CERTIFICATE OF MAILlN.~~\ \"N
./
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NO 'r-' r N A
PROVIDE FOR INSURANCE-POSTMASTER ~"
i , ..........,..,... ......."....." i." I 211
R,iceivedFrm: 1IiJ'Ii.f,....""'....,''''' ~1l1c:.n,11 \>. \ I V
, AUon\eys at law \ . :<
i 975 EastOft Road, Suite 102 I ~
Wan'ii..tun. .........ylu.nia 1891'ii
J
iil
." ,. '"' -'" <~ " ... .. ... ~ -.. "
PS Form 3817. January 2001
L4,:::~ ~.~.."
.~
I'...:
,( ~' I ,/_,
<"llI.[;[ll;
BENNETT & DOHERTY, P.C.
BY: Jeffrey A, Bennett, Esq,
Attorney I,D. 63352
975 Easton Road, Suite 102
Warrington, PA 18976
(215) 343-4100
Attorneys for Plaintiff
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
vs.
No, 2001-02397 P
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013,
Defendant(s).
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYL V AN1A
: SS
COUNTY OF BUCKS
Jeffrey A. Bennett, Esqnire, being duly sworn according to law, deposes and says that
he is an officer of Plaintiff; that he is authorized to make this affidavit on behalf of Plaintiff; that
the above named Defendant resides at 26 Longstreet Drive, Carlisle, P A 17013 and that the
Defendant is not in the Military Service ofthe United States, nor any State or Territory thereof or
its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments
, " ~
"J~ __=~~r.'._
thereto.
, j
~J'
Jeffre&~qUire
Attorney for Plaintiff
before
,2001
NOTARIAL SEAL
STEPHEN DOHERTY, Notary Public
Doylesto"m Boro, Bucks County
M Commission Ex ires June 23, 2003
Page -2-
-, -~ -" "
~'
..
BENNETT & DOHERTY, P.C.
BY: Jeffrey A, Bennett, Esq.
Attorney I.D, 63352
975 Easton Road, Suite 102
Warrington, PA 18976
(215) 343-4100
Attorneys for Plaintiff
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1/98,
series 1998-2,
Plaintiff,
vs.
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013,
Defendant(s).
"
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
No. 2001-02397 P
CERTIFICATION OF ADDRESSES
TO THE PROTHONOTARY:
" I ^, l i- ,,,,;..~ ,'~ 0; "..
.-,- r
The address of the Plaintiff, judgment creditor, is One Ramland Road, Orangeburg, New
York 10962, and the last known address of the Defendant, judgment debtor, is 26 Longstreet
Drive, Carlisle, P A 17013.
Dated: 7"'~ / 0 I
By: r;J~'
Jeffrey . Bennett, Esqmre
Attorney for Plaintiff
975 Easton Road, Suite 102
Warrington, PA 18976
215-343-4100
Attorney J.D. # 63352
""~.
-
, ~ j
.'
__;~ ' _'" ,~ c .
"~,-,,-, !ttl
.'
BENNETT & DOHERTY, P.C,
BY: Jeffrey A. Bennett, Esq,
Attorney I.D, 63352
975 Easton Road, Suite 102
Warrington, PA 18976
(215) 343-4100
Attorneys for Plaintiff
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
Ys.
No. 2001-02397 P
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013,
Defendant(s).
NOTICE OF ENTRY OF JUDGMENT
NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER
HAS BEEN ENTERED AGAINST YOU.
If you have any questions concerning the above, please contact:
Jeffrey A. Bennett, Esquire
Attorney for Plaintiff
975 Easton Road, Suite 102
Warrington, Pennsylvania 18976
(215) 343-4100
~~~Illi"",';g~~ill1;iiM~~{;i;!'h8;1'''''"'lifu1''Mlo(l;Hli'&ili;;t'''':!l;;C''''''iii'r~L'i! '~"~__ ',,~ ....,'~~~~ ~~~ ~-"""" "~" [::I.' ~'
t 7'J 0 ~ c.__:',
ft- f ....0
,
8 '-
f --
~ (j) -
......... ~
~ ~ F! ~~~ C
,-:!-'~ l ~',
.~ 6' "'--,~ -.
~ j:'>~< ;-S:)
..
=> --.:.~;
1- -< Co ~:u
'" -:;,:
~
~...- -- ~,. >,-"
'I
. "
,
,~.._- ..~
BENNETT & DOHERTY, P.C,
BY: Jeffrey A, Bennett, Esq.
Attorney I.D. 63352
975 Easton Road, Suite 102
Warrington, PA 18976
(215) 343-4100
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
Plaintiff,
vs.
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013,
Defendant(s).
J .1 ~ ~
, -11.
'.-'"
. -,w._
"',f.,
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
No. 2001-02397 P
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue a Writ of Execution in the above matter:
Amount Due
Interest from 7/10/0 I
Per diem $10.04
(Costs to be added)
Dated: 7~(P ~ () I
$41,259.60
$
$
By:
Jeffre A. Bennett, Esquire
Attorney for Plaintiff
975 Easton Road, Suite 102
Warrington, PA 18976
215-343-4100
Attorney J.D. # 63352
~wf~_iJ;lill!lltd-f.t~~~~@,JiMgj"~ ~'''''\~~~~~'';Ii.~1l:1<u.",~.!l~:iii~~;~ ._'~'m,",,~'fq,,' -" -="'~
~0
ft-fi
~
IV
'-...J
~:69..
""
~ 0
C>
........
'-
g
~~
9v..o~t;!~
d8(9i3D
I I
.....
"
~
~
o
~
~
:::
~
....
_,__~ 0
,
~
,
,
-=-
""'
v.,
-
"-
o
~
~ ~ ~
~q~
. '"
,
----Li ~
~
~
D
o
C)
Ci~f
Ll
",.
-,
:=::
~~~ ;~-:;
'S:~,:,_'
- ,
.
-::;;--,.
::;J
~':::~,
~:::::
:::>
G:=
._,
~}
'""
-~
,'"~-,'
~~ ~';'-, - '
4 " ..
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
vs.
No. 2001-02397 P
MARlBETH CHUDYK
26 Longstreet Drive
ClIrlisle, P A 17013,
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129.1
LASALLE NATIONAL BANK, Plaintiff in the above action, by its attorney, JEFFREY
A. BENNETT, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 154 West Middlesex Drive,
ClIrlisle, PA 17103,
I. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS
Maribeth Chudyk
26 Longstreet Drive
Carlisle, P A 17013
2. Name and address ofDefendant(s) in the judgment:
NAME LAST KNOWN ADDRESS
Maribeth Chudyk
26 Longstreet Drive
Carlisle, P A 17013
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME LAST KNOWN ADDRESS
GMAC Mortgage Corp ofPA
8360 Old York Road
Elkins Park, P A 19027
I.. ~
-,( "";'-'"-
~ """""'1:;
. '.
-
4. Name and address of last recorded holder of every mortgage of record:
NAME LAST KNOWN ADDRESS
Lasalle National Bank
One Ramland Road
Orangebnrg, NY 10962
GMAC Mortgage Corp, ofPA
8360 Old York Road
Elkins Park, PA 19027
5. Name and address of every other person who has any record lien on the property:
NAME LAST KNOWN ADDRESS
None
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
NAME LAST KNOWN ADDRESS
None
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:
Cumberland County
Tax Claim Bureau
1 Court House Square
Carlisle, P A 17013
Domestic Relations of
Cumberland County
1 Court House Square
Carlisle, P A 17013
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
r~~1 ~~d
Date JEF~;; ~ETT, ESQUIRE
Attorney for Plaintiff
~~~W~1"',.,!t&iY;MI..~~~i;;ji!f4l70il?;i;~1-iii7";""!'i#,~i!l";'~
,-,
^~.' '..
=~ _ <",_,em,
w ',~~~o,'
"," "'
'.h,aJ
. "'1IItii!!..~,
~"~~ ' ..
-.'."".
",""~. .
"' ,~
(') C..
s= ;\
, L.
,J
(j'l -
,('-,,~
-~ !.
U?
~::: ,
'-
., ,
,-:,. C ',.f.1
.' =>
--{ :0
~ C:l -"
. .
, ~
"
11
;1
I
I
"
.
.
.
:~.."o
, ~--
~".
, I
, 1'_-
"
~ "'ill'__. "
~
,
.-
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
vs.
No, 2001-02397 P
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, PA 17013,
Defendant(s).
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MARIBETH CHUDYK
26 ,Longstreet Drive
Carlisle, P A 17013
PLEASE BE ADVISED THAT TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY
AND TillS DEBT WAS NOT REAFFIRMED, TillS CORRESPONDENCE IS NOT AND
SHOULD NOT BE CONSTR'UltDTO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.
Your house (real estate) at 154 West Middlesex Drive. Carlisle. PA 17103 is scheduled to be
sold at the Sheriffs Sale on December 5, 2001 at _.M. at the Cumberland County Court
House. 1 Court House SQuare. Carlisle, PA 17103, to enforce the court judgment of $41.259.60
obtained by Lasalle National Bank (the mortgagee) against you. If the sale is continued, the new date
will be announced at the time of sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THE SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To fmd out how much you must pay, you may call: (215) 343-
4100.
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
,-~~ -
"~ ",'.
~
"'.
,
lsj' '~
~.
"
sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
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 Sheriffs sale is not stopped, your property will be sold to this highest bidder. You may
find out the price bid by calling (215) 343-4100.
2. You may be able 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 (215) 343-4100.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and
the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled toa share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the
sale. This schedule will state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the filing of the schedule of
distribution.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GOT TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Court House
Carlisle, PA 17103
(7171) 240-6200
~ "
,-
'.' .
,'",', ,",'.
.I.
~ -'
DESCRIPTION
ALL THAT CERTAIN piece or parcel of land with improvements thereon erected situated in the
Township of Middlesex, County of Cumberland, Pennsylvania bounded and described as follows:
BEGINNING at a pin on the Southern side of North Middlesex Drive (T-499) at the dividing line
between Lots Nos. 1 and 2, as shown on the hereinafter mentioned Plan of Lots; thence along said
dividing line between said Lots Nos. 1 and 2 South 17 degrees, West a distance of One hundred
Seventy-five (175) feet to a pin at the line of lands of Ruth A. Clemson; thence along said line of
lands of Ruth A, Clemson, South 82 degrees, 42 minutes, 20 seconds East a distance of One
hundred (100) feet to a pin at line of lands of Raymond Smyser; thence along said line of lands of
Raymond Smyser North 17 degrees East a distance of One hundred Seventy-five (175) feet to a pin
on the Southern side of North Middlesex Drive (T-499) frrst mentioned above; thence along said
Southern side of North Middlesex Drive (T-499) North 82 degrees, 42 minutes, 20 seconds West a
distance of One hundred (100) feet to a pin on the same at the dividing line between Lots Nos. 1
and 2 as shown on the hereinafter mentioned plan of Lots, the point and place of beginning.
BEING Lot No.1 as shown on the subdivision plan of property for Ruth Clemson as prepared by
Ernest J. Walker, Professional Engineer, on April 24, 1972 and recorded in the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 23 page 109.
BEING improved with a dwelling house known as 154 West Middlesex Drive, Carlisle,
Pennsylvania.
~~~l\i"",iB.it<"'lb~0"'ii:~iml!ilIiilll>iiii>:~U',~~Iiii'~'M\&'J-!ii;'t,q,.,*jj;,~lt'","----4L<w;<t!OJffi',~~"'-""<
=, -:., T]J'Jg J1[
II~,L~ ..
~. ..,',"'''' _. ~,"'''' .~
',"-~._","'."",,,,", .-"
Iiiii.iiJNi~~;"'u.
~~"""","M
-"~ -
~iIit'iiilllll -~
,
-
(2 (~!
'---
c'
-
~r ~'~,
:f;'::'
~,~: ~
~.~- ';-
-,--.-.
'_:-, \ ~
/
-- ,
.,>
--
--<~ (:;'.;
"~
1.
'I
I
I
I
!
i
I
I
I
~
."
,-,. ,".-,,--- 'L:(''!i 11,',
..,
LaSalle National Bank, as Trustee
Under the Pooling and Service
Agreement date 6/1198 Series 1998-2
VS
Maribeth Chudyk
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-2397 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Jeffrey Bennett.
Sheriff's Costs:
Docketing
Surcharge
Posting Handbills
Law Library
Prothonotary
Share of Bills
Mileage
Levy
Advertising
Certified Mail
Poundage
Postpone Sale
Law Journal
Patriot News
30.00
20.00
.50
1.00
3.25
15.00
1.40
$71.15 paid by attorney
09-21-01
Sworn and subscribed to before me
Prothonotary
so~:
~ ...._o.!';.e~~
R. Thomas Kline, Sheriff
BY CJocitI S~
Real Estate Deputy
This..l.t.L.. day of ~~
2001, A.D. Gr--- Q. ~L)€'. .,~
'1) '1
/,'> Ut ?J'lOS 8'
/) V7;;o
\UV'
.Jim
--
"""
I" .
"-.
'""",
I ~
~. '< '9.
,
.J.
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
vs.
No. 2001-02397 P
MARlBETH CHUDYK
26 Longstreet Drive
Carlisle, PA 17013,
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129.1
LASALLE NATIONAL BANK, Plaintiff in the above action, by its attorney, JEFFREY
A. BENNETT, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 154 West Middlesex Drive,
Carlisle, PA 17103.
1. Name and address ofOwner(s) orreputed Owner(s):
NAME LAST KNOWN ADDRESS
Maribeth Chudyk
26 Longstreet Drive
Carlisle, P A 17013
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS
Maribeth Chudyk
26 Longstreet Drive
Carlisle, PA 17013
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME LAST KNOWN ADDRESS
GMAC Mortgage Corp ofPA
8360 Old York Road
Elkins Park, PA 19027
f' - "
~' , ,
"~._~"
,:
.'
".
,
.j...
4. Name ,md address oflast recorded holder of every mortgage of record:
NAME LAST KNOWN ADDRESS
Lasalle National Bank
One Ramland Road
Orangeburg, NY 10962
GMAC Mortgage Corp. ofPA
8360 Old York Road
Elkins Park, PA 19027
5. Name and address of every other person who has any record lien on the property:
NAME LAST KNOWN ADDRESS
None
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
NAME LAST KNOWN ADDRESS
None
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:
Cumberland County
Tax Claim Bureau
1 Court House Square
Carlisle, P A 17013
Domestic Relations of
Cumberland County
1 Court House Square
Carlisle, P A 17013
{'Co -01
Date
I verifY that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
JF:FrJf~:f:Fm, ESQUIRE
Attorney for Plaintiff
_~____~_ ___'_'.;:: ~.~, _ ~ m'-'-.,-'-i-'-'~--'.---------;:;---;----:------:-----' ~, ,"
_ . _ _ ____ ~____,_,_,d
~-
-
,
. .
1,
, i, "'
..
.,.
LASALLE NATIONAL BANK, as
Trustee under the pooling and
servicing agreement dated 6/1198,
series 1998-2,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL ACTION - LAW
Plaintiff,
vs.
No. 2001-02397 P
MARIBETH CHUDYK
26 Longstreet Drive
Carlisle, PA 17013,
Defendant( s).
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MARlBETH CHUDYK
26 Longstreet Drive
Carlisle, P A 17013
PLEASE BE ADVISED THAT TIDS FIRM IS A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY
AND TIDS DEBTW AS NOT REAFFIRMED, TIDS CORRESPONDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.
Your house (real estate) at 154 West Middlesex Drive. Carlisle, PA 17103 is scheduled to be
sold at the Sheriffs Sale on December 5, 2001 at .M. at the Cumberland County Court
House. 1 Court House Square. Carlisle, PA 17103, to enforce the court judgment of $41.259.60
obtained by Lasalle National Bank (the mortgagee) against you. If the sale is continued, the new date
will be announced at the time of sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THE SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 343-
4100.
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
~~-!\ir,;~l('1I!i>"t1~j;8,Y!,i~~..i"j,~'tN,p.\l.~t~-i;j"'~~:';",'i"~!.h;';"'"""'I",,"S';~j~%,\,*,~~,.hS,;'~"''"''''-''''''''"'''''I'=~ '~R:~:i '.. '<OlMrll"'~ '''''..~~~ ~
....
sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
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 this highest bidder. You may
find out the price bid by calling (215) 343-4100.
2. You may be able 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 (215) 343-4100.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5 . You have the right to remain in the property until the full amount due is paid to the Sheriff and
the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled toa share of the money which was paid for your house, A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the
sale. This schedule will state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the filing of the schedule of
distrihution.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR Ckl'o/NOT .AFFORD ONE, GOT TO OR TELEPHONE urn OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Court House
Carlisle, PA 17103
(7171) 240-6200
,It ''''~ ,', ""__",'_""~~,," _"_,..,,,,'d,,,"'_~,,,,,,,, ,',' ,"," __".. ",,'~>_ ~ q _-.<"~,,,J ,., ~ __ n
-
""'
"'~,
,
"
. .
,
0'
-,~..~
" .-
- ",.
.
,
J
. ,
...
.
..
DESCRIPTION
ALL THAT CERTAIN piece or parcel of land with improvements thereon erected situated in the
Township of Middlesex, County of Cumberland, Pennsylvania bounded and described as follows:
BEGINNING at a pin on the Sonthern side of North Middlesex Drive (T-499) at the dividing line
between Lots Nos. I and 2, as shown on the hereinafter mentioned Plan of Lots; thence along said
dividing line between said Lots Nos. I and 2 South 17 degrees, West a distance of One hundred
Seventy-five (175) feet to a pin at the line of lands of Ruth A. Clemson; thence along said line of
lands of Ruth A, Clemson, South 82 degrees, 42 minutes, 20 seconds East a distance of One
hundred (100) feet to a pin at line of lands of Raymond Smyser; thence along said line of lands of
Raymond Smyser North 17 degrees East a distance of One hundred Seventy-five (175) feet to a pin
on the Southern side of North Middlesex Drive (T -499) frrst mentioned above; thence along said
Southern side of North Middlesex Drive (T-499) North 82 degrees, 42 minutes, 20 seconds West a
distance of One hundred (100) feet to a pin on the same at the dividing line between Lots Nos. 1
and 2 as shown on the hereinafter mentioned plan of Lots, the point and place of beginning.
BEING Lot No.1 as shown on the subdivision plan of property for Ruth Clemson as prepared by
Ernest J. Walker, Professional Engineer, on April 24, 1972 and recorded in the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 23 page 109.
BEING improved with a dwelling house known as 154 West Middlesex Drive, Carlisle,
Pennsylvania.
---
""",,' ~J,"
:,--',
, ,
.
, 1.
WRIT OF EXECUTION and/or ATTACHMENT
CDMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 0 '1-2397 CIVIL ffi!. TERM
CIVIL ACTION. LAW
TO THE SHERIFF OF
Cum~;t:'land
COUNTY
To satisfy the debt, interest and costs due LaSalle National Bank, as Trustee under the pooling and
service agreement dated 6/1/98, series 1998-2 PLAINTIFF(S)
from Maribeth Chudyk, 26 Longstreet Drive, Carlisle, PA 17013
DEFENDANT(S)
(1) You are directed to levy upon the property 01 the delendant(s) and to sell See Leqal Description
(2) You are also directed to attach the property of the delendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notffy 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 account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other
than a named garnishee, you are directed to not"y him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Atty's Comm
Ally Paid
Plaintiff Paid
%
Due Prothy
Other Costs
$,50
$1.00
Amount Due $41,259,60
Interest frOll 7/10/01 per diem $10,04
L.L.
5165,30
Date
Julv 11, 2001
Curtis R, Long
Prothonotary, Civil Division
~ bv .0/Vy, f{ - P 71;C/i/Uru. /
Deputy
REQUESTING PARTY
Name Jeffrey A, Bennett, Esq,
Address: 975 Easton Road, Suite 102
Warrington, PA 18976
Allorney for Plaintiff
Telephone: 215-343-4100
Supreme Court ID No. 63352
~~il>#~<ft.d,?~H;'"
,__,iM2,!l;-J"$ii-,ii,:.;\\fi;&:'<Yl.-';-"lSc~}~ft;;'_;'i",,\i!'!'''f,,;,,.;;I[~''''","iii":oi,,;:,,',,,;il~"4,<W-'~'ill~~~_. "j~lil,al~;ri!;jll'.ijll,liHll~IMiiiljjl1L~~i>W-"'---
J. ..
,. ,,'"
REAL ESTATE SALE No. 03 .
\.' SpJ 4> I 2()O I
.,,- 'Ilr'" \e'Jiec Uf)Oil the ::e18''i''''''
Cumberland County,
&/i / i tJ 0 ~ and more it,
(VII fi d. l i JiJ! N[LJJP .
'oered as: /54 (/I(V!idiJ.€ W't Dr.
inter!, 1m';"
, on Exhibit "A" filed wi!
this writ and by this reference incorporated herein.
I)ate:~' G I d60 f
By: Qnd!..( 5f/J/ldt. -
f!1~( rsfrl-re ()~uft{
,
(--J
l=ti;)
~
<s:e>
rnnJ
,
,
\1! l.!h' /, ...,
. ~." i,/ ::,'/Hl,<
, ''':1d
~.
10, Jld cZ t
JII-'i!;fll'; 2 f 7tf
llf&.Ji,W;~" "
'''- '-"""!fL --':';,:!!~\lJ~
-Jj'.'J4~
~