HomeMy WebLinkAbout01-04563MARK J. tJDREN & ASSOCIATES
BY: Mark J. IIdren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SIIITE 500
CBSRRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland Bank successor by
Merger and Acquisition to
First Federal Savings and
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Loan :Cumberland County
David J. Crook
22 Eastwood Drive
Carlisle,Silver Spring
Township, PA 17013
Defendant(s)
= NO . ~ ~ ~- 'US~L,3
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be
entered 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.
YOII SHOIILD TAKE THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THS OFFICE
SET FORTH BELOW TO FIND OVT WHERE YOII CAN GST LEGAL HELP.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166 or 800-990-9108
~~,_.
Le han demandado a usted en la Corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) digs de plazo al partir de la fecha de la demanda y la
notificacion. xace falta ascentar una comparencia escrita o en
persona o con un abogado y entregar a la Corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la Corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso 0
notificacion. Ademas, la Corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLSVS SETA DBNANDA A IIN ABOGADO IM~DIATAMSNTS, SI NO TISNS ABOGADO
O SI NO TISNH SL DINSRO SIIFSCISNTS D8 PAGAR TAL SSRVICIO, VAYA SN
PERSONA O LLAffi8 POR TSLSFUNO A LA OFICINA CIIYA DIRBCCION S8
SNCIIBNTRA S3C~ITA ABAJO PARR AV8RIGIIAR DONDS SS PIISDS CONS8GIIIR
ASISTBNCIA LEGAL.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166 or 800-990-9108
s,
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
LAW OFFICES OF MARK J. UDREN
/s/ Mark J. Udren, Esquire
1040 N. Kings Highway, Suite 500
Cherry Hill, NJ 08034
(856)482-6900
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. If Plaintiff is an assignee then it
is such by virtue of the following recorded assignments:
Assignor: Hart Mortgage Corp.
Assignments of Record to: HSBC Bank USA f/k/a Marine Midland
Bank successor by Merger and Acquisition to First Federal Savings
and Loan Association of Rochester
Recording Date: 12/29/93 Book: 462 Page: 701
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with PA.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 22 Eastwood Drive
MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Silver Spring
COUNTY: Cumberland
DATE EXECUTED: 12/23/93
DATE RECORDED: 12/29/93 BOOK: 1189 PAGE: 61
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Note as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
7/21/01:
Principal of debt due and unpaid $97,357.41
Interest at 7.00
from 8/1/00 to 7/21/01
(the per diem interest accruing on
this debt is $18.93 and that sum
should be added each day after
7/21/01) 6,625.73
Title Report 250.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $139.89 and that sum should
be added on the first of each
month after 7/21/01) 336.85
Late Charges
(monthly late charge of $33.82
should be added on the fifteenth of
each month after 7/21/01) 914.48
Recoverable Balance 1,500.00
Other Fees 131.50
Attorneys Fees (anticipated and actual
to 5~ of principal) 4.,867.87
TOTAL $112,263.84
7. The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be collected
in the event of a third party purchaser at Sheriff's Sale. If the
mortgage is reinstated prior to the sale, reasonable attorney's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A", and made part
hereof, and defendant(s) have failed to proceed within the time
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $112,263.84 plus interest.,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
rk J'. Udren, ESQUIRE
RK J. UDREN & ASSOCIATES
torney for Plaintiff
torney I.D. No. 04302
ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITIIATE IN T$E TOWNSHIP OF SILVER SPRING,
COIINTY OF CVMHERLAND AND COMMONWEALTH OF PENNSYLVANIA, 88ING MORE PARTICULARLY
BOUNDED AND D83CRISED AS FOLLOWS:
_.-. BEGINNING AT A POINT ON-T88--EASTERN-LINE OF-SASTWOOD DRIVE, AT THS NORT8W8STERN
CORNER OF LOT NO. 25 ON T88 PLAN OF LOTS HEREINAFTER DSSCRISED, T88 PLACE OF
88GINNING; THENCE ALONG T88 DIVIDING LING OF LOTS NOS. 24 AND 25 SOIITH 73 DEGREES
00 MINUTES 00 SECONDS 8A3T 150 FEET TO A POINT; THENCE ALONG T88 LIMB OF LANDS NOW
OR LATE OF J0S8IA J. Z82GL8R, NORTH 17 D8GR885 00 MINUTES 00 SECONDS EAST 100 FEET
TO A POINT-, THENCE ALONG THE DIVIDING LINB OF LOTSNO. 24 AND 23, NORTB 73 DEGREES
00 MINIITES 00 SECONDS W85T, 150 FEET TO A POINT ON TH8 8AST8RN LINE OF EASTWOOD
DRIVE; THENCE ALONG TH8 EASTERN LINB OF EASTWOOD DRIVE, SOD'TH 17 DEGREES 00 MINUT83
00 SECONDS W83T, 100 F88T TO A POINT, T88 PLACE OF BEGINNING.
BEING LOT-NO. 24 ON TEE PLAN OF LOTS KNOWN AS JAY RIDGE MANOR; SECTION A, AS
RECORDED IN THE OFFICE OF TSE RECORDER OF DEEDS FOR CUMHBRLAND COiHdTY IN PLAN HOOK
N0. 22, PAGE 106.
NAVING TSER80N ER$CTED A HI-LEVEL BRICK AND FRAME DWELLING 80IISE KNOWN AND NDM88RED
AS 22 EASTWOOD DRIVE.
i ~.
HSBC m
May 17, 2000
- __---
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on
The HOMEOWNER'S MORTGAGE ASS
home is in
if.HEMAP can help. you must MEET
La notificacion en adjunto es de suma importancia, pues afecta
su derecho a cont'inuar viviendo en au casa. Si no comprende el
contenido de esta notificacion obtenga una traduccion
inmediatamente llamando esta agencia (Pennsylvania Housing
Finance Agency) sin cargos al numero mencionado arriba. Puedes
ser elegible para un prestamo por el programa llamado "Homeowner's
Emergency Mortgage Assistance Program" el cual puede salvar su
casa de la perdida del derecho a redimir su hipoteca.
EXHIBIT A
HSBC Mortgage Corporation (USA)
2929 Walden Avenue, Depew, NY 14043 ~N
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.
HSBC m
Mortgage Account Number 119142-3
Page 2
May 17, 2000
Homeowner's Name(s): David J Crook
Property Address: 22 Eastwood Dr
Carlisle PA 17013
Loan Account Number: 119142-3
Original Lender: FIRST FED
(If original lender blank then original lender and current lender
are same).
Current Lender/Servicer: HSBC Mortgage Corporation (USA)
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
BE ELIGIBLE FOR FINANCIAL
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE
FOR EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY-
BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY C
YOUR CONTROL,
BEYOND
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 o orec osure on your mortgage for thirty (30)
days from the date of this Notice. During that time you must
arrange and attend a "face-to-face" meeting with one of the
consumer credit counseling agencies listed at the end of this
Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF
XC805
HSBC Mortgage Corporation (USA)
2929 Walden Avenue, Depew, NY 14043 F0p°1X01~
LENDER
HSBC m
Mortgage
Page 3
May 17,
Account Number 119142-3
2000
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one
consumer cre it counse ing agency fisted at the end of this
the lender may NOT take action against you for thirty (30)
the date of this meeting. The names, addresses and tele h
of designated consumer credit counseling agencies o
lender
scneaule one race-z
of your intentions.
of the
notice,
days after
one numbers
se your
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default
or t e reasons set ort ater in this Notice (see following pages
for specific information about the nature of your default.) If you
have tried and are unable to resolve this problem with the lender,
you have the right to apply for financial assistance from the
Homeowner's Emergency Mortgage Assistance Program. To do so, you
must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer
credit counseling agencies listed at the end of this Notice. Only
consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the
Pennsylvania Housing Finance Agency. Your application must be filed
or postmarked within thirty (30) days of your face-to-face meeting.
YOU MUST FIi,E YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF
YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance
are very united. They will be disbursed by the Agency under the
eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after
it receives your application. During that time, no foreclosure
proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your
application.
HSBC Mortgage CorporatiDD (USA)
2929 Walden Avenue, Depew, pry 14043 F°1V°tl01°1B
LENDER
~HSBC m
Mortgage Account Number--119142-3
Page 4
May 17, 2000
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION
IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed ban7cruptcy you can still apply for Emergency
Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender
on your property ocated at: 22 Eastwood Dr
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following
months and the following amounts are now past due:
XC807
HSBC Mortgage Corporafion (USA)
2929 Walden Avenue, Depew, NY 14043 _ ~ o~
03-01-00 throu h 05-01-00 $ 2,540.05
Ot er c arges
HSBC
Mortgage Account Number 119142-3
Page 5
May 17, 2000
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not
applicable):
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30)
DAYS o t e ate o t is notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER, WHICH IS $ 3,185.87, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cash, cashier's check, certified
.. ..,. _ ,.v .~,..,,... ,.ra -~--~-.~ ae..t ,-„ .
HSBC Mortgage Corporation (USA)
Suite 3201
Buffalo, NY 14270-3201
You can cure any other default by taking the following action within
THIRTY (30) DAYS of the date of this letter: (Do not use if not
applicable.)
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default
wit in THIRTY 30 DAYS o t e date of this Notice, the lender
intends to exercise its rights to accelerate the mortcraae cTe~t.
be considered due immediately and you may lose the chance to pay
the mortgage in monthly installments. If full payment of the
total amount past due is not made within THIRTY (30) DAYS, the
lender also intends to instruct its attorneys to start legal action
to foreclose upon your mortgaged. property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be
so y t e S eri to pay o t e mortgage debt. If the lender
refers your case to its attorneys, but you cure the delinquency
before the lender begins legal proceedings against you, you will
still be required to pay the reasonable attorney's fees that were
actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's
fees actually incurred by the lender even if they exceed $50.00.
Any attorney's fees will be added to the amount you owe the lender,
which may also include other reasonable costs. If you cure the
default within the THIRTY (30) DAY reriod, you will nom required
HSBC Mortgage CorporatioD (USA) -
2929 Walden Avenue, Depew, NY 14043 ~X016"B
LENDER
HSBC /D
Mortgage Account Number 119142-3
Page 6
May 17, 2000
OTHER LENDER REMEDIES - The""lender may also sue you personally for
t e unpai principa balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not
cure t e e au t wit in t e THIRTY 30 DAY period and foreclosure
proceedings have begun, you still have the right__to cure the default
and prevent the sale at any time u to one our a ore t e S eri 's
Sale. oY` u may do s~navina~l amount t en east due, plus
curing your ae=ault in the manner set =ortn in tnis notice wil
restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the
ear lest ate t at suc a S eri 's Sale of the mortgaged property
could be held would be approximately six (6) months from the date of
this Notice. A notice of the actual-date of the Sheriff's Sale will
be sent to you before the sale. Of course, the amount needed to cure
the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by
contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender
A ress•
P 'q~i ne Number
Fax Nu er:
Contact Person•
HSBC Mortgage Corporation (USA)
2929 Walden Avenue, Depew, NY 14043
HSBC Mortgage Corporation (USA)
Suite 3201, Buffalo, NY 14270-3201
(800) 338-6441
(716) 651-6943
Patricia Hartsock
EEEEI XEIIGYE
LENDER
HSBC m
Mortgage Account
Page 7
May 17, 2000
Number 119142-3
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale,
wi en your owners ip of the mortgaged property and your right to
occupy it. If you continue to live in the property after the
Sheriff's Sale, a lawsuit to remove you and your furnishings and
other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You X may or may not (CHECK
ONE) sell or transfer your home to a buyer or transferee who will
assume the mortgage debt, provided that all the outstanding
payments, charges and attorney's fees and costs are paid prior to
or at the sale and that the other requirements or the mortgage are
satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT 'TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
Sincerely,
Ms. R. Morgan
Default Compliance Specialist
Default Servicing Department
XC811
HSBC Mortgage Corporation (USA)
2929 Walden Avenue, Depew, NY 14043 Rw.eomw
LEROER
~„
address below:
rFq.c.,r;, ._ _.
3: Type
Certified Mai{ O Expess Mal
~' ^ Registered ^ Retum Receipt for Merchandi:
'~ Tl r..~~~.ew u~a 1"1 r. n n .....,
`'+'j~.A•r`-•. 14. Restricted Delivery? (Extra Fee) ~ .. ~ Yes
x .
K;~ l ~ 9t zfa3 .,
Domestic Retum Receipt
Mark J. Udren, Esquire, hereby states that he is the attorney
for the Plaintiff, a corporation unless designated otherwise; that
he is authorized to take this Verification and does so because of
the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he has
personal knowledge of some of the facts averred in the foregoing
pleading; and that the statements made in the foregoing pleading
are true and correct to the best of his knowledge, information and
belief and the source of his information is public records and
reports of Plaintiff's agents. The undersigned understands that
this statement herein is made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
Mark J. Udren, ESQUIRE
MARK J. UDREN & ASSOCIATES
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-04563 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HSBC BANK USA ET AL
VS
CROOK DAVID J
TIM REITZ
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
DAVID
the
DEFENDANT at 2116:00 HOURS, on the 15th day of August 2001
at 22 EASTWOOD DRIVE
CARLISLE, PA 17013 by handing to
DAVID J CROOK
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 18.00
Service 4.55
Affidavit .00
Surcharge 10.00
.00
32.55
So AnsweQQrs~~:
R. Thomas Kline i
09/16/2001
MARK UDR^"'
Sworn and Subscribed to before By:
me this 30 ~ day of
.~ urk ~yonl A.D.
-~ C.~ ~~0
P othonotary '
,.. ...
MARK J. UDREN & ASSOCIATES
BYE: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHAIAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition -
to First Federal Savings and
Loan
Association of Rochester -
Plaintiff
v.
David J. Crook
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 01-4563 Civil Term
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification for the
Verification attached to the Complaint in Mortgage Foreclosure with
regard to the captioned matter.
DATED: September 18, 2001
MARK J. UDREN & ASSOCIATES
BY:
Esquire
Plaintiff
.~
The undersigned, an officer of the Corporation which is the
Plaintiff in the foregoing Complaint or an officer of the
Corporation which is the servicing agent of Plaintiff, and being
authorized to make this verification on behalf of the Plaintiff,
hereby verifies that the facts set forth in the foregoing Complaint
are taken from records maintained by persons supervised by the
undersigned who maintain the business records of the mortgage held
by Plaintiff in the ordinary course of business and that those
facts are tx'ue and correct to the best of the knowledge,
information and belief of the undersigned.
The undersigned understands that this statement is made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: ~~\
.~ . ~~~~~
/~~d~ _`
Name:
Title: l~enee Crane #11968
Company: .
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition
to First Federal Savings and
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
ATTORNEY FOR PLAINTIFF
'COURT OF COMMON PLEAS
:CIVIL DIVISION
-Cumberland County
:MORTGAGE FORECLOSURE
NO. 01-4563 Civil Term
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
Defendant(s) for failure to file an Answer to Plaintiff's Complaint
within 20 days from service thereof and for foreclosure and sale of the
mortgaged premises, and assess Plaintiff's damages as follows:
As set forth in Complaint $112,263.84.
Interest Per Complaint 1,116.87
From 7/22/01 to 9/18/01
Late charges per Complaint 67.64
From 7/22/01 to 9/18/01
Escrow payment per Complaint 279.78
From 7/22/01 to 9/18/01
TOTAL
I hereby certify that (1) the addresses of the Plaintiff and
Defendant are as shown above, and (2) that notice has been given in
accordance with Rule 237.1, a copy of which is attached hereto.
J. REN & ASSOCIATES
Mark J. Udr n, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE: ~~ ~~-yI
PRO PROTHY
MARK J. IIDREN & ASSOCIATES
BY: Mark J. IIdren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SIIITE 500
CHERRY HILL, NJ 08034
HSBC Bank USA fjkja Marine Midland
Bank Successor bx Merger and
Acquisition to First Federal Savings
and Loan Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring Township, PA
17013
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 01-4563 Civil Term
DATED: September 7, 2001
TO: David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring Township, PA 17013
INPORTANT 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 DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249.-3166 or 800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166 or 800-990-9108
NOTICE: PIIRSIIANT TO THE FAIR D88T COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DSST. ANY INFORMATION OBTAINED WILL B8 IISED FOR THAT
PIIRPOSA.
MARK J. ffDREN & ASSOCIATES
BY: Mark J. IIdrea, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SIIITS 500
CHERRY HILL, NJ 08034
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition
to First Federal Savings and
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 01-4563 Civil Term
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF '~~„J" ~(~~
COUNTY OF ~~
SS
THE UNDERSIGNED being duly sworn, deposes and says that the
averments herein are based upon investigations made and records
maintained by us either as Plaintiff or as servicing agent of the
Plaintiff herein and that the above Defendant(s) are not in the
Military or Naval Service of the United States of America or its
Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, as amended; and that the age and last known residence and
employment of each Defendant are as follows:
Defendant:
Age:
Residence:
Employment:
Defendant:
Age:
Residence:
Employment
David J. Crook
Over 18
As captioned above
Unknown
Over 18
As captioned
Unknown
Sworn to and subscribed
before a this ~~'' day
~r 2 00~ .
o Pu lic
JOYCE E. BURKOWSKI
Notary Public, State of New York
Qualified in Erie Couniy )
My Commission Expires Oct. 4,
above
Name:
Title:
Company:
Crane #1196$
docket fot Case: '" + GetCaseNoQ + " (" + DktTypeExpand(txi.gsDktType) + ") Page 1 of 2
Bankruptcy Docket Report
100-02812 (Harrisburg)
CROOK, DAVID J.
Docket items entered between 01/01/1931 and 09/10/2001
Filing No. Docket Entry
Date
06/23/00 1 VOLUNTARY PETITION under chapter 13 [EOD 06/23/00] [JR]
06/23/00 2 NOTICE of intent to dismiss case unless missing documents aze filed: due by 07/10/00 Re: Item # 1.
[Complied] [EOD 06/23/00] [JR]
07/13/00 3 CORRESPONDENCE to Attorney allowing until July 19, 2000 to file missing documents. Re: Item #
2. [EOD 07/13/00] [CA]
07/27/00 4 ORDER dismissing case for debtor's failure to FILE THE REQUIRED DOCUMENTS [EOD
07/27/00] [JC}
07/28/00 5 MOTION to reconsider Order FILED BY DEBTOR [Disposed] (EOD 07/31/00] [JC)
MOTION of Debtor to reinstate case [Disposed] [EOD 07/31/00] [JC]
07/31/00 6 Schedules, Statements, Plan & Summary and all missing documents Re: Item # 2. [EOD 08/01/00)
[CA]
08/01/00 7 ORDER vacating Re: Item # 4. [EOD 08/01/00] [JC]
This entry disposes of motion. Re: Item # 5. [EOD 08/01/00] [JC]
ORDER reinstating case Re: Item # 5. [EOD 08/01/00] (JC]
08/02/00 8 FINAL REPORT of Ch. 13 Trustee [EOD 08/02/00] [JC]
08/04/00 9 NOTICE TO CREDITORS OF ORDER REINSTATING CASE Re: Item # 7. [EOD 08/04/00] [JC]
08/11/00 10 CERTIFICATE of Mailing of Notice of 341 Meeting. Objections to the plan are due 15 days after
meeting held. [EOD 08/11/00} [CA]
10/02/00 11 341 meeting held. [EOD 10/02/00] [CA]
10/27/00 12 ORDER Confirming Plan [EOD 10/29/00] [JC]
02/05/01 13 MOTION for relief from stay HSBC MORTGAGE CORPORATION FEE PD. $75.00 #565863-BR
[Disposed] [EOD 02/05/01] [JC]
REQUEST for admission (EOD 02/05101] [JC]
CERTIFICATE OF NON-CONCURRENCE [EOD 02/05101} [JC]
02/05/01 14 ORDER that answers azedue on 02/26/01. Re: Item # 13. [EOD 02/05/01 ] [JC]
02/16/01 15 CERTIFICATE of service Re: Item # 14. [EOD 02/16/01] [JC)
02/21/01 16 ANSWER by DEBTOR Re: Item # 13. [EOD 02/22/01) (SP]
03/01/01 17 CORRESPONDENCE from Movant requesting matter be listed for hearing. Re: Item # 16. [EOD
03/01/01] [JG)
03/02/01 I S CORRESPONDENCE SETTING HEARING on 03/21/01 at 09:30 A.M. at FED.BLDG., BKRPTCY
CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 13. [EOD
03/02/01][JC]
05/21/01 19 PROCEEDING MEMO re hearing not held. Debtor is consenting to motion. Order lifting stay can be
http://pacer.pamb.uscourts.gov/cgi-bin/foxweb.exe/npacer/nPacer?ExecThis=docket&puic... 09/10/2001
Docket For Case: " + GetCaseNoQ + " (" + DktTypeExpand(m.gsDktType) + ") Page 2 of 2
entered. Re: Item # 16. [EOD 05/21/01] [TG]
' 05/21/01 (20 ~ ORDER granting relief from stay Re: Item # 13. [EOD 05/21/01] [JC]
PACER Service Center
Transaction Receipt
09/10/2001 11:55:58
PACER Login: mu0011 Client Code:
Description: Docket Case Number: 1 2000-02812
Billable Pages: 0 Cost: 0.14
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MARK J. UDREN & ASSOCIATES
SY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition
to First Federal Savings and
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 01-4563 Civil Term
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Amount due $113,728.13
Interest From 9/19/01 3 199.17
to Date of Sale March 6, 2002
Per diem @$18.93
(Costs to be added) $
_~~:s-..
MARK J. UDREN & ASSOCIATES
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland .
Bank successor by Merger and
Acquisition
to First Federal Savings and ,
Loan
Association of Rochester -
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
`'~ `~ ~/1
5
NO. 01-4563 Civil Term
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the judgment, interest and costs in the above matter, you
are directed to levy upon and-sell the following described property:
22 Eastwood Drive
Silver Spring Township, PA 17013
SEE LEGAL DESCRIPTION ATTACHED
Amount due
Interest From 9/19/01
to Date of Sale March 6, 2002
Per diem @$18.93
(Costs to be added)
By
$113,1 8.13
Prothonotary
Clerk
Date
ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITVATE IN THE TOWNSHIP OF SILVER SPRING,
COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE PARTICULARLY
BOUNDED AND DESCRIBED A5 FOLLOWS: ~-
BEGINNING AT A POINT ON THE EASTERN LINE OF EASTWOOD DRIVE, AT THE NORTHWESTERN
CORNER OF LOT NO. 25 ON THE PLAN OF LOTS HEREINAFTER DESCRIBED, THE PLACE OF ~ .
BEGINNING; THENCE ALONG THE DIVIDING LINE OF LOTS NOS. 24 AND 25 SOUTH 73 DEGREES
00 MINCJTES 00 SECONDS EAST 150 FEET TO ~A POINT; THENCE ALONG THE LINE OF LANDS NOW
OR LATE OF JOSHLA J. 2ETGLER, NORTH 17 DEGREES 00 MINUTES 00 SECONDS EAST 100 FEET
TO A POINT; THENCE ALONG THE. DIVIDING LINE OF LOTSNO. 24 AND 23, NORHT 73 DEGREES
00 MINUTES 00 SECONDS WEST, 150 FEET TO A POINT ON THE EASTERN LINE OF EASTWOOD .
DRIVE, SOUTH 17 DEGREES 00 MINUTES 00 SECONDS WEST, 100 FEET TO A POINT, THE PLACE
OF BEGINNING.. ~ -
BEING LUT NO. 24 ON THE PLAN OF LOTS KNOWN AS JAY RIDGE MANOR; SECTION A, AS
RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY LN PLAN BOOK
NO. 22, PAGE 106. ,
HAVING THEREON ERECTED A BI-LEVEL BRICK AND FRAME DWELLING HOUSE KNOWN AND NUMBERED
AS 22 EASTWOOD DRIVE.
BEING KNOWN AS 22 EASTWOOD DRIVE, CARLISLE, PA 17013.
PROPERTY ID NO.: 38-23-0583-027
TITLE OF SAID PREMISES IS VESTED IN DAVID J. CROOK, MARRIED MAN, BY /
DEED FROM ROBERT C. WOLF AND HELEN JANE WOLF, HIS WIFE, AND THE /,
HOMESTEAD GROUP, INC., A PENNSYLVANIA CORPORATION. DATED
08/24/1993, RECORDED 12/29/1993, IN DEED BOOK S 36, PAGE 688.
,
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. N0.04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger
Acquisition
to First Federal Savings
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
=MORTGAGE FORECLOSURE
ATTORNEY FOR PLAINTIFF
"COURT OF COMMON PLEAS
:CIVIL DIVISION
:Cumberland County
and
and
NO. 01-4563 Civil Term
Defendant(s)
CERTIFICATE TO THE SHERIFF
I HEREBY CERTIFY THAT:
I. The judgment entered in the above matter is based on an Action: -
~. In Assumpsit (Contract)
B. In Trespass (Accident)
~C. In Mortgage Foreclosure
-D. On a Note accompanying a purchase money mortgage and the property
being exposed to sale is the mortgaged property.
II. The Defendant(s) own the property being exposed to sale as:
-X_A. An individual
B. Tenants by Entireties
C. Joint Tenants with right of survivorship
D_ A partnership
E. Tenants in Common
F. A corporation
III. The Defendant(s) is (are):
-8_A. Resident in the Commonwealth of Pennsylvania
B. Not resident in the Commonwealth of Pennsylvania
C. If more than one Defendant and either A or B above is not applicable,
state which Defendant is resident of the Commonwealth of
Pennsylvania.
Resident:
rk J. Udre ESQUIRE
Address & I.D. above
MARK J. UDREN & ASSOCIATES
BY: Mark J. IIdren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITB 500
CHERRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition
to First Federal Savings and
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
Defendant(s)
01-4563 Civil Term
' NO
C E R T I F I C A T E
Mark J. Udren, Esquire, hereby states that he is the attorney for
the Plaintiff in the above-captioned matter and that the premises are not
subject to the provisions of Act 91 because it is:
( ) An FHA insured mortgage
( ) Non-owner occupied
( ) Vacant
( X ) Act 91 procedures have been fulfilled.
( ) Over 24 months delinquent.
This certification is made subject to the penalties of 18 Pa. C.S.
Sec. 4904 relating to unsworn falsification to authorities.
/ MP REN & ASSOCIATES
Ma k J. Ud ESQUIRE
ATTORNEY FOR PLAINTIFF
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITS 500
CHERRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition
to First Federal Savings and
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 01-4563 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and
Acquisition to First Federal Savings and Loan Association of Rochester,
Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets
forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at: 22
Eastwood Drive, Silver Spring Township, PA 17013
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
David J. Crook
22 Eastwood Drive, Carlisle,
Silver Spring Township, PA 17013
2. Name and address of Defendant(s) in the judgment:
Name Address
Same As #1, Above
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
None
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein. See Caption above.
CitiFinancial, Inc. 3401 Hartzdale Drive, Suite 126
Camp Hill, PA 17011
5. Name and address of every other person who has any record lien on the
property:
Name Address
None
6. Name and address of every other person who has any record interest in
the property and whose interest may be affected by the sale:
Name Address
Real Estate Tax Dept
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
1 Courthouse Square, Carlisle, PA 17013
13 N. Hanover Street, Carlisle, PA 17013
Bureau of Compliance, Dept. 280946
Harrisburg, PA 17128-0946
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:
Name Address
Tenants/Occupants 22 Eastwood Drive, Carlisle,
Silver Spring Township, PA 17013
I verify that the statements made in this affidavit are true and correct
to the best of my personal knowledge or information and belief. I
understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
DATED: September 18, 2001
K J. UDREN & ASSOCIATES
Mark J. Udren, ESQ.
Attorney for Plaintiff
~.
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SIIITE 500
CHERRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition
to First Federal Savings and
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
01-4563 Civil Term
' NO
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring Township, PA 17013
Your house areal estate) at 22 Eastwood Drive, Carlisle, Silver Spring
Township, PA 17013 is scheduled to be sold at the Sheriff's Sale on
March 6, 2002, at 10:00 a.m. in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA to enforce the court judgment of
$113,728.13, obtained by Plaintiff above (the mortgagee) against you. If
the sale is postponed, the property will be relisted for the Next
Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY B TO R NT THT H T F' T
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must pay,
you may call: (856) 4a2-6900.
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
. '~. -
vpt7 any gmrrr gg A3L•E TO SAVE YOUR PROPERTY Ap7D YOU HAVE OTHER RIGHTS
''~[raN rF THS SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-482-6900.
2. You may be able to petition the Court to set aside the sale ifthe 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 656-482-6900.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
Y0II SHOIILD TA&8 THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TSLEP80N8 THS OFFICE LISTED 88LOW TO FIND ODT WHERS YOII CAN
G8T LEGAL BELP.
LAWYER REFERRAL SSRVICB
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166 or 800-990-9106
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166 or 800-990-9108
,.~,.,.
I ~ F y
!' //'~:
~. /
ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING,
COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE PARTICULARLY "
BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT ON THE EASTERN LINE OF EASTWOOD DRIVE, AT THE NORTHWESTERN
CORNER OF LOT NO. 25 ON THE PLAN OF LOTS HEREINAFTER DESCRIBED, THE PLACE OF
BEGINNING; THENCE ALONG THE DIVIDING LINE OF LOTS NOS. 24 AND 25 SOUTH 73 DEGREES
00 MINUTES 00 SECONDS EAST 150 FEET TO ~A POINT; THENCE ALONG THE LINE OF LANDS NOW
OR LATE OF JOSHLA J. ZE IGLER, NORTH 17 DEGREES 00 MINUTES 00 SECONDS EAST 100 FEET
TO A POINT; THENCE ALONG THE. DIVIDING LINE OF LOTSNO. 24 AND 23, NORTT 73 DEGREES
00 MINUTES 00 SECONDS WEST, 150 FEET TO A POINT ON THE EASTERN LINE OF EASTWOOD .
DRIVE, SOUTH 17 DEGREES 00 MINUTES 00 SECONDS WEST, 100 FEET TO A POINT, THE PLACE
OF BEGINNING..
BEING LUT N0. 24 ON THE PLAN OF LOTS KNOWN AS JAY RIDGE MANOR; SECTION A, AS
RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY LN PLAN BOOK
NO. 22, PAGE 106.
HAVING THEREON ERECTED A BI-LEVEL BRICK AND E'RAME DWELLING HOUSE KNOWN AND NUMBERED
AS 22 EASTWOOD DRIVE.
BEING KNOWN AS 22 EASTWOOD DRIVE, CARLISLE, PA 17013.
PROPERTY ID NO.: 38-23-0583-027
TITLE OF SAID PREMISES IS VESTED IN DAVID J. CROOK, MARRIED MAN, BY
DEED FROM ROBERT C. WOLF AND HELEN JANE. WOLF, HIS WIFE, AND THE
HOMESTEAD GROUP, INC., A PENNSYLVANIA CORPORATION. DATED
08/24/1993, RECORDED 12/29/1993, IN DEED BOOK S 36, PAGE 688.
r
n~..s
. `°
MARK J. UDREN & ASSOCIATES
BY: Mark J. IIdren
ATTY I.b. NO. 04302
1040 N. ICINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition
to First Federal Savings and
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
Defendant(s)
ATTORNEY FOR PLAINTIFF
'COURT OF COMMON PLEAS
:CIVIL DIVISION
•Cumberland County
:NO. 01-4563 Civil Term
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies
that:
1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which
is attached hereto as Exhibit "A", was 'sent to every recorded lienholder and
every other interested party known as of the date of the filing of the
Praecipe for the Writ of Execution, on the date(s) appearing on the attached
Certificates of Mailing.
2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and
certified mail on the date appearing on the attached Return Receipt, which
was signed for by Defendant (s) on the date specified on the said Return
Receipt. Copies of the said Notice and Return Receipt are attached hereto as
Exhibit "B".
3. If a Return Receipt is not attached hereto, then service was by personal
service on the date specified on the attached Return of Service, attached
hereto as Exhibit "B".
4. If service was by Order of Court, then proof of compliance with said
Order is attached hereto as Exhibit "B".
All Notices were served within the time limits set forth by Pa Rule C.P.
3129.
This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Dated: January 29, 2002 MARK J. UDREN & ASSOCIATES
BY:
Mark J. Udren, Esquire
Attorney for Plaintiff
.+ 1
MARK J. UDREN & ASSOCIArTES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900 '
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition
to First Federal Savings and
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY ''7.4043
--J Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
Defendant(s)
DATE: September 20, 2001
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
N0. 01-4563 Civil Term
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): DAVID CROOK
PROPERTY: 22 Eastwood Drive Silver Spring Township, PA 17013
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
C~erland County Sheriff's Sale on March 6. 2002, at 10:00 a.m.,
at the CONIl~IINSSIONEERS HEARING ROOM, 2ND FLOOR, COURTHOUSE,
CARLISLE, PA. Our records indicate that xou may hold a mortgage
or judgment on the property which will be extinguished by the sale.
You may wish to attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date
specified by the Sheriff not later that 30 days after sale.
Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the
schedule. r
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-~.a-.rmssFrsSPm#m .si'se .. - A1~T .+•.Axnvo. _
S
STATE OF PENNSYLVANIA, l
COUNTY OF CUMBERLAND S ss.
Robert P Ziegler
I+-------------------------^------
Rccarderof
Deeds in and for said Cotmty and State do~hereby certify that the 5heri[fs Deed in which
Veterans Affairs Sec of
the same having been sold to said grantee on the ____
March
------------------------------------°--- A. D.,.
Execution
6th
is the grantee
day of
2002
_____, under and by virtue of a writ______________
24th
issued on the -------------------------------------
Sept 2001
day of __________________________ A. D., _____y out of the Court of Comtnan Pleas of said County as of
Civil 2001
---------~------^--------------•-------------------~------------------------------ Term,.
.-----
4563 HSBC Bank USA fka Marine Midland Bank
Number __________ y__, at thcsuitof ______.ohm-to-~irs-E-~ed-orai--Sa~+s-$c-3-a- ~kssee-~€
Rochester David J Crook
-----°-----'---'------------------ against-------------'--------'----------"------'---------- ~
duly recorded in Sheriffs Deed Book No. ____ 241 ___, Page _____ 88 __^.
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said o[fice this _ ~________ day
of __ ~~ ~ ------------------- A. D., ~~ ~_
--- -------- --- ----------------
Recorder of Deeds
HSBC Bank USA f/k/a Marine Midland
Bank, successor by merger and acquisition
To First Federal Savings and Loan
Association of Rochester
VS
David J. Crook
hi The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-4563 Civil Term
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states
that on November 6, 2001 at 9:05 o'clock pm, EST, he served a true copy of the within
Real Estate Writ, Notice and Description, in the above entitled action, upon the within
named defendant, to wit: David J. Crook, by making known unto David Crook
personally, at 22 Eastwood Drive, Carlisle, Cumberland County, Pennsylvania, its
contents and at the same time handing to him personally the said true and correct copy of
the same.
Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that
on January 03, 2002 at 9:30 o'clock A.M., E.S.T., he posted a true copy of the within
Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of David J. Crook located at 22 Eastwood Drive, Carlisle, Pennsylvania,
according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: David J. Crook, by regular mail to his last known address of 22
Eastwood Drive, Carlisle, PA 17013. This letter was mailed under the date of January
18, 2002 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the
sum of $1.00 to Attorney Mark J. Udren for The Secretary of Veteran Affairs, an Officer
of the United States of America, its successors and assigns at law. It being highest bid
and best price received for the same The Secretary of Veteran Affairs, an Officer of the
United States of America, its successors and assigns at law of 5000 Wissahickon Avenue,
Philadelphia, PA 19144, being the buyer in this execution paid Sheriff R. Thomas Kline
the sum of $857.14, it being costs.
Sheriff s Costs:
Docketing 30.00
Poundage 16.81
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
.50
1.00
6.50
1.63
15.00
20.00
330.50
289.50
24.20
25.00
26.50
$857.14 paid 3/13/02
Sworn and subscribed to before me
This ~ day of
2002, A.D. ~j
iothonotary
S~%~~ ~~~
R. Thomas Kline, Sheriff
BY~~CL.c.f
Real Esta e Deputy
3~ ~`'
~ ~~
Ue. 3 ~ 91 ~
~d3~~~
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. N0. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition
to First Federal Savings and
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
Defendant(s)
'COURT OF COMMON PLEAS
:CIVIL DIVISION
:Cumberland County
-MORTGAGE FORECLOSURE
'NO. 01-4563 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and'
Acquisition to First Federal Savings and Loan Association of Rochester,
Plaintiff in the above action, by its attomay, Mark J. Udren, ESQ., sets
forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at: 22
Eastwood Drive, Silver Spring Township, PA 17013
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
David J. Crook
22 Eastwood Drive, Carlisle,
Silver Spring Township, PA 17013
2. Name and address of Defendant(s) in the judgment:
Name Address
Same As #1, Above
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
None
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein. See Caption above.
CitiFinancial, Inc.
3401 Hartzdale Drive, Suite 126
Camp Hill, PA 17011
5. Name and address of every other person who has any record lien on the
property:
Name Address
None
6. Name and address of every other person who has any record interest in
the property and whose interest may be ,affected by the sale:
Name Address
Real Estate Tax Dept
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
1 Courthouse Square, Carlisle, PA 17013
13 N. Hanover Street, Carlisle, PA 17013
Bureau of Compliance, Dept. 280946
Harrisburg;•PA 17128-0946
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:
Name Address
Tenants/Occupants 22 Eastwood Drive, Carlisle,
Silver Spring Township, PA 17013
I verify that the statements made in this affidavit are true and correct
to the best of my personal knowledge or information and belief. I
understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
DATED: September 18, 2001
K J. UDREN & ASSOCIATES
Mark J. Udren, ESQ.
Attorney for Plaintiff
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
HSBC Bank USA f/k/a Marine
Midland
Bank successor by Merger and
Acquisition
to First Federal Savings and
Loan
Association of Rochester
2929 Walden Avenue
Depew, NY 14043
Plaintiff
v.
David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring
Township, PA 17013
Defendant(s)
ATTORNEY FOR PLAINTIFF
'COURT OF COMMON PLEAS
:CIVIL DIVISION
:Cumberland County
=MORTGAGE FORECLOSURE
'NO. 01-4563 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: David J. Crook
22 Eastwood Drive
Carlisle, Silver Spring Township, PA 17013
Your house (real estate) at 22 Eastwood Drive, Carlisle, Silver Spring
Township, PA 17013 is scheduled to be sold at the Sheriff's Sale on
March 6, 2002, at 10:00 a.m. in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA to enforce the court judgment of
$113,728.13, obtained by Plaintiff above (the mortgagee) against you. If
the sale is postponed, the property will be relisted for the Next
Available Sale.
NOTICE OF OWNER'S RIGHTS
VO DV $ TO R VENT HT HFRT 'S AT
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must pay,
you may call: (956) 482-6900_
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
vpU pinv gmTir BE ABrF m0 SAVE YOUR PROPERTY AND YOU HAVE OTHER RTGHT$
F~raN TF THE SHERIFF'S SALE DOES TARE PLACE_
1. If the Sheriff's Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 856-482-6900.
2. You may be able to petition the Court to set aside the sale if-the bid price
was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 856-482-6900.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a-share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten ;
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOII SHOIILD TAKE THIS PAPER TO YOIIR LAWYER AT ONCB. IF YOII DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICB LISTED BELOW TO FIND OIIT WHERE Y0II CAN
GST LEGAL HELP.
LAWYER REFERRAL SERVICE
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166 or 600-990-9108
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166 or 800-990-9108
e;
~ . ~-
. ,
ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING,
COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE PARTICULARLY '~
BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT ON THE EASTERN LINE OF EASTWOOD DRIVE, AT THE NORTHWESTERN
CORNER OF LOT NO. 25 ON THE PLAN OF LOTS HEREINAFTER DESCRIBED, THE PLACE OF -
BEGINNING; THENCE ALONG THE DIVIDING LINE OF LOTS NOS. 24 AND 25 SOUTH 73 DEGREES .
00 MINUTES 00 SECONDS EAST 150 FEET TO A POINT; THENCE ALONG THE LINE- OF LANDS NOW
OR LATE OF JOSHIA J. 2EIGLER, NORTH 17 DEGREES 00 MINUTES 00 SECONDS EAST 100FEET
TO A POINT; THENCE ALONG THE. DIVIDING LINE OF LOTSNO. 24 AND 23, NORHT 73 DEGREES
00 MINUTES 00 SECONDS WEST, 150 FEET TO A POINT ON THE EASTERN LINE OF EASTWOOD
DRIVE, SOVTH 17 DEGREES 00 MINUTES 00 SECONDS WEST, 100 FEET TO A POINT, THE PLACE
OF BEGINNING.- ~ - .,
BEING LUT N0. 24 ON THE PLAN OF LOTS KNOWN AS JAY RIDGE MANOR; SECTION A, AS
RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN HOOK
NO. 22, PAGE 106.
HAVING THEREON ERECTED A HI-LEVEL BRICK AND FRAME DWELLING HOUSE KNOWN AND NUMBERED
AS 22 EASTWOOD DRIVE.
BEING KNOWN AS 22 EASTWOOD DRIVE, CARLISLE, PA 17013.
PROPERTY ID NO.: 38-23-0583-027
TITLE OF SAID PREMISES IS VESTED IN DAVID J. CROOK, MARRIED MAN, BY
DEED FROM ROBERT C. WOLF AND HELEN JANE WOLF, HIS WIFE, AND THE %
HOMESTEAD GROUP, INC., A PENNSYLVANIA CORPORATION. DATED .
08/24/1993, RECORDED 12/29/1993, IN DEED BOOK S 36, PAGE 688.
WRIT OF EXECl~710N~and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO.
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
01-4563 CIVIL 19
CIVIL ACTION -LAW
To satisfyy the debt, interest and costs due, HSBC Bank USA f/k/a Marine Midland Bank,
successor by merger and acquisi ion o irs
Asses-iat-ice`` of R0.Chasi-ar PLAINTIFF(S)
x
David J. Crook, 22 Eastwood Dr., CArlisle PA 17013
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located
at 22 Eastwood Drive, Silver Spring Twp., Carlisle PA 17013. (See
attached legal description.)
(2) You are also directed io attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to noCrfy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to ar for the accourn of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property ofihedefendant(s)notlevieduponansubjecttoattachmentisioundinthepossessionofanyoneother
than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $113,728.13 LL $, 50
Interest 9/19/01 - 3/6/02 $3,199.17 DueProthy $1.00
iem
Atty's Comm % Other Costs
Atty Paid $104.5 5
Plaintiff Paid
Date: September 24 , 2001
REQUESTING PARTY:
CURTIS R. LONG
Prothonot ,Civil Division
by:
Deputy
Name iyarlc-d ~:d=gn-, Esquires
Address: 1040 N it' ngs ii' ghwa~--rSt~-~D0
Attorney for: P=ainti€€
Telephone: (-i~~6~--482 -see
Supreme Court 1D No.
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(iJnder Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JANUARY 25, FEBRUARY 1, 8, 2002
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
~~~
Ro er M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
8 day of FEBRUARY. 2002_
pd07RR1Al ~ lC
L E. 5P5'f~El~, _ ~A ty
CatiSsle , ~° . 52005
pfiy ' -°
REAL ESTATE SALE 1pO. 9
Writ No. 2001-4563 Civil
HSBC Bank USA f/k/a
MarJne Midland Bank,
successor by merger and
acquisition to
N7rst Federal Savings
and Loan Association
of Rochester
vs.
David J. Crook
Atty.: Mazk J. Udren
ALL THAT CERTAIN piece or paz-
cel of land situate in the Township
of Silver Spring, County of Cumber-
]and and Commonwealth of Penn-
sylvania, being more pazticulazly
bounded and described as follows:
BEGINNING at a point on the
eastern line of Eastwood Drive, at
the northwestern corner of Lot No.
25 on the plan of lots hereinafter
described, the place of beginning;
thence along the dividing line of Lots
Nos. 24 and 25 South 73 degrees
00 minutes 00 seconds East 150
feet to a point; thence along the line
of lands now or late of Joshia J.
Zeigler. North 17 degrees 00 min-
utes 00 seconds, East 100 feet to a
point thence along the dividing line
of Lots No. 24 and 23, Norht 73
degrees 00 minutes 00 seconds
West, 150 feet to a point on the east-
ern line of Eastwood Drive, South
17 degrees 00 minutes 00 seconds
West. 100 feet to a point, the place
of beginning.
BEING Lot No. 24 on the plan of
lots known as Jay Ridge Manor;
Section A, as recorded in the Office
of the Recorder of Deeds for
Cumberland County in Plan Book
No. 22, page 106.
I-IAVING TI-IEREON ERECTED a
bi-level brick and frame dwelling
house known and numbered as 22
Eastwood Drive.
BEING KNOWN AS 22 Eastwood
Drive. Cazlisle, PA 17013.
PROPERTY ID NO.: 38-23-0583-
027.
TITLE OF SAID PREMISES IS
VESTED IN David J. Crook, maz-
ried man, by deed from Robert C.
Wolf and Helen Jane Wolf, his wife,
and the Homestead Gmup, Inc., a
Pennsylvania corporation. Dated
OS/24/1993, recorded 12/29/
1993, in Deed Book S 36, page 658.
- j .
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The
Sunda~Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the prihted notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily andlor Sunday/ Metro editions which appeared on the 29th day(s) January and the 5th and 12th
day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dau hin in scellaneous Book "M",
Volume 14, Page 3i 7. ~ ~, ~~
PUBLICATION `~
COPY worn to ar>~y~sed bef a his 22nd d of Fe u ry 2002 A.D.
$ A L E #9 Teary L Rusa@II, Notary Public
Hsrtlsbw9, DeupMn CAUmY
My Comrelsslon ExQirea.Nxre 6, 2 '
' Member,PennsywanlaASSOdetbnotWotanes NO ARYPLIBLIC
My commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLANDCOUNTYCOURTHOUSE
CARLISLE, PA. 17013
r Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 288.00
Probating same Notary Fee(s) $ 1 .50
Total $ 289.50
Publisher's Receipt for Advertising- Cost
The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
By ....................................................................