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Home My WebLink About01-06606 -" ,J,1i \iliii1. ~- ~~.~ ~h" '-~. ,.. '-'"'~lilt~'i;J~-'i- ,. MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANTS CIVIL ACTION - LAW NO. 2001 6606 IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants JEANNE K. RITTER AND DONALD L. RITTER for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $12.55 from 5/1/01 to 12/1/01) Late charges ($30.68 per month to 12/01) Escrow Deficit 5% Attorney's Commission $35,236.12 $ 2,685.70 TOTAL $ 184.08 $ 650.58 $ 1. 761. 81 $40,518.29**V ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG By' Leon Ie ).D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKF\DOCS\CUMBERLA\RITTER.P .~, ;~~ , ",. ""~- "" ~,'- ~-"1 '-;c-~~f';i # " MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANTS CIVIL ACTION - LAW NO. 2001 6606 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on January 9, 2002 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 j~~ ~-~ ~ .- - .~." ~. ~'~~~1l_1J.l!t-- " ~;,c<',,"~"'ilf,>', , MIDFIRST BANK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA VS. : NO. 01-6606 JEANNE K. RITTER AND DONALD L. RITTER Defendant : CIVIL ACTION LAW : IN MORTGAGE FORECLOSURE DATE OF TillS NOTICE: January 9, 2002 TO: JEANNE K. RITTER 402 NORTH FILBERT STREET MECHANICSBURG, PA 17055 DONALD L. RITTER 402 NORTH FILBERT STREET MECHANICSBURG, PA 17055 TIDS LAW FIRM IS A DEBT COLU1CTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TlIEPURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE yOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF TillS NOTICE, A JUDGMENT MAY BE ENTERED AGAlNST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TillS 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE, CARLISLE, PA 17013 PURCELISRUGrt. By ~ ' LEON P. HALLER, Attorney for Plaintiff LD. # 15700 1719 N. Front St., Harrisburg, P A 17102 (717) 234-4178 &J lLc""'>-<:iJ_~:li,i~i!li~~,fji:lFG~*",g,i:!,:;ji,,.g,4lJ1!",Mj".h-1V. ',-,," _c'_L'" _'_'~':':""'~:'>'_".J",_";"..~,~,,,,~,..&~-:jjl!ilf@'&tii1lil/lit{lllJf1'Yil1il!ilJiWl;ri~;il~m10l!ii!0~~- , ("J 0 ,..) 0 .(Q. C f'J i ~ ~J" 'T] ~ ...0 ~1J ;.;;",~ :~ fIl "", ~'--;f'~ I r" ~ft:' ;;;:) iTI g in UJ)'-' G) (:J ......... <:: _c" F ~:: ,r-1 U ~~,-" --C) __n_ , 1..) '1 r :,..-:>< (,:'"?(~ ~ ?v >l~o: ;,jf-n ~ C3 C;.; ;:-~. :J1 :;: - :::1 --J ::J.J '. -< ~ - ~^ ~ " ,-" . ,,~ ,;..-' '-I-J~li;j'~W' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2001 6606 MIDFIRST BANK, PLAINTIFF TOTAL AMOUNT OF JUDGMENT $40,518.29 v' Interest at $12.55 per diem to sale date $ 2,334.30 Late charges at $30.68 per month to sale date $ 153.40 Escrow Deficit $ 2,000.00 TOTAL $45,005.99* VS. JEANNE K. RITTER AND . DONALD L. RITTER, DEFENDANT(S) *SALE DATE: WEDS.,June 5, 2002 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above case. Date: March 12, 2002 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leon P. Haller PA I.D. #15700 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 402 North Filbert Street, Mechanicsburg, PA 17055. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY ""~ j_:iir-{_~~ii:wllifjllGt!if:$-:<i:,')ji1\!!j;iii;;Hic:J~',;';k''''!1~W-'~W*,~<,'~",;,--,-a4_oi'-"i',.' ",';O',_",,"'~-A--'e;}~,":~~ill~~d~~~liJi',rl\!t~-...~------ '\ ~ { ~ ~ ~. ~ ~ ~ -, ~ ~ ~ :--- !'1 6"- ~ C) d 0 , d 8 ~ 8 - ~ D ~ 0 0 c, C) U v c f'..,) ---c"' tv ~ I I I I I :g: -",~ ~ & ~ r -OC~ ~C:,' -n t- rnr'- :;::0 ;:;-:-= ~ 23-' -,,,. - , , 7!:'-- ".---' ~ " t'_-,.'_ " , C\ ~ c.) - "- ~(? " ~~ ~-:: " " "- zi~~:; .':-':2~~ ~ ~ ~ ;~:~;Tl " P(~:: ...... ,., -:::,. .rfZ :eel :..51 :.G -<: .~ ~~ "'" ~'~n _~__~ ",_".~r" _ _, ~ .~ -. "_ e_' ~ _ ", ,.. ~~n_ - ".<~-" ~, ~ L"i:kI.l>:l--"_ ~~- ^]h~'''"~,'' . . All THAT CERTAIN tract or parcel of. land with the improvements thereon erected situate in the Borough of Mechanicsburg. County of Cumberland and Commonwealth of Pennsylvania. being,more particularly bounded and described as follows. BEGINNING at a point on the easterly line of Filbert Street. which point is 78 teet North of the northeasterly corner of Portland and Filbert Streets; thence along the easterly line of Filbert Street North 21 degrees 40 minutes West 58 feet to a point; thence North 68 degrees 20 minutes East 124.55 feet to a point; thence South 21 degrees 40 minutes.East 20 feet to a point; thence South 3} degrees 39 minutes West 66.77 feet to a point; thence South 68 degrees 20 minutes West 69.65 feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS402 NORTH FILBERT STREET, MECHANICSBURG, PA 17055 BEING THE SAME PREMISES WHICH Helen L. Lowe by deed dated 8/26/83 and recorded 8/29/83 in Deed Book I-3D, Page 837 granted and conveyed unto Donald L. Ritter and Jeanne K. Ritter. TO BE SOLD AS THE PROPERTY OF DONALD L. RITTER AND JEANNE K, RITTER ON JUDGMENT NO. 2001 6606. PARCEL: 18-822-0519-148 -, " ~ - ~~ ~- !~. ~, '-",,~~,_,;.__'i",ii,~~<:' -. ~_';.;, ,.- ~ MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANTS CIVIL ACTION - LAW NO. 2001 6606 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 402 NORTH FILBERT STREET, MECHANICSBURG, FA 17055: 1, Name and address of the Owner(s) or Reputed Owner(s): Jeanne K. Ritter 402 North Filbert Mechanicsburg, PA Street 17055 Donald L. Ritter 402 North Filbert Mechanicsburg, PA Street 17055 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: First Deposit National Bank 219 Main Street Tilton, NH Valerie Park Rosenbluth, Esquire 25 E. State Street P. O. Box 1779 Doylestown, PA 18901 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : .~""~'''"'~,~="<' "". -. -jf-'~~ jr~HK;,Jwr.>!i: ~. 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7. Name and address of Plaintiff has knowledge who has may be affected by the sale: every other person of whom the any interest in the property which TENANTS IF ANY.,. Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated,) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 12, 2002 7ft; ;.~~t~I~~.;,j1J'~*i~',^"'!>,"".&l&l!;fg,\t'J~t&;;;,t{:!l;iilj1ili!~CEti1'~,~.,._';li;'_':~'\~"';it;i,ii'1~'';'\'''.iJ;';,rJ''_P-!'f'''':;,t0,~,!i1>!I~~blirlihlil~~~.:;(~~iM;;'-""'-~ 0 C::> [---" -' C- r--.:; --n ;:;-".?" 3;: _~~n -0 ('," ;:1~"" III L: :C:J ~ ~- ,-- (1) C,J -< r-- .::..:::: ~?: '.c: -h C) ~ C Z :.11 --; -<'", ...J n - n , - --,,~ ~ , ." .-- ~ ~~~" 't_ -.hu~1&l.i1'--~ ~=~ ""';"~~''',",' MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANTS CIVIL ACTION - LAW NO. 2001 6606 IN.MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 .TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, June 5, 2.002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner'S Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 .,-1__ _ THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: "~~!''''~--:~!~'!",~ 402 North Filbert Street Mechanicsburg CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2001 6606 THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property is: JEANNE K. RITTER AND DONALD L. RITTER 'll '''' . '~~.1 ~, - -- I ~ 8ofilli~'~ - ~~" Ueaf ~ " ,. :o;~:;~",~;,j'~"'"'i A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TI~E AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically, of these rights. If you wish to exercise your rights, YOU' MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: I. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This ~ - -'~ -~. ..."~, ..iw; ~. .l,~~~, -mlm-'~" "'^"~~'llic-%.~~' petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execut~on~s attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 j 70' -" I -L~ ~U~~ ~,~ ,~- . Ii' .I, - jllillllillllil:-~~. ~ -i'- ~ 11 "U ~"- ......"".1Mih.,"f'\ii)j}{Y.,;l-"ci~-0_-9''--'"'-~ , . ^11 THAT CERTAIN tract or parcel of. land with the improvements thereon erected situate in the Borough of Mechanicsburg. County of Cumberland and Commonwealth of Pennsylvania. being.more particularly bounded and described as follows. BEGINNING at a point on the easterly line of Filbert Street, which point is 78 feet North of the northeasterly corner of Portland and Filbert Streets; thence along the easterly line of Filbert Street North 21 degrees 40 minutes West 58 feet to a point; thence North 68 degrees 20 minutes East 124.55 feet to a point; . thence South 21 degrees 40 minutes East 20 feet to a point; thence South :3:r degrees :39 minutes West 66.77 feet to a point; thence South 68 degrees 20 minutes West 69.65 feet to a point. the Place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS402 NORTH FILBERT STREET, ~ECHANICSBURG, PA 17055 ,BEING THE SAME PREMISES WHICH Helen L. Lowe by deed dated 8/26/83 and recorded 8/29/83 in Deed Book I-3D, Page 837 granted and conveyed unto Donald L. Ritter and Jeanne K. Ritter. TO BE SOLD AS THE PROPERTY OF DONALD L. RITTER AND JEANNE K. RITTER ON JUDGMENT NO. 2001 6606. PARCEL: 18-822-0519-148 m ,~~:..,;,~ '~~~i~~fWi&iH81::"'l:~iBt-1itN~.ji'*'tl\."';'cf'''''''' 0 \';k!''',,,"" "";_\;-i"f'd"_~'i~:j;j:,i:.4.li~4~~$;.l:Il!.:..uH,mill@!Ur>'~'~ '~._I~j1t'7'~--.w , ~ (") c:, (J c: r"J ,1 ~;: :~t: -0 C'; 'j:;-"J. ~ rn C :c~ , "7 ~. i --;,'::' , , (/1 0_' T "< \? ~:: --0 ,,- ;,,:;, J':" C.J Z C: (~ h'l p' c >-;7 ~- :"i :.n 5:) -.< ...J -< ,<, ~ ,.'"<- .- ~_., ~,~'" ..d' F ~~ ~-" - ~"......,~~ '~.'" '''~'S4't'5''~": > MIDFIRST BANK Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW YS. JEANNE K. RITTER AND DONALD 1. RITTER Defendants ACTION OF MORTGAGE FORECLOSURE # (!) J- Co (QfYo TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 !W1Fllse may proceed without you and a judgment may be entered against you by the Court without further uotice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. .1 Ei\N!',fi <, r:J~)N>\i CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 717-249-3166 A VISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQillER OBJECCION G'i:)!N'tRA LAS QUEJAS EN ESTA DEMANDA. '.'''"g ,. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGillR CON EL PROCESO SIN SU p!A1i~jFrClP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DEClDIR A FAVOR DEL DEMANDANTE Y tmQtJERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSffiLE QUE USTED PUEDA PERDER DINERO, PROPlEDAD U OTROS DERECHOS lMPORTANTES. ...', LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. ,,':\',1'-; ,):! ,fi'SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE,ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 717-249-3166 ;-' j~ : ~ ~~': . ~:-f;:' , !': i ' :.I~ , ",', .. ,-,: ::e----"" , . , _"_~'_~'~._~~u_ <.," '" . -= ';"";~"'--"'~'"'~'$..--O-~" MIDFIRST BANK, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. JEANNE K. RITTER AND DONALD L. RITTER, CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendants THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 US.C. 1601 ~l' I.;' ; ,l,^' The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity ofthe aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. !vllf)~- , JE/\1'. IX;\ PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, P A 171 02 (717) 234-4178 Attorney LD.# 15700 Attorney for Plaintiff p' 'J'>.., j ~ ,,..~, --".,,~ ' ~- "~ , ,1', ,", ~ ""-'._ ~-"" 1" '<.l.o.M.""-'"i'a&l.:,;h4,~1-f~~' " ,'\',\', MIDFIRST BANK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW () / -a,(eO 1/"1 ACTION OF MORTGAGE FORECLC:1SURE vs. !fE'ANNE K. RITTER AND DONALD L. RITTER, Defendants COMPLAINT IN MORTGAGE FORECLOSURE ..,. . bPlaintiff is MIDFIRST BANK, a corporation whose address is 3232 WEST RENO, OKLAHOMA ivHD[rCITY, OKLAHOMA 73107. J 2. Defendant, JEANNE K. RITTER, is an adult individual whose last known address is 402 NORTH FILBERT STREET, MECHANICSBURG, PENNSYLVANIA 17055. Defendant, DONALD L. DO:~ RITTER, is an adult individual whose last known address is 402 NORTH FILBERT STREET, MECHANICSBURG, PENNSYLVANIA 17055. .3. On or about, August 26, 1983, the said Defendants executed and delivered a Mortgage Note in the sum of $46,900.00 payable to PB MORTGAGE CORPORATION, which Note is attached hereto and marked Exhibit "A". , " ')(, 4. Contemporaneously with and at the time ofthe execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and ,.,',>- ,\\'; Commonwealth in Mortgage Book 735, Page 381 conveying to original Mortgagee the subject premises. <";C<.: The Mortgage was subsequently assigned to MERRILL LYNCH MORTGAGE CORP. and was recorded in the aforesaid County in Book 297, Page 1025. The Mortgage was further assigned to MIDFIRST BANK and was recorded in the aforesaid County in Book 619, Page 188. Said Mortgage and Assignments are incorporated herein. ..' 5: The land subject to the Mortgage is: 402 NORTH FILBERT STREET, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly described in Exhibit "B" attached hereto. ,..t, ~ .,,,,;, " , ,'~ -"~ '"~ -~ -. ,,-" -<~,~"..- 'l~ ' -", -l@!j:JJ~~.Ii<d, ]\i'-" 6. The said Defendants are the real owners of the property. ..;}. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on June 01,2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: '~ 1, . UNPAID PRINCIPAL BALANCE $35,236.12 Interest at $12.55 per day From 05/01/2001 To 12/01/2001 (based on contract rate of 13.0000%) $2,685.70 Accumulated Late Charges 6, Late Charges $30.68 From 06/01/2001 to 12/01/2001 $184.08 Escrow Deficit $650.58 " ,," Attorney's Fee at 5% of Principal Balance TOTAL $1,761.81 $40,518.29 **Together with interest at the per diem rate noted above after December 01, 2001 and other charges and costs to date of Sheriff s Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and PennsylvllIlia law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the (). Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgrrtent has been entered upon said Mortgage in any jurisdiction. 9. Plaintiff has complied with the notice procedures required by Pennsylvania Act 160 of 1998 by sending to each Defendant, by regular mail, a copy of the Combined Act 6/91 Notice. A true and correct copy of the Combined Act 6/91 Notice is attached hereto as Exhibit "C". 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. l! ",."",.,,~ ',.- - ~"",,..;J',. ~ ~- ^ '~~ " ..., L"'rllr"~.I!!W,_'-'- 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. '.:i 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 13.0000% ($12.55 per diem), together with other charges and Fpsts including escrow advances incidental thereto to the date heriff s Sale and for foreclosure and sale ,. . of the property within described. By: i, , PURCELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff J.D. # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) "'Ii UJt~11 . ,,11HJ 1)'L":' !,i -,,; . "" 'M N~ ~-~ 1~11111~1111~IIIIIIIIIII!mlml~IDI~I~ 54lU4870 I NTE v A form 16-6136. (Home Ll,),ol,llJ Revist<<l March 1978. Use Op- tional Section 18l0. Titlo 38, U.S.C, Acceptable to Federal Na- tional Mortgage Association. 37052891 PENNSYLVANIA MORTGAGE NOTE CUMBERLAND I Pennsylvania. $ 46900.00 26. AND 19 . 83 August FOR VALUE RECEIVED, the undersigned, DONALD L. RITTER JEANNE K. RITTER HIS WIFE . hereinafter called the Maker, promises to pay to PB MORTGAGE CORPORATION a. OOl'POro..tion Qrzani7.~ and existing under the laws of the THE ST ATE hereinafter designated as the Payee, the principal sum of Fo '[' t Y Six Hundred and No/IOO . .t If Thirteen wItb m ere5 rom date at the rate of per centum ([3.0 ot1'o) per annum on the unpaid balance until paid. The said principal and interest shall be payable at the office of PB MORTGAGE CORPORATION in HADDDNFIELD, NJ 08033 t 76 EUCLID AVENUE a K i v a or sueh place as tbe bolder may designate in writing in monthly installments of a~a 8f?1~'b,gbteen Dollars ($518. 8H eommeneing on the first d:lY of 0 c t obe r , 19 &1\nd on the first day of each month thereafter until the princi- pal lind- interest are fully paid, except that the final payment of the entire indebtedness evidenced herebY. if 110t sooner paid, shall be due and payable on the first day of September ,2013 Privilege is reserved to prepay at any time, without premium or fee, the entire indebtedness or any part thereof not less than the amount of one installment,. or One Hundred Dollars ($100.00}, whichever is 'lelm. Prepayment in fun shall be etedited on the date received. Partial prepayment, other than on an instaUment due date, need riot be credited until the next following installment due date or thirty days after such prepayment, whichever is earlier, Simultaneously with the eXl'{",ution uf this Note the Maker hus executed and delivered to the Payee a Mortgage secured upon certain prl1miJ;es situat,E:d in the Count.r of CUMBERLAND , Commom~'ealth of Pennsylvania, mOl"€' particularly described ill the Mortgage. All of the terms. cov~. nants, provisions, conditions, stipulations and agreements contnined ill Mid Mortgage to be kept and perlormed by the Mnker a.re hE:,'eby marle a 1>~u't. of this Note- to the s~\mt.' extent nnd with the same force and effect as if they were fuiI)' set forth herein, and thE' Maker c()ven~mts and agrees to perform the :mme, or cause the same to be kept anel 11f'rform(!d, strictly in uccordal1t'e with the terms and pro- visions thereof, The whole of the principl.l.I sum or any part thereof, and of allY other sums of money secured by the Mortgage given to secure this Note, shall, forthwith, at the OptiOll of the Payee or any subsequent holder thereof, become due and pal'able immedilttely, without notice or demand, if default be made in any payment undel. this Note, and if the. defaul1. is not made good prior t.o the due date or the next such installment: or upon the happening of any default which, by the wrms of the Mortgage given to secure this Note, shull entitle the Payee, or any subsequent holder hereof, to declare the same, OJ" any pal1; thereof, to be flue llnd payable. The Maker dop.s hcrebl' empower nny attorney of any court tlf record within the United State!> or elsewhere to app(mr for Maker, with 01' without a dedaration filed, and confeRS judgment or judg. ments' agninst said Maker in favor of the Payee or any sub.<lequent holder hereof, a.<:; of any term, for the, entire un))aid r~\'inei))a\ 1J{ thi1i Note, and p..1l other suma paid by th~ holder hereof to 01" on behalf. of the Maker PlU'l:munt to thfl terms of this Note 01" said .Mortgage, and all. flrl'earages of interest there- on, togethel' with costs of suit. attorney's commission of 5 1ft for collection, and a release of all errors, on which judgment execution or executions ma)' issue forthwith. The Muker hereby waives the right of inquiaition on all property levied upon to collect the indebtedness evidenced hereby and does voluntarily condemn t.he same and authorizes the Prothonotary to enter such condemnation. and waives and releases all laws, now in f01'ce O}' hereafter enacted, relating to exemption, appl'aisement or stay of execution. The agreements herein contained shall bind, and the benefits and advantages shall inure to, the respective successors and as~igns of the pa.rties hereto. Wherever up-eel, the singular number shall in. elude the plural, the plural the singular, and the use of any gender shall be applicable to all genders< IN WITNESS WHEREOF, the Maker has caused these presents to be executed under seal the day and yearfirst.\bovewritte-n. ~ . A/7~ Signed, Sealed and Delivered ~~AI;lr . K "," --__ . .(SEAL) in the .Presence of: - __ nn T _ (SEAL) I I / . ...:1.../ .//.. j.~1.- no n_ n __ _'m_m__ n _nmn___ _ nn nn (SEAL) .............................................. ....... (SEAL) OF NEW JERS~~ororder, Thousand Nine Dollars ($46900.0~ = -...---'- THIS Is To CERTIFY that this is the Note described in and secured by Mortgage of even date here~ with s.ecured an real estate situate in CUMBERLAND /,f'County, Com1l!onwealt4 of Pennsylvr"'1ia, .... \ A" . EY-~(10rr ,I Ii I ( --7t;:~:;~~..::~~'-;&/~:~:;~~;;~p~.ii;:.. ,~.k '; ~ w..'" ,>.' ~-~;;i1~00:~:, ...~ " , L "-"- BE PA'l TO W'T:::::C:JT UCOUB . ...-. ~.~ U.l:.; lIllR OF: ~ERRU!. r::;:::n ~"!~:tTGAG r n Mc..ct. U31\'~'1;.'f) T 3l..l.::iB l.N3;:;;:-;- Hd 30M ..t:r:n.l(1.~}~ ='\a ./ '. ' >lNVG l~jkj;ii ~OH:i :.:10 11301:l0 3H1 01 ^Vd3S11noo3111nOH~M -k- ~ ~ ' l:lii:~~,:,1 oIIlltlJ08S lURlO,ssV :~g NOI1WHOdHO~ ,0V51HOI'I !:Jlm T.., aSJn(t}~J U'lOqW/i )JNVl:I J.S'Hl.!lGlW ::lO 1I30H0 3IU 01 ),,11. '!f1 ~~~~'i;:;i~"''' __~_ 'm "L;_ " .j, " ~, , ' , ..... -. 100 '. n ALL THAT CERTAIN tract or parcel of land with the improvements thereon erected. situate in the Borough of Mechanicsburg. County of Cum- berland and Commonwealth of Pennsylvania, being more particularly bounded and described as follows: BEGINNING at a point on the easterly l1ne of' Filbert Street; which po~nt is 78 feet north of the northeasterly corner of Portland and Filbert Streets; thence along the easterly line of Filbert Street North 21 degrees 40 minutes West 58 feet to a point; thence North 68 degrees 20 minutes East 124.55 feet to a point; thence South 21 degrees 40 minutes EAst 20 feet to a pointj thence South 33 degrees 39 minutes West 66.77 feet to a point; thence South 68 degrees 20 minutes West 69.65 feet to a point, place of BEGINNING. BEING premises known as 402 North Filbert Street and having thereon erected a brick stucco ranch type dwelling house. BEING the same premises which Helen L. Lowe, unremarried widow by her deed dated August 26. 1983 and intended to be recorded herewith, granted and conveyed unto Donald L. Ritter and Jeanne K. Ritter, his wife. ~I"S Ii~\i~ u 'It>:") rt,f,t vl..1 ". ~ ~ . ~.. . sien thel:efol.' shaH ot-cur. PROVIDED, that ill case default shall be made in the payment of any installment of principal and interest, or llny othE!T payment hereinabove or jJl the conditions of said re-eited Note provided for, or in the keeping and performance by the Mortgagor of any covenant or agreement contained therein or in this Mortgage to be by said Mortgagor kept and performed, in the manner- and at the time speeified for the pel'formance thereof, such defal11t will entitle Mortgagee forthwith to bring and sue out an Action of Mortgage- Foreclosure upon this Indenture of MOl1:gage, or to institute any other appropriate action or proceeding to foreclose a morlgage, and to proceed thereon to Judgment and execution, for recovery of said principal debt or sums and all interes.t th~l'eon and all other sums hereby secured, together with an attorney's commission for collection, as aforesa.id, and costs and expenses of suc.h Pl'04 ceeding, and to pursue any and all other appropriate legal or equitable remedies in such casea provided BODv ',,;:., r,I.;:: :~.~Jj 11'i:) JI ExHIBIT '-.:) ~ ~ ,~".... . ~'" ~ IllW"' .- .......... ," ~'"', -'i,;Wffi;!!.~\~;eWdW~^"i:;, Nov-05-0! 05:09pm From-MIDLAND MORTGAGE REFERRAL T-741 P. 03/12 F-569. CONTENIDO' DE ESTA NOTIFICACfON OBTENGA UNA TRADUCCION INMEDITAMEN11: LLAMANDO ESTA AGENClA (pENNSYlVANIA HOUSING FINANCE AGENCY) SIN CARGOS A.l NUMERO MENCIONADO ARRiBA. PUEDES SEa ELEGIBL.E PARA UN PRESTAMOPR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSiSTANCE PROGRAM" EL CUAl PUEDE SALVAR SU CASA DE LA PER,).!DA DEl DERECHO A REDIMIR SU HlPOTECA. Hom"owner's Nam:(s) : Property Addre$s' DONALD L RITIER JEANNE K RU"rER 402 N FILBEWr ST M~CHANICSBURC fA 17055-3329 44234500 Midland Mortgage: Co. - Loan Accounr No.; Lender/Servicer: HOMLWWNER'S EMERGENCY MORTGAGE ASSISTANCE l'ROC-RAM YOU MAY liE ELIGlBl.F. FOR HNAJ'IClAI. ASSISTANC€..W"AlCn CAN SA. vr. Yetm ROM:R FROM FORECLOSURE AND HE!.1' YOU M.<\KE FU'rIlRE MOlt'l"C,AC,f J> A. YIVU.:NTS If YOU COMPL'i WlTa TilE PROVI5IpNS OF Tm: nOLVf€OWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 19113 (THE "ACT"), YOU MAYBE ~UGlBU: FOR EMERGENCY MORTGAGE ASSfSTANCE: IF YOUR DEFAULT liAS BEEN CAUSED BY CffiOIMSTANCES BEYOND ~OUR CONTROL, u." ~OU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND - IF YOU MEET OTHER WGUm.iTY REQUlREiVu:NTS ESTABUSRED BY THE PE~S\'1..VANlA aO(JSING FINANCE ACENCY. Tf-MPORARY STAY OF FOREel OSlJRE - Under the ACI, you are ~nlilled 10 a ternpor.1ry Slay of foreclosure on youc mortgage for llurry (30) days from rh~ dare ofrhi~ Nonc~. DUring tl:31 rime you must arr.llIg~ and attend a "face-ro-fac~" meenng with on~ of rhe conS1>ffi<=r credll counsding agenCl:S listed ar the end ofthi;Nolic~. 'IBIS MEETTi'lG MUST aCClftt WITHIN THE NEXT 130\ DA VS. IF VOU DO NOT APPLY FOR 8v(ERGENCY MOltTGACF. ASSlSTANC . YOU IS BRING YOUR MORTO G UP TATE Tl PART OF THIS NOTICF- CALLED "aD. 1'0 CURE 'YOUR MORTGAGE nEF Aut. T' F.XPLAfNS HOW TO BRfNG YOUR MORTGAGE UP TO DATE CONSUMER CREDIT C.OUNSEI.ING AGENCIES -If you meer Wlth one llithe consumer credit counsehng agenck~ hsr"d at the end of thiS NQllCe, the lend~r may NOT lake acnon ~!lamsr you for thll1:Y (30', days after rhe: dale ofthl. meel1ng. The: names. addresses an<lldeoholl~ - ExH--I~11 "c.. II RECEIVED TIMENOV.. 5. 5: 12PM PRINT TIMENOV. 5. 5: 17PM ~ ". ~W" ~ ~-."~ ,I '~ "" ~" ok ~<"- , !tjli'.d.~l"");t;',, Nov-05-0! 05:09pm From-MIDLAND MORTGAGE REFERRAL T-T41 P.04M H69. - .numbers nf dt:51l!I\alcd cons\.mer ~Tecllt COunSdlO!! all:enc!"s fnr tI,,, countY u' which the uroPem is located art" St:l fonh at the elld Ot"thlS Nonce It is only necessary to schedule one face-to-face meeting. Advise your lender immedIatelY of your lnt"ntions. A PPLIC A TION FuR MORTGAGR ASSISTANCE - Y cur mortgage IS 10 default for l/le reasons .et fot'lh lat-:r In thIs Notice (see foLlowmg pages for .peclf.~ infolI1l4tlon about the nature ofyout d"fault.l If you have med and are unable to resolve ttus problem with the lend"" you have the: nght to apply for flllancllIl aSS1sranc" from the Homeowner's Emergency M"ng~ge Assist<>llce Progrllm. To do so, you must fill out, Sign and tile a completed Homeowner's Emergency Mortga!:e ASSIstance Proll1'aal Application With one of the dcsign..tc:d cOllsumer credit counseling agencies listed anhe end oftlus Notice. Only cons1.Imer credit counsehng agencIes have appl1~arions for the program and they will assist you In submining a complete application to the P,:nnsylvania HOUSUlg Finance Agency. Your applIcation MUST be filed or paslJIlarked within thirty (30) days of your face-to-face meeting. YOU MUST mI. YOUR APPUCATION PROMPTLY. IF YOU FAlL TO PO SO OR if. YOU DO NOT FOLLOW THE OTHER'l'IME PERIODS SET FORTH IN THIS LETTER, FORE<;LOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSlST,\NCE WILL BE DENIED. 1 ~ - AGENCY ACTION - Available funds for emergency mortgage aSS1StllIlCe aTe very lunird. They Wlll be disbursed by the Ageney under the eligilnlity criteria established by'the ACt. The Pennsylvania Housing Fuu.nce Agency has sixty (60) days to make a decision after It receives yallrapplication. During that time, no foreclosure proceedings wm be p=ed against you if you have met the time requirements set fonh aba"e. You wlll be notified direcdy by the: Pennsylvania Housing Finance Agency of its deciSion on your applicanon. NOTE: IF YOli ARE CtJR.RENTL Y P~OTEcrED BY THE FlLING OF A PETiTION IN BANKRUPTCY, THE FOLLO'wING PART OF THIS NOTICE IS FOR lNFORMATION PURPOSES Ol'lLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT TIlE DEBT. (If yo II have fJ.Icd bankruptcy YOIl can still :!.pply for Emergency Mongage Assbt3..llce.) - RECEIVED TIMENOV, 5. 5: 12PM PRINT TlMENOV. 5. 5: 17PM t;;!; - ~-""''''' ~$:'o_ Hov-05-01 05:09pm From-MIDLAND MORTGAGE REFERRAL T-741 P. 05/12 F-56Q. BOW- TO CURF- YOUR MORTGAC~~ OlCFAUI.T lBrint> it liP to clate). - NATURE 01;- THO: DE~AIlLT - The MORTGAGE debt held by the above knclcr 011 your property located at. 402 N FllBERT S't MECHANICSHURG PA 17055-3329 1S SER[OUSLY IN DEFAlJLTbecal.lse YOU HAVE NOT M..!\DE MONTHLY MORTGAGE PAYMENTS tur the following months and the followmg amounts lire now p.'zt due: . TOlal Due $ 3 n 1. 46 WHICH !NCLUDES: (a) Monthlyplyments frO"1 t/l/Ol through 10/1/01 - (at$613.66 PEll MOrHlt) (b) Uncollected Late Charges ancl fees HOW TO CURE THE OF-FAULT - You may cW"e the default wltlun TIiIRTY (30) DAYS of the dllotC of this nOllce BY PAYING THE TOT.\!. AMOUNT fAST DUE 'f0 Un: LEND'<':l<, WHICH 13 1--_, PLUS ANYMORTGAGE PAYMENTS AND LATE CHARGES Wl-lICi"l BECOME PAST DUE DURING TIiE nURT't' (30) DAY PERIOD. Payn,enlS must be made euher bv ca;)h t.:3..3h~cr's-chec:k. e~lfi~d check Qr monl:'V order made:" n9.vable and liimf TO: - Ami: CaShIers MIdland Mcngage Co. PO Box 268888 Oldahoma City. OK 73126 l~' VOU DO NOT CURE TlaE DEFAlfl.T - If you d~ not ClIre the default withm TIiIRTY (30) DAYS of the date of this'Norice. the l@fder intends to exerci~e its ri~hts to acc"lente the murteape debt. TillS means that the enllfe outSrandmg balance of this debt Will bcconsideced d"e mlmedlatdy :,nd you may lose the chmce to pay the mongage in monthly Installments. If full payment of the total amowlt past d"e IS not made w,thin TIilRTY l30) DAYS, the knder .I~o Imends to LI1StIUct its attoiIleys to Start legal activn to foredos" upon Your mortra~ed pro~ IF Tffi;' MORTGAG~ IS FORECI.OSi:D UPON - The mortgaged proper!}' will be sold by the Sheriff to pay orfthe mortgage debt. lfthe lelll.ler refers YOI.Ir cage to lIS attorneys, but you cure the delinque'lcy b.:fore the lender begins legal proceedings ag~mSt y;)U, you Will StIli be requm:d to pay the reasonable attorney's fees that were actulllly I/lcurrc:d, up to $50.00. However, Iflegal proceed.;;\gs arc StlLned against you, you will have to pay ..II r":>son,,blc attom"y', fees actually inCLllTed by the lender even if they ellCced $50.00. AJ.1Y atlumey's fees wm be added to tile amou.11C you OWe the lender, which may include other reasollable coStS If vou ellre the debult within tll" THl'RT't {30! DAY ,,"riod. "au wiJluo( be required 10 m arlora"v', fees. OTffi'R LENDlcR REMEOU:S -1ne lender may also sue you personally for the Wlpald prinCipal balmce and all ow.". swns due under the mortgage - RICl'lT TO emu THE DEFAUl.T PRIOR TO SHEnIFF'S SALE -If you have not Cl!(cJ the default withu. the TIiLRTY (30) DA Y'pc:riod and tor<:c!osure ptocecdillllS halle bcgUll, ~ClU still have the ri!!:~t 0 Cute the dc:fa t and reV tthe sale at an nme II to.One hour <:torems Sheriff's Sale. You ma'f do so bv pavin2 thelOUlI amoW\t then oB5t du" olus any laleor other char~es then due: rea.~onllbte'a[[ornev'S fees and cOSL~ connec~d WIth the tc,recll!lsure sale ;lna anY other COSts c.mnccte:d w"th the Shmffs S3k hS snc;ciried in INtlnna by the lender and!!:l nc:rfonnln2 any r,lher reaulreimc:n~s under the- mnrtQa2e. Curillg you.... deCd-u.lt in the :us.uuer .)..:,; RECEIVED T1MENOV.~ 5:12PM PRINT TIMENOV, 5, 5: 17PM "A>; ~ L . ~' ,I ~~'- '. Cd m'_ ' -. ",. Ikfl;iiiiMiIiiit~ Nov-05-01 05: 10Plll From-MIDLAND MORTGAGE REFE~AL T-741 P.06/1Z F-S6a forth ill this IlOtie: Will re,"tore your worrg;<gc to the S:lwe p"sitioD :1. if you bad Dever dl:iaulted. - F-ARLJJ:ST POS:;IBl. Ii: SIJERlFF'S SALE DATE - It I; estimated tt.at the e~rhest date that s~"h a Sheritrs Sale of the: mortgaged property could be held WOUld be approxiUl:lldy SlX (6) mOllths frOID Ihe date Or this Notice. A notice of tile actual dale of the Shenffs Sale WIll be sent to you before the sale: Of COUTSe, the amOllllt oceded to cure thol <Iefault will Increase: the longer you wait . You may f<lld out ellactly wh..t rile required payment or action Will be by contacting the lcnller. flOW TO CON1 ACT THE (.F.Nb~R: Mtdland Mortgage Co. PO. Bolt 26648 Cklahoma CitY, OK 73126 Ptlnne (800) 552-3000 fal<. (405) 946-2677 , li:FWrT OF SAF.RfFF'S ~ - You ,:houlJ reahze that" Sheriff's S1le will cad yOll( ownerslup of the mQrtgaged property and your nghtto occupy lI. IfYO<l connnue to live: ill UIC property after the: Sheriffs Salol. a lawsuit to remove YOll and your furnishIngs and other belongings could be stlll'led by ~ lender at any nme. - ASSUMPTION OF MORTGACE - You mayor may not ~ able [0 sell or rraJlsfer your home to a buyer or transferee who Wllllllisume the IllOrtguge debt. dependmg on the telllls .nd cOCld1llons outlin.=d In your mortgage ana prOVided lh:ll alllhe OUl,Standl:l1:\ paymcnu, d.:lCl!es aud artomey's fees lllld costs are paid pnor 10 .:II at the sale aCId that the other leqUlrementS of the mortgage arc ~allsfied. . J YOU MA. Y ALSO BA VR Tm: lUGHT: TO SELL TIffi I'ROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGS DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSID1J1l0N TO PAYOFf niB DEBT. - TO HA VE nn~; DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HA.VE THE MORTGAGE RESTORED TO THE SAME POSITlON AS IF NO DEf....ULT a'\.D OCCURFED, IF YOU CUll.E 1l1E DEF....ULT. (HOWEVER. YOU DO NOT HAVE TI-nS RlGHT TO CURE YOUR DEFAUlT MORE THAN THR.EE TIMES IN ANY CALENDAR YEAR.) TO ASSERT 11-iE NONEXlSTENCE OF .... DEFAULT IN ANY FORECLOSU)lJ;: PROCEEDING OR /\NY OTHER LAWSUIT INSTITUTED UNDER TIiE MORTGAGE DOCUMENTS TO ASSERT ANY OUiER DEFEN~E kl.1 flEUE\'E yeU MA Y 1lA VE Te SUCH ACTION BY 1HE LENDER. TO SEEK PROTECTION UNDER fEDI!R.I>J. BANKRUP'fCY LAW RECEIVED TIMENOV.5. 5:12PM PRINT TIMENOV ~ 5:17PM ~, ~~ , ~,- Nov-05-0! 05:10pm From-MIDLAND MORTGAGE REFER~AL _, I" , . ~ '"( " -> "''ll~ T-T41 P.OT/IZ F-569. M id la n d M 0 rtg age Co. P.O. 80l< 26648 Okhhom. City.Okhhon.. 73126 '11000 (:lOO) SSJ.1QQO F1.A (<t05) ""b-J077 OCTOBER 1, 2001 JEANl'lE K RIT'rEll 402 N FILllERT ST ~ECftANICSBURG PA 17055-3329 - ACT 91 NOTICE 'TAIffi ACTION TO SAVE ':OURHOME FROM FORECLOSURE , , TIlls is an officllll :lonce: that the mort~ace on vour home is in de:fa...lt and the l~nder intends tu foreclose. :\uc.::itic mformation about th<: nittlre of the d<:f~ult is provided in the attached n.gcS - The: HOMEO\l. MER'S MORTGAGE ASSISTANCE PROGRAM lIiEMAP) OlDy he able t:l .I!sln to s.ve VO'IT home TIlls notiCe e:ltolains how the: prOlmltn works. To see ifHEMAP can he:\ll. vou mustMEF.T WlTH A CON~JJMER CREDIT COUNSELING AGENCY WlTI-{IN 10 Dp, YS OF THE DATE OF nus NOTICE Take this Notice with \/0'" when you me:e:t with the Counsehn~ A~e:ncv. The naTlle addr~s. and l)hone nl,lmber of C-llnsumer Cred.t COllnsehnl! A"en";es sCIVlnl( vem,. CounlV are .isle.:! at lhe- "nd of lh.s Nonce. If VOll hav<: anY o\ICStions vou may call the Pennsvlvan~ HOl,lsinlZ Finance AlZcncv toll tl-<,,, lot 1-800-)42-2197 /Pct'SJ>ns wuh il1lDairrrl he:annl! can call/717\ 780-1869. Thl~ Notic,. cat.rains Important legal mfchnanolt. If you hav,,:u1Y questiuns, (<:presenrarives at the Consumer Credil Counselmg Agency lnay be able to hdp explam It. YOIl may also want to contact an Boorney in your arcll. Thc local bar assoClanon m~y be able [0 help you find i lawyer. LA NOTlFICA,::ION EN ADJUNTO ES DE SUMA lMPORTANCLA. PUES AfECTA SU DERECHO A CONTfNUAR VlYIENDO EN SU C.'\SA Sl NO COMPRENDE EL - RECEIVED TJMENO~. ~ 5:12PM PRINT TIMENOV. 5. 5:17PM ~ . ,-- .1 ^,'_".""",,, ,...._... ~, --' '"~iJn~l:.l~'bl,0 -- Nov-05-01 05:10pm T-T41 p.Q8m forth ill this ~QtiCI' will restore your mong:lge to the same position as if YlIU had never defaulted. From-MIDLAND MORTGAGE REFERRAL F-5S9- F-ARLJEST POS~lBLF- SHl:'RlI'F'S SAtE DATE -It IS eSluna.cd th"t the earliest date ElIat s...dl a Shenffs Sa,e of the mortgaged propertY could be held wOllld be apprll.tialately SIX (6) months from tbe ,late ofthis Nutice. A notice of the ~ctual date oithe Sheriff's Sale WIll be sc:nt to you before ,he sale Of course, the amount needed to cure the default w.ll increa~e lhe longer you wait. You may find Ol.lt exactly what the required payment or action will be by contacnng the lender. ROW TO com.\CT TIJ::[ LENDER: M,dland Morrg3ge Co P.O. Box 26648 O~ahoma City, OK 73126 Phone (800) 552-3000 Fu (405) 946-2677 -- EFFECT Of SHERIFF'S SALE - You should realize Ihat a She:iffs Sale will end your ownership ofthe mortgaged propen:y and your righllO occupy il. If you COllOnlle 10 hVe in lhe propertY after the Sheriff's Sale. a lawsuit to remu'le YOl.l and. your timti,hings and other belonl,'1ngs could :Ie starred by me lender at any nme. ASSUMPTION OF MORTGACE - You mayor may ROt be able to seU or rrads[er your home to a buyer or rnln,.feree who W\1l assume the mOrtgage debt, depending on the: terms and concllrions outlined III your mortgage and proviCled that all the outstanding paymen~, chartes :ll\u anorney's fees and costS are paid prior to or at the SlIle and th:itthe "ther requIrements or Lhe mortgage are S3ti,;fjtd. j . -- YOU MAY Al:.f>O llA \IE TffF I'...1GRT: TO SELL TIlE PROPERTY TO OBTAIN MONEY TO P!\ Y Off TIIE MORTGAGE D(13T OR TO BORROW MONEY FROM ANOTHER-lENDING INSmUTION"fO PAY Off Tt1~ DEBT. TOHAVETIUS DEfAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE TIiE MORTGAGE RESTORED TO TIlE SAME POSITION AS IF NO DEfAlll.. T HAD OCC~O. IF YOU CURE THE DEFAULT. (HOWEVER. YOU PO NOT HAVt; THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES 1N ANY CALENDAR Y1~) TO ASSERT nrE NONEXISTENCE. Of A DEfAm.T IN ANY FORECLOSURE PROCEEDlNG OR ANY OTIlER LA wsurr INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA. Y l:lA VE TO SUCH ACTION BY TIiE LENDER. ( TO SEEK F-ROTECTlON UNDER FEDERAL BANKRUPTCY LAW RECEIVED TIMENOV. ,.5. 5: 12PM PR;NT TIMENO~ ~ 5:17PM ~ ~ "~ '" 1iI~ ^ IT"-"='- ~"","..i..J;L't'~'iJW"""'i" Nov-05-0t 05:11pm From-MIDLAND MORTGAGE REFER~AL T-74t P,09/12. F-569' LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANClA. FOES AFECTA SU DERECHO A CONTINUAR VIVIWDO EN SU CASA. SI NO COMf'RENDE EL _ CONTENIDO Df EST A NOTIFICAC10N OBTENGA. UNA TRADUCCION INMEDlTAMENrE LLAMANDO ESTA AGENClA (pENNSYlVANlA HOUSING FINANCE AGEl\CY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER EtEGlBLE PARA UN PRESTAMO PR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGR&\I1" El CVAL PUEDE S..o..LVAR SU CASA DE LA PERDlDA DEL DERECHO A REDIM!R 3U HIPOTECA. Homeowner's Nam~(>) . Property Address, DONALD L RITTER. JEANNE 1<. RITTER 402 N FILBER.T ST MECHANICSBURC PA !/055-3~29 44:<34500 Midland Mortg'4ge Co. ; . Loan Account N..: LcnderlScrvicer; - HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU M:AY BF- EUCIBLE FOR fINANCh.L ASSISTANCR WHlCR CAN SAVE YOliR ROME FRUM FORECLOSlflU; Al'ffiIlELI' YOU MAKE F\JTIJRE MORTGAGE PAYMENTS I IF YOU Cor.-ll'L Y WlTI:I THE PROVlSIONS OF nn: BOMEOWNER'S ~~MlLRGENCY MORTGAGE ,~SlSTANCE ACT OF 1983 (THE "Aer"), YOU M....Y BE EUGIBLF. FOR EMERGl:NCY MORTGAGE ASSISTANCE: IF YOUR OF-FAULT HAS BEJ;:N CAUSED BY cm.CUMST_-0ICES BEyorm YOUlt CONTROl., IF YOu RAVE A REASONABLE PROSl'RCf OF l:IF;JNC ABU: TO P....y YOUR MORTGAGE PAYMENTS, AND IF YOl! MEET OTHER EUCmn.1TY llEQlJlREMl:NTS ESTAIsUSHED BY THE PENNSYLVA,NIA ROUSING FINANCE AGENCY. - TEMPORAR.Y STA Y .oFI FOnF.CLOSURE - Under the ACt, y"u are ~nritle<l to a ternpOC:;l1' stay of foreclosJI'e on yourmottgage for tlurtY (30) days from tile cbt~ "fthlS Notice. DUflll!l':la, time you must l.rrang~ lIt\d imend a "face-to-face" m~"ting Willi one of tl\~ conS\lm~r ct'edit counseling agellcks listeCl ~t the end of t. S Notice.. THIS M:EETNC MlJs:E aCClrn. WITHIN TBJ! XT 130, . AYS. . ou a NGT I'IPL '{ OR. E. GNCV MaRTGAGE ASS1STANCI:E you MOST BRING YOUR MORTGAGE UP TO 0.... TE. nrF- PI\RT .of nIB NonCEc...LLED ';HOW"tO CURE YOUR MOR.TGAGE IJF.FAUl.T' EXPLA.INS HoW i.o BlUNG YCUR MORTGAGE UP '1'0 Oil. TF. RECEIVED 7IMENO~,~ 5:i2PM ~R'U. .'M"UOV 5 .I . i J.~ 1 I 1. II (. ~~ . . r, . 7')11 :;. I .I .Iv. ""~ '.~~' ' r ~ t-" ~" .J&Y:ll:lllill..~"""~~'L, Nov-05-01 05:11pm From-MIDLAND MORTGAGE REFERRAL T-741 P.lOM F-569- CONS1J1\lffiR "CREDiT COUNSELING AGENCIES -lfyou.nc:~r wITh on" of the consumer credit counseling agencies hsted at the end of this Notic~, the l~nder may NO'f take aClion ag:'lIIsl you tor chirty (30) dlyS after the dale" of this meetmg. The names addresses andtdeohone numbcr~ of dcsirmaled consumer credit counselinll a2encic:l for the count'< In which the oroocrtV is located are Set forth at the end ofth.s Notice It i. only necessary to schedule one faco:-t.:l-face meetLllg. AdVIse: your lender Immedlatel" of yuur inreunons. - APl'LICA TiON FOR MORTGAGE ASSISTANCE - YOllT mOrtgage is in del:.ult for the reasons Set forlh la~:r III this Nonce (see tollowmg pages tor speCific infonn~hon ;;boutthc nature of your default.) [fyou have tricd ami are unablc to resolvl: tlus problem with the lemler, you have: the right to apply for fmanclal assistance from lhc: Homcowner's Emergency Mortgage AsSistance Prograrr.. To do so, you must fill out, siGll and fil~ a completed HomeoWller's Emergl:llcy MOl1ga~e Asslstanc~ Program Application wilh one of Ihe dc:signaled conSumer credit counsehng a!:encles listed at the end of thiS Notice. Only consumer credit counsdmg agencIes have appliClltlOnS for the prob'Illm and they will assist you In submmlnll a complet~ appliclirlon to the Pennsylvania Housml;l finance Agency. YOllfapphcation MUST ce tiled or posnnarkc:d wuhlll thirty (30) days vf your face-to-face mcennll. 1 YOU MllST FIU: \'OUR APPLICATION PROM.PTl.Y. IF YOU FAll. TO no SO OR I!~ YOU DO NOT FOLLOW 'I'1IE OT!llLR TIME PElUODS SET FORTH IN TmS LETTER, iORECLOSURE MAY PROCE.!>:D ACAINST YOURHOm IMMlLDlA.TELY AND YOIJ.RAPPUCATlON FOR MORTGAGE ASSISTANCE Wn.L BE-DENlEO. - AGENCY ACTI(IN - A~ailable funds for cmergc:ncy morrg!ge aSSlSlance are very limIted. They will be: disbLL -sed by the Agency l1l'lder the dlglbihlY critma eStablished by the Act. The Pennsylvania Hou'.lIlg Finance Agl:tlcy has SIXty (60) days 10 malte a deciSion aft~r It receiv~s your apphcation During that rime, llO lorcdosure procc:edings will be pursued against you if you have met the lime -.:qulremo:nrs set forth abQre. You Will be nonfied directly by the Pennsylvalll~ Housmg FJllanCl: Agency of ItS dc:ci.ion on your applicatloll- NOTE: IF YOU ARE CUlRlu:NTL" PROTECTED BY THE mING OF A PETITION IN 8ANI\.RUPTCY, THE FOllOWING PART OF TIDS NOnCE IS FOR lNFOltMATlClN PURPOSES ONl..Y AND SHOULD NOT BE CONSIDERED AS AN ATI.EMl'T TO COLLECT THE DEBT. (If you h:lYe 611:d bauU\lptcy YOIl can still apply for Emergency Mo.-rg:lge A,sista"cc.) - RECEIVED TjMENO~ .~ , ' : ?Pllj J. I... il PRiNT T:MENOV. 5. , . , 7P" oJ'l m. ~ i- ~-' ~ ~,~ -'~-,,-~ Nov-05-0! 05:11Pm From-MIDLAND MORTGAGE REFER~AL T-741 P.11/1Z F-569 HOW-TO CURE YOUR MOR.TCAGE DEFAULT (Briup it Lip to doll~\. NATURE OFTID: DEFArn_T- The MORTGAGE debcheld by Ihe above knLleTon your property located at: 1,02 N FI1.BERT St ~ECHANICS8Uac FA 17055-3329 IS SfRIOUSL Y IN OEF AUL T because YOU a, VE NOT M.'\DE MONTHL Y MORTCAGE PAYMENTS for the followmg months and th". following amounrs are now p:lS[ (ILle: . Toeal Due $3111. 46 mil CH INCLUDES: -- (a) Monthly p;.ymenrs from 6/1/01 through 10/1/Ol (b) Uncollectd L3[c Cnarges and Fec; (:11 $ 613.66 p..r mon~h) ROW TO CURF- fHE DEFATJL T - You may cure the jefault withm TIiJll.TY (30) OA YS of the date of this not:ce BY PAYING THE TOTAL AMOUNT PAST DUE TOTRE LENnEll, WHICH IS i-~ PLUS ANY MORTGAGE P^ YMENTS AND LATE CHARGES WlilCU BECOME PAST DUE DURlNG l1:IE THIRTY (30) DAY PERIOD. PaYments must be ma<lc ".\theT bv ca;h CashleT" ~heek:. eerofi".d eh",~k OT monev order mAtI~navable and ~ent to: Attn. Cashiers Midland MOItgage Co P.O. Box 268888 Oklahoma City. OK 73126 IF yOU DO NO'\.' ('1lRJi' TlIE DEF I\UL T - If YOll do not :ure the default wlthm TIiIRTY (30) DAYS of the dille of this NOllCC, the I der intends to e1erd~" its i, s to acc~ et:lt" lh~ olOrtpa\:e debJ. ^.nls means that the enEue utstandUll; balance of this debt will be conSidered due Ul'IInedlately l4ld you may lose the chance to pay the mortgage Ul mon[hly installments If full paymc:nt ofth\: total amount past dlle is not made withm TIURTY (30) DA VS, dIe \c:nder also IOleni.ls to insU"UCt its attorneys to surt legal action to foreclose upon YOllr morlL'll~ed p,'ooerty. -- IF TTfl;' MORT(;AGE IS FORECI.OSEllIIPON - Themorrgaged property Wlll be sold by the Sheriff to payoff the mOl'l~a~e debt. lethe lendc:r rd"ers yow: Cll$e to Irs attoi'neys, but yOll cure the dehnq~11CY bc:fore the lender begins legal proceedings agalOst YOll, you WIll sall be: required to pay the reasona.ble attorney's fees thaI were a=l\y utCUlTed, up [0 S50.00, Hvwel/er, if legal pccceedmgs are SUIted against you, you wil1 have to pay all [easonable aaomcy's fcrs actually lIlc&aTed by the lender "vcn if they exceed :Ii50.DO. Any an:omey's fees will be added to 11Ie amount you OWe the lender, whkh may include other reasonable cOSts. Ir vou cure tbe default within the THIRTY (30\ DA V "efiod, YOU will not be required to 9:.\1 attoruev'~ fees. OTlmR LENDER REM:tOIES - The lender may aloe Sue you personally for the unpaid principal balance and all other sums dl.le unjer the moItg:lgc. RIGHT TO CURE TlmDEF '\.1Jt;T PRI,OR TO SHEIUn"S "Al.E - If you have nat cured the default w,tlIill tho: 'l'lURTY (3D) :.6:'1. V~Od and forcclo!W"<; Pl'oceedings .11ave beg\lll, v3u still have the right to cure the d9fa"lt llnd .eveiU the sale at anV time uO l<l one hour beror.. Ih.. Shenrfs Sale. Yo" mavt.lo;SObY"D~Virie rllc toral amounlthen past dUe plus any},He,orulhc:r charges then <We. reasonable:: atrOme1l's fees and COS\S e"nnected WIth tnetoreclasure,sale and anv other COSts connected Wiith the S!ierift's S"le as speCIfied in wntinl!" bv [h.:.)er~ddr anil Lv Derformtn!1 any .nht:T reQ"iTemen[~ under the: morreaee CUNg your ljeC:l.1l1c in thelll:lIl1~er Sl;t - RECEiVED TiMENO~'~ 5:12PM PHiN? ?iM~};OV. o. 5:; 7?M ,- '., i:'_Zi2\;.~if.J~".J , I , --- . -lili, ,~, -:'''''-~iW()~~-Xt' Nov-05-01 05:12am From-MIDLAND MORTGAGE REFERRAL T-741 P.12/12 F-569 Midland Mortgage CO. P.O. Box 266~8 Okh.homa City, Oklahoma 73126 Phooe (gOO) S5~.lQQO fa (OOS) 94&.2077 OCTOBER. 1, 2001 DON./\.l.D L RUTER. 402 N Fl1.8ER'I ST MECHANICSBURC PA 17055-3329 - ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE I Th,s IS an offict:.1 nonce that the mort~age On Your home i~ In default. and the lender .Otend. to foreclose SOecl fie Information about the n:lture of the ddalll, IS provided 10 the a!Cached pa..eS. The HOMEOWNER'S MORTGA-GE ASSISTANCE PROGRAM (REMAP) may he able tu helo to saVe vour home ThIs nnClee explains how the DT02l1lm worles. - To see IfHEMAP can help YOU must MF.F.T WITH A CONSUMER CREDIT CO(JNSELING AGENCY Wl THIN 30 DAYS OF TIlF. DATE OF nas NOTICE. Take tlus Nonce WIth vou whc:n YOU mee! With Ihe COllIlsdiOl! AeenCy. The name ad.ircss and phone number of Coosumer Credit COLUlSelinl! Aeenci-s servin.. vo"r COLln'" ar.: IIsred at [he end O([lllS Notice. levou have anv Quesnons, vou may call [he P=nsvlvania Hou.Slng Final1ce Al!<.'ncy toll free at 1.800-142.~397. (Per,ons with Imoa,red heann" Can call (7] 7) 780- ]869. TIllS Nonce c"ntams Important lcgal ir.tormation. If you hav.: any qu~rions. representallVc3 al the Consumer Credil Counselmg Agency may be able to help explain it. You may also W3(lt 10 contact an attorney in your area. The local bar association may be able to help you find a lawyer. RECEIYED T:MENO~'~ 5: 12PM PRINT TIMENOY. ~ J. ~ '7~\1 J: I ~ m ~-- - -1 '0",.",",...' . . f ~_" J -~~-=, " o~~t;_h?$"',"': VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for the Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by MIDFIRST BANK, Said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: November 21, 2001 Leon P. Haller, Esquire , _w . _,._1 jj'j~-(rJ"'~:,~~i!lj:mfffii!!!~m~OOi'~";'~~'i'.Jm>-j'!<;"'G;_;'d1 ~"''''<'!'J'''-'S);b-,'M'.!'''\i::i,;r,""iili1;w*<iJi<~Illl~JjIir''''''-'' ,.--"'-' .... '~ "~~ ?i~ -.,..t. 9-J - --- ~ -Sf o e .J.ILU ~, '" ^ ,0>," o,~,,,,1 "C""'c;",v.;.,,:~'-" "~_",,_,__,_ "".-. "" . '-if" -"~I~IlF-~="--'-lUJ- ,- , ~=- - @ ~ ..,.;:: .()) C() a2 r -=== - () c~ ,"~ c: " :s: ~ ~?{: :.:> "-:::: :2 ,T~ !".) , Z- ,- Ui C-" --< ~cj --0 .. )O'C :h.: ':~~~ Z-j Zc 'd -~rn >c: L.....-' Z C--' ::;~ :;! ~O 4- -<. r- ~ ~ ~ ~ -".. "" n,'"'~-~, ,~,^t"~",,, ,",~"" _, .",- ~ ~~ ~' ~"~, , -~ [- ~, "'-"l. ~,~=. ~';;";"'.'r. "'~"""Jji;~iiillrli/'!"'lii;li"":i,b~-'1'J;-{ . SHERIFF'S RETURN REGULAR f' ~ -J. 10 / CASE NO: 2001-06606 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDFIRST BANK VS RITTER JEANNE K ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RITTER JEANNE K the DEFENDANT , at 1840:00 HOURS, on the 5th day of December, 2001 at 402 NORTH FILBERT STREET MECHANICSBURG, PA 17055 by handing to JEANNE K RITTER 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 Service Affidavit Surcharge So Answers: 18.00 6.50 .00 10.00 .00 34.50 ~~~ R. Thomas Kline 12/10/2001 PURCELL KRUG HALLER Sworn and Subscribed to before By: ~~~ Deputy Sheriff ~ - me this /3 - day of ~"tt- .2H!( A.D. ~ . Q, 'n.'IP;,. 1/fffI- Prothonotary' I T~'~ - ~~~~ ~' 0 . '1:i1l --1, J(.""Y ""\4i"~!67ot!'!",,~.'; SHERIFF'S RETURN REGULAR . -., ... CASE NO: 2001-06606 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDFIRST BANK VS RITTER JEANNE K ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RITTER DONALD L the DEFENDANT , at 1840:00 HOURS, on the 5th day of December, 2001 at 402 NORTH FILBERT STREET MECHANICSBURG, PA 17055 by handing to JEANNE K RITTER 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 Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 r'"~~"'<~ R. Thomas Kline 12/10/2001 PURCELL KRUG HALLER Sworn and Subscribed to before By: c!9;,/7rJ;1~~ ~ Deputy Sherif~ me this Yo-' /3 ..- day of ~"",J.." -' ;L6-tJ( A.D. ~ C'. )p...al:~ ,0Ju-::- P othonotary I '-r-' " .'<l ,t. .:.w;'"n_l~:J't.':'i MlDFIRST BANK Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. JEANNE K. RITTER AND DONALD 1. RITTER Defendants ACTION OF MORTGAGE FORECLOSURE # 01- (P(Q{)('p TIDS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 t\1~ l'~se may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET L,EGAL HELP. .; ; ::,' \ >~:' ': , ..:>~',,\ ; CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 717-249-3166 A VISO LE BAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION coNtRA LAS QUEJAS EN ESTA DEMANDA. , .',' <'.' RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU fiARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FA VORDEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA i:lBdsION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. '0 , .!! .. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 ';..";, ~'. i, , TRUE COPY FROM RECORD i;] T estimooy whereof. I here t!llto S6I my haCill ;il? th~ ~ said rt at Carl_..~ fh. . ~ , JiIrottIOOotllrJ[ , :1'- -.'.1 :', . I ,~ .,-- j "~ ' '! '". " . L~~lf;; MIDFIRST BANK, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. mANNE K. RITTER AND DONALD L. RITTER, CNIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendants THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.c. 1601 Tj !~ The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any infonnation obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. \;,!i}' ~; r'.:,.\;" ,u(}\' PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, P A 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff "' '" ~~,,," -, '0, _"__, OiM"',"liirimtl'" MIDFIRST BANK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. JEANNE K. RITTER AND DONALD 1. RITTER, ACTION OF MORTGAGE FORECLOSURE Defendants COMPLAINT IN MORTGAGE FORECLOSURE L Plaintiff is MIDFIRST BANK, a corporation whose address is 3232 WEST RENO, OKLAHOMA \:ii)[:CITY,OKLAHOMA 73107. 2. Defendant, JEANNE K. RITTER, is an adult individual whose last known address is 402 NORTH ,; l .' . FILBERT STREET, MECHANICSBURG, PENNSYLVANIA 17055. Defendant, DONALD 1. .' RITTER, is an adult individual whose last known address is 402 NORTH FILBERT STREET, MECHANICSBURG, PENNSYLVANIA 17055. 3. On or about, August 26, 1983, the said Defendants executed and delivered a Mortgage Note in the sum of $46,900.00 payable to PB MORTGAGE CORPORATION, which Note is attached hereto and marked Exhibit "A". , 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 735, Page 381 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to MERRILL LYNCH MORTGAGE CORP, and was recorded in the aforesaid County in Book 297, Page 1025. The Mortgage was further assigned to MIDFIRST BANK and was recorded in the aforesaidCounty in Book 619, Page 188. Said Mortgage and Assignments are incorporated herein. 5. The land subject to the Mortgage is: 402 NORTH FILBERT STREET, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly described in Exhibit "B" attached hereto. h'''_ -'". .I~" ~, .' ;,'" :';' "J'~~-'" 6. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on June 01,2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $35,236.12 Interest at $12.55 per day From 05/01/2001 To 12/01/2001 (based on contract rate of 13.0000%) $2,685.70 Accumulated Late Charges , \..1, Late Charges $30.68 From 06/01/2001 to 12/01/2001 $184.08 7. Escrow Deficit $650.58 Attorney's Fee at 5% of Principal Balance TOTAL $1,761.81 $40,518.29 **Together with interest at the per diem rate noted above after December 01, 2001 and other charges and costs to date of Sheriff s Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the (:. Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Plaintiff has complied with the notice procedures required by Pennsylvania Act 160 of 1998 by sending to each Defendant, by regular mail, a copy of the Combined Act 6/91 Notice. A true and correct copy of the Combined Act 6/91 Notice is attached hereto as Exhibit "C". 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. > " iill~f"'jjLtt;'i; 10. Defendants are not members of the Armed Forces ofthe United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 1 I. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Housing Finance Agency not to qualifY for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 13.0000% ($12.55 per diem), together with other charges and costs including escrow advances incidental thereto to the date heriff s Sale and for foreclosure and sale ,. ofthe property within described. By: n/ PURCELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) ..~ \ .....:,;..;1. !i;,ij'. i,IJh.'i,' . <" <' " = '-,. 111I1111~11~1I111111111111~1I1111~1I11~1I1111111 541l1487tllNTE VA Fmm 2~336a (Home LU411J Revised March 1978. Use Op- tional Sedion 1810. Title 38, U.S.C. Acceptable 10 Federal Na~ tronal M~ Association. 37052891 PENNSYLVANIA MORTGAGE NOTE CUMBERLAND I Pennsylvania. , 46900.00 19 . 83. August 26. L. RITTER AND . hereinafter called the Maker, promises to pay to FOR VALUE RECEIVED. the undersigned, DONALD JEANNE K. RITTER RIS WIFE PB MORTGAGE CORPORATION a corporation organized and existing under the laws of the THE STATE hereinafter designated as the Payee, the principal sum of Forty Six Hundred and No/IOO . , Thirteen with mterest from date at the l'"dte of per centum q3.00~) 1Jer annum on tbe unpaid balance until paid. The said principal and interest shall be payable at the office of PB MORTGAGE CORPORATION in RADDONFIELD. NJ 08033 t 76 EUCLID AVENUE . a a i v 5 . 01' such place as the holder may desIgllate in writing in monthly installments of a'fia Bf?l~bghteen Dollars ($518.8)~ commencing on the first d.V of 0 c t 0 be r , 19 a,Jtnd on the first day of ench month thereafter until the prinei~ pal and interest are fully paid, except that the final payment of the entire indebtedness evidenced hereby. if 110t sooner paid. shall be due and }lRyable on the first day of September .2013 Privilege is reserved to prepay at any time, without premium or fee, the entire indebtedness or any part thereof not less than the amount of one installment, or One Hundred Dollars ($100.00), whichever is less. Prepllyment in full shall be credited on the date received.. Partial prepayment, other than on an instaDment due date, need not be credited until the next fonowing installment due date or thirty days after such prepayment. whichever is earlier, Simultaneously with the cXt'cution uf this Note the Makel'lms executed and delivered to the l'ayee a Mortgage secured upon certain pl'(!mi~es situa1l:d in the Countr of CUM.BERLAND . Commonwealth of Pennsylvania, murf' l)llrticutarly described in the A-Iortgug-e. All of the terms, cove~ nants, provisions, conditions, stipulations and agret>.ments contllined ill snid MOI'tgnge to be kept and performed by th~ Milker are hereby made II purt of this Note to the suml' extent and with the same force and effect as if they were ruily set forth h('irein, und tht' Maker covenants and agrees to perform the same, or cause the same to be kept nnd IlPI.rormed, strict.ly in accordance with the terms and pro- visions thereof. The whole of the principIil sum or an.}' part thereof, and of Bny other sums of money secured by the MOI.tgage given to secure this Note. shall. forthwith, at thf" optioll of the Payee ot' any subsequent holder thereof, become due and pal'uble immedintely, without notice or demand, if default be made in any payment unde1' this Note. and if the defaul1. is not made good pl'ior t.o the due date or the next such installment; or upon the happening of any default which, by the tt!rms of the Mortgage given to secure this Note, shull entitle the Payee. or any subsequent holder hel'eof, to declare the same, 01' any part thereof, to be due and payable. The Maker does hereby empower any attorney of any rourt (If record within the United St."lW or elsewhere to aPIHlur for Maker, with 01' without a dedaration filed, and confeRS judgment or judg- ments 'against said Make.. in favor of the Payee or an)~ sub!;equent hold.er ~ereof. as of any term. for the entire unpaid principal of this: Note, and all other sums p."lid by the holder hereof to or on behalf of the Maker Pl~uunt to th.. terms of this Note or said Mortgage, and all, nrl'earages of interest there- on, together with costa of suit, attorney's commission of 5 ~ for ("ollection. and a release of an errors. on which judgment execution or executions may issue forthwith. The Maker hereby waives the right of inquiHition on all propel'ty levied upon to collect the indebtedness evidenced herebr and does voluntarily condemn Ute same and authorizes the Prothonota-:y to entpr such condemnation, and waives and releases all laws, now in force OJ' hereafter enacled, relating to t'xemption, appraisement or stay of execution. The agreements herein contained shall bind, and the benefits and advantages shall inure to. the respective successors and asl'igns of the parties heretu. Wherever uRed, tht> singular number shall in- clude the plural, the plural the singulm', and the use of any gender shall be applicable to all geJJders, IN WITNESS WHEREOF, the Maker has caused these presents to be executed under seal the day and year first llbove written. ~ . A/'J~ Signed, Sealed and Delivered ~~AL" . 1> "." ............(SEAL) in the ,Presence of: ., h h"" 'T ' h'h.....mh.., (SEAL) ....,.:l...~!(~:.i~~.....:,..'f..~:!..-..._n__u_u_____._...h..........__.. .___..____.n..nn....:.___.________.....___._____....n_....:.....~ (SEAL) '.h..................h...................h.h'............m.m. (SEAL) OF NEW JERS1i:X or order, Thousand Nine Dollars (,46900.0~ THIS Is To CERTIFY that this is the Note described in and secured by Mortgage of even date here-- with secured on real estate situate in CUMBERLAND /1County, ComIQonwealth of Pennsylvr.:J.ia. " ~ k" ( ._;Jf:L~~..~c....!..I..~!~..:.:~.:..-//:~.:.i:YO--~;;;;;;-hbil:;:... E~rtlBn II A tI';/C~')_'",J ''# y/~. "'~''''''...r..-..'''''~'' ~' ..0.;- ~,. ["'~' I "~Il!.ifi:tl~lt1J"-~j . W'T::O:JT BEOOURSIl. PAY '0 '..:: V,,:lllR OF: ,'I ,'- ';"'1. 'k' '~. ""'......=.'.. .t",$i&t:;, AJ1ltJOoS lU1l8!SSY :~B "ERell' r ......" ;"':'l~TGAG II n... '-11"'1 ....., r n 14C1r"l.~ lE:f^.~"t.r.: T 3.J..J39 .iN ::!::Hn- 1:Id 3:JIA -~l(;:}; , :Aa ./ " >IN-In l~~.::t..:-an:-, ---.;------ ::10 l:l30l:l0 3H.l Ol. A\fd 3SI:In003l:l J.nOHJJM NaIlWHadH~ 19\'lllHOI'l 1~1:,1 T. ',l as.tnO)O.1 tnC'LJi!,:. )fNVl:l J.SllI.dmw :lO lI3aHo 3IU. o.t AY. 't" '..."......... .,,,.c..., j /' ] I l 'I. 0' ". 'I' ,';,,":....:-i.\~;i ~"~ ~" ...... ...... '.0 'e n ALL THAT CERTAIN tract or parcel of land with the improvements thereon erected~ situate in the Borough of Mechanicsburg, County of Cum- bel'land and Commonwealth of Pennsylvania, being more particularly bounded and described as follows: BEGINNING at a point on the easterly 11ne of' Filbert Street; which po~nt is 78 feet north of the northeasterly corner of Portland and Filbert Streets; thence along the easterly line of Filbert street North 21 degrees 40 minutes West 58 feet to a point; thence North 68 degrees 20 minutes East 124.55 feet to a point; thence South 21 degrees 40 minutes EAst 20 feet to a point; thence South 33 degrees 39 minutes West 66.77 feet to a point; thence South 68 degrees 20 minutes West 69.65 feet to a poiot, place of BEGINNING_ BEING premises known as 402 North Filbert Street and having thereon erected a brick stucco ranch type dwelling house. BEING the same p~mises which Helen L. Lowe, unremarried widow by her deed dated August 26, 1983 and intended to be l"ecorded. herewith, granted and conveyed unto Donald L. Ritter and Jeanne K. Ritter, his wife. bout qvr 735 ?t.r.t u 1.1) sian therefor shall 'Occur: - - . PROVIDED, that in case default shall be made in the payment of any inatalJment of principal and interest, or any other payment hereinabove or in the conditions of said rE-Cited Note provided for, or in the keeping and performance by the Mortgagor of any covenant or agreement contained therein or in this MOl.tgage to be by said Mortgagor kept and performed, in the manner and at the time specified for the performance thereof, such default will entitle Mortgagee forthwith to bring and sue out an Action of Mortgage Foreclosure upon this lndenture of Mortgage, 01. to institute any other appropriate action or proceeding to foreclose a mortgage. and to proceed thereon to jUdgment and execution, for recovery of said principal debt or sums and aU interest thereon and all other sums hereby secured, together with an attorney's commission for coUection. as aforesaid, and coats and expenses of such pro~ ceeding, and to pursue any and all other appropriate legal or equitable remedies in such cases provided bO:J~ 'i,~:"j f!.t;; ~~~;'j ExHltslT II~}I ~oY-05-01 05:09pm From-MIDLAND MORTGAGE REFERRAL ," Wlj" " lli' .,. 'c."~ <, , -wlIi~~w,i~,i~, T-741 P.OSIIZ F-569 CONTENIDO' DE ESTA NOTIFICAClON OBTENGA UNA "IRADUCC10N INMEDITAMENTE llAMANDO ESTA AGENClA (pENNSYLVANIA HOUSING FINANCE ACENCY) SIN CARGOS Ai. NUMERO MENCIONADO ARRiBA. PUEDES SEa ELEGIBLE PARA UN PRESTAMO PR EL PROGRAMA LLAMADO "HOMEOWNElt'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PER~lDA DEL DERECHO A REDlMIR SU HIPOTECA. Homeowner's Nam;(s) : - Loan Account No.: LenderISc:rvicer: DONALD L RITTER JEANNE K k!~"I'ER 402 N FrLBEl~r ST MECHANICSBURG PA 17055-3329 4423ltSOO Midland Mongage Co. Property Addre$s' HOMEOWNER'S EMERGENCY MORTGACE ASSISTANCE I'ROC-RAM YOU!\IIA Y BE EblGInf.F. FOR FCN.u-lCb\l. ASS(STANC~ \VInCa CAN SAvr. Yem~ ROM];: FROM FORECLOSmu: Al'ffi liEU' YOU M"-KE Flrflll'J.: MOk1"C:ACI~ P A 'fMENTS - IF YOU COMPL'i wrra TIlE PROVlSI~NS Or, TJIE nOME OWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 19213 (THE "ACT"), YOU MA. Y BE lllGmu: FOR EMERGENCY MORTGAGE ASSlSTANCE: (F YOUR DEFAULT BAS BEF..N CAUSED BY CffiOJMSTANCli:S BEYOND YOUR CONTROL, IF YOU IlA VE A REASON'ABLE PROSPECT OF BEiNG ABLE TO P.... Y YOUR MORTGAGE PAYMENTS, AND IF.YOU MEET OTHER ELlGIBn.lTY REQUIREID:NTS ESTABUSm:.o BY THE PENNSYL.VANIA aOUSlNG FINANCE ACENCY. TEMPORA-In' STAY OF ~ORECI OSURE: Undenhe Acl, you are cntitled 10 :1 tempar.u')' stay of forecLO$Uf< on your mortgage for t1urty (30) dill'S from the date of Ihi~ Nonce. Dunne Ill)t time you mU$1 arc..ngc an<l attend a '"face-lo-facc" meenng with onc of the consumer cred'l co~eling agencl~s listed al the end of this Notice. TSlS MEETING MUST OCCUlt }VITHlN THF. NILXT 1301 D.... ''is. IF YOIl DO NOT APPLY FOR EMeRGENCY MORTGAGF. ASSISTAN~ . YOU lS BRING YOUR M TO G UP T TE Tar PART OF THIS NOTICR CALLEh "RO TO CURE YOUR MORTGAGE DEFAULT' EXPLAINS HOW TO BlUNG YOUR MORTGAGE Ul' TO DATE CONSUMER CREDIT OOUNSEUNG AGENCIES -If 1'0\1 meel With onc orthe consuOler cred,t coun$elmg agencicio I,Sled at me end of thiS Notice, the lender may NOT talce Bcnon ~!lamsl you for thirty (30., days after thc date ofthl. meeting. The names addresses anl\ ldenhollc - Exr+/517 "Cd RECE I VED T IMENOV. 5. 5: 12PM PRINT TIMENOt ~ 5:17PM ~,~ ......... " ~ ('" t-"IT~~"~ ~ov-05-01 05:0Spm From-MIDLAND MORTGAGE REFE~AL T-141 P.04/1Z F-5BS --- 'numbers of dtoSlmalcd conS\lmer ~"Tedll counsd1n!! o.~encj.,s ior tho: eOUDry '" which the urop.,1tV is localed arl"St:C forrh al rhe end ofc!\JS Nonce It is only necessary to scheduk one face-ro-face meeting. Advise yOur lender ;mmCd'3relv of your Inrenrion3. A PPLICA nON FuR MORTGAGE ASSISTANCE - Ycur mOTlgage IS lfi defal/lt for CIle reasons .et forth lat.:r In rlus Notice (see following pages for .pecd:;: infonn~[lon abouc the narure of your d.,faLllt.) If you have tned and are unable to resolve this problem wirh the lender, you have the nght to apply for fmanellll assmancc from the Homeowner's Emergency Murtg:lge AssistMlce Progr4m. To do so, you muot fill out, Sign and file a completed Homeowner's Emergency Moctgal:e ASSIstance Program Application wIth one of the dcsigIl4!C:d cOIClum"r credit counseling agencies listed at the end ofws Notice. Only consumer credit counseling agencIes have apph;:ations for the program and they will assist you m submining II complete applicatlon to the P,:nnsylvania Housmg Finance Agency. Your apphcatlon MUSTbc: filed or poslJIlarked within rhirty (30) days of your fac"'lO-face meeting. YOU MUST mI. YOUR APPUCATlON PROMPTLY. IF YOU FAll. TO DO SO OR If. YOU DO NOT FOLLOW THE OTHER TIM:E PERIODS SET FORTH IN TBIS LE'ITRR, FORECLOSTJB.E MAY PROCElm AGAINST YOUR HOME Jl\I.lM:EI)IATELll AND YOUR APPLlCA TlON FOR MORTGAGE .ASSIST~CE: WILL BE DENIED. I ~ - AGENCY ACTION - Available LUnds for emergency mortgage aSSIstance are very lanite:!. They wtll be dishw-sed by the Agency under the eligibility criteria established by"the Act. The Pennsylvania Housing FlIl~nCe Agency has siltty (60) days to make a decision after It receives your application. I>uring that time, no foreclosw-e proceedings WIll be punued against you if you have met the time requirements set forth above. You WIll be notified directly by the PClUlSylvania Housing Finance Agency of its deciSion on your applicaDon. NOTE: IF YOU ARE CURRENTL Y P~OTEcrED BY TIlE FlLING OF A PRTITIOl'f IN BANKRUPTCY, THE FOLLO'wING PART OF THIS NOno:: IS FOR INFORMATION PlJRPOSES ONLY AND SHOULD NOT BE CONSIDERED AS Ai'! AlTEMl'T TO COLLEcr THE DEBT. (If YOll have flied baokruptcy YOIl caD stillllpply for Emer::eocy Mortgage ASsbt:ul.<:e.) - RECEIVED TIMENOV. 5. 5: 12PM PRINTTIMENOV.5. 5:17PM ..~, ~~ ,0 ."...._~~ ' ~ , ;..,,",,,,.,'- ':liloi:~,iifj,~; ~ov-05-01 05:09pm From-MIDLAND MORTGAGE REFERRAL T-741 P.05/12 F-569 HOW. TO CURie YOUR MORTGAG~: OF-FAUl.T (BriG!> it up to date). - NA TURf Or. THO: DE FA lILT - The MORTGAGE debt held by the above knder all your property located al. 402 N F!lBERT ST MECHANICSBURC PA 17055-3329 IS SERlOUSL Y IN DEFAULT because YOU BA Vi NOT M..'\DE MONTHLY MORTGAGE PA YMENTS fur Ihe following months and the following alOountS life now p.';:! due: . Toral Due $ 3 j 71. 46 WICH INCLUDES: (a) Monlhlyplymc:nrsfro,,1c/l/Ol Ihrough 10/1/01 - (aIS'613.66 PElt MON'tli) (b) Uncollected Late: Charges anl\ FeeS HOW TO CIIRE!.HE OIt.FAUL l' - You may cure the default wlthm THlR"l'Y (30) DAYS of the ch.te orthls nOllce BY PAYING THE 1'OT.\1. AMOUNT PAST DUll: TO THE LEND~ll., WHICH lS 1..-_, PLUS ANY MORTGAGE PAYMENTS AND LAtE CHARGES WlilCli BECOME PAST DUE DURING TIiE THIR.TY (30) DAY PERIOD. P"vmenls mu.'t be made enher bv ca;)h .:lUhicr's check. t:~lfi~d chr.ek Or mORe''' order mad!: n9.vable: and. :scT1! roo . I ; - A!tn; Cashle''S MIdland Mcrtgage Co. PO Box 2688&8 Oklahoma City, OK 73126 .' IF 'LOU DO NOT CURE TRE DEFAtn.T-Ifyoud'-lnotclICcthe deiaLlltwitlun THIRTY (30) DAYS oflhe date of lllis Norice, tilt lerder intends to exerci~e its ri\,hts to :[cceler:>.te rhe m(lrtplI.lIe debl. TillS means that lhe entire outstandmg ball1l1ce ofws debt wIll,bt: cCJnside.ed due ltnIT\edllltc:ly :,nd you may lose tbe chance to pay the mongage in mombly l!lsUlllments. If full payment of rhe IOUlI amowlt past due IS not made: Wlthin TH1RTY PO) DAYS, the lender ~I~u Intends to instrUct its altoit\C:ys to stan: legal aClion to foreclose upon vour morll'al!ed proneny. IF THE MORT(~AG~~ IS FORECI.OS~D UPON - The mOltgaged propefl}' will be sold by the Sherifft<:l pay oCflhe mortgage debt. !fthe lender refers YO\lr case to Its allOmeys. bUtYOLl cure rhe delinque'lcy b::f<lre the lender bcgms legal proceedings ag~mSt y-'u, you WIll still be reqUIred to pay the reasonable atl<lmey's fees thar werellCtllllUy mcurred, up 10 $50.00. However, IfIcgal proceed.:l~S arc sllorted againsl you, you will have to pay "II r""son1hle' attorney's fees acrually incurred by the Il:l\der eVen if they ellCe.:d $50.00. AllY lIttumcy's feeS Will be added to tile amoUllt yOl~ OWe tile lender, which may include other reaso'lable COSIS If vou Cllre the debult with.intbe TKmTY 130\ DAY lM:riod. II0u Will ,,01 be required tQ wu: arrornev's tees. OTllER LF.~ICR REMEDIIt.S- The lender may also sue y<l" personally tor lhe unpaId prinCIpal balmc.:: and all other sums due under the mortgage - RICA.TTO emu: TfIE,l>EFAlTI.T PRIOR TO SHERIFF'S SALE -If you have nOlc\!rd the default withlr. the TIiIR* (39) DAY'period and forcclo.-ure proceedinlls halle bc!ll!l', ycm still halle the Ti21>t 0 cutc!theidef:l I and reV [the sale at an nme u lQ.onehou dure [h. Sherifr. Sale. You mavldo so bvipaving lhe cOllll amOuftllhcn Dastdut: DillS atlVlale ol-olher char!!es then du.. rellllonal!.le'allomev's fees and cClSL~ connected with rh.. !hr..dMLlre sail<: ;Iii;! any other C()St5 c,)nnecI..d !",.rh [h~ SIIl:"rifrs S31" hS S/lCCifi~d in wnnnQ by th" I<:ndc:r :u~d ~ nc:rtOnnm2 any (,'Cher rea:u'lremc:ntS under th~ mnrtQaee. Cdriag YOIIl" defalllt ill the :.banner .\-=.: " . RECEIVED TIMENO~:~ 5:12PM PRINT TIMENO~ ~ 5:17PM ~ - __f L .. .' "","""".~ '.." "'~ _;';".' _ ,'= ''[1\:,(- ~ov-05-0 1 05: 10pm From-MIDLAND MORTGAGE REFE~AL T-741 P.OB/12 F-5B9 fo"h ill this 1I0tic~ will restore your wortg:.g.: co the same plI$itioll :I, if you bad never deialllted. - F-ARLIF.ST POSSIBLE SHERJFF'S SAl..E DATE -It I. estimated ct.at the euhest date that su<:h a Sheriffs S~le Oflhe: mongaged property could be held WOUld be approxiu1:utly SIX (6) mOll.ths from the date ofthi" Notice. ^ notic~ of the actual date Oflhc Shenffs Sale Will be sent to you before the sale: Of cours~, the amount o"eded co cure the ue:fault will inCrease: the longer you wait '( ou may find out ellacrly wh..t the re:quite:d payment or action Yilll be: by contllcting th" lcnller. ROW TO CON"! ACT nlE llli'IDF-R; MIdland Mortgage Co. P O. Bolt 26648 Cklahoma Cicy. OK 7J 126 Phon.: (800) 552-3000 f~(405)946-2677 . EFm'rT OF SflRRfFF'S ~ - You ;hou].1 reahze lIlat" Sheriff's Sale: will end yoU( ownerslup of the mortgaged propeCty and YOU( nght to occupy It. If you connnue to live ill a,e property after the Sheriffs Sale. a lawsuit 10 remove you and yo.... iu:mislungs and other belongings could bc slarted by the lender at any nme. ASSUMP'l'lON OF MORTCACr.: - You mayor trial' not be able to sell or lI3nsfer your,home to a buyer or transferee who Will assume the: mortgage debt, depending on th" tellns ~rld condItIons ourlin.:d III )"Ollt moctgag<: an.:! prOVIded rh:lr ..11 rhe oulSt:lIldJ..~ payment>. d.:<rlt". JlJ,d aaomcy's fees llIld costs are paid pnor to;)r at the sale and that the other reqUlfCllIcntS orllle 1lI0rtgage arc saosfied. ., - - RECEIVED TIMENOV., 5. 5: 12PM PRINT TIMENOt ~ 5:17PM ;'li~ ~ov~05-01 05:10pm From-MIDLAND MORTGAGE REFER~L , , ~,'- '\lli!~~u; T-T41 P,D7I12 H6S M id la n d M 0 rrg age Co. P.O. Box 2&1>48 Okbhom. City.OkJ.hon.Ol 7312& Pl.... ('00/ ;;z.,ooo f,. ('OS) '...J4?? OCToaea 1. 2001 JEANl'lE K RIT'l'Ell 402 N fILBERT ST ~EcaANICSnVRG PA 11055-3329 - ACT 91 NOTICE 'TAIffi ACTION TO SAVE \:OUR HOME FROM FORECLOSURE I . TIllS i~ an offiel3l .lone:" thaI the mnrreao,: on vour home is in default and Ihe I..n~ imends tll foredos". :'iue.:ifi: Infonnarion about lhe- natllre (lithe I1Cbulr is provid<:d in [h" arra"},ed p:lI1"~, - The HOl\liEO\\oNER'S MORTGAGE ASSISTANCE PROORAM IHEMAPl mav ~ able [0 h.elv to SOlVe VOIlT home TillS, nolic" ",,-plains how th" prOlmlm \lfQrks. To see ifHEMAP <<:an hdl'. .,ou mustMEiET WIlli A CONSUMER CREDIT COUNSEUNG AGENCY WlTI-I!N 10 DAYS OF TH~ DATE OF THIS NOnCE Take this Notice with 1/0U when 1/0U meet with the Counsehnl! Aecnev. The name addr~ss and nnone numb<<r of Consumer Credit Cour.sehn\: A;ren"ieS s<;\"V\n~ vc.ur CCUDt'I are .istc:l 3.l the end ofthlS Nonce. If 'IOU have,9.nV Questiuns YOU may c:alllhe hnn.vlvama \-fou.in!! Finane" A!!"""v:toll free at 1-800--142-2~97 Il'ersnns with irnl>arn,n heanned... "all 17\11 780-1869. Thl~ Notic" COt.tains lllIportanllegal U1fcfmanon. If yOu have any q~stioos. r<:presCt\ca[ives at the Consumer (:redit Counsl:hng Agenc-j may be abl., to help ex.plam It. Y 01.1 may also want to contact an attorney in your Ml:"1I. The: Jodi bar assoclanon nl~y b~ able 10 help you find a IIlWYc:r. LA. NOTlFlCA..::lON EN A.DJUN1'O ES DE SUM.'I. 1MPORThNCLA. PUES AFECTA SU DERECHO A CONTfNUA..R VlVlEtIDO EN SU C.'l.SA. 51 NO COMPRENDE EL - RECEIVED TIMENOV.: 5. 5: 12PM PRINT TIMENOV. 5. 5: 17PM - ~ov-05-01 05:10pm T-T41 P.09/IZ forth ill this ~Qtic.. will restore your- mOrtg:lge to che same posicillll as jf YlIU had never defaulted. From-MIDLAND MORTGAGE REFERRAL I,"" - J- ^', "~:tE;i.:& H6S F-AR.LIEST ,POS5.lBLF- SlIER.1FF'S SALE DATE -It IS estunalod th:.t the "arl.est dale that s...~h a Shenffs Sa.e Qf th", mortgaged property could be helc1 wOllld be apprllx.i:alately SIX (6) months from tile clare Oflllis Notice. A notice of the: llCtIl4I date Mehe Sheriffs Sale: WI!! be: ~C:m to you ~fore Ihe sale Of course. the amQunt needed to cure the d"fa...lt win increa~c: the longer YOll wait. You may find out ellaet!y what the requl!"e:d payment or action will be by eontaenng the lender. flOW TO CONT~CTTIn' lENDER: Midland Mortgage Co P.O. Ball 26648 O.oahoma City, OK 73126 PhQne: (800) 552-3000 faJ( (405) 9-'16-2677 - EFFECT Of SHERIFF'S SALE - You should realiZe: that a Sbe::iffs Sale will end your ownership Qf Ilte: mQrtgaged property and your right to occupy it. lfyoll COllnn\IC to hv\: in the property after the Sheriff s Sale, a lawsuit 10 remove YQu and your tumishings and other belonl.'1ogs CQuld :ll: Started by me Icnc1er at any nme. ASSUMPTION I)F MOR.11'CACE - You mayor may not be able co sc:U or ll'2;sfer }tour how" to a buyer or min,.ferce who W\ll assume the mortgage debt, depel\ding on the terms and conditions outlined In your mortgage and provid\:d that allllte: oUlStaIlding pa)'Illen~. chutes and anomey's fees and CQsts..e paid prior to or at the SlIle and th:;.t the: "tlle:r requIrements oi!he morrga!:\: are s:lti,;fied. ; > VQUMAY ALSO HAVE TffFRlGRT: TO SELL 1HE PROPERTY TO OBTAIN MONEY TO fA"{ Olor THE MORTGAGE DffiT OR TO BORROW MONEY FROM ANOTHER. LENDING INS1TfU1"ION TO P A. Y Ol'FTIr" DEBT. - TO Hi\. VE TIllS DEfAULT CURED BY ANY nmu> PARTY ACTING ON YOUR. BEHALF. TO HA. VE THE MORTGAGE RESTORED TO TIlE SAME POSiTION AS IF NODEfAll1.. T HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER. YOU DO NOT & Vii TIllS RIGHT Tt) CURE YOUR DEF Aut T MORE THAN THREE TIM.f.S IN ANY CALENDAR 'II~) TO ASSERT TIlE NONEXlSTENCEOF A DEFAIn.TIN ANY FORECl-OSURE PROCEEDiNG OR ANY 01HER LAWSUIT INSnnITED UNDER. IH.E MORTGAGE DOCUMENTS. TO ASSERT ANY OTIiER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY UiE LENDER. \ TO SEEK rROrECTION UNDER FEDERAL BANKRUPTCY LAW RECE I VED T IMENOV. '. 5. 5: 12PM PRINT TlMENOV. 5. 5: 17PM ~ :L ';-'~,i ~ov-05-01 05:11pm From-MIDLAND MORTGAGE REFER~AL T-T41 P.09/1Z F-569 - LA NOTn:-ICACION EN ADlUNTO ES DE SUMA lMPORTANCiA. PUES AfECTA SU DERECHO 1\ CONTINU/\R VIVI.ENDO EN 50 CI\5A. 51 NO COMl'RENDE EL CONTENIDO DE .ESTA NOTIFiCACiON 013TENGA UNA TRADUCCION INMED!TAMENl'E LLAMANI>O ESTA AGENClA (pENNSYlVANIA HOUSING FINANCE AGEl\CY) SIN C/\RGOS At NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGffiLE PARA UN PRESTAMO PR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRA>.W' EL CUAl. PUEDE SALVAR 5U CASA DE LA PERDIDA DEL DERECHO A REDIMlR SU HIPOTECA. Homeowner's Name(i) . Loan Account Nil.' Ll:Ildcr/Scrvicer: DONALD 1. RITTIi:R JEANNE K RITTER 402 N FILBERT ST MtCHANICSBURC PA !/055-3329 44L34500 MIdland Mortgage Co. j . Property Address. - HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU M:AY BE ILUGIRLE FOR rINANClu. ASSISTANCE WHlCA CAN SAVE YOUR HOME FRuM FORECLOSUIU: A.!'ffi HELP YOU MAKE FUTIJRE MORTGAGIL PAYMENTS I iF YOU COMl"LY WlTH Tn PROVlSIONS OFTIIE BOM.EOWNER'S E~RGENC~ MORTGAGli: ,~SlSTANCE ACT OF 1983(TBE "AC1""), YOU MAY BE EUGIBLE FOR EMERGl:NCY MORTGAGE ASSlSTANCIi:: IF YOUR DEFAULT HAS BE~N CAUSED BY ClR.CUMST"~C(";:S BE'iOrm YOUR CONTROL, IF YOU HAVE Atu:ASONABLE P1l0Sl'ECf OF BErne ABLE TO PA'i YOUR. MORTGAGE PAYMENTS, AND IF YOIJ MEli:T OTfiEa ELIGma.lTY REQ0mIM5:NTS EST~USHED BY nrE PENNSYLV ANlA ROUSING FINANCE ....GENCY. - TEMPOllARY STA.Y 0);' FORF.CLOSURE- Under !he ACt, )'<.l11 are enrideJ to II temporr.l)' stay of forcclosJre on your mortgage for j1urty (3D) days from tbe cbte "ftllls Notice. Dunn!!, l:.a, time you must l.mngc: .nd attend a "face-to-face" meeting W11b ooe of tile consumer credit counseling ageucic:s listed at !he end oft s Notice. THiS MEF.TNC M'l JS1 OCCUR WITHIN Tm XT30....Y..OU 0 NOT ^P OR. E . CV MORTGAGE ASS1STA!NCE.YOU MUST BRING YOUR MORTGA.GE UP "]'0 l)A TE. TtrF. PART OF THB NOTlC~ CAtLED "HOW TO CURE VOlTR MORTGAGE i)EFAUL-T" ID(llLAfNS RoW TO BRING YOUR MORTGAGE UP'fO Of\. TF. RECEIVED TIMENOV. '5 5: 12PM PRiNT TfMENOV, 5. 5. t 7UM d l.LV. \\J, -~'""-" 'itrI ~... .~ -' .,I~ ~_j!!ljj_1ilfi:!lm' " ", - ~OO:, ~ov-05-01 05:11pm From-MIDLAND MORTGAGE REFERRAL T-T41 P.IO/IZ H69 CONSlfl\o:ffiR CREDIT COUNSELING AGENCI1!.S -lfYOll IT!c:c:r with (}Jl" of the consume"!" credit counsding ag:ncie$ listed at the end of lhis Notic", the lender may NO'!, lake aClion ag:iIlISl you tor thirty (30) dlyS aftd"!he dale ofthls meenng. TIle names addresses anti tdeohone number~ of desirnaled <onsuro"r credit counselinll' .eene;.,s for th" counlV m which the propertY is located are Set forth at the end ofthlS No,ice It i. only necessary to sche<Jule one facc-t.:l-face meetLllg. Ad\llsc: your lender Immedlatelv of yilur intellnon.. - APl'LICA TION F,:)R MORTGAGE ASSISTANCE - Your mortgage is in def:.ult for the reasons Set forth lat.:t III this Nonce (see tollowmg p..ges tor speCific inform~hon about the nalur" of your default.) If you ha ve lricd ami are unable: to resolv" tlus problem Wilh the lender. you have the right to apply for fmanclal assistance from the Homeowner"s Emergency MOrt~a!lc AsSiStance PrognlIr.. To do so, you must fill out, Sign and fil" a completed Homeowner's Emerg"ncy Mortga~e ASSistance Program Application with one of the d"signated consumer cr"dll counsehng aUencles li.ted at the end of thiS Nonce. Only consumer Credit counseling age:ncles ha"e applicanons for !he program and they will assist YOIl In submmln~ a campier" appliCAtion to the P:lUlsyl"ania HouslOll Finance Agency. VOllC ~pphcation MUST be filed or posnnarked Wltlun mirty (30) days .)f your face-to-face m"enn,. 1 YOU MlIST FlU: YOUR APPUCATION PROM.PTl..Y. ro YOU FAD.. TO DO SO OIlIf YOU DO NOT l"OLLOW TIlE aUI/LR TIME l'ElUODSSET FORTH IN TIQS LETTER, .fORECLOSURE MAY PROCEJ.,:D AGAINST YOURBOME IMMEDIATELY AND YOUR. AffUCATION FOR MORTGAGE ASSISTANCE Wfi.L BE-DENlED. - AGENCY ACTI(,N -A"ailable funds for "mergdlcy mortg:ille aSSIstanCe are very limIted. They wdl b" disbu:sed by the Agency Wider me "bglbibry critma established by the: Act. Tlte Pennsylvama Hou>.mg Finance Ag"ncy has SIXty (60) d:>.ys to make a deciSIon aftcr IC receiv<:s your apphcatiun Dl1ring that rime, 1,0 foreclosure proc".dings will be pursued against you ify<.>u have met the rime -.:qulremc:nIS set fuflh aboye. You Will be ncmfied directly by the Pennsylva1ll3 Housmg FInanCe: J'>.gency of ItS d"cision on jour applicanon. NOTE: IF 'lOll ARE CUR.RENTL Y PROTECTED BY THE mING OF A PETITION IN .8ANI\RUPTCY, THE FOllOWING P.UT OF TmS NOTICE IS FOR lNFOUMATIUN PUlU'OSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATIEMl:'T TO COLLECT THE DEBT. (Ii you h:lve ful:d bllUkcuptcy you can still apply for Emergency MOI"Ig:lge AS5ista..~..} - RECEIVED T1MENO~:~ 5:12PM PRINT T!MENO~ ~ 5:17PM ~'; ~~ ~~~~ 0 """>'^'~r<---'"" ~"htllP.l'~,*; ~ov-05-01 05:11pm From-MIDLAND MORTGAGE REFER,RAL T-741 P.II/12 F-569 HOW-TO CURr YOUR MORTGACE DEFAULT (Brim' it up to dalel, NATIIRE OfTID: OEFAlJLT - The MORTGAGE debt held by the above kndi:Ton your property located at: 402 N FIl.BERT ST ~CijANICSBURC PA 1/055-3329 IS SfRIOUSL Y IN DEF Aut T because YOU a'\ VE NOT M..illE MONTHlY MORTCAGE l'A YMENTS for the followmg months and th.. following amounts are now pdSt rn.e: . Total Due$3111.46 \lInCR INCLUDES: - (a) Monthly p:.ymenrs from 6/1/01 through 10/I/Ol (b) Uncollectd l-at" Cnarges and Fee" (:).[$ 613.66 p..r \Dom:h) ROW TO CURl!. IHE OEFAULT- You may curethe.iefaultwithm THlll.TY(30) DAYS of the date ofmis no<:e" B'i P...\:1NC THE TOTAL AMOUN'l" PAST DI1I TO TIm LENDER, WHICH IS l.-~ PLuS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME PAST flUE DURING TIiE THlR.TY (30) DAY PERlOO. Pavmenrs must be m3c\c either b" cllih cashIer', "heck: eertlfied eheck or money or&. matl..navabk and ~ent to: Arm. Cashi.ers Midland Mortgage Co P.O. Box 26888& Oklahoma City. OK 73126 IF vOU DO NOT ('1!R.E TIIE DF.FA.UI. T -1fyou do not ~ure the default wlthm THIRTY (30) DAYS of the dale Clfthis Nonce, the I d,,~ intends to.exerci~e inri to acc~ler:ue th~ mortpa~e debt.. .~1us means that the entire urstandU1!; balance oflhis debt will be considered due unmedlately l.lld you may lose the ChllllCC 10 pay the: mongage m mOnthly insrallmellls If full paymc:ntofthe total amoUfitpastdue is notma~ within TH!R1Y (30) DAYS, the lender al~o U1tc:nUS to inslTUCt its attorneys to ~t:Itt legal action to ro~eclllse npoll your mortraeed O"DDem. - IF TIlE MORT(~AGE IS FORE('I.OSEIl UPON - The mol'tg3ged propc:rty WIll be sold by the Sheriff to pay off the man-gage deb.. lfthe leodc:r rcfctS your ease to Its attorne)'s. but you cure the dehoquellCY before the lender begins Ie:b'lll proceedings agamst you, you WIll sail be required to pay the reasOllable attomcy's fees that were: actU:illy Incurred. up to $SO.OO. Hvwe"er, iflegal proc:eedmgs are stanc:d against you, you will ha"e to pay all reasonable anolTlCY's fees actually Incurred by the . lender e:"en if they exceed $SO .00. Any AltOrney' $ fees will be added to rhe amoWlt you OWe the lender, whieh may include other reasonable costs. If '(IIU cure the defa.ult within the THIRTY 130\ DA V "erilld. vou will nOI be requi~ed to 9"''' attll~uev's rees. OTHER LF.NDER !U:JVO::OIES - The lender may al~ Sue you personally for the unpa,d pnncipal balance and all other sums due un.ier the monpge. RJ CRT TO CURE TIq'. DiEF l\lll. T PRIOR TO SHEROiF'S 3ALE -If you have nvl cured the default W.U1UI the: 1'Hj:Rn (30) P-'" 'ti~Ud and foreclosU(C procelOdings have bC:gIJIl, YOU srill have the riJ:ht to cure:, the 'detllult and, '. . "<'I\t the: sale .at anv time uO I<) one hour bero.... Ihe Shenfrs Sale. You mOlv Uo.!sobvpa..nne!the toral amounuhen llasrduc: !llus any hlte or ..ther charges then 4ue.reasonllbl.. ar:tome"'~ fees and COSLsci>rinecled IV\th the fore:clnsure sale and an" other com connected With the Sherift's S:.lc: as SDeelfied in wntin" b" the knder an.:1 Lv cerformlnl! any .uhcr reqi..iremenr: CInder the: morn!a!!e: ClIring your 4~r:l.ub ill the D111l1ler Sl:t - Drfrlvrn TIUIUnU.~ ~.I?PU DO i U'1' '1' nrC''IIYf\\7 C C. I I"JOtK ~ ~ ~" r'~ "=" -.- i'-' ~ ~' t~~~(t:r,~,;, ~ov-D5-DI 05:12pm From-MIDLAND MORTGAGE REFERRAL T-741 P.IZ/12 F-569 Midland M ortga ge Co_ P.O. Box 16648 Oklahoma City, Oklahoma 73126 Ph"". \'00) 55J.lOOo Fa (.OS) "6.2617 OCTOBEa 1, 2001 DONALD LUTTER 402 N FILBERT ST ~CHAWICSBURC PA 17055-3329 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE I I I - The:: HOMEOWNER'S MORTGAGE ASS1STANCE PROGRAM (REMAPl may he: able [0 helD TO sav", your home:: ThIs nO[lceexvlains how the llt"OllTam worles. Ii \' ! i. I' i' I , t. , E' i ! V , , t- 1 Th,s IS an OffiCl;,1 nonce [hat [he:: mon:~allc On Your home i~ In default. and [he lender Imends to foreclose SDecI fic Infonnation abo/lt the: n:lture of the defaul[ IS DT'Ovid'ed 10 the:: a[[ached P""e::S. .. To see IfHOiJAP can help YOU must MF.F.T WITH A CONSUMER CRF..DIT r.OUNSELINO AGENCY W1THfN 30 DAYS OFTHF.DATE OFrmS NOTICE. Take dus NOl1ce WIth VIll.! whe::n vou'.ncd WIth theCounsdinl! Allenc". The name. ad;lrcss . and Dhone numbcr of CooSumer Crcdit Counseling Aeencie::s Servin>! vour Coun'" ar.: liSted at the ..rid o[thls lIIorice. Itvou have anv Questions. YOU may call 'hc P=svlvani" Hou..slnl! FinanCe Altt"ncv toll free,3r 1.800-142.'397. (PcT!oon. wilh ImDalred hean"", ell" call (717) 780-1869. r f rt [ I' This NOtice c"ntams Important legal ~,tonnation. If you rn,"e any q~tions. representative, at the Consumer Credit Counseling Agency may be able to help explain it. You m:lY also WB(lt ~o contact an atto,ney in your area. The local bar association may be: able 10 help yo.. find a lawyCf. R~r~rvrn 'Iurunu ~ L.11'\T'\1I 11 _ul <' '~ '........ VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for the Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by MlDF1RST BANK, Said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: November 21,2001 LeonP. Haller, Esquire ", """". ~"..' . ---<":1 ~~~, I I , . i i. f I"~ - ~ 9 ~S9 '- ~~~~~ ~ ,- ,- - ~ , "",,'~,.~, "'" ,"'''~, ..,<~~",. ,--c' ,"" r'. ".."'''~ '1 OFFICI': OF Tfjf: SilERIFF eVilEfi'!.\;!,) COUNTY NtJr 26 3 26 FH '01 L:(.".HL!~LE PENNSYL VANIA J)jJfMjJf$ ~~mmr._ Fl1ltiW~.!"~~'MmrW1i'-'''I'''''i"":!C,!"",xj,, ~Y'IW'<Jj, 1l!IN~~~~~~~'- ell R ~~ ," L;',.-"" ". ~~ -',,,,, ~ ""~lrl" ".'~Q<<<l\1!tJ;;;,;~!~- , BENEFICIAL CONSUMER DISCOUNT d/b/a BENEFICIAL MORTGAGE COMPANYOFPA : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. JOHN CARROW, JR. AND SUSAN CARROW : NO. 2001-6609 CIVIL TERM ORDER OF COURT AND NOW, this 28TH day of DECEMBER, 2001, Plaintiffs leave for alternate service of pleadings is DENIED without prejudice. Plaintiff is directed to attempt to serve the defendant John Carrow, Jr. at the home of his Mother in Florida. If that attempt fails, we will consider another petition for alternate service as long as it sets forth the attempts to discover Defendant's Florida address. Edward E. Guido, J. Terrence J. McCabe, Esquire .) For the Plaintiff ~M John Carrow, Jr. ~:~?-'llt>\ 506 Walton Court ~ Lemoyne, Pa. 17043 :sld I .- -I _'. " <,. ~ 0 ". - ~ , ~ ~~ , ,"', - -'" ^ . -", -~.~, "'~~"""'~"'~'.~"'~.''"''.'' .,,,'~."' ~"' i':;1_i:D~C,t:r:'rc~ OF <":P:;\!Olf\HY Of DEe 28 AI') 10: 1.,.8 CUM8UiiJV'iU COUNTY PENNSYLVANIA Dr.c f(jJl...,.....'!JM.,j~\\!N,~,~,$'!,'I*":""(<J!t'~..,f,!,~{!l':i1~1jill!:~~~- ''''T'"'''',~,.,,~_ ~ :_,;",},TI'J,,[,,~~~':,,_U.3~: ;,' ' 'j" -"""'I?~>'~i-."- ~~~ -~!li\ittJW!~~i."~ McCABE, WEISBERG AND CONWAY, P. C . BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Df~l 2001 Attorney for Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE: COMPANY OF PA v. JOHN CARROW, JR. and SUSAN CARROW CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-6609 Civil Term ORDER AND NOW, this day of , 2002, the Plaintiff is granted leave to serve the Complaint in Mortgage Foreclosure and all other subsequent pleadings that require personal service and the Notice of Sheriff's Sale upon the Defendant, John Carrow, Jr., by regular mail and by certified mail, return receipt requested, and by posting at the Defendant's last-known address and the mortgaged premises known in this herein action as 506 Walton Court, Lemoyne, PA 17043. BY THE COURT: J. o ....,'~.o" '~"" ' _".., _ """', .~:'0 .",' _'I,,, r ",,"_"" -, .."''-,,','".~J:..:>>.k.."';'~~'f.;. """^"".' , ,;,;~"" ~,;, ~,,'" '0 '" '~,' i':i~~; McCABE, WEISBERG AND CONWAY, P. C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE: COMPANY OF PA v. JOHN CARROW, JR. and SUSAN CARROW CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-6609 Civil Term PETITION TO ALLOW SERVICE ON THE DEFENDANT BY REGULAR MAIL. CERTIFIED MAIL AND POSTING PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 I. Plaintiff attempted to serve a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, John Carrow, Jr., at the Defendant's last-known address of 506 Walton Court, Lemoyne, PA 17043. However, the Sheriff advised that he was unsuccessful since per Co-Defendant, Susan Carrow, the Defendant, John Carrow is in Florida with his mother and she does not know when he will return. A copy of the Sheriff's Return indicating the same is attached hereto and marked as Exhibit "A." 2. Plaintiff has searched for a forwa~ding address for Defendant, and the Post Master has advised that there is no change of address order on file for the Defendant, John Carrow, Jr., from the address of 506 Walton Court, Lemoyne, PA 17043 (See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B"). rr~ --,~ 'd" , ". .{! '" ,,'~. ,; ,;' .j..' 0":' " ,;:." ~,~ ~^ . f1!ffi2l5.io" 3. Plaintiff has checked the Local Telephone Directory for an address for Defendant; there is a listing for the Defendant, John Carrow, Jr., at 506 Walton Court, Lemoyne, PA 17043, however the phone has been disconnected (See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B"). 4. Plaintiff has made inquiry with the Jane Owens, a neighbor residing at 508 Walton Court, who stated that there was domestic trouble between John & Susan; they spilt up. The house looks secure, but she does not known where John moved to (See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B"). 5. Plaintiff has made inquiry of the local tax bureau and the tax bill is mailed to 506 Walton Court, Lemoyne, PA 17043 (See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B"). 6. Plaintiff has made inquiry with the Social Security Administration and was advised that there are no death records on file for the Defendant, John Carrow, Jr. (See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B") 7. Plaintiff has investigated the Defendant's Voter Registration Record, and the Cumberland County Voter Registration Office, has advised that the Defendant, John Carrow, Jr., is registered to vote at the address of 506 Walton Court, Lemoyne, PA 17043 (See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B"). 8. If service cannot be made on the Defendant, John Carrow, Jr., the Plaintiff will be prejudiced. WHEREFORE, Plaintiff prays this Honorable Court grant an M__~ , ,,'~ .~-" .-- - " '.Le:" '0"""" ",,__,,1, , -',. 'f('n~~' Order allowing the Plaintiff to serve the Complaint in Mortgage Foreclosure, and all other subsequent pleadings that require personal service, and the Notice of Sheriff's Sale upon the Defendant, John Carrow, Jr., by regular mail; certified mail, return receipt requested; and by posting at Defendant's last- known address and the mortgaged premises known in this herein action as 506 walton Court, Lemoyne, PA 17043. JclJMl4A~ ~ ' fhttfrJ.JX- TERRE CE J. McCABE, SQUIRE Attorney for Plaintiff ......., ~, ~' . " -,,". c, ~, ;,'t....;;"";-;,,,d"^~,>--,'",', _,0,: ~+",~",.-- >,M ':"Ji~'ii-ii~} McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE: COMPANY OF PA v. JOHN CARROW, JR. and SUSAN CARROW CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-6609 Civil Term MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. TERRld~BJ 'E~~{~ -'.. ~} , '",- 'J ~ ";",,, --" :~~,~:o_ .. , ",~ . , , ~',,,'>, "''' , , ""n k"J(':i~')\t'~: . McCABE, WEISBERG AND CONWAY, I? C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 I?hiladelphia, I?ennsylvania 19109 (215) 790-1010 Attorney for I?laintiff BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE: COMPANY OF PA v. JOHN CARROW, JR. and SUSAN CARROW CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-6609 Civil Term CERTIFICATION OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff, hereby certify that I served a true and correct copy of the foregoing Petition to Allow Service on the Defendants by Regular Mail, Certified Mail, and Posting Pursuant to Pa.R.C.P. 430, by United States Mail, first class, postage prepaid, on the 18th day of December, 2001, upon the following: John Carrow, Jr. 506 Walton Court Lemoyne, PA 17043 I J;t1JA1AA J, (hd~ TERRENCE J. McCABE, ESQUIRE ',\T 0-- .', '- '.-~ ,~"' ~,,~;,', ,,f'~,, b' ^. ~-- -- "~- ,,-";' ,_' " ,I ,'" '-' 0>- . VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. ~4904 relating to unsworn falsification to authorities. ~~ j. fhcUJA-. TER ENCE J. McCABE, ESQUIRE ~,,~,",- -, '-, ,c', , , "~"'!';'l""-lr!1~!jjki~' ,"~", ,''''''''i'V' ~_,j",..,"",~,.~, c._ """""'-- "~ I" ,~ '~ "'~~J~~_ SHERIFF'S RETURN - NOT FOUND ;,CA$E' NO: 2001-06609 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS CARROW JOHN JR ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT CARROW JOHN JR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , CARROW JOHN JR PER SUSAN, JOHN IS LIVING WITH HIS MOTHER IN FLORIDA AND DOES NOT KNOW WHEN HE WILL RETURN. . Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 10.40 5.00 10.00 .00 43.40 sod~ /. ._~ R. homas Kline Sheriff of cumberland County MCCABE WEISBERG CONWAY 11/30/2001 Sworn and subscribed to before me day of this A.D. Prothonotary \T "A" F'(l\ , B 1"\, ") .. ,,~.. - Of, .~~ - _'Oi:ll"~cP.<<""",,>rd',,;",,"" '. LARRY DEL VECCHIO PROCESS SERVER FOR McCABE, WEISBERG & CONWAY, P .C. P.O. BOX 3221 WARMINISTER, PA 19874 (215) 442-5668 (215) 442-9727 FAX Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. JOHN CARROW, JR. NO. 01-6609 LAST KNOWN ADDRESS: 506 Walton Court, Lemoyne, PA 17043 LOANNUMBER: 5-1466PA AFFIDAVIT OF GOOD FAITH EFFORT TO LOCATE DEFENDANT (S) I hereby certifY that on November 30, 2001, a good faith effort was made to discoverthe correct address of said defendant (s), by: 1. Inquiry of Postal authority; Postal authority states defendant's mail is delivered as addressed at property. 2. Examination oflocal telephone directories and 411 assistance; John Carrow, 506 Walton Ct., (717) 774-3341, Number is Disconnected 3. Neighbor Contacts: Jon & Jane Owens, 508 Walton Ct., (717) 774.7207, Jane stated property is abandoned. There was domestic trouble between John and Susan; they split up. The water is off, but house looks secure. She doesn't know where John moved too. P.J. Sterling, 504 Walton Ct., (717) 774-8009, Mrs. Sterling stated the property has been empty since April of2001. 4. Tax Information: Tax office has mailing address same as property, 506 Walton Ct. 5. Death Records: Social Security has no death records for the defendant under his social security number. 6. Voter Registration: The defendant is registered at property, 506 Walton Ct. I certifY that this infonnation is true and correct to the best of 7ledge, information and belief. BY:. ~ Larry Del Vecchio, Process Server NOTARY PUBLIC: Sworn to and des~' ::fO~.~.iS...;)2.~~~.~..d~:....I~~"'.Wd . ~ //~ " ~ ~'A ' ~ ..-;:/.) ~' :I P... - -, . _ Notariai SeOl '~I . 0~U~~:P~O HESSER. Notary Public I . N 1WP.. BUCKS COUNT''''' LMY COMMISSION_~IRES FEB. 29, 2004 ; EXHIBIT "8" . m~~{~'}';" '. LARRY DEL VECCHIO PROCESS SERVER FOR McCABE, WEISBERG & CONWAY, P.C. P.O. BOX 3221 WARMINSTER, PA. 18974 (215) 442-5668 FAX (215) 442-9727 November 30,2001 Postmaster Lemoyne, P A 17043 REQUEST FOR CHANGJ;: OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Address: John Carrow, Jr. 506 Walton Ct. Lemoyne, PA 17043 The following information is provided in accordance with 39 CFR 265.6(d) (4) (ii). There is no fee for providing boxholder information, The fee providing change of address infomlation is waived in accordance with 39 eFR 265.6 (d) (1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Process Server 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting Pro Se- except a corporation acting Pro Se must cite statute: Process Server for McCabe, Weisberg & Conway, P.C. 3. The names of all known parties to this litigation: Beneficial CDC v. John Carrow, Jr. & Susan Carrow 4. The court in which the case has been or will be heard: Cumberland County, PA, Court of Common Pleas 5. The docket or other identifying number if one has been assigned: 01-6609 6. The capacity in which this individual is to be served: Defendant(s) THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSEPCTIVE LlTlGATlON COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000.00 OR INPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMRATlON OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I CERTIFY THAT THE ABOVE INFORMATION IS TRUE AND THAT THE ADDRESS INFORMATION IS NEEDED AND WILL B8 USED SOLELY FOR SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITlG~~_. _______ ~I/ - - P.O. Box 3221 LARRY DEL VECCHIO Wanninster. PA. 18974 For McCabe, Weisberg & Conway. P.C. FOR THE POST OFFICE USE ONL Y ( NO CHANGE OF ADDRESS ORDER ON FILE />&\ need ~ /' ~ 'iV1Q\-\ \ IS 'l.'iC \ \\l'i: ,o::c.\ O':c.. l-A' ,~:J'pOST MARK NEW ADDRESS OR BOXHOLDER'S NAME AND PHYSICAL STREET ADDRESS: ;ci~';lli';;~~!l~li'J.'ifliJ.~~~~~f~,~.h" 1"," \?5' ~ HI II ;k'! ",.',,-- Y-';c:"-k;' _''''fi';f:>i.JJ',;,~{..t:a,~~__1l1U~~1Ur;;'O"~El_3~~~;1I1jTr~U' ,=^ ~ ~_ _, _"'_,~'_ "--1",,,-- ' _ __ ,. I~ iIF - - .. ~ Q 0 n c. -"t~1 gJ6j '=' ""1 P1 ---......,., fn ,) f~~:~ ~~~ w:J.J Z:C 1'0 ~\cj 5!lz a !'-, . ,<,0 ""', =~~,~? /-:;"'ii ~o -'. --:;.:;.("j )>0 N 7"""jr,n C rl ~ "'" 5J ...J -< !~" ~,,_.~~.. "' - , . ~~,,"'''''~- Midfirst Bank VS Jeanne K. Ritter and Donald 1. Ritter ["j .L..__ , J 'J"<.l b,. '-~"'-'~I;"'''-'\<' In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6606 Civil Term R. Thomas Kline, Sheriff, who being du1y sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Leon P. Haller. Sheriff s Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Law Journal Patriot News 30.00 30.00 15.00 .50 1.00 25.20 13.80 15.00 15.00 1.44 12.12 265.40 193.75 $618.21 Sworn and subscribed to before me This / j It;- day of y,.......... 2002, A.D. G..r, {} ~ ~ Prothonotary SOAn~ ?"'""'J : ,,< ~ R. Thomas Kline, Sheriff BY0(jct.!J~ Real Estate Deputy I.~/() lk3fo7'-/9 !2tv. /) (. .) OV m "_~_i . . ^ ~~~~""~....... ~'C'~ ...... ~~ ......... ~ , "" , . " I~"" ""~1fdllllillf.uj . ;,~,'rr:"",r,.,,~:- . MIDFIRST BANK, pLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANTS CIVIL ACTION - LAW NO. 2001 6606 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the followin~ information concerning the real property located at 402 NORTH FILBERT STREET, MECHANICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s) Jeanne K. Ritter 402 North Filbert Street Mechanicsburg, PA 17055 DOnald L, Ritter 402 North Filbert Mechanicsburg, PA j Street' 17055 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: First Deposit National Bank 219 Main Street Tilton, NH Valerie Park Rosenbluth, Esquire 25 E. State Street P. O. Box 1779 Doylestown, PA 18901 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : c O;ol ;;;..",,,,-,~,"~,,",""-~,.._-., ~>l >~~.'14~ "_OM r.......... ~~ ~"""'" L,;,k,. ~' JlL~~~~ :NT .' ~ ;'--"~';""!Iii.ill..iti<',i~Hl'~-,;;,~, 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 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: TENANTS IF ANY '" Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I ~erify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. . ~. ------~rL Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 12, 2002 _,,,><,,,,,,",,~'_ 'H ' "" ~ .... ........... -. ~ ~"""'"~". IkJl~ .d- ''-~kj_,i"" { I f MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANTS CIVIL ACTION - LAW NO. 2001 6606 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, June 5, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of, the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 402 North Filbert Street Mechanicsburg CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2001 6606 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: JEANNE K. RITTER AND DONALD L. RITTER ",,"'..~;.-~_'..~"..,,~. ""~ ~ ~ '\'< - . . >~'- I. 1ol1!~~ ~""1f,;j~J;iJlilla&~":!i_Uldl~~__~;t:"",-",,,,-,,,,/,,. i , ( A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE T~E AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically, of these rights. If you wish to exercise your rights, YOU" MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania l7013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: I. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This .E ,",~rr _ """""i!Iil- ...~ -...,..il5_iwJOlIIS'ili\mli'#.l~~Ili1!' .~ '~~'.~~~Q- - , r petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of. the Writ of Executi.on.is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 J )fu:"";&r~,,,,'''<'__;,,' " . ;:,"~4dl~""" - ~-,..~ -,."~ ~' ,~~~ ,~ .~" J~~-oE!lI~~;'~~lWmwid~"";'. , ~ll THAT CERTAIN tract or parcel of. land with the improvements thereon erected situate in the Borough of Mechanicsburg. County of Cumberland and Commonwealth of Pennsylvania, being.more particularly bounded and described as follows, BEGINNING at a point on the easterly line of Filbert street. which point is 78 feet North of the northeasterly corner of Portland and Filbert Streets; thence along the easterly line of Filbert Street North 21 degrees 40 minutes West 58 feet to' a point; thence North 68 degrees 20 minutes East 124.55 feet to a point;.thence South 2l degrees 40 minutes East 20 feet to a point: thence South JJ degrees J9 minutes West 66.77 feet to a point ; thence South 68 degrees 20 minutes West 69.65 feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS402 NORTH FILBERT STREET, MECHANICSBURG, PA 17055 BEING THE SAME PREMISES WHICH Helen L. Lowe by deed dated 8/26/83 and recorded 8/29/83 in Deed Book I-3D, Page 837 granted and conveyed unto Donald L. Ritter and Jeanne K. Ritter. TO BE SOLD AS THE PROPERTY OF DONALD L. RITTER AND JEANNE K. RITTER ON JUDGMENT NO. 2001 6606. PARCEL: 18-822-0519-148 ']j ~JUl.;' ~'" ~~ - J-, "."._'., --' '~ ,;- -..,'- ~"' :~',~:'},'l!io,tf",~""o-,;"__,, WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANIA)' COUNTY OF CUMBERLAND) NO 01-6606 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDFIRST BANK PLANTIFF(S) From JEANNE K. RITTER AND DONALD L. RITTER (l) You are directed to levy upon the property of the defendant( s) and to sell SEE LEGAL DESCRIPTION OF PROPERTY (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$40,518.29 L.L.$.50 Interest AT $12.55 PER DIEM TO SALE DATE $2,334.30 Atty's Conun % Due Prothy $1.00 Atty Paid $122.50 Other Costs LATE CHARGES AT $30.68 PER MONTH TO SALE DATE $153.40 ESCROW DEFICIT $2,000.00 Plaintiff Paid Date: MARCH 13, 2002 CURTIS R. LONG Prothonotary, Civil Division By: r t<~,yf REQUESTING PARTY: Name LEON P. HALLER, ESQ. Address: 1719 N. FRONT ST. HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 ,"f -,'.i :'i',V"if,/!t1~~;~":it!#,~,~,~,,"~,~:k'4l'*li!l,*_,itg;il:;.lj""_!@.B;@t#~~"~j!",~iffli?~hfii'i~.&;;:,Ji:i',.~w.,'-""1Iiii ' ~~11M1 . Real Estate Sale #50 On March 14,2002 the sherifflevied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, P A known and numbered as 402 North Filbert Street, Mechanicsburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 14, 2002 By: Jo c4SWIi:f?t Real Estate Deputy @S) CViJ CVil. c:::::J @ ~ .... ."-1.-__1 '~"1: .... >- -,- a:", \JJ=, .. '~ ~ ~J'} " ~~::: 'c' <>J , OJ c-. , c _'C" ld , , - - ",'''- - ..L W .... "" 0-. .... <.:' ... 0 = .~'" -, . _~ '~M ,"~~,_ ,_" > ,. ~,<_~,~ " - ~, "', ~, ~,",,~.J.ic~ ..~~ - -, I,.,' " ...a, .._~,>, ~;~,,' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYL VANIA : ss. COUNTY OF CUMBERLAND : 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 ofthe said Cumberland Law Journal on the following dates, VIZ: APRIL 26, MAY 3,10,2002 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. SWORN TO AND SUBSCRIBED before me this 10 day of MAY. 2002 NO EAL. LOIS E. SNYDER. Notary Public CidsIe Bolo, Cumberland County My CommIs8Ion Expires MaR:IIS, 2005 "T"." --,'~~',-~~' ~~~,,;~ .-. _'~' c. <__l . ~ ;"'. MAL ESTATE SALE NO. 50 Writ No. 2001-6606 Civil Midfirst Bank 'vs. Jeanne K. Ritter and Donald L. Ritter Atty.: Leon P. Haller ALL THAT CERTAIN tract or par- cel of land with the improvements thereon erected situate in the Bor-- ough of Mechanicsburg, County of Cumberland and Commonwealth of Pennsylvania, being more particu-- larly bounded and described as fol- lows: BEGINNING at a point on the easterly line of Filbert Street, which point is 78 feet North of the north- easterly corner of Portland and Fil- bert Streets; thence along the east- erly line of Filbert Street North 21 degrees 40 minutes West 58 feet to a point: thence North 68 degrees 20 minutes East 124.55 feet to a point; thence South 21 degrees 40 minutes East 20 feet to a point; thence South' 33 degrees 39 min- utes West 66,77 feet to a point; thence South 68 degrees 20 min- utes West 69.65 feet to a point. the Place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 402 NORTH FILBERT STREET. MECHANICSBURG. PA 17055. BEING THE SAME PREMISES WHICH Helen L. Lowe by deed dat- ed 8/26/83 and recorded 8/29/ 83 in Deed Book 1-30. Page 837 granted and' conveyed rmto Donald L. Ritter and Jeanne K. Ritter. TO BE SOLD AS THE PROP- ER1Y OF DONALD L. RITTER AND JEANNE K. RITTER ON JUOOMENf NO. 200 I 6606. PARCEL: 18-822-0519-148. '-'l "~","-;-~<, ~"I'L;""''''F''.,,,' )j;~u;;,~,~;~;..l-, ' I," e_'..,,}~, . . I THE PATRIOT NEWS SUNDAY PATRIOT NEWS '- ~ THE Proof of Publication Under Act NO.587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the 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 612 to 818 Market Street, In the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav 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 printed 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 23rd and.3Oth day(s) of April 2002 and the 7th day(s) of May 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 knowiedge of the facts aforesaid and is duly authorized and empowered to verify this statement on behaif of The Patriot-News Co. aforesaid by virtue and pursuant to a resoiution 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 Dauphin in Miscellaneous Book "M", V;I~::I~:~~~~' ~....~..........................n................ COpy worn 0 an su scn e e ore m IS 1 th day M A.D. olanafSea S ALE #50 Terty L. RUSSell. Notal)' Public _ _ _ _____'__ Harrisburg. Dauphin County REAL ESTATE SALE No. 50 My Commission Expires June 6. 2002 .~-- Writ No. 2001-6606 Member. Penns;ytvanla Association of NotarfesMy commission expIres June 6, 2002 . Civil Term Midflrst Bank vs ':'- Jeanne K. Ritler and Donald L. Ritter . .~~ Ally: Leon P. Haller DESCRIPTION __ML IRA! CERTAIN tract or parcel of land with jhe itrqJrovements thereon erected situate in the Borough of Mecbanicsburg, County of Cumberland -afid Commonwealth of Pennsylvania, being more particularly hounded and described as follows: :BEGINN~G at a point on the easterly line of I F11bertStreet, wbicb point is 78 feet North of the ' .;, 'rt01iliea~tel.~ comet of Pcrtlanrl and Filbert Sb:eets; I '-the~e a1o~g, the e~lerly line of Filbert Street Nolth : -2! degrees 40 nunules West 58 feet to a point; t _ thence North 68 degrees 2.0 minulesEast [24.55 feet ~ _,I9::aP!lint;thence South 21 degrees 40 minutes East IIIJlIreet In point: llien" souib 33 degrees 39 Publisher's Receipt for Advertising Cost mmulesWest66,77feelloapomt;lhenceSoulh6& I , degrees 20 minutes.West.69,65 feet to a point, the . publisher of The Patriot~News and The Sundav Patriot-News, newspapers of general PJaceofBEGINNlNG. ,. f h f 'd . d bl' . d 'f' h h h ~AYlliO~QN erected a residential dweJling el receipt 0 tea oresal notice an pu IcatlOn costs an certl les t at t e same ave ! known as 402 North Fllbert Street, Mechanicsburg, . opAl?OSS.-c . BEING THE SAME premises which Helen L. Lowe by deed dated 8126183 and recorded 8129/83 in Deed BooK. 1-30,-Page 837 granted and conveyed unto DCnaldL. Rltter and Jeanne K. Ritter. TO BE SOLD as the property of Donald L. Ritter and JeanlleK.RilterOil ludgmelltNo. 200t6006, I FARCELNo.: lS-8Zl-0S19.148. , CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTIiOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT.NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ $ $ 192.00 1.75 193.75 By....................................................................