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HomeMy WebLinkAbout99-02078 . (j tf ii ,~ ~~. '. (1 z .~ ':1" .. . ;" ". ;~I' hi:' "': ,~ I', ~,>; ,'if",; ..,... '.,'{. '::>9~J, '.:;'~~Jr : .;;~ ~ .....1.;;; LV .~. GOJ..DBECK McCAFFBRTY & McKEEVER BY: Joseph A, Goldbeck, Jr, Attorney 1,0,"16132 Suite 500 - The Bourse Bldg. 111 S, Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONAL CITY MORTGAGE CO. P,O. Box 1820 Dayton, OH 45401-1820 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. RONALD E, LEAMER AND SHELLY A, LEAMER (Mortgagor(s) and Real Owner(s)) :ACTION OF MORTGAGE FORECLOSURE 101 Fieldstone Drive Carlisle, PA 17013 Defendant(s) Term No, ^\..iJ.~~t I.rl~(\.\>J .J . \"C \ \ ,:..........1....'...... . of....'.. . 'J'" t\'{\\': ~r:; '-'qq - clo iP (L~ THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO 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 againat 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 attor.oey and filing in writing with the court your defenses or Objections to the claims set forth Against you. You are warned that if you fail to do so the case may proceed without you and a judgml!!nt may be entered against you by the Court without further notice for any money claimed in the Complaint or tor any other claim or relief requested by the Plaintitf. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER ro YOUR LAWYER AT ONCE. IF YOU 00 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OlTI' WHERE YOU CAN GET LEGAL HELP. Court Administrator CUmberland county Courthouse, Carlisle, PA (117) 240~6200 Legal Services Inc. a Irvine Row, Carlisle, PA 17013 (717) 243-9400 A V ISO LE MAN DEMANDADQ A USTEn EN LA CORTE. SI DESEA DLFENDERSE CONTRA LAS QUEJAS PERESENTAOAS, ES ABSOLtrrAMENTE NECESSARIO CUE: USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SEa SERVIOO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGAOO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTa DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS CUEJAS EN ESTA DEMANDA. RECUEROE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COlTI'E PUEOE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEOA PERDER OINERO, PROPIEDAD U OTROS OERECHOS IMPORTANTES. LLEVE E5TA OEMANDA A UN ABOGADO IMMEDIATAMENTE. 51 NO CONOCE A UN ABOGAOO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADQS) , 215~23a-6300 . Court Administrator Cumberland County Courthouse, Carlisle, PA (717) 240~6200 Legal Services Inc. a Irvine Row, Carlisle, PA 17013 (117) 243-9400 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is NATIONAL CITY MORTGAGE CO" P,O. Box 1820, Dayton, OH 45401-1820. 2. The name(s) and addreas(es) of the Defendant(s) is/are RONALD E. LEAMER, P.O. Box 479, Carlisle, PA 17013 and SHELLY A, LEAMER, P.O, Box 479, Carlisle, PA 17013, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3, On February 24, 1997, mortgagor (s) made, executed and delivered a mortgage upon the premises hereinafter described to NATIONAL CITY MORTGAGE CO., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1367, Page 400. The mortgage has not been assigned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due December 1, 1998, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6, The following amounts are due on the mortgage: Principal Balance Interest from 11/ 1/98 through 3/31/99 at 6.750% Per diem interest rate at $19,27 Attorney's Fee at 5% of Principal Balance Late Charges 12/ 1/98- 3/31/99 Monthly late charge amount at $58,14 Costs of suit and Title Search Escrow Balance Deficit Monthly Escrow amount $171.64 $ 104,184,53 2,890.50 5,209,23 232.56 560.00 $ 113,076,82 603,83 $ 113,680.65 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed, 8. A Notice of Homeowners' Emergency Mortgage Assistance Act of 1983 has been sent to the Defendant (s) by regular mail in accordance with Acl 91 of 1983 of the Commonwealth of Pennsylvania on the date set forth in the true and correct copy of such notice attached hereto as Exhibit "A", The date of the postmark on the Notice was the same as the date of the Notice. The Defendant(s) has/have not had the required face to face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant (s) through the plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency, WHEREFORE, Plaintiff demands judgment in mortgage foreclosure the sum of $113,680.65, together with interest at the rate of $19,27, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: GO BY At & McKEEVER J ph A. Go dbeck, Jr" Esq. ney for Plaintiff VERIFICATION I, I'IIILl!P J COBB , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief, I understand that false statements therein are made subject to the penalties of 18 Pa. C.S, 4904 relating to unsworn falsification to authorities. Date: ?~~ PHILLIP J. COBB ASSISTANI' VICE PRESIDEm' ,- National City, Mortgage Million.' CUr Mortgllve Co. 3i!31 NowrNllk Dllvo. MI.1mlsburo. OhkJ 45342 To'ophono (937) 910.1200 February 05, 1999 COpy Mailing Addr..., PO Oox 1820 E' Oay1on. Ohoo45401.1B20 X':".. J'iN~',}r A Certified Mail Receipt Requested Ronald E Leamer 101 Fieldstone Dr Carlisle PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The purpose of this letter is to collect a debt and any information obtained will be used for that purpose. 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 adjunto 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 immediatament 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 cas a de la perdida del derecho a redimir su hipoteca. ACT 91 NOTICE Important: Notice of Homeowners Emergency Mortgage Assistance Act of 1983 Please read this notice. You may be eligible for financial assistance toward your mortgage payments. RE: NCM Loan No. 859677-4 Date: February 05, 1999 Your mortgage is in serious default because you have failed to promptly pay installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $ 3,604.58. This sum includes the following: delinquent principal, interest, taxes, insurance, and late charqes NationaICity~ Mortgage cOpy NaUOfta. Cft, Mortva,e Co. 32J2 N.wm,I.... Oll\llt , Mlt1nwlburg, Otwo .~,342 Tolophonw (937) 910. 'lOa Mallln9 Ad....1 ro 00. 1820 Oay1on, Ohm ..5..01.1820 Page 2 Loan No. 859677-4 You may be eligible for financial aS8istancc that will pn'VCIlI foreclosure on your mortgage if you comply with the pluvilliOlW ot 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 of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency. 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 (30) days from the date of this notice. During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. That meeting must occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address,and telephone number of our representative is: National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 , f I I I I I I I , I I. I 1 I See the attached list for the name(s) and address(es) of (a) designated consumer credit counseling agency (ies) . It is only necessary to schedule one face to face meeting. You should advise this lender immediately, of your intentions. 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, sign, and file a completed Homeowners' Emergency Assistance Application. It must be filed or postmarked within (30) days of your face to face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed on the attachment. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105, telephone number 717-780-3800 or 1-800-342-2397 (toll free number). Persons who are hearing impaired can call 1-800-342-2397. NationaICily. tv10rtgage COpy Nation.. CIl.,. Mortga.e Co. 3232 t~own\.lJk OflVd . MIAn\l,wlg. Ohio 115342 relephooo (9m 910,'200 Mailing Addr..,r po_ Dolt 18lO Da)1on. Ohio 45401.1820 Page 3 Loan No. 859677-4 An application for assistance may be obtained from a COIHJumer cr"dit counseling agency, or directly from the Pennsylvania Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do so or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. 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 counseling agency will help you to fill out the application. 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. In addition, you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclosure." you must read both notices because 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 assistance. Sincerely, MRS. NEWTON Collection Department Enclosure XC670/XC671 DEW NationaJCity. Mortgage cOpy N_lIon_1 Clt~ MortU_ge Co. J232 Newma'k OliVO. Miatnjsburg, Ohio 4S342 relephooe (931) 910,1200 U.lUl1g Addr.'11 PO. 00, 1820 o.yton. Ohio 45401.1820 DESIGNATED CONSUMER CREDIT COUNSELING AGENCIES ACTION HOUSING, INC. Two Gateway Center Pittsburgh PA 15222 412-281-2102 CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYLVANIA, INC. Suite 500, 309 Smithfield Street Pittsburgh PA 15222 412-471-7584 P.O. Box 278, 500-02 Third Street Duncanville PA 16635 814-696-3546 662 North Main Street Greensburg PA 15601 412-652-8074 125 North Jefferson Street New Castle PA 16101 412-652-8074 HOUSING ACTION COALITION, INC. Westmoreland County Only 714 Philadelphia Street Indiana PA 15701 412-349-6600 HOUSING OPPORTUNITIES, INC. 623 Versaillies Avenue McKeesport PA 15134 412-664-1590 MON-VALLEY UNEMPLOYED COMMITTEE 600 Walnut Street , McKee sport PA 15134 412-678-1409 URBAN LEAGUE OF PITTSBURGH, INC. Allegheny County Only BUilding for Equal Opportunity 200 Ross Street Pittsburgh PA 15219 412-261-1130 URBAN LEAGUE OF HARRISBURG, INC. 2107 N. 6TH STREET Harrisburg PA 17101 717-234-5925 CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1211 Chesnut Street - Suite 411 Philadelphia PA 19107 215-563-5665 CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 1031 Linden Street Allentown PA 18102 215-821-4011 XC017 DEW NationaICily. Mortgage COpy NIllon.' Clt, MOft,.._ Co. J2:12 Nllwm.llk OliVO. M..lmisburg. Ohio ~5342 TlllllI)hooo (9~1) 910.1200 Mllllnv Addr..IJ f~O DOl' 820 O,lj1on, 01"" 45401-1820 February 05, 1999 Ronald E Leamer Po Box 479 Carlisle Cenified Mail/Retul n Receipt Requ PA 17013 ACT 9;' NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FOReCLOSURE The purpose of this letter is to collect a debt and any information obtained will be used for that, purpose. 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 adjunto 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 immediatament 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. Important: Notice of Homeowners Emergency Mortgage Assistance Act of 1983 Please read this notice. You may be eligible for financial assistance toward your mortgage payments. RE: NCM Loan No. 859677-4 Date: February 05, 1999 Your mortgage is in serious default because you have failed to promptly pay installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $ 3,604.58. This sum includes the following: delinquent principal, interest, taxes, insurance, and late charqes , , National City. Mortgage COpy N.llo..1 CII, Wortg.g. Co, 3232 Ntwma,k Drive' "'.amlsbu,O. Oh.o .5342 1.'.phoOl (9371910,'200 ".lllng Addr..11 PO. Do. '820 Oaytoo, 01>0 .~O,., 820 Page 2 Loan No. 859677-4 You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisio"" of the Homeowners' Emergency Mortgage Assistance Act of 1983 (The "Ar.t"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency. 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 (30) days from the date of this notice. During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. That meeting must occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address, and telephone number of our representative is, National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the attached list for the name(s) and address(es) of la) designated consumer credit counseling agency(ies). It is only necessary to schedule one face to face meeting. You should advise this lender'immediately of your intentions. 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, sign, and file a completed Homeowners' Emergency Assistance Application. It must be filed or postmarked within (30) days of your face to face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed on the attachment. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105, telephone number 717-780-3800 or 1-800-342-2397 (toll free number) . Persons who are hearing impaired can call 1-800-342-2397. NationaICily. Mortgage COpy H.lIon.' CIl, M........ c., 3232 Nowmll'" o,t'fW . MtAr-,..bufg, Otwo lli3J<6i ToIophone (937) 910.1200 ".lIIng Ad..... PO 00. '820 0.....00, 01110 tStO','820 DESIGNATED CONSUMER CREDIT COUNSELING AGENCIES ACTION HOUSING, INC. Two Gateway Center Pittsburgh PA 15222 412-281-2102 CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYLVANIA, INC. Suite 500, 309 Smithfield Street Pittsburgh PA 15222 412-471-7584 P.O, Box 278, 500-02 Third Street Duncanville PA 16635 814-696-3546 662 North Main Street Greensburg PA 15601 412-652-8074 125 North Jefferson Street New Castle PA 16101 412-652-8074 HOUSING ACTION COALITION, INC. Westmoreland County Only 714 Philadelphia Street Indiana PA 15701 412-349-6600 HOUSING OPPORTUNITIES, INC. 623 Versaillies Avenue McKeesport PA 15134 412-664-1590 MON-VALLEY UNEMPLOYED COMMITTEE 600 Walnut Street McKee sport PA 15134 412-678-1409 URBAN LEAGUE OF PITTSBURGH, INC. Allegheny County Only Building for Equal Opportunity 200 Ross Street Pittsburgh PA 15219 412-261-1130 URBAN LEAGUE OF HARRISBURG, INC. 2107 N. 6TH STREET Harrisburg PA 17101 717-234-5925 CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1211 Chesnut Street - Suite 411 Philadelphia PA 19107 215-563-5665 CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 1031 Linden Street Allentown PA 18102 215-821-4011 XC017 DEW , . ' .. , . . I' " , , . . J" . ' '. . NationaICily. tv10rtgage Page 2 Loan No. 859677-4 COpy N.Ucn.' CUV' MOfta8v_ Co. J2Jl Nowma.k 0""'1 . Mlilmlsbu'g. OlkO 45342 TDlep/lone (937) 910"200 M.llhtV Add,.... PO 00' 1820 Dayton, Ohoo 4540'.'820 You may be eligible for financial assistance that will prevent foreclosure on your mortgagl" if you comply with the !H'uviBionr; 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 of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency. 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 (30) days from the date of this notice. During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. That meeting must occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address, and telephone number of our representative is: National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the attached list for the name(s) and address(es) of (a) designated consumer credit counseling agency(ies). It is only necessary to schedule one face to face meeting. You should advise this lender immediately of your intentions. 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, sign, and file a completed Homeowners' Emergency Assistance Appli.cation. It must be filed or postmarked within (30) days of your face to face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the off.ice of one of the designated consumer credit counseling agencies listed on the attachment. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105, telephone number 717-780-3800 or 1-800-342-2397 (toll free number). Persons who are hearing impaired can call 1-800-342-2397. NationaICily. Mortgage COpy Natlona' 011, Mort.... 00. 3232 Ntwm4,k 011'41' . MWlt1lIWufg, Ohio ..~J.t2 T.I.phono 19171 9'0'200 Mallin, Adelr..1I PO 00. tB20 Dayton, Of"" 45401.'820 DESIGNATED CONSUMER CREDIT COUNSELING AGENCIES ACTION HOUSING, INC. Two Gateway Center Pittsburgh PA 15222 412-281-2102 CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYLVANIA, INC. Suite 500, 309 Smithfield Street Pittsburgh PA 15222 412-471-7584 P.O. Box 278, 500-02 Third Street Duncanville PA 16635 814-696-3546 662 North Main Street Greensburg PA 15601 412-652-8074 125 North Jefferson Street New Castle PA 16101 412-652-8074 HOUSING ACTION COALITION, INC. Westmoreland County Only 714 Philadelphia Street Indiana PA 15701 412-349-6600 HOUSING OPPORTUNITIES, INC. 623 Versaillies Avenue McKee sport PA 15134 412-664-1590 MON-VALLEY UNEMPLOYED COMMITTEE 600 Walnut Street McKeesport PA 15134 412-678-1409 URBAN LEAGUE OF PITTSBURGH, INC. Allegheny County Only Building for Equal Opportunity 200 Ross Street Pittsburgh PA 15219 412-261-1130 URBAN LEAGUE OF HARRISBURG, INC. 2107 N. 6TH STREET Harrisburg PA 17101 717-234-5925 CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1211 Chesnut Street - Suite 411 Philadelphia PA 19107 215-563-5665 CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 1031 Linden Street Allentown PA 18102 215-821-4011 XC017 DEW National city. Mortgage COpy H.llon.1 City MMI,_,. Co. 3~132 Nuwrt","k O"VIJ . MI3lntsoorg. Oh.o .5342 TDlopllOM (9171910,1200 ....llIng Addl..11 PO 00. '820 Dayton. 01'1.0 4S401.t820 Page 2 Loan No. 859677-4 You may be eligible for financial assistance that will prpvent foreclosure on you 1- mortgage it you comply with the provisiolH; 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 of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency. 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 (30) days from the date of this notice. During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. That meeting must occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address, and telephone number of our representative is: National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the attached list for the name(s) and address (es) of (a) designated consumer credit counseling agency (ies) . It is only necessary to schedule one face to face meeting. You should advise this lender immediately'of your intentions. 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, sign, and file a completed Homeowners' Emergency Assistance Application. It must be filed or postmarked within (30) days of your face to face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed on the attachment. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105, telephone number 717-780-3800 or 1-800-342-2397 (toll free number) . Persons who are hearing impaired can call 1-800-342-2397. " .' . .' . : '. '. . " '. . National City. Mortgage COpy H.lIon_' elf, MOl"..'. Co. J1J~ t~m.wh OlloiW. M..i+rtiioOutQ, OI.u ..53012 T'lhll~k,)/~ (1):111 UIO.I)OO Melling Add,..,. PO DOl 1820 Oay1on. Oh.o 4540'.1820 Page 3 Loan No. 859677-4 An application for assistance may be obtained from a consume, credit counseling agency, or directly (1'011I the Pennsylvania lIounillg FilliIIlC.. Agency. It is extremely important that you file your appl iCdtioll promptly. If you do not do so or if you do not tollow the other time periods set forth in this letter. foreclosure may proceed againat your home immediately. 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 counseling agency will help you to fill out the application. 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. In addition, you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclosure." you must read both notices because 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 assistance. Sincerely, MRS. NEWTON Collection Department Enclosure XC670/XC671 DEW ~ ~ .J! ,/ ~J~ ~1~ ~ t \-;~ i;: (Xl ?; t:.: - ~9 N 8~ 1+~' ':"1= ~~ C- r-':::] " -~ 0:' ~"- I ;, :.? a:::-~! CO: ()!;::; ~~ 0.. J~~t .:: u. en 5 0 0" U ~ I I . I '" ~Q~~ -t~g '~ d ,~ ~!z 'Do ]i3 '0. ~1 ' , p ~~~ ~ ~ ~ - ~~~ ~ '" C). - ~ {'.. ;;Y~<J.c >- ill ~ ~ Z U.lf,! ,;, ~:><t: [)._" ~Cl :C I:J~ u.. .. u.. "" ..- r- (1::.J ~c-. " . t, - -~0. wI.. N /. tiU. e.. ;-C7 .1JGJ i~ .... ~!Ja.. (/; u.. en 5 0 '" u ,\ . SHERIFF'S RETURN - REGULAR CASE NO: 1999-02078 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY MORTGAGE CO VS. LEAMER RONALD E ET AL DAWN KELL , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within REINSTATED NOTICE & COMPLAINT was served upon LEAMER SHELLY A the defendant, at 14:08 HOURS, on the 28th day of September 1999 at 101 FIELDSTONE DRIVE CARLISLE, PA 17013 ,CUMBERLAND County, Pennsylvania, by handing to POSTED PROPERTY a true and attested copy of the REINSTATED NOTICE & COMPLAINT together with MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing POST PROPERTY Affidavit Surcharge So answers: ~~~~~ l<.. m S J.ne, erJ. GOLDBECK~ MCCAFFERTY MCKEEVER 09/29/19~9 by ~<1.LcYT) cJ. ILLL JJepucy ::;her~Li 6.00 6.00 .00 8.00 ~..u.uu Sworn and subscribedrto before me this ,;It; 1b day of ..j,nE",.J. ,. . , 19 q~ A.D. qlul,r A- f'.. ~ J...QW!i. '~rot:honot:ary . GOLDBECK, McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney J.D. #16132 III S. Independence Mall East Suite 500 The Bourse Building ATTORNEY FOR PLAINTIFF Philadelphia, P A 19106 NATIONAL CITY (lJ5) 627-1322 fax (215) 627-7734 COURT OF COMMON PLEAS NATIONAL CITY MORTGAGE COMPANY P.O. BOX 1820 DAYTON, OHIO 45401-1820 CUMBERLAND COUNTY VS. NO. 99-2078 RONALD E. LEAMER SHELLY A. LEHMER 101 FIELDSTONE DRIVE CARLISE, PA 17013 PRAECIPE TO REINSTATE COiYIPLAINT To the Prothonotary: Kindly Reinstate the Complaint. {. ~ , ;:-~: i-~' ;:(- o. (: l~ ~ . , , , , ('J ~- ..- :..! " .j ... {... - ~, " '-') ~-' . GOLDBBCIt MCCAPFHRTY & MCltRRVRR JOSBPH A. GOLDBBCIt, JR. Attorney 1.0.816132 Suite 500-The Bourse Building 111 S. Independence Mall Bast Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCXBRVRR, BSQUIRB Attorney 1.0. 856129 Attorney for Plaintiff 5EP - 2 1999 ' ~ NATIONAL CITY HOR'roAGB CO. P.O. Box 1820 Dayton, OK 45401-1820 : IN THB COURT OF COMMON PLRAS OF COHBBRLAND COUNTY : VB. No. 99-2078 RONALD B. LRAMRR SHRLLY A. LRAMRR (Mortgagors and Real Owners) 101 Fieldstone Drive : Carlisle, PA 17013 ORDRR AND NOW, this $ '" day Of~ 1999, upon consideration of the Plaintiff's Motion for Substituted Service under Pa.R.C.p. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant, Ronald B. Leamer, has been unsuccessful, it is, ORDBRBD and OBCRBIID: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Se~e the Complaint in Mortg~~ In ~.:., _,I .. ~ ru. 1/)cQ.){I} Foreclosure upon Defendant'-1lY posting a copy of the Complaint upon the premises 101 Fieldstone Drive, Carlisle, PA 17013, and Plaintiff is directed to serve the Complaint by certified and ...._~, ';: ~!r tJtnu,~~ r-~Tft. - .'; regular mail to the Defendant's last known address, and that all ~.I(' 1')01). '" further service of legal papers, including but not limited to ~ C:::~ GOLDBBCIt MCCAFFHRTY to HCKBRWR JOSBPH A. GOLDBBCIt, JR. Attorney 1.0.816132 Suite SOD-The Bourse Building 111 S. Independence Mall Rast Phila~elphia. PA 19106 215-627-1322 BY: MICHARL T. MCKRRVRR, BSQUIRE Attorney 1.0. 856129 Attorney for Plaintiff NATIONAL CITY MORTGAGB CO. P.O. Box 1820 Dayton, OK 45401-1820 IN THB COURT OF COMMON PLRAS OP CUMBBRLANO COUNTY vs. No. 99-2078 RONALD B. LBAMBR SBRLLY A. LBAMBR (Mortgagors and Real Owners) 101 Fieldstone Drive Carlisle, PA 17013 'DIIS LAJf FIRM IS A DEBT COLLBC'l'OR AIIID lIB ARB AulllU'J.'.LlIti "l'O COLLECT A OBBT OIIBD "l'O OUR CLIRRT. AMY IRPORMATION OBTAIRRD PRac 'IOU WILL DB USRD JroR TBB PORPOSB OF COLLBC'l'IlC TBB OBBT. MOTION JroR SUBSTITU1'!ill SERVICR UNDER PA.R.C.P. 430(al plaintiff, by and through its attorney, Michael T. McKeever, Bsquire, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a first 1IIOrtgage upon the premises 101 Fieldstone Drive, Carlisle, PA 17013, hereinafter, the "1IIOrtgaged premises", 2. Defendants, RONALD E. & SHELLY A. LBAMBR, are the 1IIOrtgagors and real owners of the 1IIOrtgaged premises. 3 . The last known address of Defendant, Ronald E. Leamer is 101 Fieldstone Drive, Carlisel, PA 17013, as set forth in Paragraph 2 of the Complaint. i i I I I If ii' , " 'I I. " GOLDBECK, MCCAFFERTY & MCKEEVER A PROFESSIONAL CORPORATION SUITE 500 THE BOURSE BUILDINC 111 SOUTH INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 1215) 627.1322 FAX (2151 627-7734 Josepn A. GOldPeck. Jr, Gary E. Mccaflertv Mlcnael T, MCkeever May 18. 1999 TO: POSTMASTER carlisle, PA 17013 Request for change of Address or Boxholder Information needed for service of Legal process Please furnish the new address or affix change of address sticker below or the name and street address IIf a boxholderl for the following: RONALD E. LEAMER 101 Fieldstone Drive, carlisle, PA 17013 NOTE: The name and last known address are reQuired for Change of address Informa~on. The name. If known, and post office box address are required for boxholder Information. The following Information Is provided In accordance with 39 CFR 2S6,6 Id) (6) 1111. There Is no fee for providing the boxholder Informa~on. The fee for providing change of address Information IS waived In accordance with 39 CFR 256.6 Id) 1111 and (2) and corresponding Administrative support Manual 3S2.44a and b. 1. Capacity of requestor le,gl process server, attorney, party representing hlmselfl: Attornev for PlaintIff 2. statute or regUlation that empowers me to serve process: PA, Rule Civil procedure Number 440 3. The names of all known parties to the litigation: COUNTRYWIDE HOME LOANS INC" F/KlA AMERICA'S WHOLESALE LENDER VS. JAMES N. GOOD 4. The court In which the case has been or will be heard: court of Common Pleas ALLEGHENY county,S. The docket or other IdentifYIng number If one has been Issued: DOCKET , GO 99-4392 6, The capacity In which this IndIvidual Is to be served: Defendant WARNING Tne SUDmlsslcn of false In'ormatlon to ooaln and use of tne address Information Of DQXnOlaer InformatIon for any purpose other than eM serv1ce of tria legal process In connectIon wltn actual or prospective Iltl9atlan coula result In criminal penalties Including a fine up to $10,000 or ImprISonment or to avoid ~ent of tne fee for cnange of address Information of not more t~n 5 vears. or I)otn mtle 18 U.s.c. sectIon 1001J FOR POST OFFICE US POSTMAR NEW ADDRESS OR BOXHOLDER'S STREET ADDRESS Maills delivered to the address given. -NO change of address order on file. -MOved, left no forwarding address. -Not known at address given. -NO such address, eijj:"flle: CWD<l336/F P.o, 80><,.;}3 3 ;Uevv k; OWn {'n.... . :;./ >- "r'" cf} .. \,., '," a. I _. -'. . .- -. C/) c. .::, , ./ ~/ --" / EXhibIt A ~.....' ~ g; .. :r. . ::> !i 0 u at '" .... I - .. - , ff, ... = .D ..... s: - :::> - u -= .,. REL125D CUMBERLAND COUNTY Public Inquiry Acreage .440 Map Number Old Ref 21-05-0433-108 MIDDLESEX TOWNSHIP CUMBERLAND VALLEY S.D. Grantor Grantee(l) (2) Address PENN HAIU\! S COI,STRUCT I uN C')MPA LEAMER, RONALD E. & SHELLY A. 101 FIELDSTONE DRIVE CARLISLE PA 17013 Land Use Code Consideration Sale Date Deed Bk/Pg R 3 125900 6/01/1992 35R 1026 SITUS: Desc. (ll 0101 FI ELDSTONE DRIVE (2) Property Dese. (1) THE MEADOWS (2) LOT 33 PI. 3 PB 58 PG 70 (3) HOUSE Preferred Land Val Land Val 1960 Total Value Improvement Val 9490 11450 Mineral Val F12=Cancel F10=Sa1es Hist F2=Dono Clean&Green? SqfL B1dg Area Gross Area Dimensions Year Built 1757 138 14 9 Mobile Horne Code Mobile Horne Park Mobile Horne Mfg. Mobile Horne Unit F5=Tax Hist OCC125D CUMBERLAND COUNTY Occupations Master File Maintenance Option ~ Municipality District No. < -'l > Control No. < 340<l > When Adding, leave control no. blank for the computer will assign it, Name Address LEAM~R. SHf:LLY 101 FI EI.DSTONE DR. City 1 State / Zip Situs Street CARLISL~ 101 FI El,OSTONE DR, !:Ii 17013 Social Security No. 171-42-4241 Birth Date School District No. < 21160 > Occupation Code < 23 > Old Occupation Code CUMBERLAND VALLEY SCHOOL DIST. 300 CLERICAL WORKER 000 Exempt? ( Y or N) li Data Source ~ Add Timestamp 6/07/91 Press ENTER to UPDATE FS=Tax Hist F6=Maint Hist F8=Supplmnt F12=Cancel F1S=Alsmnt Inq F4=<Find> .J OCCl25D Option l:: Municipality Control No. CUMBERLAND COUNTY Occupations Master rile Maintenance District No. < -21 > < 2022 > When Adding, leave control no. blank for the computer will assign it. LEAMER. RONALD E, Name Addres5 City / State / Zip Situs Street Social Security No. P. O. BOX 233 CARLISLE 1 n 1 PT F.!.DSTONE DR, E8 17013 163-46-9932 Birth Date School District No. < 21160 > Occupation Code < 68 > Old Occupation Code CUMBERLAND VALLEY SCHOOL DIST. 500 TRUCK DRIVER (LONG DISTANCE) 000 ( Y or N) tl Data Source 8..S..B Add Timestamp 1/14/93 Press ENTER to UPDATE F5=Tax Hist F6=Maint Hiot F8=Supplmnt F12=Cancel F15=Assmnt Inq Exempt? F4=<Find> . . .' .' . , ' , , ': - . - ". . FACT SHEET Federal Driver's Privacy Protection Act The Federal Driver's Privacy Protection Act (DPPA) becomes effective September 13. 1997. The passage of this Act provides additional protection to the public regarding the disclosure 01 driver and vehicle Information, The Implementation will bring uniform requirements Into place across the United States, fn Pennsylvania. Ihls law creates some new requirements lor the release of driver and vehicle Information, Prior to the DPPA. all vehicle and. some limited driver Information could be purchased without a signed release by the driver/owner or a notarized statement of intended use by leg Iii mate business Interests, However. with the Imp/emenlalion of DPPA. we will not process any requests for Information without either a signed release by the driver/owner or a notarized statement of In1ended use by an authorized requester, DPPA restricts disclosure 01 driver and vehicle information and allows release only to those who have a legitimate business need, such as employers and insurance companies, NEW REQUIREMENTS FOR REQUESTING DRIVER AND VEHICLE INFORMATION IN PENNSYLVANIA Complellon of form: DL-503. "Request for Driver Information". (8-97) DL-135. "Request for Vehicle Information". (8-97) · Full name and address of the requester · Signed release from the driver and/or owner of the vehicle OR a notarized statement of intended use by the requester Forms have been revised in compliance with the DPPA. Requests not In compliance cannol be processed after September 13. 1997 and will be returned to the requester with correspondence indicating the reason it cannot be processed, FORMS CAN BE OBTAINED AT: . Tag services · Messenger services . Auto clubs . Notaries · By calling: IN STATE OUT-OF-STATE TDD IN STATE TDD OUT-OF-STATE 1-800-932-4600 (717) 391-8190 1-800-228-0676 (717) 391-8191 You may start using the revised forms prior to Implementation. Also. for your convenience. forms and this fact sheet may be photocopied. ,', ,i', EXHla AugU.P.f19~;.. 'I SHERIFF'S RETUR~ . NOT FOUND, .. CASE NO: 1999-02078 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY MORTGAGE CO VS. LEAMER RONALD E ET AL R. Thomas Kline , Sheriff, who to law, says, that he made a diligent search named defendant, to wit: LEAMER RONALD E but was unable to locate Him in his bailiwick, being duly sworn according and inquiry for the within He therefore returns the REINSTATED NOTICE AND COMPLAINT IN MORTGAGE FORECLOSURE NOT FOUND ,as to the within named defendant LEAMER RONALD E PROPERTY IS VACANT, RETURN NOT FOUND AS PER ATTORl~EY, 7/12/99. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3,10 .00 8.00 So answers: '. 4"- /- ~ G~d/~~ !(, m ~ e,::; ~rt $..~.LU GOLDBECK~ MCCAFFERTY & MCKEEVE 07/12/19~9 Sworn and subscribed to before me this 19 day of A.D. ",rochonocary GOLDBBCK MCCAFFBRTY & MCKBBVBR JOSBPH A. GOLDBBCK, JR. Attorney I.D.816132 Suite 500-The Bourse Building 111 S. Independence Mall Bast Philadelphia, PA 19106 215-627-1322 BY: MICHARL T. MCKRRVRR, BSQUIRB Attorney I.O. #56129 Attorney for Plaintiff NATIONAL CITY MORTGAGB CO. P.O. Box 1820 Dayton, OH 45401-1820 IN THR COURT OF COMMON PLEAS OF CUMBRRLANO COUNTY vs. No. 99-2078 RONALD B. LBAMRR SHRLLY A. LBAMRR (Mortgagors and Real Owners) 101 Pieldstone Drive Carlisle, PA 17013 CERTIFICATE OP SERVICE MICHARL T. MCKBBVBR, Bsquire, do hereby certify that true and correct copies of the the foregoing Motion for Substituted Service have been served upon the Defendant, Ronald E. Leamer this 9r-t<. day of ~rJ-:' 1999, by first class mail, postage prepaid. , ESQUIRB t:; c'l ;- "- , '" "; ,'.; , , ) . : '" U: , ) .. ,I -, . , ~:l r.,) , )'-- -, ( ;: '"/ ::"J 'Ii,:; ~... -j:..:... m -' u, U ~I C\I ~i ..:t M x: Z~ CI.. I <:0 Q B: N ifjI' a... l&J !. en ~ "" Cl"\ ) CASE NO: 1999-02078 P COMMONWEALTH OF PENNSYLVANIA, COUNTY OP CUMBERLAND SHERIFF'S RETURN - NOT FOUND NATIONAL CITY MORTGAGE CO VS. LEAMER RONALD E ET AL R. Thomas Kline , Sheriff, who to law, says, that he made a diligent search named defendant, to wit: LEAMER SHELLY A but was unable to locate Her in his bailiwick. the REINSTATED NOTICE AND COMPLAINT IN MORTGAGE FORECLOSURE NOT POUND ,as to the within named defendant LEAMER SHELLY A PROPERTY IS VACANT, RETURN NOT FOUND AS PER ATTORNEY being duly sworn according and inquiry for the within He therefore returns s~answe s: ," ~/~/%' , ~, ~efln- $..q.uu GOLDBECK~ MCCAFFERTY & MCKEEVE 07/12/19"9 Sworn and subscrib~to before me this Ie;. ~ day of ~ 19 9Cf A.D. Sheriff's Costs: Docketing Not Founa Affidavit Surcharge 6.00 10,00 .00 8.00 q, CJr~ar~' t ~~~~~~;;' ~~c~;~~:c~~ ~r~CKEEVERil- :.'".~i'~i~~~E-':; Attorney I,D,U16132 ._" Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff -'. , 'I'f';'....... ,~ .,~-:I :j;J':~C'J.""h'~ ':', ~'''' C~""~. .~ NATIONAL CITY MORTGAGE CO. P.O, Box 1820 Dayton, OH 45401-1820 Plaintiff IN THE COURT-OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. 101 Fieldstone Drive Carlisle, PA 17013 Defendant(s) . 'f ...~\ .. . lr\ \~';\\' t\~\\ IW . , . 1'1 - ;<'0 7/ :ACTION OF MORTGAGE FORECLOSURE Term 2 ~ ~ No. l'<;~d:\t~~t;g ~?l ,....r'=- ~\;,\~~.\I~:1.t , -::m ,'f\"'''':'\~'\v\.o ~C co ;.)~, \\\-J\\"~ -:::". ".;J~(' r:....J -c :...~ ~.- -.' t )-- ~~8 ..h ~~ , l.~ . . -/ - ~ '0 '"" RONALD E. LEAMER AND SHELLY A. LEAMER (~ortgagor(s) and Real Owner(s)) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO 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 J.n court. If you wish eo defend against the claims set forth in the following pdges. you must. take action within twenty (:~Ol days after t.he 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 !let earth again!lt you, You are warned that if you eaU to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or lor any other claim or reliee requested by the Plaintiff. You may lose money or property or other rights important to you. " 'tOU SHOULD TAKE THIS PAPER TO YOUR LAIrNER AT ONCE. IF 'tOU 00 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, C;O. TO OR TELEPHONE THE OFFICE SET FORTH BELCH' TO FIND otrr WHERE YOU CAN GET LEGAL HELP. Court Administrat;r CUmberland County Courthouse, Carlisle, PA (717) 240-6200 Legal Services Inc. a Irvine Row, Carlisle, PA 17013 (717) 241-9400 A V ISO LE HAN DEMANDADO A USTED EN LA CORTE, SI DESEA DEFENOERSE CONTRA LAS QUEJAS PERESENTADAS, ES _ ,'" ABSOLUTAMEmE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DtMANDA Y AVISO. ":.:- ..st.;." PARA DEFENDERSS SS NECESSARIO QUE USTEO, 0 SU ABOGAOO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL Ptnn'O DE VISTA ,~~~ DE USTED Y CUALQUIER OBJECCION COtn"'RA LAS QUEJAS EN ESTA DEMANDA. ~""f'.~~ RECUERDE: 51 USTED NO REPONDS A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ""I. . ENTONCES, LA COUTE PUEDE, SIN NOTIFICMIO, DEClDIR A FAVOR DEL DEHANDANTE \' REQUERIRA QUE US'IED CUHPLA. CON TODAS '~.:J; LAS PROVlSIONES DE ESTA DEMANDA, PeR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DlNERO, PROPIEDAD ' ,:.~"f" . U OTROS DERECHOS IMPORTANl'ES. ,.' " LLEVE ESTA DEMANDA A UN AEl0GA00 IMMEDIATAMZNTE. '.,;;__ SI NO CONOCE A UN ABOGAOO, I..I..AME AI. -LAWYER REFERENCE SER'/ICE- (SERVICI0 OS REFEitENCIA DE ABOOADOS), ow:; 215-238-6300, TRlJE -...- Court Administrator t-OPV FROM RE<X>Fti> .;....... CUmberland County Courthouse, Carlisle!, PA In TIIt1Jnouy whereof, I here UIl!ll".II"AI--" ~" (717) 240-6200 .uu.I evt '-7 ~ "'IV 01 ~'Id at,CaI1Isle. P&.:~ y " ,?;; - Legal Services IQc. 8 Irvine Row, Catlisle, PA 17013 (717) 20.9400 COMPI.AINT IN MORTGAGE FORECLOSURE -, 1. Plaintiff is NATIONAL CITY MORTGAGE CO., P.O. Box 1820, Dayton, OH 45401-1820. 2. The name(s) and address(es) of the Defendant(s) is/are RONALD E. LEAMER, P,O. Box 479, Carlisle, PA 17013 and SHELLY A. LEAMER, P.O. Box 479, Carlisle, PA 17013, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3. On February 24, 1997, mortgagor (s) made, executed and del i vered a mortgage upon the premises hereinafter described to NATIONAL CITY MORTGAGE CO" which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1367, Page 400. The mortgage has not been assigned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subj ect to said mortgage is described as attached. 5. The morLgage is in defaul t because monthly payments of principal and interest upon said mortgage due December 1, 1998, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 11/ 1/98 through 3/31/99 at 6.750% Per diem interest rate at $19.-27 Attorney's Fee at 5% of Principal Balance Late Charges 12/ 1/98- 3/31/99 Monthly late charge amount at $58.14 Costs of suit and Title Search $ 104,184.53 2,890.50 5,209.23 232.56 560.00 Escrow Balance Deficit Monthly Escrow amount $171.64 $ 113,076.82 603.83 .-~~i: $ 113,680.65 :'-z:~h d-;~lI& . iJ<<.r ";"",'~, .,', '.:.;-" "li' ....<;;;"Jo ~"".,s, . -"" '~", ' . " '.,....... . .$:"", ~~';~~ '~-.~ 7, The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. National City. Mortgage N.Uonll CIIV MorI9_0_ Co. J~J2 Nt..IMIk, OllVf . Mi.tnllbu,O. Ohio .53.2 T.,.phOn' (937) 910,1200 .,\ February 05, 1999 "'.llIng Add,...r PO, Do. .820 COpy fV' ,1..' ~" Oay1on.0!>0'5.0','820 , /\rq~djj'A Certified Mail Receipt Requested Ronald E Leamer 101 Fieldstone Or Carlisle PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The, purpose of this letter is to collect a debt and any information obtained will be used for that purpose, 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 adjunto 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 immediatament 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 Act of 1983 Please read this notice. You may be eligible for financial assistance toward your mortgage payments. , .... .', ....;; RE: NCM Loan No. 859677-4 Date: February 05, 1999 Your mortgage is in serious default because you have failed to promptly pay installments of principal and interest, as required, a period of at least sixty (60) days. The total amount of the delinquency is $ 3,604.58, This sum includes the following: delinquent principal, interest, taxes, insurance, and late charqes for ..-I< . . ';,,~,., . ,'. $"~I'" ..,,-~' , .\':~ '.. 'f: .~.....;'<~ ' .. -, ,,"l::'lr. ..".~t~ ......l.t.:.,:~:.. ..i~!;;t!l~' ..... ...:.:.)\~;~ ,...,.;~~~ .:~;'\J'~, ~~,.~ ;~~~j.~~~ National City. Mortgage N.llonal Cltv Mortgag. Co. 3232 Newrn.1I1l O'IVO . Mlo1m11bu'Q, 0N0 "53f2 T.lephon. (9:17) 910.1200 .', cOpy Mailing Add,...: PO. DOl 1820 O"y1on. Oh.O ..5..01.1820 Page 2 Loan No, 859677-4 You may be eligible for financial 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 of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency, 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 (30) days from the date of this notice, During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency, The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. That meeting must occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address, and telephone number of our representative is: National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the a~tached list for the name(s) and address (es) of (a) designated consumer credit counseling agency (ies) . It is only necessary to schedule one face to face meeting. You should advise this lender immediately, of your intentions. 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, sign, and file a completed . .. ~" ::~::::~:::~:::::::~~::~:::::::::::;::':::f:::::::::::: :::::':" .~~ Finance Agency, or you must file it at the office of one of the ~;~ designated consumer credit counseling agencies listed on the ..~~ attachment. The Pennsylvania Housing Finance Agency is located at., ...1,'. 2101 North Front Street, P,O, Box 8029, Harrisburg, PA 17105, .";;, ,~. telephone number 717-780-3800 or 1-800-342-2397 (toll free number). '4~~; Persons who are hearing impaired can call 1-800-342-2397, ..."- National City. Mortgage COpy N.Uonal ell, MOl't9_'. Co. 32J2 NawrN/k Olive. f.41nwSburg. OhIo 4S3.2 r"''''''''''IVJ7) VI0"200 .., February 05, 1999 ....11I1111 Add,...: PO DOl 1820 Oty1On, Ohoo '5'01"820 Ronald E Leamer Po Box 479 Carlisle Certified Mail/Return Receipt Requ PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The purpose of this letter is to collect a debt and any information obtained will be used for that. purpose, The Commonwealth of Pennsylvania's Homeowner's Emet~ency 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 adjunto 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 immediatament 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. Important: Notice of Homeowners Emergency Mortgage Assistance Act of 1983 Please Fead this notice. You may be eligible for financial assistance ~oward your mortgage payments, RE: NCM Loan No. 859677-4 Date: February 05, 1999 Your mortgage is in serious default because you have failed to promptly pay installments of principal and interest, as required, a period of at least. sixty (60) days. The total'amount of the delinquency is $ 3,604.58. This sum includes the following: delin uent rinci al, interest, taxes, insurance, and late char , National City. Mortgage COpy Natlon.1 City Mor',.,. Co. :1232 N.wmark Orlv, . Ml4misburg, Ohio 45342 r.,..hone (9371910"'200 .~ Page 2 Loan No, 859677-4 Mailing Addr."l PO, Bo. 1820 Oayton.O"'0454010l820 You may be eligible for financial 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 of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency, 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 (30) days from the date of this notice, During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency, That meeting must occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting, The name, address, and telephone number of our representative is: National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the at,tached list for the name (s) and address (es) of (a) designated consumer credit counseling agency(ies). It is only necessary to schedule one face to face meeting, You should advise this lender" immediately of your intentions. ..' .....'" . ~r1L '::~: . ~_ T' ..'.~ 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, sign, and file a completed Homeowners' Emergency Assistance Application. It must be filed or postmarked within (30) days of your face to face meeting. You must either mail your application to the pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed on the attachment. The Pennsylvania Housing Finance Agency is located 2101 North Front Street, P,O, Box 8029, Harrisburg, PA 17105, telephone number ,717-780-3800 or 1-800-342-2397 (toll free number). Persons who are hearing impaired can call 1-800-342-2397. "" ," ,., National City. Mortgage M,.lIona' CItV' Mortg.g. Co. Jn~ N......fMlk OU"I . M1lrTlllbutg, ONa ..~).t2 Tetephone (1)]719'0.1200 .\ COpy M.lllnv Add,...: PO 00. t 820 O.y1on. 0",0 4~401.IB20 Page 3 Loan No. 859677-4 An application [or assistance may be obtained from II consumer credit counseling agency, or directly from che Penll<Jylvania Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do so or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately, Available funds [or emergency mortgage assistal.ce 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 counseling ayency will help you to fill out the application. 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, In addition, you may receive another notice from this lender under Act 6 of 1974, That notice is called a "Notice of Intention to Foreclosure." you must read both notices because 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 assistance, Sincerely, MRS. NEWTON Collection Department Enclosure XC670/XC671 DEW . ~. .'-..t",,,:' ..........."~.. National City. Matgage N.1Ionl. cny MO'*VIIII. Co. 313:1 N.wm."k 011.... . M1lItTWSbutQ. Ohio 45342 r.lft;lhone (9)7) 9'0.1200 ." M.lllng Add,...: PO 00. 1820 Ol"'on. 0"," 05001.1820 Page 2 Loan No. 859677-4 COpy You may be eligiblc for financial a~sistance that wlll prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgagc Assistance Act of 1983 (The "Act"), You may be eligiblc for emergcncy temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agcncy. 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 (30) days from the date of this notice, During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency, The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency, That meeting must occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting, The name, address, and telephone number of our representative is: National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the attached l~st for the name(s) and address(es) of (a) designated consumsr credit counseling agency (ies) . It is only necessary to schedule one face to face meeting. You should advise this lender immediately of your intentions. 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, sign, and file a completed Homeowners' Emergency Assistance Application. It must be filed or postmarked within (30) days of your face to face meeting. You must either mail your application to the pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed.on the attachment. The Pennsylvania Housing Finance Agency ~s located at 2101 North Front Street, P,O, Box 8029, Harrisburg, PA 17105, telephone number ,717-780-3800 or 1-800-342-2397 (toll free number). Persons who are hearing impaired can call 1-800-342-2397. - ' .:-,., ,;;,i~ "*'1" ':';"11' , ".t~~. . ."~::.:"'~ , ........~. . .:.' ~~;fP~f --..J;re~ -:::-~'~~lI ..........,-'.;:." ) ~t :..~..""-;~ .' ,.~.....:.:.. ~...~,~,'\;, National City. Mortgage COpy H.II~".' Clly 1.10""... Co. 3232 Ntwmark OilY. . MI.mt'bufQ. Ohio .S3C2 T.""""".19371910,'2oo -\ Mailing Add,..., P,O 80. .820 01"00.01"" 45.01.1820 DESIGNATED CONSUMER CREDIT COUNSELING AGENCIES ACTION HOUSING, INC, Two Gateway Center Pittsburgh PA 15222 412-281-2102 CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYLVANIA, INC, Suite 500, 309 Smithfield Street Pittsburgh PA 15222 412 -4 71-7584 P,O, Box 278, 500-02 Third Street Duncanville PA 16635 814-696-3546 662 North Main Street Greensburg PA 15601 412-652-8074 125 North Jefferson Street New Castle PA 16101 412-652-8074 HOUSING 'OPPORTUNITIES, INC. 623 Versaillies Avenue McKeesport PA 15134 412 -664 -1590 HOUSING ACTION COALITION, INC. Westmoreland County Only 714 Philadelphia Street Indiana PA 15701 412-349-6600 MON-VALLEY UNEMPLOYED COMMITTEE 600 Walnut Street McKee sport PA 15134 412-678-1409 URBAN LEAGUE OF PITTSBURGH, INC, Allegheny County Only Building for Equal Opportunity 200 Ross Street Pittsburgh. PA 15219 412-261-1130 -, URBJI.N LEAGUE OF HARRISBURG, 2107 N, 6TH STREET Harrisburg PA 17101 717-234-5925 INC. CONSUMER CREDIT COUNSELING SERVICE 1211 Chesnut Street - Suite 411 Philadelphia PA 19107 215-563-5665 OF DELAWARE VALLEY ,t_"' ." ~J:i' ,.. CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 1031 Linden Street Allentown PA 18102 215-821-4011 XC017 DEW . ,.,-,' ";"','- " .... National City. Mortgage "a. ion.. ell, MorIV.V_ CO. J:JJ N.....,'n.l'. Ofl'W'tt . M.atnl'bufO. Ohio 4$342 T,.,.phON (937) 910.1200 ..\ COpy Mailing Add,...: PO IloJ 1820 0.,..".,.0"'" '5'0'.'820 Page 2 Loan No, 859677-4 You may be eligible for tinancial 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 of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency. 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 (30) days from the date of chis notice, During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency, The purpose of that meeting is to attempt to work out a repayment plan or to ocherwise settle your delinquency. That meeting must occur in the next chirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting, The name, address, and telephone number of our representative is: National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the at.tached list for the name(s) and address(es) of (a) designated consumer credit counseling agency(ies). It is only necessary to schedule one face to face meeting, You should advise this lender immediately' of your intentions, 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, sign, and file a completed Homeowners' Emergency Assistance Application. It must be filed or postmarked within (30) days of your face to face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file i~ at the ,?ffic,: of one of the" .,;' ',~;6,;" designated consumer credit counsel~ng agenc~es l~sted on the . ~~~'~ attachment. The Pennsylvania Housing Financ,: Agency is located...ar1-":;~ 2101 North Front Street, P.O. Box 8029, Harr~sburg, PA 17105, "~'.''>''',., telephone number ,717-780-3800 or 1-800-342-2397 (toll free number) ;"'.~~0:1;;: Persons who are hearing impaired can call 1-800-342-2397. National City. Mortgage COpy NaUonal ell)' Morloage Co. 3232 Newmatk OrtYe . MiamlSbu'Q. Otvo 453<12 1"'_19J1) 9'0.1200 -\ DESIGNATED CONSUMER CREDIT COUNSELING AGENCIES MallinI' Addr...: PO, 80, 1820 Oaylon, Ohio 45401.1820 ACTION HOUSING, INC. Two Gateway Center Pittsburgh PA 15222 112-281-2102 CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYLVANIA, INC, Suite 500, 309 Smithfield Street Pittsburgh PA 15222 412-471-7584 P.O, Box 278, 500-02 Third Street Duncanville PA 16635 814 -696-3546 662 North Main Street Greensburg PA 15601 412-652-8074 125 North Jefferson Street New Castle PA 16101 412-652~8074 HOUSING ACTION COALITION, INC, Westmoreland County Only 714 Philadelphia Street Indiana PA 15701 412-349-6600 HOUSING OPPORTUNITIES, INC. 623 Versaillies Avenue McKeesport PA 15134 412-664-1590 MON-VALLEY UNEMPLOYED COMMITTEE 600 Walnut Street MCKeesport PA 15134 412-678-1409 URBAN LEAGUE OF PITTSBURGH, INC, Allegheny County Only Building for Equal Opportunity 200 Ross Street Pittsburgh PA 15219 412-261-1130 URBAN LEAGUE OF HARRISBURG, INC. 2107 N. 6TH STREET Harrisburg PA 17101 717-234-5925 CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1211 Chesnut Street - Suite 411 Philadelphia PA 19107 215-'563 -5665 CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 1031 Linden Street Allentown PA 18102 215-821-4011 '.'~.:~h.;~';~ .,..,.~..!I~~. : -::.~>~~ ",-~:\":,';"'.,.5. ;..;','...,~:: ,...:~~;.,;1j~.. ,'.,::::ii~.;_. . ' ..f.'.". .-. ...... : -.,.'. ".~". ,~." '. .' :,,"'...\-.!..r."/~" XC017 DEW ., . ."~ .;......~..-"...... "'.' , .,.,;:~~.., . ~ GOLDBECK McCAFFERTY & McKEEVER BY, Joseph A. Goldbeck, Jr. Attorney I.D.U16132 Suite 500 - The Bourse Bldg, III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ., NATIONAL CITY MORTGAGE CO, P.O, Box 1820 Dayton, OH 45401-1820 Plaintiff IN THE COURT, OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW 101 Fieldstone Drive Carlisle, PA 17013 Defendant(s) . of""'. . \r'i "'II' t\~\\ 1\" ." Term No. r,.,.<;.~~~s~~t r"" t.,jI(....\I yf'.~~\)~\,,:. \ Cfl-c107f C'ut-L vs. :ACTION OF MORTGAGE FORECLOSURE RONALD E. LEAMER AND SHELLY A. LEAMER (Mortgagor(s) and Real Owner(s)) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO 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 wiBh to detend against the claims Bet. forth in the (ollowing pages, you must take action within twenty (20) days ateer the complaint and notice are served, by ent.ering a written appearance personally or by attorney and tiling in writing with the court your defenses or objections to the claims set torth against you. You are warned that it you tail to do 80 the case mal proceed without you and & judgment may be entered agaj nat you by the Court without turther notice for any money claimed in the Complaint or for any other claiD or relief requested by the Plaintiff. You may lose money or property or other rights important to you. ' 'IOU SHOULD TAKE THIS PAPER TO YOUR LAWYER .\T ONCE. IF YOU CO NOT HAVE A LAwYER OR CANNOT AFFORD ONE, Ga TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAll GET LEGAL HELP. Court Administrat;r cumberland County Courthouse, Carlisle, PA (717) 240.6200 Legal Services Inc. a Irvine Row, Carlisle, PA 17013 (717) 243-9400 A V ISO LE RAN DEHANDACO A USTED EN LA. CORTE. SI DESEA DEFENDERSE COtn"RA tAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIa QUE USTED RESPONDA cENTRO DE 20 DlAS DESPUES DE SER SERVlDO CON ESTA DEMANOA Y AVISO. PARA DEFENDERSE E5 NECESSARIa QUE USTED, 0 5U ABOGJ\DO, REGI5TRE CON LA CORTE EN FORMA ESCRITA, EL PUNT'O DE VISTA DE USTEO Y CUALQUlER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: 51 USTED NO REPONDE A ESTA DEMANDA, SE PUEOE PR05EGUIR CON E1. PROCESO SIN 5U PARTICIPACION. ENTONCE5, LA COUTE PUEOE, SIN NOTIFlCARIO, DEClDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPI.A CON TODAS LAS PROVI5IONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEOA. PERDER DlNERO, PROPIEDAD U OTROS OERECHOS IMPORTANTES. LLEVE ESTA OEMANDA A UN .ABOGACO IMMEDIATAMENTE. 51 NO CONOCE A UN ABOGJ\DO, LLAME At "LAWYER REFERENCE SERVICE" (SERVICIO DE P.EFERENCIA DE ABOGADOSl, 215.238-6300. Legal Services Inc. a Irvine Row, Carlisle, PA 17013 (717) 243.9400 TRUE OOPY FROM RECORD II TestIlnoIJy wIlereof. I here unto let ray IIMII ilIld _ oll:i!f ou at C~r1Isle. Pa,.._ :.Ik'~ 11~ 4~ Court Administrator CUmberland County Courthouse, Carlisle, PA (717) 240-6200 . . COMPl~INT IN MORTGAGE FORECLO~ '. 1. Plaintiff is NATIONAL CITY MORTGAGE CO., P.O, Box 1820, Dayton, OH 45401-1820. 2, The name(s) and address(es) of the Dcfcndant(s) is/are RONALD E, LEAMER, P.O, Box 479, Carlislc, PA 17013 and SHELLY A, LEAMER, P,O. Box 479, Carlisle, PA 17013, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3. On February 24, 1997, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to NATIONAL CITY MORTGAGE CO" which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1367, Page 400. The mortgage has not been assigned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due December 1, 1998, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 11/ 1/98 through 3/31/99 at 6.750% Per diem interest rate at $19.27 Attorney's Fee at 5% of Principal Balance Late Charges 12/ 1/98- 3/31/99 Monthly late charge amount at $58.14 Costs of suit and Title Search Escrow Balance Deficit Monthly Escrow amount $171,64 $ 104,184.53 2,890.50 5,209.23 232.56 560.00 $ 113,076.82 603.83 $ 113,680.65 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. .\ 8. A Notice of Ilomeownero' Emergency Mortgage Anoiotance Act of 1983 han been Dent to the Defendant (D) by regular mail in accordance with Act 91 of 1983 of the Commonwealth of Pennoylvania on the date oct forth in the true and correct copy of ouch notice attached hereto as Exhibit "A". The date of the postmark on the Notice waD the same aD the date of the Notice, The Defendant(s) has/have not had the required face to face meeting within the required time and Plaintiff han no knowledge of any ouch meet ing being requeated by the Defendant (8) through tho Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, plaintiff demands judgment in mortgage foreclosure the sum of $113,680.65, together with interest at the rate of $19.27, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. & McKEEVER Go dbeck, Jr., Esq. Plai,:ntiff VERtFT<"ATTON I, PHILLIP J COBIl , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best ,of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities, Date: ?~~ PHItLIP J. COBB ASSISTANI' VICE PRESIDENT .., 1,,' ,.,", ~ .-'."', , '~'.~\' ',"'\1';:;' '.~~'''~~ ':";;l -'.1.. National city. Mortgage NaU.".' Caty ...or...,. Co. 3ZJ2 NftWrNllk Oll~ . MllImllbu+'g. 0N0 .S3.fiZ relophoMl9J7) 1110, '200 .', MaUll., Add,..., PO 001 1810 EX D'ylon.0h00'~'0',181O ." .... J"'J " "". iI~ijJ]' A February 05, 1999 Certified Mail Receipt Requested COpy Ronald E Leamer 101 Fieldstone Dr Carlisle PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The purpose of this letter is to collect a debt and any information obtained will be used for that purpose. 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 adjunto 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 immediatament 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 Emer~ency Mortgage Assistance Act of 1983 Please read this notice. You may be eligible for financial assistance toward your mortgage payments. RE: NCM Loan No, 859677-4 Date: February 05, 1999 Your mortgage is in serious default because you have failed to promptly pay installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $ 3,604.58. This sum includes the following: delinquent principal, interest, taxes, insurance, and late charges NationaICily. Mortgage COpy N.llon.1 Cllr Mortgaae Co. 32JZ Nawmmk Drive. Ml.1mi5tMg. OhIo 4>>42 re'ophonoI9J71910,1200 .. Page 2 Loan No, 859677-4 Mailing Add,..., PO 00. 1820 Dayton. ONO 4S401,1820 You may be eligible for financial aonintance that will prevent foreclosure on your mortgage if you comply with the provisiono 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 of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency. 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 (30) days from the date of this notice, During that time, 'you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency, The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. That meeting must occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting, The name, address, 'and telephone number of our representative is: National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the attached list for the name(s) and address (es) of (a) designated consumer credit counseling agency(ies). It is only necessary to schedule one face to face meeting, You should advise this lender immediately, of your intentions, 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, sign, and file a completed Homeowners' Emergency Assistance Application. It must be filed or postmarked within (30) days of your face to face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed on the attachment. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O, Box 8029, Harrisburg, PA 17105, telephone number 717-780-3800 or 1-800-342-2397 (toll free number), Persons who are hearing impaired can call 1-800-342-2397, National City. Mortgage copy Nation.' CII, Morlgage Co. nJl Newm."" Ofl'W'8 . Muanwlbu,g, Ohto 4$342 Tolophono (9J7) 010.1200 .., Mailing Addr...r PO Box t 820 Oayloo. 01>00 45401,1820 Page 2 Loan No, 859677-4 You may be eligible for financial anointance that will prevent foreclonure on your mortgage if you comply with the proviaiono of the Homeowners' Emergency Mortgage A,Wit;tancc Act of 1983 (The "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstanceo beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency, 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 (30) days from the date of this notice, During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency, The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency, That meeting must occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address, and telephone number of our representative is: National City Mortgage 3232 Newmark Drive MiamiSburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the attached list for the name(s) and address(es) of la) designated consumer credit counseling agency (ies) , It is only necessary to schedule one face to face meeting, You should advise this lender'immediately of your intentions. 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, sign, and file a completed Homeowners' Emergency Assistance Application. It must be filed or postmarked within (30) days of your face to face meeting, You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed on the attachment. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P,O, Box 8029, Harrisburg, PA 17105, telephone number 717-780-3800 or 1-800-342-2397 (toll free number) . Persons who are hearing impaired can call 1-800-342-2397. National city. Mortgage COpy Hanon8' CUy U.....,. Co. J;'J~ NIHirl'f\4t.. On.... . ~mu,huHJ, OhK) "~"7 Tllldllhon4l(O]7) 910.1100 "'ailing Addr."1 PO 00. 11110 Odylon, ()hoo 'S'OI"S;>O Page 3 Loan No, 859677-4 An application [or aouintan"e may be obt<tined [rom a consumer credit counocling agency, or dit'('''l'.ly [rom the Pennsylvania Houning Finilllce Agency, It is extremely important that you [lle your application promptly. If you do not do so or i[ you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. 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 importanc that' your application is accurate and complete in every respect. The counseling agency will help you to fill out the application, The Pennsylvania Housing Finance Agency has sixcy (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, In addition, you may receive another notice from this lender under Act 6 of 1974, That notice is called a "Notice of Intention to Foreclosure." you must read both notices because 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 assistance. Sincerely, MRS. NEWTON Collection Department Enclosure XC670/XC671 DEW " National city. Mortgage COpy NIUon.' eliV' Mortaav_ Co. J232 NIrM'''''. Oil..,) t Mt.1m11burg. Ohlo 4~42 1..........(031) 010,'200 .., ....lll"g Add,..., PO Do. '820 Dly1on, Ohio 'S'Ol ,1820 February OS, 1999 Certified Mail/Return Receipt Req Shp.lly A Leamer 101 Fieldstone Dr Carlisle PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The purpose of this letter is to collect a debt and any information obtained will be used for that purpose, 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 (600) 342-2397. La notificacion en adjunto 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 immediatament 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. Important: Notice of Homeowners Emergency Mortgage Assistance Act of 1983 .Please read this notice. You may be eligible for financial assistance toward your mortgage payments. RE: NCM Loan No. 659677-4 Date: February OS, 1999 Your mortgage is in serious default because you have failed to promptly pay installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $ 3,604.58. This sum includes the following: delin ent rinci al, interest, taxes, insurance, and late char es NationaICily. Mortgage National Cltv Mo,Ioa,. C.. J'.I~ N.WfT\ltrll, Olive' UlAnlllbufO, OhiO 4$3.42 ''''ephont (931) 1HO.12oo ,,\ Page 2 Loan No. 859677-4 COpy Mailing Add,..,: PO DOl 1820 Dayton. 011oo 45<401.1820 You may be eligible Cor financial asoistance that will prevent forec10oure on your mortgage if you comply with the provisions of the Homeownero' Emergency Mortgagp Assistance lIct 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 of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency. 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 (30) days from the date of this notice. During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. That meeting must Occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting, The name, address, and telephone number of our representative is: National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the attached list for the name(s) and address(es) of (a) designated consumgr credit counseling agency (ies) . It is only necessary to schedule one face to face meeting. You should advise this lender immediately of your intentions. 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, sign, and file a completed Homeowners' Emergency Assistance Application. It must be filed or postmarked within (30) days of your face to face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed on the attachment. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O, Box 8029, Harrisburg, PA 17105, telephone number 717-780-3800 or 1-800-342-2397 (toll free number). Persons who are hearing impaired can call 1-800-342-2397. National city. Matgage COpy Mallon_I Cltv Mortva... Co. J2J~ Nowma,k O,iv. . M~mi'bu'g. Ohio 45342 Tol.pt'OOO (937) 910.1200 .., "'.111110 Add,..,. PO 601 1820 Oo1yton. OhIO 45401.'820 Page 3 Loan No. 859677-4 An application for assistance may be obt.~inRrl from a consumer credit counseling agency, or directly from the Pennsylvania Housing Finance Agency, It is extremely important that you file your application promptly, If you do not do so or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately, 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 counseling agency will help you to fill out the application, 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, In addition, you may receive another notice from this lender under Act 6 of 1974, That notice is called a "Notice of Intention to Foreclosure." you must read both notices because 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 assistance, Sincerely, MRS. NEWTON Collection Department Enclosure XC670/XC671 DEW National City. Mortgage COpy ".Uon.1 en)' Mor1ga.e Co. 3232 NeWm.lrk Onve . Mlllml'buIO. ONQ .!t342 Telephono (937) 910.1200 ..t M.IUng Add,.,.: PO Do. \820 Dayton. Ohio 45401.1820 Page 2 Loan No, 859677-4 You may be eligible for financial assistance that will prevent foreclooure 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 asoistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency. 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 (30) days from the date of this notice, During that time, you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency, That meeting must occur in the next thirty (30) 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 proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address, and telephone number of our representative is: National City Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Attn: Collection Department 1-800-523-8654 See the attached list for the name(s) and address(es) of (a) designated consumer credit counseling agency(ies), It is only necessary to schedule one face to face meeting, You should advise this lender immediately' of your intentions. 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, sign, and file a completed Homeowners' Emergency Assistance Application. It must be filed or postmarked within (30) days of your face to face meeting, You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed on the attachment. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P,Q. Box 8029, Harrisburg, PA 17105, telephone number 717-780-3800 or 1-800-342-2397 (toll free number). Persons who are hearing impaired can call 1-800-342-2397, National City. Mortgage COpy N.Uonll CII., Mort...e Co. J232 No"""",,,, O,l.... . MHllntsburO, Ohio 45342 Telephone (937, 910.1200 .', Page 3 Loan No, 859677-4 Milling Add,...: PO Do. 1820 D"yton. 0"",, .5.01.1820 An application for assistance may ~e obtained from a consumer credit counseling agency, or directly from the Pennsylv.:Ini.:l Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do no or if you do not follow the other time periods set forth in this letcer, foreclosure may proceed against your home immediately, 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 counseling agency will help you to fill out the application. 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, In addition, you may receive another notice from this lender under Act 6 of 1974, That notice is called a "Notice of Intention to Foreclosure." you must read both notices because 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 assistance. Sincerely, MRS. NEWTON Collection Department Enclosure XC670/XC671 DEW ~:"/....i;. National City. Mortgage COpy N.IIDnal City Morlaaa_ Co. :1232 N,wmalk Om.. . MlAmI,tu\), Ohk.4$342 '.'.phooo IOJ7) 9'0,10'00 ., M.lllng Addt."l PO 00. tezo Ooyton, Ohoo osool"ezo DESIGNATED CONSUMER CREDIT COUNSELING ^GEN('n~!l ACTION HOUSING, INC. Two Gateway Center Pittsburgh PA 15222 412-281-2102 CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYLVANIA, INC, Suite 500, 309 Smithfield Street Pittsburgh PA 15222 412-471-7584 P.O. Box 278, 500-02 Third Street Duncanville PA 16635 814 -696 -3546 662 North Main Street Greensburg PA 15601 412-652-8074 125 North Jefferson Street New Castle PA 16101 412-652-8074 HOUSING ACTION COALITION, INC, Westmoreland County Only 714 Philadelphia Street Indiana PA 15701 412-349-6600 HOUSING OPPORTUNITIES, INC, 623 Versaillies Avenue McKee sport PA 15134 412-664-1590 MON-VALLEY UNEMPLOYED COMMITTEE 600 Walnut Street McKeesport PA 15134 412-678-1409 URBAN LEAGUE OF PITTSBURGH, INC. Allegheny County Only Building for Equal Opportunity 200 Ross Street Pittsburgh PA 15219 412-261-1130 URBAN LEAGUE OF HARRISBURG, INC, 2107 N. 6TH STREET Harrisburg PA 17101 717-234-5925 CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1211 Chesnut Street - Suite 411 Philadelphia PA 19107 215-563-5665 CONSUMER CREDIT COUNSELING 1031 Linden Street Allentown PA 18102 215-821-4011 SERVICE OF LEHIGH VALLEY XC017 DEW . .;;~:':<.. ,...' 1..'. ....) ;...." -, ~,.. .~ ~,'