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Home My WebLink About01-03290 -4.~_ ~ ~~'. ~ - ~ -J _ <- ~ ';;"~!,;-- FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE ISO, HORSHAM, PA 19044 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. DI- -3l-'j()~ v. CUMBERLAND COUNTY JEFFREY I. PAUL 1906 LOGAN STREET, CAMPHILL,PA 17011 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 306586431 "- " --",'" ~, ' ,-So,; IF TmS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM TIDS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION pRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITmN TmRTY (30) DAYS OF RECEIPT OF TmS PLEADING, COUNSEL FOR PLAINTIFF WILL 0BTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITIllN TmRTY (30) DAYS OF RECEIPT OF TIDS PLEADING, COUNSEL FOR PLAINTIFF WILL ~END DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT TmS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER to TIDS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE TmRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF TIDS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN TIDS SUIT. ;-- ,- :J}, " ,c' "", ~ 'i.f~!m~"., 1. Plaintiff is: GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150, HORSHAM, PA 19044 2. The name(s) and last known addressees) of the Defendant(s) are: JEFFREY I. PAUL 1906 LOGAN STREET, CAMP HILL, P A 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 11113/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1497, Page 972. By Assignment of Mortgage Recorded 7/28/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 620, Page 393. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 2/110 I and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." ~,~- ",1 ", - ~.~..... -" 'li~;;! ' 6. The following amounts are due on the mortgage: Principal Balance Interest 11110 I through 5/110 I (per Diem $19.44) Attorney's Fees Cumulative Late Charges 11113/98 to 5/110 I Cost of Suit and Title Search Subtotal $101,381.68 2,352.24 4,000.00 138.92 550.00 $108,422.84 Escrow Credit Deficit Subtotal 394.06 0.00 ($ 394.06) TOTAL $ 108,028. 78 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sentto the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $108,028.78, together with interest from 5/1101 at the rate of$19.44 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. ;;Jd--'/ ~ i~FE~~~,~QU~ Attorney for Plaintiff j~" - ~".b~ , ," , , - ~'-- ~ -11 . t I "---' ~. "j?', First MClrtgage Loan'Servicing PO Box 85071 San Diego CA 92186-5071 3451 Hammond Ave PO Box 780 Waterloo IA 50704-0780 GMA~ Mortgage Date: April 11, 2001 ACT 91 NOTICE l'AKE ACl'lON TO SAVE YOUR HOME FROM FORECLOSURE Tbis i. an official notice that tbe mort2~2!'.on )'ourhome i.;n defaJllt,al!.!!. t,,~I!'.!Id!'J:intend. to foreelo.e. Specific infor!!ll!tion a.!>out t.!!.e nature of tbe !!.~fa_ult I~ provi<!ed in tbe attached pa ~e.. --..--.. The DOMEOWNI<:R'~~10RTGAGK~'[~ST~NJ":I<:J'RQGRAM.OO:MAP).!I1aY.!>~,,-l1!e to help to .ave YOur borne. Tbis Notice eXllla;n. bow tbel!!!!gram work.. 1'0 see ifDEMAP can help. vou must MEET WITH A CONSU~mR CREmT CQJ!NSELING AGI<:NCY \\1TlIIN 30 DAYS OF TDE DATE OF TlIIS NOTICI<:. Take this Notic~ with_you_ wbe!!)'o.umeeiwith tbe Counselin2 A2encv. T.be name. addre.. and pbone numbcr ofCon.umer Credit Counselil!~ Agencies .ervinID"our Coun!)' are listed althe endoftbis Notice. If you bave any quc.tion.,you may call the Pen...)'lvani'!.Dou.in g fi!l a II.!'J' Mencv toll frec at 1.800-342.2397 .O'~..~n. wit!lj!!!I'aired!!-,,~rillg ~a" c1l11 (717) 78Q-1869). Tbis Notice cOlltaiJlS importallt legal illformation.lfyou bave any que.tio.... repre....tative. at the Con.umer Credit CoulI.clillg Agellcy may be able to help cxplai.. it. You may also wa..t to co..tact an atlOJ"liCY i.. your area. Tbc local bar association may be able to bell' you filld a lawyer. 1,A NOTJIo'ICAClON EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVII<:NI>O EN SU CASA. SI NO COMPRENI>I<: EL CONTENmO m: I<:STA NOTlFlCACION OBTI<:NGA UNA TRADUCCION IMMEI>lATAMENTE LLAMANI>O ESTA AGENCIA (PENNSYLVANIA DOUSING FINANCE AGENCY) SIN CARGOS AI, NUMERO MI<:NClONADO ARRIIlA. I'UEDES SER ELEGIIlLE PARA UN PRESTAMO POR EL PROGRAMA LLA\IADO "DOMI<:OWNI<:R'S EMI<:RGENCY MORTGAGE ASSISTANCI<: I'ROGRAM" I<:L CUAL PUEI>I<: SALVAR SU CASA DI<: I,A pI<;RI>mA m;L I>ERECIIO ARI<:J>11\-f1R SU lIIPon.;CA HOMEOWNER'S NAMI<:(S): PROPI<:RTY ADDRESS: JEFFREY I. PAUL 1906 LOGAN 81" CAMP HILL, PA 17011 I,OAN ACCT. NO.: ORIGINAL LENln:R: CURRl<:NT LENI>ERlSERVICI<:R: 306586431 N/A GMAC Mortgage Corporation EIHlBltA .= ,', ",,- ,~~ -. 'iI''ti "':iI~r ~L" HOMEOWNER'S E~mRGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BI<:.:UGIBU FOR FINANqAL~SSJ~UNCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURI<: MORi'G~G.KPAYJ\.m~'I'S- IF YOU COMPLY WITH nIE PROVISIONS OF nIE 1I0MI<:OWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE" ACT"), YOU MAY liE I<:IJGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEI'AULT HAS IlEJo:N CAUSED IlY CIRCUMSTANCES YOUR CONTROL, IF YOU HAVE A REASONAIlLE PROSI'ECT 01<' IlEING AIlLE TO PAY YOUR MORTCimI<: PAYMI<:NTS, AND IF YOU MEET OTHER EIJGIIlILI'IY REQUIREMENTS ESTAIlIJSHED IlY THI<: PENNSYI,V ANIA HOUSING FINANCI<: AGENCY, TEMPORARY STAY OF FORI<:CLOSURE -- Under the Act, you are entitled to a temporal)' stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one ofthe consumer credit counseling agencies listed at the end ofthis Notice. THIS MEETING MUST OCCUR WITHIN TIlE NI<;XT(3-~)DAYS.IF YQlLPJ)NQTDl'PLY fOR E.ME.RGE.NCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR..MORTGAGE UP TODATE. 11lE PAR1~OF THI!i NOTICE CALLED "HOW TO CURE)'OlIlL~ORIGt\C).E. DEF AULT:'EXPJ,AINS I!QWIQ BRINg YQJ1R MORTGAGE UP TO DATI,. CONSUMER CREI>IT COUNSI<:IJ~G A(;Y:~Cm~ -- If you meet with one of the consumer credit counseling agencies listed at the end Oftllis notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting.The names. addresses and teleJlhone numbers of designated COnBume[ cr<;djtco}l!1seling ag~ll.9i~s for the countv in which tll"-Jlillp,yJ1Y is located art1 set jQrt]L~ttlle end ofthi.~1'!~ti_ce.lt is only necessal)' to schedule one face-to-face meeting. Advise your lender inunediately of your intentions. . APPIJCATION FOR MORTGAGE ASSISTANCE -. Y our mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infonnation about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have tile right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and tbey will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application 1\11181' be filed or postmarked within thirty (30) days of you face-to.face meeting. YOU MUST FILl<: YOUR APPIJCATlON PROMI'TLY, IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER T1MI<: PERIODS SKI' FORTIIIN THIS LETn:R, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMI<:I>IATELY AND YOUR APPIJCATlON FOR MORTGAGE ASSISTANCE WII,LIlE DENII<:D. AGENCY ACTION -- Available funds for emcrgency mortgage assistance are vel)' limited. They will be disbursed by the Agency under the eligibility criteria e~tablished by the Act. The Pennsylvania Housing Finance Agenc.y h~s sixty (60) days to make a declSlon after lt recelves your appilcatJon. Durmg that tJlne, no forecloslIre proceedmgs will be pursued against you if you have met the time requirements set fortb above. You will be notJfied dlrectly by the Pennsylvania Housing Finance Agency of its decision on your application. E)l~\9\1 ~ g ~.m ""I,. , , """~-""'-- ,- '~,m4 [NN(on: IF YOU. Aim CURRENTLY PROnCTEI> BY THI<: Jo'IIJNG OF A PETITION IN BANKRUPTCY THE FO~,LOWING PART OF THIS NOTICE IS I"OR INI.'ORMATION PURPOSES ONIN ANI> ' SHOULI> NOT HI<: CONSII>EREI> AS AN ATTEMPT TO COLLECT 'I'm; I>FJH. _~... (If~ou h~v! me~~a~kna-,,-tc!.~ou C~"_ still ap'p!y !~r Eme!gency Mort~age Assistance.) HOW TO CURE YOUR MORTGAGE I>EI<'AULT (Bring it UP to date), NATURE OF THE I)EFAUI,T -- The MORTGAGE debt held by the above lender is on your property located at: 1906 Logan St Camp Hill, PA 17011 IS SERIOUSLY IN DEFAUL~' because: YOU I IA VI' NOT MAI>J' MONTl Il.Y MORT(iAGF I' A YMFNTS for the followin2 months and the fOllowing amount.s are now past due: February I, 2001 through April 1, 2001. See att.ached Exhibit for pa~nent breakdown. Monthly Paymen~ Late Charges NSF Inspections Other Suspense 2,846.73 69.46 0.00 7.25 0.00 TOTAL AMOUNT PAST I>UE: 2,923.44 B. YOU IIA VF l'AILl'D TO TAKE TilE FOLLOWING ACTION (Do not use ifnot applicable): HOW TO CURE nIE I>I<;J"AULT -- You may cure the default within THIR1Y (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST I>Ul<: TO 'I'm: LENI>ER, WHICH IS $ 2,923.44 , PLUS ANY MORTGAGE PAYMENTS ANDJ.ATECHARGES WlIlCH BECOME DUE DUR1NG TilE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashiers check. certified check or money order made pJ!Yable and sent to: Payment Processing GMAC Mortgage Corporation PO Box 780 Waterloo, IA 50704-0780 You c'm c~lre any other delimit by taking the following action within THIRTY (30) DAYS ofthe date of this letter: (Do not use ifnot applicable.) N tAl' b1 - 0 pp l ca e IF YOU 1>0 NOT CURE nn; DEI.'AULT -- If you do not cure the default within THIRTY (30) DAYS ofthe date ofthis Notice, tbe lender intends to exercise its ri2bts to accelerate the mortl:!!f.e debt. This means that tbe entire outstanding balance of this debt will be considered due immediately and you may ose the chance to pay the mortgage in monthly installments.lffull payment of the total amount ]last due is not made within THIRTY (30) DAYS, the lender also intends to instmct its attorneys to start legal actJon to foreeloxe upon your mortgl!~ orooertv. Il<' THE MORTGAGE IS FORECl&~J,1> JJPO~ -- The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. lfthe lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedillgs against you, you will still be required to pay the reasonable ?ttorney's fees that were actually incurred, up to $50.00. lIowever, iflegal proceedlllgs are started agalllst agalllst YOlI, you WIll have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attomey's fees wIiI be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default w;tbin tbe TDlR_TY (3Q) I>AXS pcrijld, yo-"-,,,_i!! not be required 1.'1- Jl~y_a!!orney_'~fees. tf)lt'\\&\1 '" ~, :, ~'" -lJ!' OTHER I,EN))ER REMEJ>H;S -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE J>EI"AULT PRIOR TO SIIER)]o'F'S SALI<: -- If you have not cured the default within the HIlRTY (30) DAY period and foreclosure proceedings bave begun, vou still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paving the total amount then past due. plus any late or other cbary.es then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as s]Jecified in_writing by the lender and by perfonmng any other reglnrements under the mortga~e~ Curing your default in tbe manner set forth in tbix notice wall restore your mOl12agc to the same position as if you had never defaulted. EARLIEST POSSIIII,E SHERIFF'S SALE J>ATE n It is estimated tllat the earliest date tllat such a Sheriffs Sale ofthe mortgaged propcrty could be held would be approximately six (6) months from tbe date oftbis Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will incre~e longer you wait. You may find mlt at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT nm LI<:NJ>ER: Name of Lender: Addres s: GMAC Mortgage Corporation 401 Mile of Cars Way National City, CA 91950 Phone Number: Fax Number: Contact Person: (800) 850.4622 (619) 470-5579 Collection Department EFFI<:CT OF SHI<:RIIIII'S SALE -- You should realize that a Sheriffs 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 fiID1isbings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE .- You mayor may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that tile other requirements of tile mortgage are satisfied. YOU MAY ALSo!!~VE THI<: RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF TIlE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTlTUTION TO PAY OFF nIlS DEBT. TO I1A VI' nIlS DEFAULT CURED BY ANY TIlIRD pAR1Y ACTING ON YOUR BElIALI'. TO I1A VI' 111E MORTGAGE RESTORED TO 'mE SAME pOSlTION AS IF NO DEFAULT I1AD OCCURRED, IF YO\) CURE TIlE DEFAULT. (I10WEVER, YOU DO NOT I1A VI' TlIIS RIG lIT TO CURE YOUR DEFAULT MORE lllAN TIIREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT TIlE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE pROCEI'DlNG OR ANY OlllER I ,A WStJIT INSTITCTED UNDFR TIlE MORTGAGE DOCUMENTS, TO ASSERT ANY OTIIFR DEFEl\SI': YOU BELIEVE YOU MAY I1A VETO SUCII ACTION BY TIlE LFNDER. TO SEEK PROTECTION UNDER Till' FImERAI. BANKRUPTCY LAW. CONSUl\n:R CRl<:J>IT_~OUNSf,LlNG A(a:NClES S~RYI~G YQJ1I{COUNTY IS ENCLOSE)) E;...~\-a~ " - ._1.,. ,,,,,,' .1,- I '-iI!'~~-"'~1 ~ PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY Lycoming..clinton Counties Commision for Community Action (STEP) 2138 Lincoln Street P.O. Bo. 1328 Williams port, P A 17703 (570) 326.0587 FAX (570) 322-2197 CCCS of Northeastern P A 1631 South Athenan St. Suite 100 State College, P A 1680 I (814) 238-3668 FAX (814) 238-3669 CCCS of Northeastern PA 201 Basin Street Williamsport, P A 17703 (570)323-6627 FAX (570) 323-6626 31 W. Marlcet Street ?OB 1127 Wilkes-Barre. PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 COLUMBIA COUNTY 14QO Abington Executive Park Suite 1 Clades Summit, P A 18411 (570) 587.9163 or (800) 922-9537 FAX (570) 587-9134-9135 Commission on Economics Opportunity of Luzerne County 163 Amber Lane Wilkes-Barre. PA 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1 665-{Call Before Faxing) (570) 455-4994 Hazeltown FAX (570) 455-5631-{Call Before Faxing) (570) 836-4090 Tunkhannock CRAWFORD COUNTY Booker T. WashingtOn Center 1720 Holland Center Erie. PA 16503 (814) 453-5744 FAX (814) 5749 Greater Erie Community Action Comminee 18 West 9lh Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 John F. Kennedy Center, Inc. 2021 East 20'" Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412)981.5310 eees of Western Pennsylvania, Inc. 2000 linglestown Road Harrisburg, P A 17102 (717) 541.1757 CUMBERLAl'ID COUNTY Financial Counseling Services of Franklin 31 West ]rd Srreet . Waynesbom, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N.6"'Street Harrisburg, P A 171 0 I (717)234-5925 FAX(717)234-9459 YWCA of Carlisle 301 "0" Street Carlisle, PA 17013 . (717)243-3818 FAX (717) 731-9589 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232.9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St Gettysburg. P A 17325 (717) 334-1518 FAX 334-8326 PENNSYLVANIA BULLETIN, VOL. 29, NO. 23. JUNE 5,1999 ,~.,. Ji. hi L'" '._,._~ '", 0-"":' - ALL ~ CB~H 101:: or piece of land s~~ua~e i~ Borough of Camp H~ll, cuml:>erland County, Stat:e of penns)r1.vanJ..a, IIIOre particularly ~ounde4 aAd descri~ed as follows, to W1t. BBG:z:1IllIJ:HG a~ a point on the Nor-t:.hern side of Logan S-t:.re..-lo, which point .is F.iV~ HU~d~a~i.~~;= (;:I~hf:~1n~"~~ ~~ ~~: ~~~:X'~~~i~~:goi.o~~s~:st.re6'" ..::: 7 .013.. tM hereinafter menUoned l?J.;~ of LOi::.s; thenc'! along the li.ne cb.vH;a.d~i' dLO~o:::. :n~nd:rZe:~~:::iVe degrees 24 ~nui::.es west One un '" J . f 1 d ~~;:~~:i:~. :~::~:;~ E~}JioJli~~~~~:~:~;~:~~~i~~~~i;;~~::i~:::~: (93.S8) feet to a PQ1 d. 1di L ts NOS 7 and 8 South ~ai~ Plan; ~:e:~:u:;~nga::eo;;n:un~;ed ~~n ~nd F~fteen Hundredths (~10~i;~e~eet to ..point on the Nori:h side of Logan.S-t:.r:~t~h:h~:~~ alo~g the NO~,,:h ssi.~; ~tr:r:..ga:u:~~:~t ::v::t:~;n;u~:.~ngThi.rtY_Ei.9ht ::;~~~d:h (';7"i~38) feet a cUstance of one and Seven Hundredths (1.07) feet to a point; thence conti.nuing along the North side of Logan Street by an arc curving to ~he 1ef~ having a radius of Four H~ndred F~~ty (450) feet a d1s~ance of S1xty-Eight and ~hirty-Ei9ht Hundredths (68.38) fee~ to tbe point of BEGINNING - BEJ:aG Lot No. 7 on the plan of camp Hi1.1 Gardens as recorded in the Cumber~and County Recorder's Office in plan Book 8, Page 19. BAvxaG ~RBOR erected a one-story brick ranch dwel~ing house known as and numbered 1906 Logan Street. BEJ:aG ~BE sawE PRl!:MJ:SES 'HB:ECR Phyllis S. Ribsma.., unremarried widow, by her deed dai::.ed June 9, 1988, and recorded June 1.0, 1988 in the Off~ce of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book J, Vo~ume 33, page 1006, granted and conveyed unto WilliamA. Dunke~berger and V..ler~e L. Dunke1herger, hi.s wife, GRABTORS herein. UHJJBR A1iID SUB.J1!:CT, never~heless, to restrictions, reservations, condi~ions, and rights record or visib!.e upon inspec~ion of premises. easements, of ways of ~OGS!r~ with al1. and sing-a.alar, ~he teneme..ts I hereditameni:S and appurtenances to the same be~oZlging or in aaywise appertai.ning, anCl the reversion and 'r!,"versions, remainCler and remainders, rents, issues and profits thereof; AKD ALSO al1 the esta-t:.e, right, tit!.e, interest, property, claim and demand whatsoever, both in law and equity, of -lohe said GRARroRS, of, in, to or oui: of the said premises, and every part and parce~ thereof. :ro HAVB AJIJ) ~O HOLD tl:le said p2:'ellli'lles, with a1.1 and ~be appurtenances, unto the said G~EE, hi.s/ber heirs, to and for the only proper use and behoof of the sai.d hiS/her heirs and assigns, forever. singul.ar assi.gns, GRAH'rBE, AND ~ SAXD GRAH'rORS, for theuaselves, their heirs, executors, anCl administrators, do by these presents, covenant, grant and agree to and with the said GRAR%BE, his/her heirs and assigns, that the said GRABTORS, their he~rs and assigns, a11 and s~ngu1ar the heredi~amen~5 ana pre~ses be~einahove aescr~bed and granted or mentioned, and intended so to ~e, with appurtenances, unto the sai.d GRABTEE, his/her heirs and assigns, against the said GRAH%ORS and the~r heirs and assigns against a11 and every other person or pe2:'sons whomsoever, lawfu11y o1.aiming or to c1aim the same or any part thereof, by, from or under him, her, them or any of them, shall and wi1l by these presen~s SPSCXALLr ~ARD l"OREVBR DEl"EKD. , ~ VERIFICATION SHIRLEY J. EADS hereby states that she is FORECLOSURE SPECIAI.IST ofGMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verificatiou, and that the statemeuts made iu the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best ofber knowledge, information aud belief. The undersigned understaods that this statemeut is made subject to the peualties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~;~ , DATE: 5/:J'-(/J ( .- , f! - ',,"i,"",,' "~~~illi-'l~;i ;d.~~Ji.~:;;t~lb-]~&"-~"'';,,[>.b~'",FI.i!j;):-''~"~;,{!!-''--f,-d--,';--:A'''";,J" ''CO',_'':'"'' h,<,_;<'i"";",i;,':')_'<"-;i"",,,,",,,,,-,,",,,,_,,,,~~,,.-K,b"l~l~ill!li1Yllll~~~Z\li"'''''''''Jt>~l1i~,"~''~~ (~ ~ G)~ ~ -- ?-- cJ -. _. ~ ^ l>J -..\ -. t-' .- <..)> (.N' ~ -.J ~ -t::--' ~~ "'-. "i "~--~, ".~, ~-",. ~_,c._~"~1 "._A,,__~ r':"';;. -, --"'-"1 (~;'i:. . {:::: r><,,'," ~i,- ,--- . " ,--,_cl 5-'~~, -~ ~~ - @ () c, c~, " - t-' ~ ~ , :-'....' :::.J I '" -<, ~"X --.- .-,- 'o.~ -,-, ~- '---li! FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 Attorney for plaintiff GMAC MORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. JEFFREY I. PAUL Cumberland County Defendants :No.01'3290 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ~~ F K FEDERMAN, ESQUIRE Attorney for Plaintiff Date: June 20, 2001 .i ~~ J!J[ ,'~,., ,~-' " - ," "';'"~IR~'''',;c>il'rui*",''-h~,.0;r:~t.~~.tiI!l~~'';''. ,'" .~~. -'"..-1,- o ~ Xl:,!:' n.r" ~e ~~J ~~2 L- :<l ~ .'~~,~ ,~_, ,,1,," _. c - - ~-:... ~. "tlMI c '." ~ o -'n ." N "'" -71 r':': ."~:n -~O ~'_~5 L ._-,C) ~~~ 'J> '.:G -< -0 J;0' :..n ~ ".~- >~~~"'.~. ~ "....-~~~ , - n-',"-'~ , .l"i~;j!;, i SHERIFF'S RETURN, REGULAR CASE NO: 2001-03290 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS PAUL JEFFREY I DAWN KELLL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT ' MORT FORE was served upon PAUL JEFFREY I the DEFENDANT , at 1904:00 HOURS, on the 22nd day of June 2001 at 1906 LOGAN ST CAMP HILL, PA 17011 by handing to JEFFREY I PAUL a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.30 .00 10.00 .00 37.30 r~~~t:~ R. Thomas Kline 06/25/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: CJ~ t kdL Deputy Sheriff I ~-iG day of ,,~,. ~ ,- , i m ~, WA',- SHERIFF'S RETURN ~ NOT SERVED , CASE NO: 2001,03290 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS PAUL JEFFREY I R. Thomas Kline , Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: PAUL JEFFREY I but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT ' MORT FORE REINSTATED NOT SERVED , as to the within named DEFENDANT , PAUL JEFFREY I SINCE DEFT WAS SERVED IN CUMBERLAND COUNTY DO NOT DEPUTIZE DAUPHIN COUNTY PER JASON Sheriff's Costs: Docketing Not Found Out of County Surcharge 18.00 5.00 9.00 10.00 .00 42.00 FEDERMAN 06/25/2001 MAS KLINE FF OF CUMBERLAND COUNTY Sworn and subscribed to before me this ""'~_-F-"_--' . " "' - ".1 " -. " ,~~ -~ J"-IJi FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 AITORNEY FOR PLAINTIFF C) ,- :.. ~ COURT OF COMMON PLE~S.. CIVIL DIVISION>: . GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150, HORSHAM, PA 19044 i---':' ,~-. Plaintiff TERM NO. 01- i~- '. '" v. ?J )... t1'6 "~'.'. ",' v l, I' -- ..' uJ.-V CUMBERLAND COUNTY JEFFREY I. PAUL 1906 LOGAN STREET, CAMP HILL, PA 17011 1". (.() ~l'Ji'(;)y1l1. Defendant(s) ~#,p;t-11'b CIVIL ACTION - LAW ~~ J$l~~ .o-Y~L.. COMPLAINT IN MORTGAGE FORECLOSURE "'/lIij,q,or~ NOTICE 'V "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against yOU by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Loan #: 306586431 CUMBERLAND COUNrY ..~ CUMBERLAND COUNrY BAR ASSOCIATION ~~~ 2 LIBERTY AVENUE \)< ~<?' CARLISLE,PA 17013 ..r~ ~~CJ~.. (717) 249-3166 ;.;.,~~" ~<-'\~ ,<~'VJ~ fo~ '(" TRUE COpy FROM RECmU~\.~ \fI T~ wfl8roof, Iwe unto lilt my "~,\Q ,_! mtl_ GI_ Ooort at CartIsIe, ;'.. ThlIl ~ · ---- -, We hereby certify the within to be a true and correct copy of the original filed of record FEDERMAN AND PHELAN P\4IIM-y - " J............ '~ - '.J_~~ ," :','-0 , '"r ';~ FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150, HORSHAM, P A 19044 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION TERM Plaintiff v. NO. CUMBERLAND COUNTY JEFFREY I. PAUL 1906 LOGAN STREET, CAMP HILL, PA 17011 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." You have been sued in Court If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TIDS 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. . We hGreby certify the within to be a true and correct copy of the original filed of record FEDERMAN AND PHELAN CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 306586431 'FftUI: COPY FROM RECORD III TIItimooy WOOfoof, I t~i!3 lJ1l1(\'lift illy "-' '- ~:;.':~;~~ """'" , . ~ IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM TInS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITlllN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN Al.''iD PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WlTlllN 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. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUli"lG YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAlNT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME Al'1D ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF TInS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS Ac'lD OBLIGATIONS IN THIS SUIT. ~ - , ~~ '~-".'~, "-~ ui\iliht "' ',...'~~ - , 1. Plaintiff is: GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150, HORSHAM, P A 19044 2. The nlUl:l4s) and last known addressees) of the Defendant(s) are: JEFFREY I. PAUL 1906 LOGAN STREET, CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 11113/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1497, Page 972. By Assignment of Mortgage Recorded 7/28/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 620, Page 393. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 2/1101 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." ~- ~'v;o '~ ,. "<f-' "~':"1~ ~ '11U~&"I'_ 6. The following amounts are due on the mortgage: Principal Balance Interest 1/1/01 through 5/110 I (per Diem $19.44) Attorney's Fees Cumulative Late Charges 11/13/98 to 511101 Cost of Suit and Title Search Subtotal $101,381.68 2,352.24 4,000.00 138.92 550.00 $ 108,422.84 Escrow Credit Deficit Subtotal 394.06 0.00 ($ 394.06) TOTAL $108,028.78 7. The attorney's fees set forth above are in confonnity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. rfthe Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. g1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $108,028.78, together with interest from 511I01 at the Tate of$19.44 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. Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~" - ~ ."'- '''O"''--'"~~~i", First Mortgage Loan Servicing PO Box 85071 San Diego CA 92186-5071 3451 Hammond Ave PO Box 780 Waterloo IA 50704-07110 GMAf Mortgage Date: April 11, 2001 ACT 91 NOTICE l'AKE AC1'ION 1'0 SAVE YOUR HOME FROM FORECLOSURE This is all official notice tbat tbe mor\2agc.on yQ!I.! l!o.mcJ.!.!!I,!l~fa.ult, alld theIclldcr intellds to foreclosc. Specifi~!!ofor!!la\io!la_b9ut tbe Ilature oftbc !!.cfault is providcd ill the aHacbed P:,~c;~--' - , Tbe JlO:\:.IlWWN~:!i'~_.MQ~TG1\GE A~~IST,\NCEPR.oG.RA~1 OO;~11\I') may be able to bell' to save your borne. Tbis Notice eXl'lains bow tbe I!!!!gram wOl'ks. To see if HI<:MAP can helUivou must ~IEET WITH A CONSUME~ CREDIT GQJJ~_~!9.jNGAG_k:~C'y WITHIN 30 DAYS OF THE DATE 01" THI~ NOTlCI<:, Take tbis Notice wi!!l yO.!l.~~1! yo_u m~cl ",itb tbc CounseJin2 A2encv. Tbe name. address and "bonc numbcr of Consum.er (;redil!;:ouns~lillgAgcl!.~~~ servin2your Coun~e listed at the end oftbis Notice. If)'Qu haveJillY qll.e~!io.!IJ!,Y!!'" may,~.!!Jbc Pellllsylvallil!.HousiIl2!'1,laJI.c~ Menc)' toll frec at I.800~342.2:?)!7. (p'ersolls lriWl!1!Jlai.rl;!! h!,a,Ii!lg ~all call (717) 780-1869). This ~otice contains hnportant legal infol'lnatioJi, If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain H. You may also want to COU(~ICt an attonicy in your area. Tbe local bar aSlociation may bc able to hell' you find a lawyer. LA :-iOTlFlCACION EN ADJUNTO ES DE SUMA IMI'ORTANCIA, PUES AFI<:C'I'A SU I>I<:RECJlO A CO:-iTlNUAR VIVmNDO EN SU CASA. SI NO CO~Il'RENDE EI. CONTENII>O DE I<:STA NOTIFICACION OBTENGA UNA TRADUCCION DI~mDlATAMENTE LLAMANno ESTA AGE:-iClA (n:NNSYLVANIA HOUSING FI:-iA:'\CE AGENCY) SIN CARGOS AI, NU~IERO MENCIONAno ARRIIlA.I'UEDES SIm ELEGIIlU: PARA U:'\ J'I~ES'LUIO "OR EI. PROGR,UIA LI.,UL\DO "JlO~mOWNER'S !<:;\IERGK-';CY ~IORTGAGE ASSISTA:'\CE I'ROGRAW' m. CUAI. PUEDE SAI.VAR SU CASA DELA PERDIDA DEL DI<:JU:CIIO A REDDUR SU IIII'OTECA JlmIEOW:'\ER'S NA~n:(S): I'ROI'ERTY ADDRESS: JEFFRl::Y I. PAUL 1906 LOGAN ST CAMP HILL, PA 1,011 LOA:'\ ACCT. NO.: ORIGI:-iAL LENDER: CURRE:'\T I.ENDEIUSERVICER: 306586431 N/A GMAC Mortgage Corporation E)(HtBiT A ~- ~"~- ~ ("- 'ri~~~';;. IIOMI<:OWN~:ROS Ei\II<:RGI<:NCY MORTGAGI<: ASSISTANO: PROGRA:\<I YOU MAY BE I<:U(,IBU: FOR FINAi"<l:IAI, ASSJS1:~"CE. WHICH CAN SA VI<: YOUR HOME FROM FORECLOSURI<: AND III<:U~ YOlJMAKI<: FUTURI<: i\K>Ri'GM,-KPAYMI<:NT~ IF YOU COi\-IPI.Y WITH TIll<: PROVISIONS OF TilE 1I0MI<:OWNER'S nmRGENCY MORTGAGI<: ASSIS1'A:-.IO: ACT OF 1983 (TilE" ACT"), YOU MAY liE ~:LIGIIlLI<: FOR I<:MERGI<:NCY MORTGAGI<: ASSISTA:-.IO:: ' II' YOUR m:FAUI,T HAS IIn:N CAUSED IIY CIRCUMSTANO:S YOUR CONTROL, IF YOU....l.\A VI<: A REASONAIILE PROSI'I<:CT OF III<:ING ABU: TO PAY YOUR MORT\.itGI<: PAYMI<:NTS,A:-.ID IF YOU MEI<;T OTHI<:R EUGIllILITY REQUIREMENTS I<:STAIILISIII<:D IIY nm PENNSYLVANIA HOUSING FI:\'A'iO: AGI<:'iCY. TI<:MPORARY STAY OF FORECLOSURE u linder thc Act, you are entitled to a temporary stay offoreclosure on your mortgage for thirty (30) days from llle 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 i\II<:KI'ING MUST OCqJR }VITH!;~_ TIn: ~0T (~,O) n!t n,lf YQr PP NQT 1\1'1'I.y FOR EMERGENCY MORTGAGE ASSISTANCE YOU l\'lUST BRlNG YOUR MORTGAGE UP TO DA l'E. TilE PART OF 111lS , -,. ---,----- -.--- . -.-----.------ NOTICE CAI J .ED "HOW TO .(;UR13.LQ!llU4Q~TQbGE DEI' AUI.T", EX!'),bJNSJ:LO.W TQ-BRI)\1g y-g1JR MORTGAGE UP TO DATE. CONSUMER CRI<:m:U;;.9_UN~I<JJ1'i!L~G_ENClES -. If you meet will, one of the COlmmler credit cOlmseling agencies listed at the end of this notice, the lender may NOT takc action against you for thirty (0) days afier the date of this meeting.The names. addresses an!l.J~~J1!1.Qll.c_ !lJ.mb,"gf desigJ1.ated cJll1~l,cJ11er credit co)mseling agel'cies for the COUlity.in which t)1e PT()J1c.J:ty i~)Qci!l"d!!re setJo!1hat llle cnd o[tl]isJ'io_tice. It is only necessary Io schedulc one face-to-face meeting. Advise your lender immediaIely of your intentions. . APPLICATION FOR MORTGAGE ASSISTA:-.Iq: -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infilnllation about Ihe nature of your default.) If you have tried and are unable to resolve this problemwilll the lender, you have thc right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must ~II out, sign and file a completed Ilomeowner's Emergency Assistance Program Application with one of the deslgnated consumer credit counsehng agencies listcdat the end OfIhis Notice. OnlycOlmllllcr credit counseling agencies have applications fortbe program and they will assist you in submitting a complcte application to the Pennsylvania Ilousing Finance Agency, Your application MUST be filcd or postmarked willlin thirty (0) days of you face-to.face meetmg. YOU MUST FILE YOUR AI'I'UCATIO:'\ I'ROi\IJ'TLY. IF YOU FAIL TO DO SO OR IF YOU no :'\01' FOlJ,QW nJJ<: OTIIl<:R 'IDJ}: PI<:RIODS SET FORTH L\ TillS LKITER, FORECLOSURE ~IA Y PROCI<;U) AGAINST YOUR HOME IM:m:I>1An:J,Y A~J> YOUR APPLICATlO:\ FOR MORTGAGE ASSISTA:\'CE WILL m: J>ENII<:J>. AGE:'\CY ACTION -- Available Jimds for emerpencv mOllP.npe assistance are very limited. They will be disbursed by the Agency u,id;;;' the eligibility criteria e,tabli~hed hy the-A"::\. The I'~nnsylvania Ilou,ine, Finance Agency has sixty (60) days to make J. dedsion after it recein:s your apphcatlO)l. Dunne that tlInc, no ~oreclos\l:e pro~eedlJ1gs will bc pUTSlled again't you if you have met the time requirements set forth above. You w1l1 be notIfied directly by the Pennsylvania Housing Finance Agency of its decision on your apphcatlOn. el~\~\1 ,... if - - , ~ ~- "'- '~f!' ," Nom IVYOO ARE CORRKNTI.V 1'K0lXCJ>" BY 11m ""NO OF A PEnnON IN BANKROM<Y TIm I"OLLOWING PART OF THIS NOTICl<: IS FOR INFORMATION PURPOSI<;S ONLY AND ' snOULD NOT BI<: CONSII>ERI<:D AS AN ATn:MPT TO COLLI<:CI' THI<; I>I<:IlT. __ _ (Ifyou__h~v_e ~c~ ~ankruptcy yo~ can still apply for Emergency Mortgage Assistance.) _ _ _ _ __ _ ____ n _ _ HOW TO CURl<; YOUR MORTGAGI<: I>I<;FAULT (!lring it up to date). NATURI<: OI' Tlm)lI<:I'I\ULT -- The MORTGA(,E debt held by the above lender is on your property located at: 1906 Logan St Camp Hill, PA 17011 IS SERIOUSLY IN DEFAUL1' because: YO\' llA V1'. :"\OT ~vl:\D1'. M01'\TllI.Y MORTC,A<i1'. PA YME',TS j()rthe followinp months and the following amounts are now past due: February I, 2001 through April 1, 2001. See attached Exhibit for pa~nent breakdown. Monthly Paymenfr'" Late Charges NSF Inspections Other Suspense 2,846.73 69.46 0.00 7.25 0.00 TOTAL AMOUNT PAST DUI<:: 2,923.44 B. YO\.' llA \'1'. 1'"AIl.l'.1) TO TAKI, Tll1'. FO! .1.0WI:\(, ACTIO,,", (Do not use ifnot applicahl~): now TO CURl<: 1'111<: m:FAULT -- You may cure the default within TlllRTY (30) DAYS of the date of this notice BY PAYING THI<: TOTAL AMOUNT PAST DU}<: TO TIll<: LENI>I<:R, WlllCIl IS $ 2,923.44 ,PLUS ANY MORTGAGE PAYMENTS ANDLATECIlARGES WlllCH BECOME DUE DURING TilE TIIlRTY (30) DAY PERIOD. Pavments must be made either by cash~cashier~ check. certified chcck or money order made pilyablc and sent to: Pa~nent Processing GMAC Mortgage Corporation PO Box 780 Waterloo, IA 50704-0780 You Can C~ITC any otherdelbult by taking the f()lIowing action within TIIlRTY (30) DAYS of the date of this letter: (Do not use ifnot aj)jllicabJe.] N tAl' . 1 ------- --.- 0 pp leaD e IF YOU DO :"iOT CURE TIlE DEFAULT -- If you do not cure the default within TllIRTY (30) DAYS of the date ofthi~ Notice, the lender intends to exercise its rigJlts to accelerate the mortgl!ge debt. This means that the entire outstandinp balance of this debt will be considercd due immediately and you may lose tile chance to pay the mortgage i~ monthly installments. Iffu1l payment of the total amount past dlle is not made within TIlIRTI' (30) DAYS. the lender also intends to instmct its attorneys to start legal action to foreelose unon your mor!ga2~!! pr01lt:rh', IF TIlE MORTGAGE IS FORECLOSED UPO:>; .- The mortgaged property will be sold by the Sheriff to payoff the mortgage debl.-jftliele"dci ;:efers your-case to its attorncys, but you cure the delinqucncy before the lender bcgins legal proceedings against you, you will still be required to pay the reasonable ,attorney's fees that were actually incurred, up to $50,00. However, iflegal proceedings are started agams! agamst you, you w1l1 have to pay all reasollable attorney's fees actually incurred by the Ienderevell if they exceed $50.00. AllY attorney's fees wlil be added to the amount you owe thc lender, which may also include other reasonable costs, IfYoq.f!!!.uhe_~efault within the.ImRTY (30) DAYS period, you will not be requi."ed to pay atto.f1!ey'sfecs. E){~\B\1 '" .!; 0' ,. - . ," ~ 'r--- ""-'_w ;;'-"'''''!))Y OTlmR I,ENJ>I<:R RI<:MI<:J>II<:S -- The lender m3y 31so sue you personally for the unp3id priucip31 b313nce 3nd 311 other sums due under the mortg3ge. RIGHT 1'0 CURl<; TIlE m:I"AUI,1' PRIOR 1'0 SIII>:RIl>]l'S SAU; ulfyou h3ve not cured the defmdt witllin the TIIIR'IY (30) DAY period and foreclosure proceedings h3ve begun, vou still have the right to cure the def31dt llIld llrevent the sale at anv time Ull to one hour before the Sherifl's Sale. You may do sol1)' llaving the total mnount then llast dlle. lllus llIlV late or other charges then due~3sonable 3ttornev's fees llIld costs connected with the foreclosure sale and any other costs connecteg with th!'..Sl1~.rii!'~ Sale aSJlP~cified in,writing bv the lender and by llerfornlinp 3nv other requirements under!h~ mortgage, Curing your default in the manner set fortb in this notice wJ1l restore your mortgage to the same position as if you bad never dcfaultcd. EARLlI<:ST POSSIIlLI<: SImRII<'I"'S SALE I>A n: h It is estimated th31 the earliest date th3t such a Sheriff's Sale ofthc mortgaged propcrty could be held would bea'pproximately six (6) months from the date oftbis Notice. A notice of the actual date oftlle Sheriffs Sale will bc sent to you before the sale. Of course , thc amount needed to cure the defaulfwill incre.-llle longeryou wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. JJOW TO CONTACT TIn: LI<:NJ>I<:R: Name of Lender: Address: GMAC Mortgage Corporation 401 Mile of Cars Way National City, CA 91950 Phone Number: Fax Number: Contact Person: (800) 8,0'4622 (619) 470'55"/9 Collection Department I<:FFI<:CT OF SIII<:RII<'Jo"S SAI,E -- You should realize that 3 Sheriffs Sale will end your ownership of the mortg3ged property 311d your right to occupy it. If you continue to live in the property 3fier the Sherifl's Sale, a lawsuit to remove you and your filnlishillgS 3nd other belongings could be started by the lender at 311Y time. ASSU:\OIPTION OF MORTGAGE u You mayor may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided thm all the outstanding p3ymellts, charg.es and attomey's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are s3tlsfied. YOU :\OIAY ~L~O n,~VI<:,THE,R!(an: TO SEI.1. TilE PROPERTY TO 0131',\1;>; :\10NFY TO l' A 'I' OFF TIll' MORTGAGE DFBT OR TO BORROW :VIONEY FROM A:\OTIlFR I.lSDJ);G I:\STIT\;lION TO l' A 'I' OFF TlllS DEBT. TO /lA VI' TillS DFFACLT C\JRED BY ,\NY TlllRD PARTY ACTING ON YGl:R BElIALF. TO IlA VF Tlll' ",'lORTCiACiF RI;STOIU;D TO TIIF SA:VIF POSITION AS IF );() DFF:\\"I.T 1l:\D OCCLRRED, IF '1'0\: Cl;RE TIll: DFh\LI.T. (1I0WEVI;R, '1'0\; DO );OT lIA VI' TlllS RIGlIT TO Cl:RF Yo\iR DFF:\\;1.T :vlORF TII:\); TJIRFF TI:\-Il;S IN A);Y CA1.F:\D,\R Yb\R.) TO ASSFRT Till;. :\0l\I;XIST1;:\O, 01; :\ ])]<.1':\\."1.'1' IN A);Y FORFCI.OS\."1{F PROCLJ;J)I:\CI OR A:\Y OTllER LA WSUIT I);STITl"IFD L':\))]',R TIll' ~'IORTC;AC;F DOCL'MF:\TS, TO :\SSFRT A);Y OTllI;R DFFl'.:\SF YO\: BFI.II;VF '1'0\; MAY ll;\ VI' TO S\:Cll :\CTIO:\ BY TIlF 1.F);D FR. TO SFFK PROTECTION t':\j)j;X TilL FJ',))]'.RAI. B;\:\KR\:PTCY I.A W. CONSWr{l<J:I ~1{E!lIT C()l)\SEJ.lNG AGK\CIES SERVING YOUR COUNTY IS K\CI.OSED f::'J.'(\\~~ " , '~ -\ '.......:.~"'~- ",," . '~""<~>-f PENNSYLVAJ'IIA HOUSING FINAJ'ICE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAl\1 CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY Lycoming..clinton Counties Commision for Community A<tion (STEP) 2138 Lin<oln S"..t P,O. Box 1328 WillilllTl$pon. P A 17703 (570) 326-0587 FAX (570) 322-2197 CCCS of Northeastern P A 1631 South Atherton St. Suite 100 State College. PA 16801 (814) 238-3668 FAX (814) 238.3669 cces ofNortheosrern P A 201 Bosin Street WillilllTl$pen. P A 17703 (570) 323-6627 FAX (570) 323-6626 31 W. MarketS-treet_ POB 1127 Wilkes-Barre. PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 COLUMBIA COUNTY 1400 Abington Executive Park Suire [ Clacks Summit.. P A 18411 (570) 587-9163 or (800) 922-9537 FA-X (570) 587-9134-9135 Commission on Economics Opportunity of Luzerne County 163 Amber Lane Wilkes-Barre. PA 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1 665-(Call Before Faxing) (570) 455-4994 Haze1town FAX (570) 455-5631-(Call Before Faxing) (570) 836-4090 Tunkhanno<k Booker T. Washington Center 1720 Holland Center Erie. PA 16503 (814) 453-5744 FA-X (814) 5749 CRAWFORD COl;"'TY Greater Erie Community Action Committee 18 West 911l Street Erie. PA 16501 (814) 459-4581 FAX (814H56-0161 John F. Kennedv Center. Inc. 2021 East 20lll Street . Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 Shenango VatIey Urban League, Inc. 60 1 Indiana Avenue Farrell. PA 16121 (412) 981-;Jl0 CUMBERLAND COL'NTY Financial Counseling Services of Franklin 31 West 3'd Street Waynesboro. PA 17268 (717) 762-3285 eees of Western Pennsylvania, Inc. 2000 Linglestown Road Hl1rrisburg. PA 17102 (717)541-1757 Urban League of Metropolitan Harrisburg N. 6" Street Harrisburg. PA 17101 (717) 234-5925 FA-X (717) 234-9459 YWCA of Carlisle 301 "0" Str..t Carlisle. PA 17013 . (717) 243-3818 FAX (717) 731-9589 Community Action Corron of the Capital Region 1514 Derry Street Harrisburg. PA17104 (717) 232-97;7 FA-X (717) 234-2227 Adams County Housing Authority 139-143 Cariisle St Gl:ttysburg. PA 17325 (717) 334-1518 FAX 334-8326 PE:'INSYLVANIA BULLETIN. VOL. 29, NO. 23. JUNE;. 1999 ,_~" P-- .~~." ~ , ,.'l --, ,~ ..~.' )-~, - ALL ~~ CER~H ~ot or pi.ece o~ land s~tuate i~ Borougb of Camp aill, culllberJ.and Coun~y, S~ate of penns;r~;ran1a, more particularly ~ounded and descri~ed as fo~lows, to W1t. BEG:I:l\lHZNG at a point on the Northern side of Logan Street, which point is Pive Hundred N~ne-Two (S9~) fee~ Ea~t o~ ~~: intersection of 21st Street and Loga~~s~eet~ ~~~~~~e1::i::e: Plan J.ine divi.ding LotS NOS..:...e6 .&J'nde 7~<0:idi:9 L~":.1~OS. 6 and 7 North 37 of ~ts: thence along ~u ~- ~- p' 24 ~nUtes West One Hundred Forty and ~enty- .ve ~eg~ee:thS (140 25) feet to a point on the Southern l1ne of land un ~~ late of cam Hill Estates; thence along the same North 75 ~~;rees 43 =inuteSPEast Ninety-~hree and Eighty-Eight Hund~e:tha (93 88) feet to a point on the line dividing ~otS NOS. 7da~ S ~~ said p1an' thence along the line dividing ~ots N~S. 7 an ou 28 d gree~ 38 minutes East One Hundred ~en and F1fteen Hundredths e 5 fe to a 01n~ on ~he Nor~h side of Logan 5tree~; ~hence < 110.1) <lJo.,..:h 'dP f. -"'an Street bv, an arc:: curving to the 1eft along the Nort 5... e 0 ~'" .. ,', . t Ii:' he baving a radius ot" :rhree Hundred Seventy-One and ~h.r y-~gh Hundredth (37J.. 38) feet a distance of one and Seven Hunere t s (1.07) feet to a point; thence continuing along ~he North s1de of Logan Street ~y an arc curving to the left having a radius of Four Hundred Fifty (450) feet a distance of sixty-Eight and ~hirtY-Eight Hundredtbs (68.38) feet to the point of BEGINNING - I5S:rNG Lot No. 7 on the Plan of Camp Hill Gardens as recorded in the cumberJ.and County Recorder's Offic::e in plan sook 8, page 19. BAV7BG ~RBOB erected a one-story brick ranch dwelJ.ing house known as and numbered 1906 Logan S~reet. BE:I:BG ~as SAME PREM.1:SBS 'NB:teH Phyllis S. Hihaman, unremarried widow, by ber deed dated June 9, 1988, and recorded June 10, 1988 in the Office of ~he Recorder of Deeds in and for Cumber1and County, Pennsylvania in Deed Sook J, vo1ume 33, page 1006, granted and conveyed unto Wil1iam. A. Dunkelberger and Val.eri.e L. Dunkelberger, his wife, GRANTORS herein. tJRDER A!U> SUB.JEc:r, never~heless, to restrictions, reservations, conditions, and rights record or visible upon inspection of premises. !rOGl3~.II..I:..K with aJ.l and singuJ.ar, the tenements, bered~taments and appur~enances toehesamebe~onging or in,anywise apperta:ining, and 'I:he reversi.on and . reversions , rema:inder and remainders, rents, issues and prof:its thereof; AaD ALSO a~L tbe estate, right, t:it1e, interest, property, claim and demand whatsoever, botb .in 1aw and equity, of the said ~ORS, of, in, '1:0 or o~t of the sa:id premises, and every part and parceJ. thereof. easements, of ways of s~ngul.a:t" assigns, GRAll'J:EE, ~o HAVE AND ~o HOLD the said prelll..i..ses, with all and the appurtenances, unto the sa:id G~EE, his/her heirs, to and for the only proper use and behoof of the said hiS/her heirs and assigns, forever. AND ~BE SAID GRAll'XORS, for themselves, their heirs, executors, and adnlinistrat:ors, do by these presents, covenant, grant and agree to and wit:b 'I:he said G~XE, his/her heirs and ass~9ns, ~ha~ ~he said GRABTORS, ~he~r he~rs and assigDs, a11 and singu1a~ ~he heredi~amen~s and premises he~einabove descr~bed and granted or ment:ioned, and intended so to be, with appurtenances, unto the said GRAB~~~, h:is/her heirs and assigns, against the said GRANTORS and their heirs and assigns against all. and every other person or persons whomsoever, 1awrul~y c~a~min9 or to c1aim ~be same or any par~ ~hereof, by~ from or under h~, her, ~he~ or any of them, shall. and will by these presents SPECrALLY HARRABrAKD F'OREVER DEFEHD. -~ 1..,;- .,," > " ~, . 'it' VERIFICATION SHIRLEY J. EADS hereby states that she is FORECLOSURE SPECIALIST ofGMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to tak~ Verification. and that the st3tements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~/~ DATE: ,S;~(/J( ~ , , . '-"),_'i.'_,_', E'"i;lJ'"C:T;'_~:,~,:,,,,, !',,"1:!<li4S$-'i!:-'l<L~~tl:!~%i>,;~;~~-<::;-U1iJ;~ ~ \j\ 'IV l<ll,c Ii 113 d , J I':" '_! '_~ ._', (-", IG. IIJ 9t E II \In, ~, ',l_! :IH'inO ,U!ijlC,'" ,',-'J'HO ,:i:!IH3W:: J'.\i ..lU ,;1. I 'iIl-a;,J~~1!'I&i! _1I!iWh~ ~ ~ ~ ~ . ~~~-. " .~ ~ ,-. r , , FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150 HORSHAM, PA 19044 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Plaintiff : NO. 01-3290 CIVIL VS. JEFFREY I. PAUL 1906 LOGAN STREET CAMP HILL, P A 17011 Defendant PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against JEFFREY I. PAUL, Defendant, for failure to file an Answer to Plaintiff's Cornplaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 5/1101 TO 7/24/01 $108,028.78 $1,652.40 TOTAL $109,681.18 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) notice has been given in accordance with Rille 237.1, copy attached. %OJIL 1JdJJIJ1tlf1 FRANK FEDERMAN, ESQ'tJIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. t~ DATE:.... ),..J.y.:;g u>ol (J.L/1 JAA.J J2_ , PRO PR **TIllS FIRM IS A DEBT COLLECTOR ATtEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED 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 CONSTRUED TO BE AN ATtEMPT TO COLLECT A DEBT, Bur ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** cr, ,~~,~'....... " ,- ,.' . ~-",~' . , '" '"' M_."~":;_'., SHERIFF'S RETURN, REGULAR J~A5~ NO: 2001-03290 P \ COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS PAUL JEFFREY I DAWN KELLL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PAUL JEFFREY I the DEFENDANT , at 1904:00 HOURS, on the 22nd day of June 2001 at 1906 LOGAN ST CAMP HILL, PA 17011 by handing to JEFFREY I PAUL a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.30 .00 10.00 .00 37.30 ?"'~~~t:~ R. Thomas Kline 06/25/2001 FEDERMAN & Sworn and Subscribed to before By: PHELAN <JQW~ t - ~ Deputy Sheriff me this day of A.D. prothonotary "..;,ii".i",~="",,~" U ~, ~- ~ - , l:i;:". ,,,', -~"-,"~". .." "I' '-~,,- FEDERMAN AND PHELAN, L.L.P. , Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS GMAC MORTGAGE CORPORATION CIVIL DIVISION plaintiff CUMBERLAND COUNTY vs. NO. 01-3290 JEFFREY I. PAUL Defendant(s) TO: JEFFREY I. PAUL 1906 LOGAN STREET CAMP HILL,PA 17011 fiLE COpy DATE OF NOTICE: JULY 13.2001 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 PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff .,-'->""'~ . "". ~~ ~ . i c,S~";;'lw.~~;-i .- , FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburbao Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION Attorney for Plaintiff : CUMBERLAND COUNTY Plaintiff : Court of Commou Pleas vs. : CIVIL DIVISION JEFFREY I. PAUL : NO. 01-3290 CIVIL Defendant VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of1940, as amended (b) that defendant JEFFREY I. PAUL is over 18 years of age and resides at 1906 LOGAN STREET, CAMP HILL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ?tM;L,~m~ FRANK FEDERMAN Attorney for Plaintiff .-,-,_._~-- ,--' , "" , ~ ~ ", """I/iM~"!>.";~,m%""'b' ~- - . . , . (Rule of Civil Procedure No. 236 - Revised) GMAC MORTGAGE CORPORATION : CUMBERLAND COUNTY Plaintiff : Court of Commou Pleas vs. : CIVIL DIVISION JEFFREY I. PAUL : NO. 01-3290 CIVIL Defendant Notice is given that a Judgment in the abovll.captioned matter has been entered against you on JULY ~S .2000., _ ~ dOA1L P7J;OUatJDEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party One Penn Center at Suburbao Station Suite 1400 Pbiladelpbia,pJ\ 19103-1814 (215) 563-7000 **TlIIS FIRM IS J\ DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT i\ND .<\NY INFORMATION OBTMNED WILL BE USED FOR THA.T PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED J\ DISCHARGE IN BANKRUPTCY i\ND TIllS DEBT WAS NOT REAFFIRMED, TIllS IS NOT i\ND SHOULD NOT BE CONSTRUED TO BE AN J\TTEMPT TO COLLECT J\ DEBT, BUT ONLY ENFORCEMENT OF J\ LIEN AGJ\lNST PROPERTY. ** ~~~~!j&h;("';:'i:f'_;Jrd~",*~"l!;g.,'-tf<f;\'W!cfG,!,j$""""A'b:">;'"h:i!.:(i.'b""H" "'''''~:'''L-;f_"".!.'_~,,'c!l~;~,"~~iMfI1ll~~OC- ~- ~~ ~l Q ~ - I~ e ~ " - \"J :t: ~ (rJ 3 "" :::! r ~ J ~ ~ B: ~ -~;,;J~~,I.l;~J>ilJ 011 ~~^, 11111._,"",..., .~"',.,"~__~.''''r,j'''_'''' _ ,~~-~"~,~ "_,,<-^,,,,.,.'_,, _'''''~''_~'?~'_"_'~'"~ ,~__ ,,~:,~-,. '_,~ _ C'"_',,_, ",,,-,-'",,_,_,,_r,,_,_ __~_ ln~ .~-- , ~ ~. -~ " c) C ;',) , ~ ~,.J :~) ~_J 'ft- -- _,-' . , , , .~ I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA No.: 01-3290 CIVIL vs. JEFFREY I. PAUL 1906 LOGAN STREET CAMP HILL, P A 17011 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY Kindly mark the judgment that was entered in the above captioned matter on 07/25/01 vacated upon payment of your costs only. ~o.;\fllL Jtt diM..-- Fraok Federman, Esquire Attorney for Plaintiff August 23, 2001 -..- ',-, , ,~ , : 'k",' ~\~il&)i~""""""1fu-_""~,;._~hF"'_Jiitii;6_;i'i~uf;;,,r,;i,!;,,,&;-,,J;;~~-L->';"""!';'~;,jt:i~k~;~iB:;i~:t".i~<~,~;;tl'-',:;\"~J~~~~-~" ..,,; ~s 'f1~ ~ 0 C") C) C -n ~ s: '''' r -00:: ~ nlr----: '" ~f:~~-; 1'" '" (j) r~c -...J "- ~ -<:;, ...... t' ~\.> "'0 - t >c' 11'\ "- Z-:' t:; )>U B c ",-, Z ,:::> ".-": -j :0 -< c=' -< ~ e, : ,JJl,~,_,: .J:~C!L ..~ J JljJ!lLL~.~<,,,~ ~.~_J'_._~"""~-Jj)_,~.", ~".,..,_ ",.._~"",' "_'."' _" --' _"_~_"'_.'" 0,.__"_ " ,~ ,_ -