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HomeMy WebLinkAbout99-01913 PI.AN& nDlJ.MAIIl LAWUJrO T. PKILAH H.UOLD N. LUU.H- t...r..U.mLP\.Il:DA.- PIAHCIS S. KAI..UI'WP IWII:L O. IODCIIO ....... .. ...... ....... ...........,.. WICHII.I N. IIADPOlD ,QrU.to UI DIAMDI'fD- ,ADell,. CI:IIDr' USA .. IL\HIIICIUIO' .....". L MDOOON 1.""""SUI.JM/1- -ADII1TTID IN'A AND HI .. NDI Jmlf IlINDINO ,ADM. _1011 DClHAUl .. OOODMAII ","<ll'9'dJ FEDERMAN AND PHELAN ..... ... TWO rINN arnu P'I...A.ZA tKILAD&I'NIA.'4 1110'1-1'" (215)UI-I711 '1JC(2InJ6HJ)I t'tLIC'Of'IIII(215I."'" 14HUlJPTC'f' T1U.cortD(l'n ""'616 ...... cmClI .., NOr.1M HIDI..UClfI MIDI4.'4 ltOD (111)"'47'" .... IUSIT cmClI sum... I!HTIY Clf'PICI PU.ZA :n. MADDQJt AVID'ftII W'I.J'IM(Irff, NIW IUSIY 01101 1BU.CD'III I (101) U...... T1IJ3 NO'I'1aI IS IIHT TO YOU II A.N ATrDG'T TO t:IXUCT THlINDII1P.DHUI unDID TO HBUIN 4HD AN't ENPCaMA11ONOftADCID I'a<* YOU WILL U USID POa THAT ft1II'QSL January 28, 1999 Colleen M. sawyer 1212 Gross Drive Merchanicsburg, PA 17055 Re: Premises: 1212 Gross Drive, Merchanicsburg, PA 17055 Loan No,: 0003660404 NOTICE OF INTENTION TO FORECLOSE We represent AmeriQuest Mortgage Company, the holder of the Mortgage on the above-referenced premises, who hereby advises that it will accelerate your Mortgage (demand payment in fUll) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured as provided below, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, you may request the name and address of the original creditor if different from, above. The total delinquency, including late and other charges is $3,967,23 for the months of 10/1/98 through 1/1/99. Your failure to pay the delinquent amount, plus any additional monthly payment and late and other charges (inClUding any accrued interest) that may come due within the next thirty (30) days, will result in the EX.HIBIT A acceleration acceleration permitted by of all sums due under your Mortgage. occurs, a foreclosure action or any other' your mortgage may be instituted. After remedy To avoid the acceleration of your mortgage and subsequent foreclosure action, the delinquency mentioned above and any accrual thereto must be paid by CERTIPIED CHECK OR MONEY ORDER and received in our offices at suite 900, Two Penn Center Plaza, Philadelphia, PA 19102, in or before thirty (30) days from the date of this letter, Please call (215) 241-1711 for the exact amount required. You have the right to reinstate your mortgage after acceleration by fulfilling the conditions stated in your mortgage pertaining to such reinstatement. You may call our office to discuBs these conditions. Any future negotiations attempting to reinstate your loan or acceptance of any payment less than the full amount due shall not constitute a waiver by the mortgage holder of the acceleration unless agreed to in writing by the mortgage holder. You have the right to assert in the foreclosure proceedings the non-existence of a default or any other defense to acceleration and foreclosure. Very truly yours, FEDERMAN AND PHELAN Byr~~ Frank Federman FF:mtm cc: AmeriQuest Mortgage company Attn: Jim Brownell Loan No,: 0003660404 EXH\6\T A. ACT 91 NOTICE TAXE ACTION TO SAVE YOUR HOKE FROM FORECLOSURE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information call the pennsylvania Housing Finance Agency at 1(800) 342-2397, La notificacion en ad junto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa, si no comprende el contenido de esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba, Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca, ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU KAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS Date: January 28, 1999 RE: Account No. 0003660404 Premises: 1212 Gross Drive, Merchanicsburg, PA 17055 TO: Colleen M. Sawyer 1212 Gross Drive Merchanicsburg, PA 17055 Federman and Phelan, attorney for AmeriQuest Mortgage company You may be eligible for financia1 assistance that: will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect 0~~;\,~113 FROM: your IIOrtgage payaents, and it you Het other eligibility. require.ents established by the Pennsylvania Housing Finance Aqency. Please read all of this Notice, It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (JO) days from the date of this Notice, During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency, The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next (JO) days, If you attend a face-tO-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (JO) days after the date of this meeting. As representative of the mortgage holder, our name and address is: PEDERMAN AND PHELAN, SUITE 900, TWO PENN CENTER PLAZA, PHILADELPHIA, PA 19102: Telephone Number: (215) 241-1711. The names and address of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting, You should advise this lender immediately of your intentions, Your mortgage is in default because you failed to pay promptly installments of principal and interest, as required, for a periOd of at least sixty (60) days, The total amount of the delinquency is $J,967.2J, That sum includes the fOllowing: Total of monthly payments from 10/1/98 to 1/1/99 including all accrued late charges, if any: $4,464,95 Property inspections and NSF check charges, if any: 50,00 Other charges accrued, if any: 1L..QQ LESS: Suspense (unapplied funds): TOTAL AMOUNT OF DELINQUENCY: -547,72 $J,967.23 NIA Your mortgage is also in default for the following reasons: If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund, In order to do this, you must fill out, sig~ and file a completed Homeowners' Emergency Assistanc\:.~~~90n with one of the designated consumer credit counseling agencies listed on the attachment, An application for assistance may only be obtained from a consumer credit counseling agency, The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be,filed or postmarked, within thirty (30) days of your face-to- face meeting, II is txtrtmtly impo/1Qnl thaI you fde your Gppl~alion promplIy. If you do no' do so, or if you do nol follow 1M om., u- periods sel forth in ,his ltller, fortclosun ""'y procttd agaill1il your homt immtdiGuly. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above, You will be notified directly by that Agency of its decision on your application, The Pennsylvania Housing Finance Agency is located at 2101 North Front street, Post Office Box 8029, Harrisburg, pennsylvania 17105. Telephone No. (717) 780-3800 or 1-800-342- 2397 (toll free number), Persons with impaired hearing can call 1-800-342-2397. In addition you may receive another notice from this lender under Act 6 of 1974, That notice is called "Notice of Intention to Foreclose", You must read both notices, since they both explain rights that you now have under pennsylvania law, However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance, Very truly yours, FEDERMAN AND PHELAN By:rM~ ~ Frank Federman FFjmtm cc: AmeriQuest Mortgage Company Attn: Jim Brownell Loan No,: 0003660404 sent by Regular Mail, certificate of Mailing (PS Form 38E.~H\B\1 \i - PE."l1'lSYL V A-'c"1..\. ROt'SDiG FDi..\.'iCE AGE.'iCY ROMEO"~'S DlERGE.."iCY ~10RTGAGE ASSlST..\.'iCE PROGRA."d CONSt.~1ER CREDIT COt.-,;SELDiG AGDiCIES CRA ?"FORD COl"""'!Y Bookor T. WastwlllCo C<Iltet 1720 HolW1d 5cr:e: E..,e. P." 16'03 (81.1).1'3.5,.1..1 F...x _ (81.1) .I~3.5,49 John F. Ko::m:dy Center, Inc. 202 I E.3st 20th 51r::t E..,e, P." 16510 (81.1) 898.0400 F...x .. (81.1) 898. \:2.13 Greotet Erie Community Actioo C:llI1tIli= 18 West Ninth 5tret E..;e, P." 1650 I (814).159"':581 F...x _ (814)456.0161 5he=go Valle~' tir'oznk Le:lgue, loc. 60 I loc!iana A ye"ue F=11. P." 16121 (412)981-3310 Ct.:.-[BERT .~""1) COL;.."'!Y COllSume: Credit Counseling Se:vice of Wester:! ?---,:'l\'ani.. Inc. 2000 Linglesto\llll Road IUrnsburg, PA \71~ ("il';') 5.1\.I,5i F......X II (912) i31.9589 r=ciai CounseUng Services of F:ank!in 31 West 3rd SttOe. W'~'llesboro, PA li268 (,Ii) 762,3:85 . C:lc:.'.:cit:" Action Con::nissicn of th: C:1plt31 R:gioc. is 1':' De~' SC':-e~ Ea:7..s:'u..~. P."- 1710..:. (il7) :3:.975i F.~,,( ~ (71 i) ~3~:::i Urban L~gue of :,tetlOpoliWl IUcisburg 210i North 6th Str.:e. Har:isburg, P." 1'7101 n 7) 23....59:5 F......X II (i (7) 234-9.159 yWCA of C..lisle 30 I G. Street C..lisle, P." liOl3 ("il7) 243-3818 F......X;; (;Ii) ;31-9589 : . I)..~~ ~ The p,:msylvania Housing rmance .....g."Cj' can be reached TOLL ~\800) 342.2397 PREHISES BEING: 1212 GROSS DRIVE MECHANICSBURG. PA 17055 ALL THAT CERTAIN piece of around .hualll In rhe Borouah of Mechanlcabura, Cumbcrland COllnly, Pcnnl)'lvanla, more putleularly bounded and dc.oc:ribed u follow., lO wll: DBClINNlNO al a polnl on the northern line of Oross Drive, said polnl belna located and referenced South 82 dcareca 46 mlnutcs 30 w:ond. Weal, a dlllance of 419,05 feetl'n>m the Wc:.It end o( a 25 foot nsdlus at the nonh"'.... comer of Mulbcny Road and 0'01' Drive: thence alonlllhe northern line o( Oroas Drivc, South 82 dca'OCI 46 minulCl 30 IC<:ondl Weat, e d1iWlco o( 70,0 feel 10 a point on the ..../cm line of Lat No, 66: thenco Nona the II\tnC, North 07 dea.-. 13 mlnulCl 30 .....nd. W...I, a dl.W1cc o( 125 feci 10'" poln.: .hence alona land now or lalll of aWN, Inc., North 82 dearcea 46 minuter 30 IC<:onds BasI, a dlllanec of 70 feellO a polnl on the "'Cltern line of Lot No, 68; thence alona the ..me, SOlllh 07 dcS...... 13 minute. 30 second. Bast, a diolanco of 125 fCC\ 10 Il point, .he placo of DEOINNlNO. BErNa Lot No. 67 on Subd/vl.fon Plan 0' Pm 0' Sec:tlon I and subdlvl.ion Plan of Section ]. or the Pin.1 Plan nr Valley Stream Estates. which Plan iA n:cnrded in "nd for CumbcrlMd County In Plan Book 16, Pasc. 66 and 67, H^VINO THEREON ERECTED a bl.level briek and aluminum sldlns dwelllns numbered .. 1212 Oross Drive, BEINO .he ..me premises which Dorothy R, Durkholder, unremarried widow, by her deed dlted March 13. 1992 and recorded In Cumberh\nd County Deed Book .0", Volume 35, Pale 274, S","red and conveyed unlO Tom], Sawyer and Colleen M. Sawyer, hu.band and wife. COLLEEN M, SAWYER 10003660404 VERIFICATION - -.J o.~ l3(lN ~ II hereby states that he/she is -n(t:.c.lf)SO(e. S~C;o.li"S+- of ~r;,\lMSt H6r5Clje.c-e~ mortgage servicing agent tor P1aintitf in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing civil Acti"'~_ in M~>:tgage Foreclosure are true and correct to t::.e best of his/h~ >: knowledge, information and belief, The undersigned understands that this statement is made sUbject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities, (j~~~ DATE: if d ~ ?; 1r. @ ~ ~ ~ rJB .. (.. cf) - .)./' ~ '..:0 017- (-., ,..,: ~ 1: (.);:( ~ 00 ~( .c (.: .:j r-- - :"(") - f " I -:tl J!'-- .. ffi 11 ' . c.: (I . l>.: I ~'.. ...j '<I , " '~'! ,1. ..) 0- ." ;) ~ l:; " cr, ~\ e" U ,.:-i~ rf,'" \)(~ "\,CJ.. ,'.". t\" ,,.,,,'J\' f'." ,..J ' ",'..,\" ,..~\\ ...."',(\:!J. 0"""" ~c. ". 'ul\:.?' ~~\G "(.~\": ~iiD C'C.~ ""~?' -e1.~\" ~i"-o~ I OC\~\ W'?~ ..~tllilOllrNU'OI<;O-Ul-OOO '~I'/VUO!IWWllIUIIIIl'-l/'IjOllQ'i,^,OY CGILO "'!v!l31UVOlS-1lV . ; . '. . ...' FEDERMAN AND PHELAN By: PRANK PEDERMAN Identification No. 12248 Two penn Center Plaza - suite 900 Philadelphia, PA 19102 (2151 563-7000 AMERIQUEST MORTGAGE COMPANY 505 SOUTH MAIN STREET SUITE 6000 ORANGE, CA 92868 VS, COLLEEN M, SAWYER Attorney for plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION 1212 GROSS DRIVE MECHANICSBURG, PA 17055 NO. 99-1913 CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against COLLEEN M. SAWYER, Defendant(s) for failure to file an Answer to plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess plaintiff's damages as follows: As set forth in complaint Interest - 2/1/99-6/10/99 TOTAL $102,505.48 3,928.60 $106,434.0S I hereby certify that (1) the addresses of the plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237,1, copy attached ~~ ~J~ ~ FRANK ~EDERMAN, ESQUIRE Attorney for plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED, (o-11c-4Ci ( I DATE: ...- . , FEDERMAN and PHELAN BYI FRANK PEDERMAN Identifioation No, 12248 suite 1100 Two Penn Center Pla~a Philadelphia, PA 111102 (215) 563-7000 ATTORNEY FOR PLAINTIFF AKERIQUEST MORTGAGE COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION . . . . va. COLLEEN M, SAWYER NO, 99-1913 CIVIL . . VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' civil Relief Act of Congress of 1940, as amended. (b) that defendant COLLEEN M. SAWYER is over 18 years of age and resides at 1212 GROSS DRIVE, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 Pa. C,S, Section 4904 relating to unsworn falsification to authorities, ~~t0~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff c> -,- -- r'. i.~; -" /. s:~ r:":j ) , I ~: ) ': .- : c.. '~!2 " ,") '~ ....., ~:1 .",. ~ - C: N :\~'6 c_ l , :'~--l .'," :;;-."') .r: .'"' ":) (..~, .:~..... () . '. . ~ ~ , ~ ~ -.s. --.( ""\ -~ ""<, "+ ,'" '- -:2 .0 ~ ~ J --.d ,~ li($ J ..:. \s-: ~ t ~ '~~ J "~ 'V<> ~ I ~ ~.-S~~ ~ '\"~~)~ ~ ~ '-b- ill -, - 'i;S n, ~,-~' , '<:::. ~ '1'-.... , PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 , AHEIlIQUEST KOR7GAGE COMPANY IN THE COlTRT OF COMKON PLEAS OP CllMllERLAHD COllNTY, PElINBn. V AHIA r' <: vs. NO. .7?;ln~.ftm\o....... TEIIH. 19..... COLLEEN K. SAIlYEIl. PRAECIPE FOR llRIT OP EXECUTION (MORtGAGE FORECLOSURE) To the Director of the Office of: Issue writ of Execution in the above matter: Amount Due iO.W..i'l4.-P{I,. y., . Interest from 6/10/99 TO SALE $. . .I..!o~'t-.1Jl, . . . , . @ $7.49 PER DIEM (+ costs) . . .,Dv~~.,~~ Attorney for Plaintiff(s) Note: Please attach description of property, I I .'! rr: . , . , Q Q Q . . . , . 11II .c ., , . I I ( . . , , lIoo . O.c :z: '- CI\ CI\ CI\ ... 0 . III "" "" ... ID:Z: ... - ~g~ i ...- 'lIoo ~ ~ ~ ::>Ilol 'lIoo e e e 0-10-1 tJa: '... Po >0 11II::> .... . . . ID HID ':z: Eo Eo Eo ~~ 11II0 .... 0-1 ..c lI:llol l>l lIooCJ '0-1 lI:Po ~ j Ollol 'Po 0 t>: , CJ ~ ...0 ,a: >0 "'lIoo '0 lIoo... Ii! . !:Ilol "-Gllloo O:Z: III ::> l> el .)0 ...0 Ii; :t a:.c '11II a:CJ ~ Oel )= ::l 15 lIoo... OQ 0' a: '0 CJ~ i ~ 1lol0 '... Poll: 'E< 1lol0-1 ...- ..c =a: tJ . ...11II 11II , lD .c . ZlI: a: "'::l Po .. tJ Q 11II . , , 0-1 0 0 0 ... , :z: Z :z: lIoo , " ~ e;. ~ -~~0- ~ ~ cr >- 0' ~-r; .- ...:: .- t::: u,c~ t:.~ . f.j' .)...... n::.' '-) ~ "; (.i;" .-- ....1: -J ~ Wi.- ('-I ~'-- tJ ; l~ N . (,) ..1 ' J ~~: ~.!~ - n ./- .. .: }~{: " . C,..i 0' -- -:"':1 J. U '. , ~ ~ ~ -- ~ ..., e;\- ~ ~~ .,.. 0 . I';: e:; - . - ,:~ :.J~~ I '. '.,~ ~ , l.:.. =:::.1 r; c: "-I - tl') :-.,1 C'.; !:~ . :'i:] u. ~-..i r , :'JCl.. t C"\ :~) (j t::f'l U J PEDERMAN and PHELAN By: PRANK FEDERMAN Identification No, 12248 suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIPF AMERIQUEST MORTGAGE COMPANY va. : CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION COLLEEN M, SAWYER NO, 99-1913 CIVIL CERTIFICATION FRANK FEDERMAN I ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( an FHA mortgage ( non-owner occupied ( vacant (xx) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa, C, S, Section 4904 relating to unsworn falsification to authorities, FRA~~Y!~~~ Attorney for Plaintiff >- 0' - u; - "- <, '.- 1-- N ,n .' LJ !: ( ). I.: , ,~ ..- CJ:- .. , N 0 ~" w..,., . u!t . .i i_H :0; .'C- ". m :5 u <J. u AMERIQUEST MORTGAGE COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS [ , , ~ ! ! f f I i VS, CIVIL DIVISION COLLEEN M, SAWYER ~ NO, 99-1913 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY June 11, 1999 TO: COLLEEN M. SAWYER TOM SAWYER 312 4TH STREET SUMMERDALE, PA 1212 GROSS DRIVE MECHANICSBURG, PA 17055 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. Your house (real estate) at 1212 GROSS DRIVE, MECHANICSBORG, PA 17055, is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 1, 1999 at 10:00 a.m. in the Cumberland county Courthouse, South Hanover Street, carlisle, PA L7013, to enforce the court judgment of $106,434.08 obtained by AMERIOUEST MORTGAGE COMPANY (the mortgagee) against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1, The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay, you may call: (215) 563-7000. 2, You may be able to stop the sale by filing a petition aSking the Court to strike or open the judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause, 3, You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale. (see notice on page two on how to obtain an attorney,) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE, '. 1, be sold calling If the Sheriff's Sale to the highest bidder. (215\ 563-7000. is not stopped, your property will You may find out the price bid by 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. . The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To find out if this has happened, you may call (215) 563-7000, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict you, _6, You may be entitled to a share of the money which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff on This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after 7, You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE Cumberland County courthouse CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ..... o. ,.- ~;; .~~: ...:J D .' C~ , .- ( ). . ~~: ' LC- (>; .. ::"'1 , . O. ',J .-.-, LL.:1 "~ 1/ .., ~~ ;..: j,j"' ,) i - ':-.:.. 1..._ ", .:J f.:..) G' '-' \ ~. .. _. -.. j You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney,) 1Q2 ~Y STILL BE ABLE TO SAVE ~OUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SAL!"'~QE!! ~~~~ !!LACE. ': 1, be sold calling is not stopped, your property will You may find out the price bid by If the Sheriff's Sale to the highest bidder, (215\ 563-7000, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3, . The sale will go through only Sheriff the full amount due in the sale, happened, you may call (215) 563-7000, if the buyer pays' the To find out if this has 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict you. .6. You may be entitled to a share of the money which was paid for your house, A schedule of distributio~n of the money bid for your house will be filed by the Sheriff on ~~:< :;)../TT"O , This schedule will state who will be receiving at money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distributi~~s wrong) are filed with the Sheriff within ten (10) days after ~ 7 QcnriJ , 7, You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE Cumberland County Courthouse CARLISLE, PA 17013 (717) 249-3166 (BOO) 990-910S OESCRlPTIO:'i ~LL THAT CERTAI:-i pi~c~ of ground situate in the Borough of M~chanicsburg, Cumb~r1and County, Pennsylvania, more p:micularly bound~d and d~scrib~d as follows, to wit: BEGI~:-;I:-;G at a poine on the: :-iorth~rn line: of Gross Drive. said point b~ing loca[~d and ref~renced South 82 degrees ~6 minutes 30 seconds \Vest. a distance of ~19.05 f~et from th~ \V~St ~n<l of a 25 foot radius at th~ northw~st corner of Mulberry Road and Gross Drive: thence along the Northern line of Gross Drive, South 82 degrees ~6 minutes 30 seconds West. a distance of 70.0 feet to a point on the Eastern line of Lot No. 66: thence along the same. North 07 degrees 13 minutes 30 secllnds West. a distance of 125 feet to a point: thence along land now or late of BW~;, (ncoo North 82 degrees ~6 minutes 30 seconds East. a distance of 70 feet to a point on the Western line of Lot :-.io. 68: thence along the same, South 07 degrees 13 minutes 30 seconds Eas.. a distance of 125 feet to a Pllint: the place of BEGISNING. BE(:'oiG Lot ;-';0. 67 on Subdivision Plan of Part of Section 1 and Subdivision Plan of Section 2 of the Final Plan of Valley Scream Estates. which Plan is recor<led in and for CumberlamJ County in Plan Book 16. Pages 66 and 67. HA\'!:\G '{HEREO:'\ ERECTED a bi-level brick and aluminum sieling dwelling numberd as 1212 Gross Drive. TAX pARCEL #19-23-0569-010 TITLE TO SAID PRE~IISES IS VESTED l:--i Colleen M. Sawyer -_.~'-_.'-' .,. , r- ~ I'I{AECII'E FOR WIUT OF EXECUTION. (MOlrrGAGE FORECLOSURE) 1',RC.I',3180-3183 Amcrlqunl Murlaag. Company )'Jalnllfr, Cumbcrlilnd y, No, 99-1913 Civil t Colle.n M. Sawyer D.r.n~anl(s), TO THE DIRECTOR OF TIlE OFFICE OF THE PROTlIONOTAR '(: Issue writ of execution in the above matter: Amount Due $106.434.08 Interest from 6/10/99 to 6/7/00 $6.335.00 and Costs (per diem - $17.50) $ 112.769.08 TOTAL '-;5/AA~~ FRANK FEDERM . ESQUIRE TWO PENN CENTER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. No. '" , , . . " ( , , '. , ( , '- , ",:S z 0 II'> OZ - ~ ~~ ... ] ~ ... '-l;;: ;., U - 1: = '-l~ 1:: < 3! oJ", '" ~ ~ .. =-z Co C ~"c.. ] e .. '-l = ("'.... .. Zz .. .. 'OJ ~ 'I: f.'l O'-l Q ;., '" Q i;- U .. 0] '" Q = 0 ::e=- ~ '" .c E < .. '" ... .. , .. .. ::e>, en '" C2~ :E .. .. i '" Q ,- "" 0... en ~ :E = .. = "" uz 1: ~~ .." '" "" Q = ~M-e Co "'~ ::e .. o::~ --.. ~ ~ 00 ~ 01: ~~::e .. ...U - C; .s:: .. '" Q ~ O::Q .. U ",::e :;: = in ~Z ... =-~ '" 0< 'I: - ~ UoJ .. u "E "'" '-lO:: e '-l "'" :::'-l < ;2 ~ <( ...= =- Z~ -U ./ .9 - c-- "'II- 11 j ct. ~ t ,) -i i. -6 , . . E- II 11. "'R : "& 0 ,- w ~ : ~. ~,~ <'-, ;.-: B (fJ C1l 8 j"; ~ 8 lJ:.... ~ .:;I J[) 0 'j- cr ~ ~'.~ , 0 t>O . I'. " If) tf) - ~ C;J;- rIJ 0- c;- (. -~ ' (0 - :x- l() 1)0 l:.:" 1 -,J} (lj ~. -' I ' . r.' -:;ll- Jj '-- I:. ..- ;.' .~- I ~ . C" .> <",~I " CJ U ~ {I ....,- ':3 u ~ ,~ Amerlquesl Morlgage Company ClIMIIEHlANl> COUNTY COllin OF COMMON l'lEAS l'lalntlfr, v, ('IV II. IlIVISION Colleen M, Sawyer NO. 99-1913 Ch'lI Derendanl(s). AFFIDA vrr PURSUANT TO RULE 3129 (Aflidavil No. I) Ameriques! Mort!!a!!e Companv, Plaintiff in the above action, by its allomey, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe lor the Writ of Execution was tiled the following information concerning the real property located at 1212 Gross Drive, Meehaniesbur!!, P A 17055, I. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Colleen M, Sawyer 1212 Gross Drive Mechanicsburg, P A 17055 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None .. 'L I , I r; I' i I -" >-: ct) ,,, I , J -"' ( . f , ...- (.I . r-" ::() . I - . , ('.~ , i~~ . , -0. J- I , .......) ) L) c:; l.J '-. r n , "- f'- " - ~'. , -- .,... (~ j (,',-, C I , -- , C.:. I ro- ,- I C) , L) c:.: I' I I \ I , You may need an allorney to assert your rigllls. lhe sooner you eontael one, the more chance you willllllw of stopping the sale. (See notice on page two on how to obtain an allorney.) YOU MAY STILL liE AIILE TO SAVE YOlll{ I'IWI'EIHY ANn YOl) IIA VE OTIIER RIGHTS EVEN IF TilE SIIEIUFF'S SALE nOES TAKE !'LACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may tind out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set <lside the sale if the bid price W<lS grossly inadequate eompared to the v<llue of your property. 3. The s<lle will go through only if the buyer pays the Sheriff the full <lmount due in the salc. To tind out if this has happened. you m<lY call (717) 240,6390. 4. If the amounl due from the Buyer is not paid to the Sherin~ you will remain the owner of the property as if the sale never Imppened. 5. You have the right to rem<lin in the property until the full <lmount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. Atthaltime. the buyer may bring legal proceedings to evict you. 6. You may be entitled to a slmre of the money which was p<lid for your house. A schedule of distribution of the money bid for your house will be liIed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why thc proposed distribution is wrong) <Ire tiled with the Sheriff within ten (10) days aller the distribution is tiled. 7. You may also have other rights <lnd defenses, or ways of gelling your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IFYOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY A VENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, pA 17013 (717) 249-3166 (800) 990-9108 DESCRIPT10:'oi ?Ll THAT CERTAI:-i piece of ground siruate in the Borough of Mechanicsburg. Cumberland County. Pennsylvania. more particularly bounded and described as follows, to wit: BEGIN:-iI~G at a point on the :-':orthern line of Gross Drive. said point being located and referenced South 82 degrees ~6 minutes 30 seconds \Vest. a distance of .H9.05 feet from the West end of a 25 foot r-adius at the northwest corner of Mulberry Road and Gross Drive: thence along the Northern line of Gross Drive, South 81 degrees ~6 minutes 30 seconds West, a distance of 70.0 feet to a point on the Eastern line of Lot No. 66: thence along the same. North 07 degrees 13 minutes 30 seconds West. a distance of 125 feet to a point: thence along land now or late of BW~. Inc.. North 82 degrees ~6 minutes 30 seconds East. a distance of 70 feet to a point on the Western line of Lot ~o. 68: thence along the same. South 0':' degrees 13 minutes 30 seconds East. a distance of 125 feet to a point: the place of BEGI~1'iI~G. BEl:"G Lot :-;0. 67 on Subdivision Plan of Part of Section 1 and Subdivision Plan of Section 2 of the Final Plan of Valley Stream Estates. which Plan is recorded in and for Cumberland County in Plan Book 16. Pages 66 and 67. H.-\ \'l:\G '(HEREO:\ ERECTED a bi-Ie'..el br~ck and aluminum si<.Jing dwelling numberd as 1212 Gross Dril'e. T.-\X pARCEL #19-23-0569-010 TITLE TO S.-\lD PRE~llSES IS VESTED l:-i Colleen M. Sawyer' -_..-- -..- . ." ~ , C(, " lJl:- -J () ; ~ , . cn , r~ i~ . :!.: !J. l.'l (., ) LJ ~J .' '. FEDERMAN and PHELAN Oy: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTOR:'iEY FOR PI.AINTIFF Amerlquesl Mortgage Company Plalntlfr. CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CoUeen M. Sawyer CIVIL DIVISION NO. 99.1913 Civil D.rendanl(s). CERTIFICATION FRANK FEDERMAN. ESQUIRE. hereby verifies that he is attorney for the Plaintiff in the above-captioned matter. and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, -:hLtA . - -:}J, FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff / " '. You may' need an attorney to assert your rights, The sooner you contact one. the more chance you will have of Slopping tIll: sale, (See notice on page two on how to obtain an attorney.) YOU MA Y STII.L liE ABLE TO SA VE YOUR I'IWPERTY ANI> YOU If A VE OTHER RIGHTS EVEN IF THF. SHERIFF'S SALE nm:s TAKE PI.ACF.. I. If the Sheriff's Sale is not stopped. your property will be sold to the highest bidder, You may find out the priee bid by calling (215) 563.7000. 2. You may be able to petition the Court to set aside thc sale ifthc bid price was grossly inadequate compared to the valuc of your property. 3. Thc salc will go through only if the buyer pay's the SherilTthe full amount due in the sale, To find out if this has happened. you may call (717) 240-6390. 4. If the amount due fromthc Buycr is not paid to the Shcri ff, you will remain the owner of the property as if the sale never happened. 5, You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days oflhe sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses. or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, pA 17013 (717) 249-3166 (800) 990-9108 J " '.. :,.