HomeMy WebLinkAbout01-04717FEDERMAN 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
MELLON PROPERTIES COMPANY
6000 ATRIUM WAY, MS SV-O1
MT LAUREL, NJ 08054
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CNIL DIVISION
TERM
v.
Plaintiff
CUMBERLAND COUNTY
WESLEY G. SCHOCK
KAREN L. SCHOCK
3029 MAYFRED LANE
CAMPHILL, PA. 17011
Defendant(s)
CIVIL ACTION -LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
**THIS FIItM 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 REAFFIItMED, 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 wrifing 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 maybe 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 FOR`T'H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Loan #:010788602
IF THIS IS THE FIRST NOTICE THAT YOU HAVE
RECEIVED FROM THIS 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 WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO
BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
SEND DEFENDANT(S) THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT
FROM ABOVE.
THE LAW DOES NOT REQUHtE US TO WAIT
UNTIL THE END OF THE THHZTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH
YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVH)ES
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 TAE 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 THIRTY (30) DAY PERIOD THAT BEGINS
UPON YOUR RECEIPT OF THIS 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 THIS SUIT.
1. Plaintiff is
MELLON PROPERTIES COMPANY
6000 ATRIUM WAY, MS SV-O1
MT LAUREL, NJ 08054
The name(s) and last known address(es) of the Defendant(s) are:
WESLEY G. SCHOCK
KAREN L. SCHOCK
3029 MAYFRED LANE
CAMPHILL, PA. 17011
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 4/28/94 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to MELLON BANK, NA which mortgage is recorded in the Office
of the Recorder of CiJMBERLAND County, in Mortgage Book No. 1212, Page 472.
PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an
assignment of same.
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 3/1/01 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."
6. The following amounts aze due on the mortgage:
Principal Balance $65,514.34
Interest 2,897.44
2/1/01 through 8/1/01
(Per Diem $15.92)
Attorney's Fees 3,275.00
Cumulative Late Charges 163.24
4/28/94 to 8/1/01
Cost of Suit and Title Search 550.00
Subtotal $72,400.02
Escrow
Credit 641.96
Deficit 0.00
Subtotal 641.96
TOTAL $71,758.06
7. The attorney's fees set forth above are inconformity 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 reinstatedprior 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 regulaz 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 Plaintiffls written Notice to Defendants,
a tme and correct copy of which is attached hereto as Exhibit "A"; or
(ii J 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
$71,758.06, together with interest from 8/1/01 at the rate of $15.92 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, ESQUIItE
Attorney for Plaintiff
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
DATE: June 12, 2001 FORECLOSURE
TO:
b\esley G. Schock
3029 Mayfred Lane
Camphill, PA 17011
Karen L. Schock
3029 Mayfred Lane
Camphill, PA 17011
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 INFOR:MATIOA' OBTAINED FROM YOL` 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 ENFORCEMENT OF A LIEN AGAINST PROPERTY.
This is an official notice that the morteaee on vour home is in default and the lender intends to foreclose.
Specific information about the nature of the default is provided in the attached uaees.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save
vour home. This Notice explains how the proeram works.
To see if HEMAP can hel~vou must MEET WITH A CONSL`MER CREDIT COLTSELING .4GENC1'
WITHIN 30 DAYS OF THE DATE OF THIS NOTTCE. Take this Notice with you when you meet the
Counseline Aeencv.
The name, address and phone number of Consumer Credit Counseline Agencies servine vour County are
listed a[ the end of [his Notice. If you have any questions. you may call the Pennsyivama Housine Finance
Aeencv toll free at 1-800-342-2397. (Persons with impaired hearine can call (717) 780-1869)
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseiins Aeency may be able to help explain it. You may also want to contact an
anomey in your area. The local bar association maybe able to help you find a lawyer.
LA NOTIFICACION EN ADJLTTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SL DERECHO A
CONTINL'AR VIVIENDO EN SL' CASH. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENG.4 LTA TRADUCCION INMEDITAMEN`TE LLAM.ANDO ESTA
AGENCIA (PENNSYLV.ANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA IIN PRESTAMO POR EL PROGRA~SA
LLAMADO "HOMEOWNNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL
PLEDE S.4LVAR SC C.4SA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTEC4.
STATEMENTS OF POLlC}'
HOMEOWNER'S NAME(S): Wesley G. Schock and Karen L. Schock
PROPERTY ADDRESS: 3029 Mayfred Lane, Camphill, PA 17011
LOAN ACCT_ NO.; 0010788602
ORIGINAL LENDER: Cendant Mortgage Corporation
CURRENT LENDERiSERVICER:Cgndant Mortgage Corporation
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
}'OL' MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE }}'HIGH C.4N SAVE }'OL'R HO}IE
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELiG1BLE FOR EMERGENCY
MORTGAGE ASSISTANCE.
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOL`SING FIN.gNCE .AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (3U) days Ii~om die da[z of this Nonce. llurmg [hat umz you must
arrange and attend aface-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 }'OL DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE ,YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit
counseling agencies listed at the end of this notice the lender may NOT take action againstyou for thirty
(301 davs after the date of this meetine. The names addresses and telephone numbers of desi n
consumer credit counseling agencies for the county in which the property is located are set forth at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately
of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in a default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default.) If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out,
Bien and file a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at [he end of this Notice. Only conswner credit
cotmseling 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.
}'OL MUST FILE YOUR APPLICATION PROD4PTLY'. IF YOU F.41L TO DO SO OR IF YOL
DO NOT FOLLO}}' THE O"1'HER "FINE PERlOllS SE"f FOIi'fH IN THIS LE"I"fER.
FORECLOSURE MAY PROCEED AGAINST YOUR HOME I,MMEDL4TELY AND }'OL'R
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGE.\"Cl' .ACTION-.4~ ailable funds for emer~lency mortgage assistance are very limited. They «ill be
disbursed by the Agency under the eligibility criteria established by the Act. The Penmylvania Housing
EXHIBIT A
Finance Agency has sixty (60) days to make a decision after it receives your application. Dunne that time.
no foreclosure proceedings will be pursued against you if you have met the time requtrenrents set Corth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE F1L1rvG OF A PE rrl7urv lrv
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT. j
(If you have filed bankru [c ou can still a Iv for Emer encv Mort a e Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date).
NATURE OF THL- DEFAULT-The MORTGAGE deM held b~ the ahoce lender nn your pmpert~ h~.;urd
at: 3029 Mayfred Lane, Camphill, PA 17011 1S SERIOUSLY 1N DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due: StaNEnd: 4/1/01 thru 6/1/01 at $747.40 per month.
Monthly Payments Plus Late Charges Accrued $2,381.10
NSF: $0.00
Inspections: $0.00
Other: $30.60
(Suspense): $249.14
Total amount to cure default $2,162.56
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable): N/A
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH 1S $2,162.56,
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
THE THIRTY (30) DAY PERIOD. Pavments must be made either by cash cashier's check. certified
check or money order made payable and sent to:Cendant Mortgage Corporation, 6000 Atrium Way,
MT. Laurel, NJ 08054, Attention: Collections Department.
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.) N/A.
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the ]ender intends to exercise its rights to accelerate the mortgage debt. This means
that the entire outstanding balance ul flits deb[ will be wnsidered due utmtzdmtrl} and yuu utay lu>r the
chance to pay the mortgage in monthly instaltntents. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the ]ender also intends to instruct its attorney to start legal action to
foreclose upon your mort~aee oroperty.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pap
ott [he mortgage deb[. ]f [he lender refers yow~ case to its attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required [o 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.
Am attorney's fees will be added to the amount you owe lender, which may also include other reasonable
costs. If you cure the default within the THIRTY (30) DAY period you will not be required to
attorney's fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for [he unpaid principal balance
and al] other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default
within the THIRTY (30) D.4Y period and foreclosure proceedings have begun, you still have the right to
G~H'~ I 1
cure the default and prevent the sale at anv time up to one hour before the Sheriffs Sale. 1'ou mas do so
by paving the total amount then oast due plus anv late or other charges then due. reasonable attornec's fees
and costs connected with the foreclosure sale and-anv other costs connected ~~ith the Sheriffs Sale ns
specified m wnune by the lender and by pertbrnune anv other requirements under the mortsaee Curing
vour default in the manner set forth in this notice will restore your mortgage to the same position a~ if you
had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriffs
Sale of the mortgage 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 wil I 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 am' nine
exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Cendant Mortgage Corporation
6000 Atrium Wav,
MT. Laurel, NJ 08054
Tel: (800) 330-0423
Attention: Collections Department
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff s Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the propem after the Sheriff s
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any dine.
ASSUMPTIO\ OF MORTGAGE-1"ou mayor X may not (CHECK ONE) sell or transfer
your home ro a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost are paid prior to or at the sale and that the other requirements
of the mortgage are satisfied.
YOL' MA1' ALSO HAVE THE RIGHT
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
SORROW MONEY FROM A\OTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HA\%E THE MORTGAGE RESTORED TO THE SAME POSITION AS IF \O DEPAI LT I1:\D
OCCURRED, IF YOU CURE 7HE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO
CURE POUR DEFAULT MORE THAN THREE TIMES IN .ANY CALF.\D.AR 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 YOL' BELIEVE YOL' MAY HAVE TO SUCH ACTION BY
THE LENDER
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LA\\'.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
Very truly yours,
Cullectiuno Depunnteui
Atm: Collections Department Accoum No.: 001078860?
mailed b}' 1" Class mail /Certificate o1"Mailing and Certified Mail No:
t°;~~~A~®~~I ~~~Q~~~ ~u~b~~
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~ BEN®~R~ FiE~OR~S
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S~tV®ERS REC®RC3
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PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY ASSISTANCE PROGRA.Yt
CONSUMER CREDIT COUNSELING AGENCIES
(REV. S/00)
CLINTON COUNTY
Lycoming-Clinton Comua Cammision far CCCS ofNortheastcm PA
Community Action (STEP) 1631 South Adterton St., Suite 100
2138 Lincoln Street P.O. Box 1328 Stare College, P.4 16801
Williamsport, PA !7703 - (814) 238-3668 FAX (814) 238-3669
(570) 326-0587 FAX (570) 322.2197
CCCS ofNortheaztezn PA
201 Bazin Street
WilliamspoR PA 17703
(570) 323.6627 FAX (570) 323.6626
3I W. Market Svcct
POB 1127
W ilka-Barre, PA ! 8702
(570) 821-0837 or (800) 922-9537
FAX (570) 821.1785
Commission an Economics Opportunity of Lttzeme County
163 Amber Lane
Wilke-Barre, PA !8702
(570) 326-0510 or (800) 822-0359 -
FAX (570) 829-1665-{Call Before Faxing)
(570) 451.4994 Hazeltown
FAJC (570) 455-5631-(Call Before Faxing)
(570) 836090 Tunkhannock
Booker T. Washington Center
1720 Holland Center
Erie, PA 16503
(8li) 353-5743 FAX (814) 5749
.lohn F. Kennedy Center, Inc.
2021 Eazt 20° Street
Erie, PA 16510
(814)398-0400
EAX (814) 898-1243
CCCS of Western Pennsylvania, Inc.
2000 Linglatown Road
Harrisburg, PA 17102
(717) 541-1757
Urban League of Mewpolitan Harrisburg
N. 6° Street
Harrisburg, PA 17101
(717) 234-5925 FAX (717) 234-9459
Community Action Comm of dte Capita Region
Isla perry Sveet
Harrisburg, PA 17104
(717) 232-9757 F.4X (717) 234-2227
CRAWFORD COUNTY
1400 Abington Execu[ivc Park
Suitt I
Clarks Summit, PA 1841 l
(570)587-9163 or (800)922.9137
FAX (570) 587.9134-9135
Greater Erie Community Action Committee
18 West 9'" Sveet
Erie, PA 16501
(814) 459-5581 FAX (814) 456-0161
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
(412)981.5310
Financial Counseling Services of Franklin
31 West 3i°Street
Wavnaboro, PA !7268
(717) 7623285
YWCA of Carlisle
301 "G"Street
Carlisle, PA 17013
(717) 243.3818 EAX (717) 731.9589
Adams County Housing Authority
139-143 Carlisle Sc
Gettysburg, P.4 17325
(717)33a-1518 FAX 334.8326
PE`lNSYLVANiA BULLETPS, VOL. 29, NO.23, JUNE 5, 1999
~~'~~~
All that cartaia tree! ur yurceL of lured and /,renrleea, xiruul o-, lpinU rued Lri nr! .u Mr
BorougL of Camp 8111 in 7br~ ('unnfry q/
Cumberland a»d Cn nr>ns><a~ea![h of Pen nay(uauia, more pnrticsshv7y de•xeri bar( un Ju7lunw:
SEGIBNING at a point on the southeast corner of South 31st Street and Mayfred Lane;
thence canelnuing along Hayf xed Lane,North 83 degzeee 00 minutes Ease, a distance of
109.98 #eet to a point on the dividing line between Lote Nos. 7 and 8 on the hereinaf=cr
mentioned Plan of LoCp; Chance along said dividing line, South 07 degrees 00 minutes
Eaat, a distance of !00 face eo a poinC on the dividing line between Lots Nos. 8 and
9; thence along said line, South 83 degzeee 00 mina Gas West, a distance of 109.96
f set to a point on the eastern line of South 31st Street; thence along ehe eastern
line of South 31st Street, North 07 degzeee 00 minutes 30 seconds west, a distance of
100 feet to a point, cha Place of BEGINNING.
SAVING thereon erected a one story brick and ECama dwelling known and numbered n.+
3029 Mayfred Lane, Camp Hill. Pennsylvania.
BEING Lot No.B on ehe Plan of Lots of Section "A" of Parkway Terrace.
BEING T91' SAME premises which Frances H. Rumb erger, by deed dated February 10, 1989
and recorded February 14.1989 in the Office of the Recorder of Deeds in Cumberland
County in Book 33-U Page 728 , granted and conveyed unto Michael C. Heagy and
Karen L• Heagy, Husband and Wife. The Grantors Hezain.
VERIFICATION
MARK HIINKLE hereby states that he is V.P. of CENDANT MORTGAGE SERVICES
mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that
the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best
of his 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 unswom falsification to authorities.
DATE: ~~Dl®L
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-04717 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MELLON PROPERTIES CO
VS
SCHOCK WESLEY G ET
KENNETH GOSSERT Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
WESLEY G
DEFENDANT
was served upon
the
at 1505:00 HOUR5, on the 16th day of August , 2001
at 3029 MAYFRED LANE
CAMP HILL, PA 17011
KAREN SCHOCK
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.75
Affidavit .00
Surcharge 10.00
.00
37.75
Sworn and Subscribed to before
menthis jp¢ day of
U~rw acus- ,9_va l A . D .
ProthonotaryyT-
So Answers:
R. Thomas Kline
08/17/2001
FEDERMAN & PHELAN
By:
put She f
m,~
CASE NO: 2001-04717 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MELLON PROPERTIES CO
VS
SCHOCK WESLEY G ET AL
KENNETH GOSSERT
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
KAREN L
DEFENDANT
was served upon
the
at 1505:00 HOURS, on the 16th day of August 2001
at 3029 MAYFRED LANE
CAMP HILL, PA 17011
KAREN SCHOCK
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this 30 ~ day of
~2va / A . D .
/f~
rothonotary
So Answers:
~s~.~~
R. Thomas Kline
08/17/2001
FEDERMAN & PHELAN
By:
epu e f
;...may .... _
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
One Penn Center at Suburban Stallon
Suite 1400
Philadelphia, PA 19103-1814
(2151 563-7000
MELLON PROPERTIES COMPANY
6000 ATRIUM WASY, MS 5V-Ol
MT LAUREL, NJ 08054
Plaintiff
vs.
WESLEY G. SCHOCK
KAREN L. SCHOCK
3029 MAYFRED LANE
CAMPHILL, PA 17011
Defendant(s)
Attorney for Plaintiff
:CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
FIO. 01-4717
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 WESLEY G. SCHOCK
and KAREN L. SCHOCK, Defendant(s), for failure to file an Answer to Plaintiffs Complaint
within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and
assess Plaintiffs damages as follows:
As set forth in Complaint $71,758.06
Interest 8/1/01 TO 9/20/01 811.92
TOTAL $72,569.98
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above,
and (2) notice has been given in accordance with Rule 237.1, copy attached.
~~~~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGE`/S~~AR1E HEREBY ASSESSED AS INDICATED~I
DATE: ~ X177'- / I . aGO /
TTT~"~~~ PRO PRO
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WII.L BE
USED FOR THAT PURPOSE. H' YOU HAVE PREVIOOSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS
NOT REAFFH2MED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLEGE
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
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
MELLON PROPERTIES COMPANY
Plaintiff
vs.
WESLEY G. SCHOCK
KAREN L. SCHOCK
Defendant(s)
TO: WESLEY G. SCHOCK
3029 MAYFRED LANE
CAMPHILL,PA 17011
DATE OF NOTICE: SEPTEMBER 6.2001
~- ~ ~ ~ ~
E~'s~ :tea
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
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 01-4717
Frank Federman, Esquire
Attorney for Plaintiff
FEDERMAN AND PHELAN
rr^rank Federman, Esquire
Identification No. 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
MELLON PROPERTIES COMPANY
Plaintiff
vs.
WESLEY G. SCHOCK
KAREN L. SCHOCK
Defendant
T0: KAREN L. SCHOCK
3029 MAYFRED LANE
CAMPHILL,PA 17011
DATE OF NOTICE: SEPTEMBER 6,2001
.<,~r99
~ '"' 1
e.-
G ~ ~~
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
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO.O1-4717
y- ~. SHERIFF'S RETURN - REGULAR
CASE NO: 2001-04717 P -
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MELLON PROPERTIES CO
VS -
SCHOCK WESLEY G ET AL
KENNETH GOSSERT Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
SCHOCK WESLEY G the
DEFENDANT at 1505:00 HOURS, on the 16th day of August __, 2001
at 3029 MAYFRED LANE
CAMP HILL, PA 17011 by handing to
KAREN SCHOCK
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof,
Sheriff's Costs: So Answers:
Docketing 18.00 '~
Service 9.75
Affidavit .00
Surcharge 10.00 R. Thomas Kline
~~ -
37.75 08/17/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before By:
menthis ,3o a' day of ~ put She 'l f
(~iw~,c~ ,.~ .~.vn l A. D .
~~ ~~huQe~ `~~
Prothonotary'
SHERIFF' S RETUt'2~ti - REGULAR
CASE N0: 2001-047'_7 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MELLON PROPERTIES CO
VS
SCHOCK WESLEY G ET AL
KENNETH GOSSERT
Sheriff or Deputy Sheriff of
Cumberland Count y, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
SCHOCK KAREN L the
DEFENDANT at 1505:00 HOURS, on the 16th day of August 2001
at 3029 MAYFRED LANE
CAMP HILL, PA 17011
KAREN SCHOCK
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this day of
A.D,
So Answers:
a. ~.
R. Thomas Kline
08/17/2001
FEDERMAN & PHELAN
~r.~
-'eputy e~3jff
~ ~,, /!/
Prothonotary
FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
X151563-7000
MELLON PROPERTIES COMPANY
Plaintiff
vs.
WESLEY G. SCHOCK
KAREN L. SCHOCK
Defendant(s)
Attorney for Plaintiff
CUMBERLAND COUNTY
Court of Common Pleas
CIVIL DIVISION
NO. 01-4717
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 lrnowledge of the
following facts, to wit:
(a) that the defendant(s) is/are 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 of 1940, as amended
(b) that defendant WESLEY G. SCHOCK is over 18 years of age and resides at
3029 MAYFRED LANE , CAMPHILL, PA 17011.
(c) that defendant KAREN L. SCHOCK is over 18 years of age, and resides at
3029 MAYFRED LANE , CAMPHILL, PA 17011.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
FRANK FEDERMAN
Attorney for Plaintiff
~.,
(Rule of Civil Procedure No. 236 -Revised)
MELLON PROPERTIES COMPANY
Plaintiff
vs.
WESLEY G. SCHOCK
KAREN L. SCHOCK
CUMBERLAND COUNTY
Court of Common Pleas
CIVIL DIVISION
NO. 01-4717
Defendant(s)
Notice is givell that a Judgment in the above captioned matter has been entered against you on
SEPTEMBER ~ 1 , 2001.
~ By ~i~„ n _ /~n.~r . DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN, ESQUIRE
Attorney for Filing Party
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215)563-7000
**TffiS FII2M IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WII.L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DLSCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFHiMED, THIS IS NOT
AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
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