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Home My WebLink About99-06227W-,,, l ? lF Kk . ' d`b fgf;A y Tr . 1 S5 4 1• i;{L•. * i f ? Y e a .e+ 1- ? Y } r Iv } 5- t 7 x t «o; 9 "Wo"Af T ?? y0 ; k ? SA ?pV OW F q AY 1 ?v i T c -b b v 4\C t ? 1 ) y f I t 1 ! 1 . ? . xc +?ry 5 5 l O 5 ll A tl? 1 t I ` - f E ?; It r C. 1 i V \ 1 l U ) FJ Comroe Hing LLP Identification No.: 25694 By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton,NJ 08618 VS. Plaintiff Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 Defendants Term No. 99-6227 CIVIL .............................................................. .............................................................. PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter Judgment in the amount of $139,172.44 in favor of the Plaintiff and against the Defendants for failure to file an Answer in the above action within twenty (20) days from the date of service of the Complaint and assess Plaintiff's damages as follows: (a) Principal Debt $119907.71 (b) Late Charges at $54.06 per month from $162.18 04/01/99 to 10/11/99. Late Charges at $51.55 $567.05 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE per month from 07/02/99 to 0610812000. •. (c) Interest from 03/01/99 through 06/08/2000 at $22.90 (d) Total Escrow Deficit to date (e) Reasonable Attorney's fees as in the above stated amount reflect third party sale only. If the Mortgagor reinstates the account, attorney's fees will be reasonable based upon work performed. (f) Title Report (g) Court Filing Charges (h) Uncollected Late Charge(s) (i) Escrow Credit TOTAL AMOUNT DUE DATED: June 81 2000 Respectfully submitted, $10648.05 $1098.06 $5995.39 $335.00 $459.00 $0.00 $139,172.44 C ro in )¢P BY: ?%f David B. Comroe Attorney for Plaintiff AWIN Dama es assessed as z this-84h day of June, 2000 Pro Prothonotary 2 a; Or, a_ ? r) Is. cl, r: l= ? i r?r PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA County of Cumberland Allfirst Bank, tka First National Bank of Maryland, Successor to Eastern Mortgage COURT OF COMMON PLEAS Services, Inc. c/o Cenlar Federal Savings Bank, OF CUMBERLAND COUNTY 425 Phillips Blvd., Trenton, NJ 08618 Plaintiff Tcrni _ No. 99-6227 Civil VS. Leroy K. Gordon, 720 Sterling Circle, Enola, PA 17025 and Karen E. Gordon, 720 Sterling Circle, Enola, PA 17025 Defendant PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: PREMISES: 7B Tory Circle, a/k/a Units fID-20 & ffD20•G, Laurel Hills North Condominuim I, Enola, PA, 17025 See Exhibit "A" attached AMOUNT DUE S139,172.44 1 Interest from 6/8/00 to S 2,360.97 9/6/00 c0 6.88% ; (Costs to be added) S ?) 4z David , Comroc Attorney for Plaintiff DESCRIPTION ALL THAT CERTAIN unit and the property known, named and identified in the Declaration referred to below as "Laurel Hills North Condominium I", located in East Pennsboro Township, Cumberland County, Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S.A. §3101 et seq., by the recording in the Office of the Recorder of Deeds of Cumberland County of a Declaration dated April 4, 1989, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 362, page 661, as amended and restated, being and designated in such Declaration, as amended and restated, as Unit No. D-20, together with a detached garage being and designated in such Declaration as amended and restated, as Unit No. D-20-G, which said Unit is more fully described in the Amended and Restated Declaration, dated October 15, 1990, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 388, page 483, First Amendment to Amended and Restated Declaration, dated September 22, 1993, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 455, page 201, Second Amendment to Amended and Restated Declaration, dated March 7, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 515, page 406, and Third Amendment to Amended and Restated Declaration, dated April 3, 1996, recorded iti the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 517, page 217, Plats and Plans-Site Plan, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 57, page 126, First Amendment to Plats and Plans-Site Plan, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 61, page 102, Second Amendment to Plats and Plans-Site Plan, dated October 31, 1991, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 66, page 135, Third Amendment to Plats and Plans - Site Plan, dated September 18, 1995, revised March 4, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 71, page 132, and Fourth Amendment to Plats and Plans-Site Plan, dated February 9, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 72, page 1, together with proportionate undivided interest in the Common Elements (as defined in said Declaration, as amended and restated) of 4.32%. Tax Parcel # 09-14-0835-082.620 NON-MILITARY AFFIDAVIT COMMONWEALTH OF Pennsylvania SS COUNTY OF Philadelphia RE: being first duly sworn on oath deposes and says: 1. That I am employed by the Plaintiff here as servicer of the mortgage. 2. That the captioned individual(s) are the owners of the premises described in the mortgage or deed of trust. 3. That the collection procedures of the Plaintiff are designed to discover the facts concerning the titleholder's occupations and military status. 4. That said procedures were followed in connection with the current delinquency. S. That, on information and belief, that captioned titleholders are not incompetent or in any branch of the military service. Sworn to and subscribed before me this th day of , 2000. NOTARY PUBLIC U I =g-My6;,?, 1.-- My ConuftMw ExON soq.°s i?a+ 0*vrbm, FVozyNmw AW=Vond Nd kftG t` =` U -N - i b± ?. - > i ? ?? ?? r' t 7 r . ? ' (i? ?? U O J - G ?:.. Comroe Hing LLP By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton,NJ 08618 VS. Plaintiff Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 Term No. 99-6227 CIVIL Defendants ................................................................. ................................................................. CERTIFICATION David B. Comroe, Esq., Attorney for Plaintiff in the above captioned matter, hereby certifies that Notices of Intention to Take Judgment, as set forth in PA RCP 237.1 were mailed to the Defendants on November 19, 1999. Attached hereto and made part hereof as Exhibit "A" are true and c t copies of said Notices. Da vi omroe Attorney for Plaintiff Sworn to and subscribed before me this 8th day of June, 2000. Notary Public Identification No.: 25694 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NOTARIAL mSEAL y SUE FSilwf, Notary PueYC City d Ph"MIPNA. Pnda. Cow N Commis;imiEvp-ir?,s,lul 2M2 ' t Comroe, Hing & Associates By: David B. Comroe Identification No.:25694 1700 Market Street, Suite 1400 Philadelphia, PA 19103 215-568-0400 Attorneys for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank Plaintiff VS. Leroy K.Gordon and Karen E. Gordon IN THE COURT OF COMMON PLEAS OF CUMMERLAND COUNTY CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE Term No. 99-6227 Defendants r TO: Leroy K. Gordon and Karen E. Gordon IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO IMPORTANTE USTED ESTA EN REBELDIA PORQUE HA FALLADO EN TOMAR LA ACCION EXIGIDA DE SU PARTE EN ESTE CASO. A MENOS DE QUE USTED ACTUE DENTRO DE DIEZ DIAS DE LA PECHA DE ESTE AVISO. SE PUEDE REGISTRAR UNA SEN- TENCIA CONTRA USTED. SIN EL BENEFICIO DE UNA AUDIENCIA Y PUEDE PERDER SU PROPIEQAD 0 OSTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE AVISO A UN ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO Y NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO. DEBE COMUNICARSE CON LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE OBTENER AYUDA LEGAL: Cumberland County Bar Association 7L- Two Liberty Avenue Carlisle, PA 17013 „ O%d DATE OF NOT• Mbf(aSn 2G TUM BS-[] BNOXK V, NOVEMER 191 0AW0jHGHWjLfi0N0LLVKU0:N1 DAVID B. COMROE, ESQUIRE . Ll nLn: t fR7rt V 1 n t of u-tu • t Comroe, Hing & Associates By: David B. Comroe Identification No.:25694 1700 Market Street, Suite 1400 Philadelphia, PA 19103 215-568-0400 Attorneys for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank Plaintiff Vs. Leroy K.Gordon and Karen E Gordon Defendants TO: Leroy K. Gordon and Karen E. Gordon IN THE COURT OF COMMON PLEAS OF CUMMERLAND COUNTY CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE Term No. 99-6227 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO IMPORTANTE USTED ESTA EN REBELDIA PORQUE HA FALLADO EN TOMAR LA ACTION EXIGIDA DE SU PARTE EN ESTE CASO. A MENOS DE QUE USTED ACTUE DENTRO DE DIEZ DIAS DE LA PECHA DE ESTE AVISO. SE PUEDE REGISTRAR UNA SEN- TENCIA CONTRA USTED. SIN EL BENEFICIO DE UNA AUDIENCIA Y PUEDE PERDER SU PROPIEQAD 0 OSTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE AVISO A UN ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO Y NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO. DEBE COMUNICARSE CON LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE OBTENER AYUDA LEGAL: Cumberland County Bar Association . Two Liberty Avenue Carlisle, PA 17013 L-_ 4.00 DATE OF N0T• jVMbT '3Sn HQ THM flsl7 9N0XKV, NOVEMER 19, 0,CW0E3a3M.LS0N0LLVKU0jNj DAVID B. COMROE, ESQUIRE 'cV } r r_ r. h a V 'I Comroe Hing LLP Identification No.: 25694 By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton,NJ 08618 VS. Plaintiff Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 99-6227 CIVIL Defendants ................................................................. ................................................................. CERTIFICATION David B. Comroe, Esq., Attorney for Plaintiff in the above captioned matter, hereby certifies that the provisions of the Emergency Mortgage Relief Act, P.L. 1688 No. 621, as amended, December 23, 1983 have been met. David B. Comroe Attorney for Plaintiff Sworn to and subscribed before me this 8th day of June, 2000. v W'e? 1x.'ee-;k - Notary Public NOTAf11AL SEAL sue fl+? ? r, ao, sao2 .,. ,,,.... ?? <`? ?; O`'; a.. ???. ?1 , L? , ? ?? ? ? ? V ? v Jun-14. 2000 8:50AM CH&A 14 No.39S3 P. 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE OF PENNSYLVANIA In re: Leroy Gordon and Karen E. Gordon Debtors Bankruptcy No.: 99.OS211•R)W Allfirst Bank, fka First National Bank of Maryland C/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton, N) 08618 Movant vs. Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 and Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 and Lawrence G. Frank, Esquire Interim Trustee Law Office of Lawrence G. Frank 2023 North Second Street Harrisburg, PA 17102. Respondents Chapter 7 : f" LED MAY.1 0 2M ............ ................... ............................... .........'......... O R D E R AND NOW, this 1 p aAO O , at Harrisburg, upon (allure of Debtor to file an Answer or otherwise plead, it it DERED AND DECREED that: The Automatic Stay of all proceedings, as provided under Sec. 362 of the Bankruptcy Reform Act of 1978 (The Code) 11 U.S.C. 362, Is modlfled to allow the above Movant to proceed with the execution process through, among other remedies but not limited to, Sheriffs Sale regarding premises: 5 Jun.14. 2000 8:51AM CHAA 7B Tory Circle, Enola, Pennsylvania, 17015. INTERESTED PARTIES: David 8, Comroe Comroe Hine LLP 1700 Market Street Suite 1400 Phlladelphia, PA 19103 Lawrence G. Franl,. Esquire. Interim Trustee Law OfAce of Lawrence G. Frank 2023 North Second Street Harrisburg, PA 17102 Steven P. Roth Rosenn, Jenkins and Greenwald 15 South Franklin Street Wilkes-Barre, PA 18711 No-3953 P. 3 BY THE COURT, iv "tul J. jim"46 Robert ). Woodside Bankruptcy )udee 6 Comroe Hing LLP Identification No.: 25694 By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland c/o Cenlar Federal Savings Bank 425 Phillips Boulevard IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Trenton,NJ 08618 Plaintiff ACTION OF MORTGAGE FORECLOSURE VS. Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 Defendants Term No. 99-6227 CIVIL AFFIDAVIT David B. Comroe, being duly sworn according to law, deposes and says that lie is a member of the law firm of Comroe Hing LLP, attorneys for Allfirst Bank, fka First National Bank of Maryland, Plaintiff in the above referenced matter, and as such, has the authority to make this Affidavit. 1. The Defendants, is the owner of the Premises described in the Complaint. f 2. To the best of my knowledge, information and belief, the present address of the Defendants, Leroy K. Gordon and Karen E. Gordon, is 720 Sterling Circle, Enola, PA 17025 and 720 Sterling Circle, Enola, PA 17025. Comroe Hing LLP BY: David B. Comroe Attorney for Plaintiff 2 ti ?; - u <? Ni 7 r I?11? v o `? cl V ,a Certificate To The sheriff Sheriff of Cumberland County S. Hanover Street, Carlisle, PA 17013 Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard M. C. C.P. (Circle One) Trenton NJ, 08618 Plaintiff VS. Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 Defendants Term No. 99-6227 CIVIL I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an action: A. In Assumpsit (Contract) B. In Trespass (Accident) X _ C. In Mortgage Foreclosure D. On a note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendants own the property being exposed to sale as: A. An individual B. Tenants by Entireties - C. Joint tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation I III. The Defendants are: x A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above not applicable, state which Defendants are residents of the Commonwealth of Pennsylvania: Residents: This certification must be signed by the attorney of record if an appearance has been entered; otherwise certification must be signed by Plaintiff. Name: David B. Comroe, ESQUIRE P e No.: (215)568-0400 Signature Address: 1700 Market Street, Suite 1400 Philadelphia, PA 19103 i ?; ? ??- ?,j?, h, ._ 1 6. / `? -- Y( ?1? ti I ?? ?f '?? ' ?,' ? (}j ? ??5 ?' :. ? ? ???. U a U .? Comroe Hing LLP Identification No.: 25694 By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton,NJ 08618 VS. Plaintiff Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 99-6227 CIVIL Defendants .............................................................. .............................................................. AFFIDAVIT PURSUANT TO RULE 3129.1 Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc., Plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following information concerning the real property located at 7B Tory Circle, a/Y./a Units If D-20 6 HD-20-G, Laurel Hills North Condomininium I, Enola, Pennsylvania 17025: 1. Name and address of owner or Reputed Owner: Leroy K. Gordon and Karen E. Gordon 720 Sterling Circle Enola, PA 17025 2. Name and address of Defendants in the judgment: [Date Service Code Leroy K. Gordon 720 I I1 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, 1 PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: Date Service Code Allfirst Bank 3 3607 Derry St. 6113 /al Harrisburg, PA 17111 y. cvame ana aaaress or the lase recoraea noiaer or every mortgage of record: Date Service Code Adam Wholesalers, Inc U ?3 3 1627 Ritner Highway Carlisle, PA 17013 Household Realty Corp. 25 Gateway Drive `/??IQ 6 J 3 Suite 107 U / Mechanicsburg, PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: JGate Service Code 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. I (Date Iservice Code I 2 Court of Common Pleas of I 3 Cumberland Co., Domestic Relations Div. 13 N. Hanover St. Carlisle, PA 17013 Court of Common Pleas of rU 3 Cumberland Co., Domestic ?I13Q Relations Div. Courthouse One Courthouse Sq. Carlisle, PA 17013 Child Support Enforcement 6I?3I U Agency 3 PO Box 320 Carlisle, PA 17013 Court of Common Pleas of Cumberland Co.,Domestic Relations Div. 3 00 1627 Ritner Highway Carlisle, PA 17013 Condominium Association, Laurel Hills North Condo. I d 13 0o 3 c/o Charlene Tallman 1150 Sterling Ct. Enola, PA 17025 Laurel Hills North Condo. I I II? ob 744 Wertzville Rd. b 3 Enola, PA 17025 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 3 4.??yiaaw.++i.,a.M.ws?vp`.1aKi^t?ur.[vP,?r,*n? u?.:.._..,';,?..o..wrt3ta97.W^Y.s»ryv:.•p!e M1?9:, y,.+?::x" 7. •x mss; ...,?,. t aY?t.?2a>dcriR?+__ DATED: P nt e C 1 4 4 F r r U r pcp 7 H 0 a 0 0 0 W m V 3 6 m m m R n I C C N ` or M r W x O rd M O C ? 3 m T a N to n m c O ^ N r a 53 ^ n ? _a0 ! p " i Cm<' 0 p* to C'j - Z' no "i Y A e-1 r 0 ^y V rl O O s o N D n o .. p to ro r (A w c 31 iom 9 w m uD z - 1 d < a w R ' -? > i i7 F 0 b - ?D o n O ! m 0 c i O 88 W I T W ( SdS o D ? G 0 r?u r x - z a n ?? N? i? _ P TA MAY BE USED F PROV IOE FOR IA Racelred From 11 .nu IN'tnNATIUNAL MAIL. DOES NOT POSTMASTER Irt, COMROE HING LLP" 1700 l L Suite 1400 -4 F-7 7 , ii' JIAJ Affix fee nary m stamps or meta Postage and Post mark. Inquire of P, tmastet for currant ...___.?.....,. .. rWI%N' V Iq N On, plea of oromuY mad add"Ited to'. Allfirst Bank 3607 Derry St. Harrisburg, PA 17111 Allfirst(Cenlar) vs Cordon i PS Form 3817, Mar. 1989 I -N . 1 M s?g 4 M ??rS r a w ?? t F c N rat 0 08 yg C o m O + A e a u " 1- W H h rr t $ n o r o Frt., O 4 $ e _^ C m s A to n n 2 Lo 0 r, r TO :0 C) 4 , A n 8n r rr 0 VO D> n v 0 w o e m r TO o a ": ? 7 < W °m C TO " .+ Z a m TO M 0 li? O i ^ O 8 s 1D o D CJ N z a 1 4 4 S au , 0 0 f 'f 4' l i s 7a - lf.J.,;r x171 0 (a c $ a n ? G S 3 _39 IAY BE USED Ff ROVIDE FOR IN Rloaed From COMROE HING wmladelohia, PA 19103- 9 Dne Dlace PI OldmarY -4-1 addlessId to Adam Wholesalers, Inc. 1627 Ritner Highway Carlisle, PA 17013 Allfirst(CENLAR) vs Gordon PS Form 3817, Mar. 1989 P TA SERVICE CERTIFICATE OF MAILIN MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. OF51Np)yr PROVIDE FOR INSURANCE-POSTMASTER Re4.rv.d F,Pm? COMROE HING L 0 ' 97 l Suite 1400 Phiiiaa o) iaa ?Haa One Dnce of ad-MY mad Walled to Household Realty Corp 25 Gateway Drive, Suite 107 Mechanicsburg, PA 17055 Allfirst(CENLAR) vs Gordon PS Form 3817, Mar. 1989 Affix fat Nan in stamps or mate postage end post mark. Inquire of Postmaster for current I J ( • 1??1 sn .. Affil) fee Aare in stoops Pr MOW Postage and Post mark. Inquire of Qostmstef for current E Plf Y 4 ?•_. tam J F to m to ,r q O N Sur h N 8 C ? $ mm A M Pi r etR . W to n g r; O a o - A n n ,m s 9$? s ?m 9 M 111 0 r c Lr p V R q> m v o g. t a Z O o It of 83 y ?6m -1 W ? M F. 02 T O r+ m D ?1 75' m T _ f D O ? C •n N I 0 0 ° . -P - m a J ccp? ` 3 R D M fD 8 r of -A w z ti N 2C _FL `I ge And S POSTAL SERVICE CERTIFICATE OF MAILING of motor nminpostage and ?. or AY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT poµ mask. Inquire of IOVIDE FOR INSURANCE -POSTMASTER Postmaster for currant Paeaed Fmm COMROE HING fee. 1700 Market Street w r?,;,elohia PA 1g103.3914 One piece or ardmerv mail &Jd,*Sled to Laurel Hills North Condo I u:t 744 Wertzvill Rd v Enola, PA 17025 MU?? Affix fee o P CIS ' o M Allfirst(CENLAR) vs Gordon PS Form 3817, Mar. 1989 ' I__...-_-.___...._... _ ......_-_..?-....ww,rw,•?a...v,.w?raww?em.war?AroIGMR"?5,'1 zM s> a 9 i a PS Form 3817. Mar. 1989 S ? B +? yt5 - POSTAL SERVICE CERTIFICATE 0 MAIL ING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER ReCo,.Qd From 0WAROE HING i_LP 17n0 Market Street Sult01400 ,c One poste of ordnHty mad addressed to. D VJ C Condo Association, Laurel Hills 1MKh Condo. I c/o Charlene Tallman 1150 Sterling Ct. Enola, PA 17025 Allis lee here In stamps or meter postage and post mark. Inquire of Postmaster for current lee. HI? NN,?a Allis lot Mrs in etampa or melee postage and post mark. Inquire of Postmaster for current W. POSTAL RVI CE CERTIFICATE OE, MAILING - MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER ?(? Received From COMROE HING LLP 17nn Mar eo1 c reet- Suite 1400 PO p la, 19103-3p,14 One o,oce of ord.nuv mad addnued to Child Support Enforcement Agent cc PO Box 320 Carlisle, PA 17013 Allfirst(CENLAR) vs Gordon PS Form 3817. Mar. 1989 4 . i ! `k )) L? _• 3 H G. 4` ? Comroe Hing LLP Identification No.: 25694 By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton,NJ 08618 VS. Plaintiff Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 99-6227 CIVIL Defendants .............................................................. .............................................................. AFFIDAVIT PURSUANT TO RULE 3129.2 AND RETURN OF SERVICE PURSUANT TO PA R.C.P. 405 OF NOTICE OF SALE David B. Comroe, Esq., Attorney for Plaintiff, Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. sets forth as of the date of the praecipe for the writ of execution was filed the following information concerning the real property located at to be sold at Sheriff's Sale on 09/06/2000. As required by PA R.C.P. 3129.2 (a) Notice of Sale has been given in the manner required by PA R.C.F. 3129.2 (c) on each of the persons or parties named at the addresses set forth below on the date and in the manner noted in the margin by the names of each and copies of each notice together with return receipts or proof of mailing are attached as Exhibits. The manner of service, as noted in the margin, utilizes the following codes: 1. Personal Service by the Sheriff or in accordance with Pennsylvania Rule of Civil Procedure 400.1. 2. Certified mail-return receipt attached 3. First Class Mail-Certificate 3817 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: June 8, 2000 David B. Comroe Attorney for Plaintiff 6 U o : gt Comroe Hing LLP Identification No.: 25694 By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton,NJ 08618 VS. Plaintiff Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 99-6227 CIVIL Defendants .............................................................. .............................................................. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Leroy K. Gordon, Karen E. Gordon Your property at 7B Tory Circle, a/k/a Units ft D-20 6 HD-20-G, Laurel Hills North Condomininium I, Enola, Pennsylvania 17025 in Cumberland County, Pennsylvania is scheduled to be sold at Sheriff's Sale on September 6, 2000, at 10:00:00 AM, in Cumberland County to enforce the Court Judgment of $139,172.44 plus accrued interest obtained by Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Comroe Hing LLP, attorneys for the Plaintiff, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: (215)568-0400 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the greater chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling the Sheriff of Cumberland County at 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of Cumberland County at 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days of 2 the Sale date. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exemptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS IS A PROCESS THE PURPOSE OF WHICH IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU OR ANYONE ELSE WILL BE USED TO THAT END. £ N 3 ALL THAT CERTAIN unit and the property known, named and identified in the Declaration referred to below as "Laurel Hills North Condominium i", located in East Pennsboro Township, Cumberland County, Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S.A. §3101 et seq., by the recording in the Office of the Recorder of Deeds of Cumberland County of a Declaration dated April 4, 1989, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 362, page 661, as amended and restated, being and designated in such Declaration, as amended and restated, as Unit No. D-20, together with a detached garage being and designated in such Declaration as amended and restated, as Unit No. D-20-G, which said Unit is more fully described in the Amended and Restated Declaration, dated October 15, 1990, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 388, page 483, First Amendment to Amended and Restated Declaration, dated September 22, 1993, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 455, page 201, Second Amendment to Amended and Restated Declaration, dated March 7, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 515, page 406, and Third Amendment to Amended and Restated Declaration, dated April 3, 1996, recorded iti the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 517, page 217, Plats and Plans-Site Plan, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 57, page 126, First Amendment to Plats and Plans-Site Plan, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 61, page 102, Second Amendment to Plats and Plans-Site Plan, dated October 31, 1991, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 66, page 135, Third Amendment to Plats and Plans - Site Plan, dated September 18, 1995, revised March 4, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 71, page 132, and Fourth Amendment to Plats and Plans-Site Plan, dated February 9, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 72, page 1, together with proportionate undivided interest in the Common Elements (as defined in said Declaration, as amended and restated) of 4.32%. Tax Parcel# 09-14-0835-082-620 t L7 •. .'i au fir.. 4f. ii C D v :.) U LAW OFFICES CONIROE, HINC & LLP SMITE 141X1 1700 MARKET STREET PHILADELPHIA, PENNSYLVANIA 19103.3914 (215) 5694HIX1 FAX NUMBER (215) 56x•5560 YMW ""'WIIIIv 0" DAVID B. COMOE GLENN F. IIINO ROBERT I. WILSON Allfirst Bank 3607 Derry St. Harrisburg, PA 17111 June 8„ 2000 RE: Allfirst Bank Vs. Leroy K. Gordon and Karen E. Gordon Docket No 99-6227-Civil Property Address: 7B Tory Circle, a/k/a Units #D-20 & # D-20-G Laurel Hills North Condo.I NOTICE OF SALE OF REAL PROPERTY Dear Sir/Madam: Please be advised that the property and improvements, if any, as set forth above, will be sold by the Sheriff of Cumberland County on September 6, 2000, at 10:00 AM. The sale will take place at The Cumberland County Courthouse or such other location as the Sheriff of Cumberland directs. This property and improvements, if any, is being sold pursuant to a Judgment entered in favor of Plaintiffand against Defendants in the Court of Common Pleas of CUMBERLAND County. The name of the owner, real owner and reputed owner of the aforesaid property is as set forth as the Defendants above. It has come to our attention that you (night be a creditor to the Defendants named herein. Sheriffs Sale of the mortgage property could adversely affect your interest if you are, in fact, a junior creditor herein. A Schedule of Distribution will be filed by the sheriff on a date specified by the Sheriff no later than thirty (30) days after said sale, and a distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date said schedule. You should check with the Sheriffs office by calling 717.240.6390 to determine the actual date of the filing of the said schedule. rely you David-Be C6mroe DBC/min ? + S is MlkU>1TA11UAlRNms?, e `. N,hIlN0.1111p27fG1{?.,, ?.:. GYlttifm> r+.i^+ ^AMNMlnk.lhh 1-:f um K. OWN „.: Agyf2lddU,Centroe ' & 1%4j been submitted to the prtrA" 61 the 14nnytvWa' Uallow Conduceo='Ack' . U Pa.C.S.A pWl el req. We nmeOnnn?? DeeM d. InIDOWol the fit if Px..?.J..A f`..6 li .r • n:.r:.J" A..A t tuber A Recorder In MfeoelWremm look $17, past 217, pub and N"46 Pten, tKorded,n IM Office d IM Retordee d.Deeds of Cumberland County bi Plan Book 57, pp+lse 124 nrst Amendment to nab and f7arreY5Rt PIK - ree"M In the Office of the Recorder of Deeds of Cumberland Cou In Plan Book fM191T1f ? MIY Y/1{x .nt'nxxn. ..? .?.n seabed I,"•4 1994 recorded in the : O?n''of - the: Recorder of Dn* d Cumberland Coonly In Ru Uook 74 pop i 132, and Fourth Amendment to nab and lar+51b f nor daled,FeMwy % l"j, retarded In the O fice d the Recorder d Deeds of CumbvWrd County in Pbn Book 72, a 1, totem with proportionate andws Interest in the Common Elements(n defined in mid Decbiatlon; e amended and rotated) of 1M:. 2aaParceka09•U46.1S-092.6?. D• Comroe, Hing & Associates By: David B. Comroe Identification No.:25694 1700 Market Street, Suite 1400 Philadelphia, PA 19103 215-568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank, " 425 Phillips Boulevard, Trenton, NJ 08618, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. ell- ",z7 VS. Leroy K. Gordon, 720 Sterling Circle, Enola, PA 17025 and Karen E. Gordon, 720 Sterling Circle, Enola, PA 17025, Defendants CIVIL ACTION: FORECLOSURE N O T I C E You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association PURPOSE O` 2 Liberty Ave. Carlisle, PA IM 0 Alm 7W (717)249-3166 Va"i 19 .M C0(1= A DEBT AND ., pq PYATOW OBTOM FROM Yo' 40ryQyg 41 ¢i =I, Sr USED TO THAT LAD LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE LISTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, 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 PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA (717)249-3166 2 1. Plaintiff is Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc., with its principal offices at c/o Cenlar Federal Savings Bank, 425 Phillips Boulevard, Trenton, NJ 08618. 2. Defendants are Leroy K. Gordon and Karen E. Gordon, with an address as set forth above. 3. On May 31, 1996 Leroy K. Gordon and Karen E. Gordon executed and delivered a Mortgage upon premises hereinafter described to Eastern Mortgage Services, Inc., predecessor to First National Bank of Maryland, now known as Allfirst Bank, which mortgage was recorded in the Department of Record at Cumberland County, Pennsylvania in Mortgage Book 1323, at page 924 on June 3, 1996. 4. This mortgage has not been assigned. 5. The premises subject to said Mortgage are known as 7B Tory Circle, Enola, Pennsylvania 17025 and are more particularly described in Exhibit "A" attached hereto and incorporated herein by reference. 6. The Defendants are Leroy K. Gordon and Karen E. Gordon the record and real owners of the said real estate subject to the Mortgage. 7. The said Mortgage is in default by reason of the fact that the monthly installments of principal, interest and escrow as due on April 1, 1999, and as due on the first day of each month thereafter are still due and owing and have not been paid; and by the terms of the said Mortgage, upon failure to make such payments 3 ME a A puro 9 7f® vuwP 'R nr 147(UjtJXTAMTANT , yptr+(lpp4l?71i7ui (WARM) PROP! e "r.k- rl g-1 mr i Pr• n„?;.. when due, the whole of the principal balance and all interest due thereon, together with late charges and other recoverable sums and attorney's fee are now due and payable forthwith. 8. The monthly installment payment composed of principal, interest and escrow due under the terms of said Mortgage and Mortgage Note for each such month was ONE THOUSAND EIGHTY ONE DOLLARS AND 20 CENTS ($1,081.20), consisting of NINE HUNDRED TWELVE DOLLARS AND 30 CENTS ($912.30) for principal and interest, and ONE HUNDRED SIXTY EIGHT DOLLARS AND 90 CENTS ($168.90) for escrow. In addition there are escrow deficits due. The monthly mortgage amount changed to $1,030.93 per month from 7/ 2/99 to 10/ 1/99 9. The following amounts are therefore due and owing on said Mortgage: (a) Principal Debt $119,907.71 (b) Late Charges at $54.06 per month from 4/ 1/99 to $ 216.24 Late Charges at $51.55 per month from 7/ 2/99 to 10/ 1/99 $ 154.65 (c) Interest from 3/ 1/99 through 10/ 1/99 at $22.90 per diem $ 4,900.60 (d) Total Escrow Deficit to date $ 1,098.06 (e) Reasonable Attorney's fees as in the above stated amount reflect third party sale only. If the Mortgagor reinstates the account, attorney's fees will be reasonable based upon work performed. $ 5,995.39 (f) Title Report $ 335.00 (g) Court Filing Charge $ 115.50 (h) Uncollected Late Charge(s) $ 459.00 4 (i) Escrow Credit $ TOTAL AMOUNT DUE $133,182.15 In addition, interest at the rate of $22.90 per day on the unpaid principal balance will continue to accrue until the default is resolved. Any payments which are allowable under the mortgage document and are necessary to protect Plaintiff, relating to real estate taxes owed or which become due on the mortgaged property together with fire or homeowners insurance premiums necessary to protect the Plaintiff, or any reasonable costs necessary to protect the property from waste or vandalism shall also become due and owing by Defendants to Plaintiff when expended by Plaintiff. 10. Pursuant to the provisions of Act No. 6 of the Pennsylvania General Assembly dated January 30, 1974, as amended, a Notice of Intention to Foreclose Mortgage was mailed by Certified Mail, Return Receipt Requested to the Defendants at the aforesaid mortgaged premises. True and correct copies of said Notices are attached hereto and made a part hereof as Exhibit "B" and same are incorporated by reference herein as though here fully set forth at length. 11. Pursuant to the provisions of Act 91 of the Pennsylvania General Assembly dated December 13, 1983, "The Emergency Mortgage Relief Act," notices in accordance with the Homeowners' Emergency Assistance Act of 1983 were mailed by regular let class mail to the Defendants at the aforesaid mortgaged premises. 5 WHEREFORE, Plaintiff prays judgment against Defendants in the sum of $133,182.15 plus interest and late charges at the contract rate to date of Judgment as set forth above and costs, both of suit and as set forth above, and for foreclosure and sale of the mortgaged premises. DATED: October 1, 1999 Respectfully submitted, Comroe, Hing & Ass ciates By: David . Comroe Supreme Court I.D. 25694 Attorneys for Plaintiff 6 for Plaintiff, having express authorization to enter into this verification verifies the foregoing Complaint in Mortgage Foreclosure and avers that the statements of fact therein contained are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, and that same are true upon the signer's personal knowledge or information and belief. 7 DESCRIPTION ALL THAT CERTAIN unit and the property known, named and identified in the Declaration referred to below as "Laurel Hills North Condominium I", located in East Pennsboro Township, Cumberland Gounty, Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S.A. §3101 et seq., by the recording in the Office of the Recorder of Deeds of Cumberland County of a Declaration dated April 4, 1989, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 362, page 661, as amended and restated, being and designated in such Declaration, as amended and restated, as Unit No. D-20, together with a detached garage being and designated in such Declaration as amended.and restated, as Unit No. D-20-G, which said Unit is more fully described in the Amended and Restated Declaration, dated October 15, 1990, recorded in the Office of the Recorder of Deeds of CuatberlantCounty in Miscellaneous Book 388, page 483, First Amendment to Amended and Restated Declamation, dated September 22, 1993, recorded in the Office of the Recorder of Deeds of Cumberland. County in Miscellaneous Uok 455, page 201, Second Amendment to Amended and Restated Declaration, dated March 7, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 515, page 406, and Third Amendment to Amended and Restated Declaration, dated April 3, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 517, page 217, Plats and Plans-Site Plan, recorded in the Office of the Recorder of Deeds of Cumberland County In Plan Book 57, page 126, First Amendment to Plats and Plans-Site Plan, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 61, page 102, Second Amendment to Plats and Plans-Site Plan, dated October 31, 1991, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 66, page 135, Third Amendment to Plats and Plans - Site Plan, dated September 18, 1995, revised March 4, 1996, recorded in the Office of the Recorder of Deeds ' of Cumberland County in Plan Book 71, page 132, and Fourth Amendment to Plats and Plans-Site Plan, dated February 9, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 72, page 1, together with proportionate undivided interest In ate Common Elements (as defined in said Declaration, as amended and restated) of 4.32%. Tax Parcel A 09-14-0835-082-620 . ... ., .. Lilts: Daupl ?. Deposit Bank and Trust Cc pany N FARMERS BANK " VALLEYRANK BANK OF PENNSYLVANIA HOPPER SOLIDAY & CO., INC. EASTERN MORTCACE SERVICES, INC. (888) 2894610 July 26, 1999 Leroy K Gordon 7 B Tory Cir Enola PA 17025 Mortgaged Propertys 7 B Tory Cir Enola PA 17025 Certified Mail No. Account No. 204437-8 YOUR MORTGAGE IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOUR LENDER MAY FORECLOSE AND YOU MAY LOSE YOUR HOME. IF YOU WANT TO SAVE YOUR HOME FROM FORECLOSURE, YOU MUST TAKE ACTION NOW BY EITHERs 1. CURING THE DEFAULT - This notice explains the nature of the default and your rights to protect your interest in your home (See Section 403'of the Act of January 30, 1974 (P.L.13, No. 6), 41 P.S. Section 403); OR 2. APPLYING TO THE HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS - Read this notice to find out how the program works. YOU MUST MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE IN ORDER TO APPLY. See Act of December 23, 1983 (P.L. 385, No. 91) 35 P.S. Section 1680.201c-1680.409c. 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 INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO, ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROORAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 ("THE ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF RESUMING YOUR MORTGAGE PAYMENTS AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLEASE READ ALL OF THIS NOTICE, IT CONTAINS AN EXPLANATION OF YOUR RIGHTS. XC177 004 DXP Page 2 Loan No. 204437-8 TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of the creditor or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan or to otherwise mettle your delinquency. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. HOW TO CONTACT THE CREDITOR: Name of Creditors Central Loan Administration Address: - P.o, qox 77410 Ewing',' NJ 08628 Telephone Number: MR. GREEN _ Contact Persons 1-800-242-7178 CONSUMER CREDIT COUNSELING AGENCY - If you meet with your creditor or with a consumer credit counseling agency identified in thin notice, the creditor may NOT take action against you for thirty (30 ) days after the date of this meeting. THE NAMES AND ADDRESSES OF DESIONATED CONSUMER CREDIT COUNSELING AGENCIES FOR THE COUNTY IN WHICH THE PROPERTY IS LOCATED ARE SHOWN ON THE ATTACHED SHEET. It in only necessary to schedule one face- to-face meeting. Advise your creditor IMMEDIATELY of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth in this Notice. If you have tried and are unable to resolve this problem with the creditor, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed on the attachment. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTOA09 ASSISTANCE WILL BE DENIED. AGENCY ACTION - 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 XC178 008 DXP Page 3 Loan No. 204437-8 application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of it's decision on your application. THE PENNSYLVANIA HOUSING FINANCE AGENCY IS LOCATED AT 2101 NORTH FRONT STREET, POST OFFICE BOX 8029, HARRISBURG, PENNSYLVANIA 17105. TELEPHONE NO. (717) 780-3800 OR 1-800-342-2397 (TOLL FREE NUMBER). PERSONS WITH IMPAIRED HEARING CAN CALL (717).780-1869. HOW YOUR MORTGAGE IS IN DEFAULT NATURE OF THE DEFAULT- The MORTGAGE debt held by the above creditor on your property located at: 7 B Tory Cir , Enola PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE THE MONTHLY MORTGAGE PAYMENTS. The following amounts are now past due: Payments of Principal and Interests 3649.20 Escrow Payments: 625.33 Late charges: 287.05 Attorney Fees/Costs 300.00 Other Chargess 159.00 TOTAL AMOUNT PAST DUE: 5020.58 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: RE-INSTATE YOUR LOAN HOW TO CURE THE DEFAULT- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE to the creditor plus any additional monthly payments and late charges which may fall due after the date of this notice and the date you make your payment. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Central Loan Administration 425 Phillips Blvd. Ewing, NJ 08626 Attn: Cash Management Department You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. XC179 009 DXP Page 4 Loan No. 204437-8 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, THE CREDITOR INTENDS TO EXCERCISE ITS RIGHTS TO ACCELERATE THE MORTGAGE DEBT. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the creditor also intends to instruct its attorneys to start a lawsuit to foreclosure upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off-the mortgage debt. If the creditor refers your case to its attorneys, but you cure the delinquency before the creditor begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.0b. However if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the creditor even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the creditor, which may also include other reasonable costs. IF YOU CURE THE DEFAULT WITHIN THE THIRTY (30) DAY PERIOD, YOU WILL NOT BE REQUIRED TO PAY ATTORNEY'S FEES. OTHER CREDITOR REMEDIES - The creditor may also sue you personally for the unpaid principal balance and other sums due under the mortgage. You can not be sued personally if you have obtained a discharge in a Bankruptcy proceeding. In that circumstance suit will be for property only. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU STILL HAVE THE RIGHT TO CURE THE DEFAULT AND PREVENT THE SALE AT ANY TIME UP TO ONE HOUR BEFORE THE SHERIFF'S SALE, YOU MAY DO SO BY PAYING THE TOTAL AMOUNT PLUS ANY COSTS CONNECTED WITH THE FORECLOSURE SALE AND ANY OTHER COSTS CONNECTED WITH THE SHERIFFS SALE AND BY PERFORMING ANY OTHER REQUIREMENTS UNDER THE MORTGAGE. EARLIEST POSSIBLE SHERIFF'S DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately NINE (9) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the creditor. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the creditor at the address set forth above. XC1BO 008 DXP Page 5 Loan No. 204437-8 EFFECT of SHERIFF'S SALE DATE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the creditor at any time. OTHER RIGHTS THAT YOU HAVE - You have additional rights to help protect your interest in the property. YQU ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS OF THE MORTGAGE ARE SATISFIED. CONTACT THE CREDITOR TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. - • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU CO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE CREDITOR. Very Truly Yours, Angela M: Bernteon Second Vice President XC181 008 DXP THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED IN RESPONSE TO THIS WILL BE USED TO FURTHER THAT END. Daupl . Deposit Bank and Trust Cc^.pany FARMERS BANK . VALLMANK BANK Of PENNSTLV.ANIA HOPPER SOLIDAT k CO., INC. EASTERN MORTGAGE SERVICES, INC. (888) 289-4610 July 26, 1999 Leroy K Gordon 720 Sterling Ct Enola Mortgaged Propertyt , PA, 17025 7 B Tory Cir Enola PA 17025 Certified Mail No. Account No. 204437-8 YOUR MORTGAGE IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOUR LENDER,)4AY FORECLOSE AND YOU HAY LOSE YOUR HOME. IF YOU WANT'TO SAVE YOUR HOME FROM FORECLOSURE, YOU MUST TAKE ACTION NOW BY EITHERt 1. CURING THE DEFAULT - This notice explains the nature-of the default and your rights to protect your interest in your home (See Section 403 of the -Act of January 30, 1974 (P.L.13, No. 6), 41 P.S. Section 403); OR 2. APPLYING TO THE HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS - Read this notice to find out how the program works. YOU MUST MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE IN ORDER TO APPLY. See Act of December 23, 1983 (P.L. 385, No. 91) 35 P.S. Section 1680.201c-1680.409c. If you need more information, call the PennsylVania Housing Finance Agency at 1-800-342-2397. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIEHDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAHANDO ESTA AOENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEOIBLE PARA UN PRESTAMO POR EL PROORAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU HAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH TEE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 ("THE ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF RESUMING YOUR MORTGAGE PAYMENTS AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLEASE READ ALL OF THIS NOTICE, IT CONTAINS AN EXPLANATION OF YOUR RIGHTS. XC183 003 DXP Page 2 Loan No. 204437-8 TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of the creditor or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. HOW TO CONTACT TH Name of Creditors AddressS Telephone Numbers Contact Persons E CREDITORS Central Loan Administration P.o. •Box 77410 Ewing; NJ 08628 MR- GREEN 1-800-242-7178 CONSUMER CREDIT COUNSELING AGENCY - If you meet with your creditor or _ with a consumer credit counseling agency identified in this notice, the creditor may NOT take.action against you for thirty (30 ) days after the date of this meeting. THE NAMES AND ADDRESSES OF DESIGNATED CONSUMER CREDIT COUNSELING AGENCIES FOR THE COUNTY IN WHICH THE PROPERTY IS LOCATED ARE SHOWN ON THE ATTACHED SHEET. It is only necessary to schedule one face- to-face meeting. Advise your creditor IMMEDIATELY of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth in this Notice. If you have tried and are unable to resolve this problem with the creditor, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed on the attachment. Only consumer credit _ counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your XC178 008 DXP Page 3 Loan No. 204437-8 application in accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of it's decision on your application. THE PENNSYLVANIA HOUSING FINANCE AGENCY IS LOCATED AT 2101 NORTH FRONT STREET, POST OFFICE BOX 8029, HARRISBURG, PENNSYLVANIA 17105. TELEPHONE NO. (717) 780-3800 OR 1-800-942-2397 (TOLL FREE NUMBER). PERSONS WITH IMPAIRED HEARING CAN CALL -(717)-780-1869. HOW YOUR MORTGAGE IS IN DEFAULT NATURE OF THE DEFAULT- The MORTGAGE debt held by the above creditor on your property located at: 7 B Tory Cir Enola PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE THE MONTHLY MORTGAGE PAYMENTS. The following amounts are now past due: Payments of Principal and Interest: 3649.20 Escrow Paymenta: 625.33 Late charges: 287.05 Attorney Fees/costs 300.00 Other Charges: 159.00 TOTAL AMOUNT PAST DUE: 5020.58 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: RE-INSTATE YOUR LOAN HOW TO CURE THE DEFAULT- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE to the creditor plus any additional monthly payments and late charges which may fall due after the date of this notice and the date you make your payment. Payments must be made either by cash, ca9hier's check, certified check or money order made payable and sent to: central Loan Administration 425 Phillips Blvd. Ewing, NJ 08628 Attn: Cash Management Department You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. XC179 009 DXP Page 4 Loan No. 204437-8 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, THE CREDITOR INTENDS TO EXCERCISE ITS RIGHTS TO ACCELERATE THE MORTGAGE DEBT. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the creditor also intends to instruct its attorneys to start a lawsuit to foreclosure upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off, the mortgage debt. If the creditor reform your case to its attorneys, but you cure the delinquency before the creditor begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.00. However if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the creditor even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the creditor, which may also include other reasonable costs. IF YOU CURE THE DEFAULT WITHIN THE-THIRTY (30) DAY PERIOD, YOU WILL NOT BE REQUIRED TO PAY ATTORNEY'S FEES. OTHER CREDITOR REMEDIES - The creditor may also sue you personally for the unpaid principal balance and other sums due under the mortgage. You can not be sued personally if you have obtained a discharge in a Bankruptcy proceeding. In that circumstance suit will be for property only. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU STILL HAVE THE RIGHT TO CURE THE DEFAULT AND PREVENT THE SALE AT ANY TIME UP TO ONE HOUR BEFORE THE SHERIFF'S SALE, YOU MAY DO SO BY PAYING THE TOTAL AMOUNT PLUS ANY COSTS CONNECTED WITH THE FORECLOSURE SALE AND ANY OTHER COSTS CONNECTED WITH THE SHERIFFS SALE AND BY PERFORMING ANY OTHER REQUIREMENTS UNDER THE MORTGAGE. EARLIEST POSSIBLE SHERIFF'S DATE - It is estimated that the earlieot date that ouch a Sheriff's Sale of the mortgaged property could be held would be approximately NINE (9) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the creditor. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the creditor at the address set forth above. XCISO 008 DXP Page 5 Loan No. 204437-8 EFFECT OF SHERIFF'S SALE DATE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the creditor at any time. OTHER RIGHTS THAT YOU HAVE - You have additional rights to help protect your interest in the property. YOU ALSO HAVE THE RIGHTt * TO SELL THE PROPERTY fO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO R-BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS OF THE MORTGAGE ARE SATISFIED. CONTACT THE CREDITOR TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT NIGHT EXIST. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE CREDITOR. Very Truly Yours, Angela M. Berntson Second Vice President XC181 008 DXP THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED IN RESPONSE TO THIS WILL BE USED TO FURTHER THAT END. Daupl j Deposit Bank and Trust Q. -.pany Nt FARMERS BANK • VALLEYBANK BANK OI' PENNSYLVANIA HOPPER SOLIDAY & CO.. INC. EASTERN MURTCAGE SERVICES, INC, (888) 289-4610 July 26, 1999 Karen E Gordon 7 B Tory Cir Enola PA 17025 Mortgaged Property) 7 B Tory Cir Enola PA 17025 Certified Mail No. Account No. 204437-8 YOUR MORTGAGE IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOUR LENDER HAY FORECLOSE AND YOU MAY LOSE YOUR HOME. IF YOU WANT.TO SAVE YOUR HOME FROM FORECLOSURE, YOU MUST TAKE ACTION NOW BY EITHERt 1. CURING THE DEFAULT - This notice explains the nature of the default and your rights to protect your interest in your home (See Section 403'of the Act of January 30, 1974 (P.L.13, No. 6), 41 P.S. Section 403); OR 2. APPLYING TO THE HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS - Read this notice to find out how-the program works. YOU MUST MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE IN ORDER TO APPLY. See Act of December 23, 1983 (P.L. 385, No. 91) 35 P.S. Section 1680.201c-1680.409c. If you need more information, call the Pennsylvania Housing Finance Agency at 1-800-342-2397. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. Sr NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAHANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAHADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU HAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 ("THE ACT"), YOU HAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF RESUMING YOUR MORTGAGE PAYMENTS AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLEASE READ ALL OF THIS NOTICE, IT CONTAINS AN EXPLANATION OF YOUR RIGHTS. XC182 003 DXP Page 2 Loan No. 204437-8 TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of the creditor or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. HOW TO CONTACT THE CREDITORS Name of Creditors Central Loan Administration Addreass -P.O.-Box 77410 Ewing;' NJ 08628 Telephone Numbers MR. GREEN Contact Persons 1-800-242-7178 CONSUMER CREDIT COUNSELING AGENCY - If you meet with your _creditor or with a consumer credit counseling agency identified in this notice, the creditor may NOT take action against you for thirty (30 ) days after the date of this meeting. THE NAMES AND ADDRESSES OF DESIGNATED CONSUMER CREDIT COUNSELING AGENCIES FOR THE COUNTY IN WHICH THE PROPERTY IS LOCATED ARE SHOWN ON THE ATTACHED SHEET. It is only necessary to schedule one face- to-face meeting. Advise your creditor IMMEDIATELY of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons not forth in this Notice. If you have tried and are unable to resolve this problem with the creditor, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed on the attachment. only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-Lace meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE HAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - 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 XC178 008 DXP Page 3 Loan No. 204437-8 application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of it's decision on your application. THE PENNSYLVANIA HOUSING FINANCE AGENCY IS LOCATED AT 2101 NORTH FRONT STREET, POST OFFICE BOX 8029, HARRISBURG, PENNSYLVANIA 17105. TELEPHONE NO. (717) 780-3800 OR 1-800-942-2397 (TOLL FREE NUMBER). PERSONS WITH IMPAIRED HEARING CAN CALL-(717)-780-1869. HOW YOUR MORTGAGE IS IN DEFAULT NATURE OF THE DEFAULT- The MORTGAGE debt held by the above creditor on your property located at: 7 B Tory Cir , Enola PA 11025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE THE MONTHLY MORTGAGE PAYMENTS. The following amounts are now past dust Payments of Principal and Intereett 3649.20 Escrow Paymentst 625.33 Late chargest 287.05 Attorney Fees/Costs 300.00 Other Chargest 159.00 TOTAL AMOUNT PAST DUEL 5020.58 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: RE-INSTATE YOUR LOAN HOW TO CURE THE DEFAULT- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE to the creditor plus any additional monthly payments and late charges which may fall due after the date of this notice and the date you make your payment. Payments must be made either by cash, cahhier's check, certified check or money order made payable and sent tot Central Loan Administration 425 Phillips Blvd. Ewing, NJ 08628 Attnt Cash Management Department You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. XC179 009 DXP Page 4 Loan No. 204437-8 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, THE CREDITOR INTENDS TO EXCERCISE ITS RIGHTS TO ACCELERATE THE MORTGAGE DEBT. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the creditor also intends to instruct its attorneys to start a lawsuit to foreclosure upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the creditor refers your case to its attorneys, but ybu cure the delinquency before the creditor begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.00. However if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the creditor even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the creditor, which may also include other reasonable costs. IF YOU CURE THE DEFAULT WITHIN THE THIRTY (30) DAY PERIOD, YOU WILL NOT BE REQUIRED TO PAY ATTORNEY'S FEES. OTHER CREDITOR REMEDIES - The creditor may also sue you personally for the unpaid principal balance and other sums due under the mortgage. You can not be sued personally if you have obtained a discharge in a Bankruptcy proceeding. In that circumstance suit will be for property only. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU STILL HAVE THE RIGHT TO CURE THE DEFAULT AND PREVENT THE SALE AT ANY TIME UP TO ONE HOUR BEFORE THE SHERIFF'S SALE, YOU MAY DO SO BY PAYING THE TOTAL AMOUNT PLUS ANY COSTS CONNECTED WITH THE FORECLOSURE SALE AND ANY OTHER COSTS CONNECTED WITH THE SHERIFFS SALE AND BY PERFORMING ANY OTHER REQUIREMENTS UNDER THE MORTGAGE. EARLIEST POSSIBLE SHERIFF'S DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately NINE (9) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the creditor. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the creditor at the address set forth above. XC180 008 DXP Page 5 Loan No. 204437-8 EFFECT OF SHERIFF'S SALE DATE - You should realize that a Sheriff's Sale will and your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the creditor at any time. OTHER RIGHTS THAT YOU HAVE - You have additional rights to help protect your interest in the property. YOU ALSO HAVE THE RIGHTS • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BdYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS OF THE MORTGAGE ARE SATISFIED. CONTACT THE CREDITOR TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE CREDITOR. Very Truly Yours, Angela M. Berntson Second Vice President XCISI 000 DXP THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED IN RESPONSE TO THIS WILL BE USED TO FURTHER THAT END. Daupl . Deposit Bank and Trust Cc "pany N FARRIERS U.ANR • V.AI.LEIEANE U.SNR Of PENNSILVANIA HOPPER SOLIDAI & CO.. INC. EASTERN M ORTCACE SERVICES, INC. (888) 289-4610 July 26, 1999 Karen E Gordon 720 Sterling Ct Enola Mortgaged Property: , PA, 17025 7 B Tory Cir Enola PA 17025 Certified Mail No. Account No. 204437-8 YOUR MORTGAGE IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOUR LENDER HAY FORECLOSE AND YOU MAY LOSE YOUR HOME. IF YOU WANT `TO SAVE YOUR HOME FROM FORECLOSURE, YOU MUST TAKE ACTION NOW BY EITHER: I.-CURING THE DEFAULT - This notice explains the nature of the default and your rights to protect your interest in your home (See Section 403 of the Act of January 30, 1974 (P.L.13, No. 6), 41 P.S. Section 403); OR 2. APPLYINO TO THE HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS - Read this notice to find out how the program works. YOU MUST MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE IN ORDER TO APPLY. See Act of December 23, 1983 (P.L. 385, No. 91) 35 P.S. Section 1680.201c-1680.409c. If you need more information, call the Pennsylvania Housing Finance Agency at 1-800-342-2397. LA NOTIFICACION EN ADJUNTO ES DE SUHA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENOA UNA TRADUCCION INMEDITAMENTE LLAHANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 ("THE ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF RESUMING YOUR MORTGAGE PAYMENTS AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLEASE READ ALL OF THIS NOTICE, IT CONTAINS AN EXPLANATION OF YOUR RIGHTS. XC184 003 DXP Page 2 Loan No. 204437-8 TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of the creditor or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. HOW TO CONTACT THE CREDITOR: Name of Creditor: Central Loan Administration Address: -P.O. Box 77410 Ewing;' NJ 08628 Telephone Number: MR. GREEN Contact Person: 1-800-242-7178 CONSUMER CREDIT COUNSELING AGENCY - If you meet with your creditor or with a consumer credit counseling agency identified in this notice, the creditor may NOT take action against you for thirty (30 ) days after the date of this meeting. THE NAMES AND ADDRESSES OF DESIGNATED CONSUMER CREDIT COUNSELING AGENCIES FOR THE COUNTY IN WHICH THE PROPERTY IS LOCATED ARE SHOWN ON THE ATTACHED SHEET. It is only necessary to schedule one face- to-face meeting. Advise your creditor IMMEDIATELY of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth in this Notice. If you have tried and are unable to resolve this problem with the creditor, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies liated on the attachment. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your XC178 008 DXP Page 3 Loan No. 204437-8 application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements not forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of it's decision on your application. THE PENNSYLVANIA HOUSING FINANCE AGENCY I8 LOCATED AT 2101 NORTH FRONT STREET, POST OFFICE BOX 8029, HARRISBURG, PENNSYLVANIA 17105. TELEPHONE NO. (717) 780-3800 OR 1-800-142-2397 (TOLL FREE NUMBER). PERSONS WITH IMPAIRED HEARING CAN CALL 1717)-760-1869. HOW YOUR MORTGAGE IS IN DEFAULT NATURE OF THE DEFAULT- The MORTGAGE debt held by the above creditor on your property located att 7 B Tory Cir , Enola PA 17025 JS SERIOUSLY IN DEFAULT becaunet A. YOU HAVE NOT MADE THE MONTHLY MORTGAGE PAYMENTS. The following amounts are now past duet Payments of Principal and Interests 3649.20 Escrow Paymentet 625.33 Late chargest 287.05 Attorney Peen/Costs 300.00 Other Chargest 159.00 TOTAL AMOUNT PAST DUEt 5020.58 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION- RE-INSTATE YOUR LOAN HOW TO CURE THE DEFAULT- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE to the creditor plus any additional monthly payments and late charges which may fall due after the date of this notice and the date you make your payment. Payments must be made either by cash, cadhier's check, certified check or money order made payable and sent tot Central Loan Administration 425 Phillips Blvd. Ewing, NJ 08628 Attn: Cash Management Department You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. XC179 009 DXP Page 4 Loan No. 204437-8 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of thin Notice, THE CREDITOR INTENDS TO EXCERCISE ITS RIGHTS TO ACCELERATE THE MORTGAGE DEBT. This means that the entire outstanding balance of this debt will be considered due Immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the creditor also intends to instruct its attorneys to start a lawsuit to foreclosure upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the creditor refers your case to its attorneys, but ybu cure the delinquency before the creditor begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually-incurred up to $50.00. However if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the creditor even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the creditor, which may also include other reasonable coats. IF YOU CURE THE DEFAULT WITHIN THE THIRTY (30) DAY PERIOD, YOU WILL NOT BE REQUIRED TO PAY ATTORNEY'S FEES. OTHER CREDITOR REMEDIES - The creditor may also sue you personally for the unpaid principal balance and other sums due under the mortgage. You can not be sued personally if you have obtained a discharge in a Bankruptcy proceeding. In that circumstance suit will be for property only. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU STILL HAVE THE RIGHT TO CURE THE DEFAULT AND PREVENT THE SALE AT ANY TIME UP TO ONE HOUR BEFORE THE SHERIFF'S SALE, YOU HAY DO SO BY PAYING THE TOTAL AMOUNT PLUS ANY COSTS CONNECTED WITH THE FORECLOSURE SALE AND ANY OTHER COSTS CONNECTED WITH THE SHERIFFS SALE AND BY PERFORMING ANY OTHER REQUIREMENTS UNDER THE MORTGAGE. EARLIEST POSSIBLE SHERIFF'S DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately NINE (9) months ftom the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the creditor. If money Is due, such payment must be in cash, cashier's check, certified check or money order made payable to the creditor at the address set forth above. XCI80 008 DXP Page 5 Loan No. 204437-8 EFFECT OF SHERIFF'S SALE DATE - You should realize that a Sheriff's Bale will and your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Salo, a lawsuit to remove you and your furnishings and other belongings could be started by the creditor at any time. OTHER RIGHTS THAT YOU HAVE - You have additional rights to help protect your interest in the property. YOU ALSO HAVE THE RIGHT1 • TO BELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OPF THIS DEBT. • TO SELL OIL TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID TO OR AT THE BALE AND THAT THE OTHER REQUIREMENTS OF THE MORTGAGE ARE SATISFIED. CONTACT THE CREDITOR TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. - • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU HAY HAVE TO SUCH ACTION BY THE CREDITOR. - Very Truly Yours, Angela M. Berntson Second Vice President XC181 008 DXP THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED IN RESPONSE TO THIS WILL BE USED TO FURTHER THAT END. U Sy ' ?. r ? j:}y t y V . CASE NO: 1999-06227 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALLFIRST BANK ET AL VS. GORDON LEROY K ET AL KATHY CLARKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GORDON LEROY K the defendant, at 1755:00 HOURS, on the 14th day of October 1999 at 720 STERLING CIRCLE ENOLA, PA 17025 CUMBERLAND County, Pennsylvania, by handing to LEROY GORDON , a true and attested copy of the COMPLAINT - MORT FORE , together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 9.92 ?? Affidavit .00 ,?,?-?? O Surcharge 8.00 IZ-1 d?SiITL? SPFj1L-1LJ. $3b.=COMROg HING & ASSOCIATES 10/15/1999 by Depty 5 Sworn and subscribed to before me this J'?' day of AXaeu,,J-,, 19 !fie) A.D. d K . CASE NO: 1999-06227 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALLFIRST BANK ET AL VS. GORDON LEROY K ET AL KATHY CLARKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GORDON KAREN E the defendant, at 1755:00 HOURS, on the 14th day of October , 1999 at 720 STERLING CIRCLE ENOLA_ PA 17025 _ CUMBERLAND , County, Pennsylvania, by handing to LEROY GORDON, HUSBAND FOR a true and attested copy of the COMPLAINT - MORT FORE , together with NOTICE , and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Servicing 6.00 Affidavit .00 .00 Surcharge 8.00 R. T QUIdis--KIZTSeS 4I.00'CO7RO i9HING & ASSOC. by all ad-L'o Ljepu6y (f Sworn and subscribed to before me this 2 tL' day of U,,. L. - 1999 A.D. ` O? t? QE'bt'IT TT ?Yy a r STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND I Robert P Zieg_ler_____ i SS. -------------------------------------- Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ________________ --- -- Allfirst Bank fka First Natl Bk of MD successor to Eastern ?$hegrantee the same having been sold to said grantee on the ---- 0.01 --------------------------------------- day of September----------------------- A. D., 1Ox2000, under and by virtue of a writ -------------- ------- Execution I4th ------------------------------issued on the ------------------------------------- day of ------- Jun* -------------- A. D., c2000 out of the Court of Comman Plea of said County as of ------- Civil-------------------------------------------------------------------- Tenn, 19---9--- Number-_6227-------- at the suit of ----__Allfirst Bk fka First Natl Bk of MD successor to ------------ ------ ------------------------------------- Eastcrn Mtg Serv Inc Leroy K Gordon Karen_E _____________________ is duly recorded in Sheriffs Deed Book No, ------229 --, Page ------------- IN 10TESTMONY WHEREOF, I have hereunto set my hand and seal of said office this day of ------------ A. D., 98.5!?:Y 1ff Reoordfr of Deeds Recorder Of Deeds, Cumberland County, Cadh4, PA My Comm ss'on Irpoes the ftst Monday 01 JUL 2002 Allfirst Bank, fka first National Bank Of Maryland, Successor to Eastern Mortgage Services Inc. -vs- Leroy K. Gordon Karen E. Gordon In the Court of Common Pleas of Cumberland County, Pennsylvania No. 1999-6227 Civil Timothy Reitz, Deputy Sheriff who being duly sworn according to law says on July14, 2000 at 4:13 p.m. EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit Leroy K. Gordon by makin gknown unto Leroy K. Gordon at 720 Sterling Circle, Enola, Cumberland County, Pennsylvania, its contents and a the same time handing to him personally the said true and attested copies of the same. Timothy Reitz, Deputy Sheriff who being duly sworn according to law, says on July 14, 2000 at 4:13 o'clock P.M. EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the wihtin named defendants to wit: Karen Gordon by making known unto Leroy Gordon, husband at 720 Sterling Circle, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on July 11, 2000 at 11:30 o'clock A.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Leroy Gordon and Karen Gordon located at 720 Sterling Circle, Enola, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Leroy K. Gordon at 720 Sterling Circle, Enola, Pennsylvania. This letter was mailed under the date of July 17, 2000 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Karen Gordon to 720 Sterling Circle, Enola, Pennsylvania. This letter was mailed under the date of July 17, 2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says that after due and legal notice had been give according to law exposed the above described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on September 6, 2000 at 10:00 o'clock A.M. EST and sold the same for the sum of $ 1.00 to Attorney Scott Dieterrick for Allfirst Bank, ika first National bank of Maryland Successor to Eastern Mortgage Services, Inc. It being the highest bid and best price quoted for the same Allfirst Bank. fKa first National bank of Maryland Successor to eastern Mortgage Services, Inc. of 425 Phillips Blvd. Trenton, N1 being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 1,095.69 it being costs. Sheriffs Costs: Docketing 30.00 Poundage 21.48 Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed Sworn and Subscribed To Before Me This JI'Day of Oa=. 2000,A.D.6. •„• - 0 - W&LAA. o ionotary 15.00 15.00 30.00 10.00 .50 1.00 18.60 .78 15.00 30.00 437.45 395.85 23.53 25.00 26.50 S 1,095.69 pd by atty 9/21/00 So ansys 3.,,? p R. Thomas Kline, Sheriff By Real Estate Deputy 36o153ck2nBS1, , Comroe Hing LLP By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton,NJ 08618 Identification No.: 25694 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff VS. Term No. 99-6227 CIVIL Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 Defendants NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Leroy K. Gordon, Karen E. Gordon Your property at iB Tory Circle, a/k/a Units N D-20 6 HD-20-G, Laurel Hills North Condomininium I, Enola, Pennsylvania 17025 in Cumberland County, Pennsylvania is scheduled to be sold at Sheriff's Sale on September 6, 2000, at 10:00:00 AM, in Cumberland County to enforce the Court Judgment of $139,172,44 plus accrued interest obtained by Allfirst Bank, fka First National Bank. of Maryland, successor to Eastern Mortgage Services, Inc. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Comroe Hing LLP, attorneys for the Plaintiff, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: (215)568-0400 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the greater chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney). 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling the Sheriff of Cumberland County at 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of Cumberland County at 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days of 2 DESCRIPTION ALL THAT CERTAIN unit and the property known, named and identified in the Declaration referred to below as "Laurel Hills North Condominium I", located in East Pennsboro Township, Cumberland County, Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S.A. §3101 et seq., by the recording in the Office of the Recorder of Deeds of Cumberland County of a Declaration dated April 4, 1989, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 362, page 661, as amended and restated, being and designated in such Declaration, as amended and restated, as Unit No. D-20, together with a detached garage being and designated in such Declaration as amended and restated, as Unit No. D-20.0, which said Unit is more fully described in the Amended and Restated Declaration, dated October 15, 1990, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 388, page 483, First Amendment to Amended and Restated Declaration, dated September 22, 1993, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 455, page 201, Second Amendment to Amended and Restated Declaration, dated March 7, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 515, page 406, and Third Amendment to Amended and Restated Declaration, dated April 3, 1996, recorded in* the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 517, page 217, Plats and Plans-Site Plan, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 57, page 126, First Amendment to Plats and Plans-Site Plan, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 61, page 102, Second Amendment to Plats and Plans-Site Plan, dated October 31, 1991, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 66, page 135, Third Amendment to Plats and Plans - Site Plan, dated September 18, 1995, revised March 4, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 71, page 132, and Fourth Amendment to Plats and Plans-Site Plan, dated February 9, 1996, recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 72, page 1, together with proportionate undivided interest in the Common Elements (as defined in said Declaration, as amended and restated) of 4.32`70. Tax Parcel d 09-14-0835-082-620 the Sale date. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exemptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS IS A PROCESS THE PURPOSE OF WHICH IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU OR ANYONE ELSE WILL BE USED TO THAT END. 3 Comroe Hing LLP By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of. Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton,NJ 08618 VS. Plaintiff Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 Identification No.: 25694 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 99-6227 CIVIL Defendants AFFIDAVIT PURSUANT TO RULE 3129.1 Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc., Plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following information concerning the real property located at 7B Tory Circle, a/k/a Units H D-20 6 HD-20-G, Laurel Hills North Condomininium I, Enola, Pennsylvania 17025: 1. Name and address of owner or Reputed Owner: Leroy K. Gordon and Karen E. Gordon 720 Sterling Circle Enola, PA 17025 2. Name and address of Defendants in the judgment: Date Service Code Leroy K. Gordon 720 I I1 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, 1 PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: Date Service Code Allfirst Bank 3607 Derry St. 611 3 Harrisburg, PA 17111 v. wame ana aaaress or Ene iast recoraea nolaer or every mortgage of record: Date Service Code Adam Wholesalers, Inc U ?3 3 1627 Ritner Highway Carlisle, PA 17013 Household Realty Corp. 25 Gateway Drive ` ?1l c 3 Suite 107 / o U J/ Mechanicsburg, PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: pate Service Code 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. jDate Service Code 2 Court of Common Pleas of I 3 Cumberland Co., Domestic GIi3 ?? Relations Div. 13 N. Hanover St. Carlisle, PA 17013 Court of Common Pleas of Cumberland Co., Domestic f I? r v 3 Relations Div. I IQ Courthouse One Courthouse Sq. Carlisle, PA 17013 Child Support Enforcement Agency 613 Ito 3 PO Box 320 Carlisle, PA 17013 Court of Common Pleas of Cumberland Co.,Domestic / Relations Div. 6 13 3 1627 Ritner Highway Carlisle, PA 17013 Condominium Association, Laurel Hills North Condo. 3 c/o Charlene Tallman 1150 Sterling Ct. Enola, PA 17025 Laurel Hills North Condo. = CG 6i 3 744 Wertzville Rd. 3 Enola, PA 17025 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 3 DATED: 3 G? l'sa n tY 4 < v !c C n t C cr •, I ?CI C ? d W O O S a O"?I N x Is ail : I+ ~ to ^ is g O z o c f D W n i, M F• i 0 0 7; ; n 03 f Of g LD . s v O n o O g o E m A N t I? a 0, B lv C CD C rT AE -4 T v F- m i 3 9>' a W O A b ? ( g m o n ? ? O ° a a' to r ?o i > 3 Sid, F p Is 1 G ?fI m x z CI t1 2 r L, e I o x y Nil/' i 1 "01aI 'M Q D_ , • r aM Y p / t O ZZ '.? k ?? • . .. e 3 e ... .... ... -. ASS 1 ' d ° py 3 ,a n c ot y K w V N N e :r O rr n 0 YOM z to M o m '° o go o p,? q -4 n -4 .. A p o N y y is 8 W ° P •C O M T m o W 'A 2 In N T Z N D O I I f3 O to r U z 0 6 _, a D191 t 8 ? fit ??39 P TAL EAVI E CERTIFICATE OF MAILI G MAY BE USED FOR DOMESTIC AND INTEA NA TIONAL MAIL, D ES NOT PROVIDE FOR INSURANCE-POSTMASTER Penied Flom COMROE HING LLF, F%2 rmlL 170 Market Stra Suite 1400 Philadetp 4 OM o"Co of oramaly "need addrelled la Allfirst Bank 3607 Derry St. Harrisburg, PA 17111 Allfirst(Cenlar) vs Gordon PS Form 3817, Mar. 1989 AII..!": ".' S!am;S or moral postage a;; post marg. Inquire of Postmaster lot current at. I? 0 P TA SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Racneed Flom COMROE HING LL 1 X00 Market 8 z w Suite 1400 Philadelphia, PA +9103- One Plan of oldInalY mad Wdrusad to: Adam Wholesalers, Inc. 1627 Ritner Highway Carlisle, PA 17013 Allfirst(CENLAR) vs Gordon Allen lot hate n Stamps at motor postage and post mark. IngYlre of Posima tat for currant too: J 10 •.a r V r ICI '?': PS Form 3817, Mar. 1989 Y Affix Ita Mrs in Stamps or motor pottage and post mark, Inquire of Foetmestor far current n. N.. tD O a v rA INTE aA F IMAY BE USED P Ft DOMESTIC AND RNATIONAL MAIL. OOFSINOjT(; PROVIDE FOa INSURANCE-POSTMASTER a Roce.Vvd Few COMROE HING LLB c ?, Suite 1400 an 0. 13• W.A one plate at grd.narY mad addrnled to Household Realty Corp. 25 Gateway Drive, Suite 107 Mechanicsburg, PA 17055 Allfirst(CE:ILAR) vs Gordon PS Form 3817, Mar. 1989 G 3 y V N Y b m ? r V 0 w t .. T N V 7d W rt A ti x I+ 7 w C7 n ? 00 Oc ro M N rt n O 4 n ,n iY (aa 0 0 orI 7 0 H M a rB s W N in °, I - o G of ? am 3 me m M, ?D J V 3 IS o05TAl SERVICE CERTIFICATE 0 I Am, too rare in stomps or AY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT motor postage and of os IOVIDE FOR INSURANCE-POSTMASTER Postmaster . for Indiiii,is r current Aacnv,d From'. COMROE HING LLP foe. 1700 Market Street w -ThWidelehia an 19103-3914 PH/, Do, pieta of oromary mail addrn,ad to 4 Laurel Hills North Condo I Do w`\ v 744 Wertzvill Rd Enola, PA 17025 Allfirst(CENLAR) vs Gordon PS Form 3817• Mar. 1989 Y 1:. 'i I=L 3 e = PS Form 3817• Mar. 1989 M : a Y R'w$xx $ai` POSTAL R I POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR OOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FDA INSURANCE-POSTMASTER Recoiled From: 0WAROE HING LLR 1700 Mcttket Street Suite 1400 r cr On, Piece of ordlnarY mail addra Oed to'. A` N C Condo Association, Laurel Hills Nprrth Condo. I c/o Charlene Tallman 1150 Sterling Ct. rnefGEIA vs Gordo! Enola, PA 17025 Allis fee nora A Stamps or motor posiapa and post mail. Inquire of Postmaster for current fa HIR C; v ?O vflaa Affix foe retain StAmPt or motor postage and post mark. Inquire of Postmaster lot current foe. MAY BE USED FOR DOMESTIC AND iNT[RNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER R 'J p ,caved From. COMROE RING LLP 17n^ R n__'- C. iee <- Suite •1400 a la, PA-1 DM Data of ordinary c? Child Su ent cc PO Box 320 Carlisle, PA 17013 Allfirst(CENLAR) vs Gordon .t e r t r' PS Form 3817, Mar. 1989 Comroe Hing LLP By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton,NJ 08618 VS. Plaintiff Leroy K. Gordon 720 Sterling Circle, Enola, PA 17025 Karen E. Gordon 720 Sterling Circle, Enola, PA 17025 Identification No.. 25b'9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 99-6227 CIVIL Defendants AFFIDAVIT PURSUANT TO RULE 3129.2 AND RETURN OF SERVICE PURSUANT TO PA R C P 405 OF NOTICE OF SALE David B. Comroe, Esq., Attorney for Plaintiff, Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. sets forth as of the date of the praecipe for the writ of execution was filed the following information concerning the real property located at to be sold at Sheriff's Sale on 09/06/2000. As required by PA R.C.F. 3129.2 (a) Notice of Sale has y.4 been given in the manner required by PA R.C.P. 3129.2 (c) on each of the persons or parties named at the addresses set forth below on the date and in the manner noted in the margin by the names of each and copies of each notice together with return receipts or proof of mailing are attached as Exhibits. The manner of service, as noted in the margin, utilizes the following codes: 1. Personal Service by the Sheriff or in accordance with Pennsylvania Rule of Civil Procedure 400.1. 2. Certified mail-return receipt attached 3. First Class Mail-Certificate 3817 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: June 8, 2000 , ( • Yz' f'' David B. Comroe Attorney for Plaintiff 6 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, Interest and costs due .and, Successor to Eastern Mortg NO. 99-6227 CIVILAB _ CIVIL ACTION - LAW fka First National Bank of Inc. c/o Cenlar Federal vc:a rlui 4ko a Vu., ucu wu, ..J v.,...av from Tinmy; G Karen _ orr1nn .mind, 7 Ster 770 Rtor lin lin g Circle Enola, RA 17075 g (71rrlo, F!nnlq PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Prernises: 7B Tory Circle, a/k/a Units ND-20 6 #D20-G, Laurel Hills North Condaminuim I, Enola. PA 17025 See legal description (2) You are also directed to attach the property of the defendant(s) not levied upon In the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been Issued; (b) the gamishee(s) islare enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) 11 property of the defendant(s) not levied upon an subject toallachmentisfoundinthepossessionofanyoneother than a named gamishee, you are directed to notify hinvher that he/she has been added as a garnishee and Is enjoined as above stated. Amount Due $139,172.44 Interest flnm 6?8/0(? to 916100 1 6.888 2 l D-97 Atty's Comm Atty Paid $121.92 Plaintiff Paid Date: June 14, 2000 REQUESTING PARTY: Name David B Conroe Fsa Address: 1700 Market St. Suite 1400 Philadelphia PA 19103 Aflorney for: Plaintiff Telephone: (215) 568-0400 Supreme Court ID No. 25694 L.L. Due Frothy. Other Costs Curtis R. Long Prothonotary, Civil Division by: />? a7 l 11 01 Deputy REAL ESTATE SALE 51.7 19 PN-7-0 the sheriff levied upon the defendants n interest in the real property situated in! Cumberland County, Pa., known and numbered as:,? o? a? ?C&jjd-40 f.'L-? and more fuiy uescribed on Exhibit "A" filed with cog this writ and by this reference incorporated herein. R1 0 e9. Hate: Bit- .t. ? ? •J ? l?? tiny THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Commonwealth of Pennsylvania, County of Dauphin) as James L. Clark being duly sworn according to law, deposes and says: That he is the Accounts Receivables Manager of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with Its principal office and place of business at 812 to 618 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT- NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and Stale aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 41h, 1854, and September 181h, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which Is securely attached hereto is exactly as printed and published in their regular dally and/or Sunday and Metro oditlonsAssuos which appeared on the 1st, 8th and 15th day(s) of August 2000. That neither he nor said Company Is Interested In the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and Is duly authorized and empowered to verify this statement on behalf of The Patrlot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and equently duly recorded in ubs adopted severally by the stockholders and board of directors of the said Company any the office for the Recording of Deeds In and for said County of Dauphin In Misc1ellaneBook "M", Volume 14, Page 317. / / PUBLICATION COPY Sworn to and subscribed bolos S A L E #57 NOIe" seal Terry L. RusNx, Notary Pudk Hunuxrtp, Deuonn county [.? Comnrssb Espies June 6, 2002 MenlDet, Pormsylvarm AsWtdtan 01 N011 30th day gfAugust 2000 A.D. commission expires Juno 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached horoto on the above stated dates $ 394.35 Probating same Notary Foe(s) $ 1.50 Total $ 395.85 Publisher's Receipt for Advertising Cost THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the some have boon duly paid. THE PATRIOT-NEWS CO. By .................................................................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAN JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 28, AUGUST 4, 11, 2000 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. >;{ AL ESTATE BAr.E NO. 67 Writ No. 1999.6227 Civil Allflret Bank. f/k/a First National Bank of Maryland VS. Leroy K. Gordon and Karen E. Gordon Atty.: David D. Control! DESCMVnON ALL THAT CERTAIN unit and the property known, named and Identi- fled in the Declaration referred to below as 'Laurel Hills North Condo. minium I', located in East Pennsb om Township. Cumberland County, Pemtsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condo- minlum Act. 68 Pa. C.S.A. @3101 el seq., by the recording In tire Office of the Recorder of Deeds of Cumberland County of a Declaration dated April 4, 1080, recorded it, tire office or the Recorder of Deeds of Cumberland County in Miscellaneous Ikxrk 362. page 001, as amended and restated. Icing and design:urd In such Drela- raunn. as antrndrd and Iv%latrd. as 'L Ro r M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this _-LLday of AUGUST. 2000 Notary 61 lathed garage being and designated in such Declaration as amended and restated, as Unit No. D•20.0, which " said Unit Is more fully described in the Amended and Restated Declam- lion, dated October 15, 1900, record- ed in the Office of the Recorder of Deeds of Cumberland County In Mis- cellaneous Book 388. page 483, First Amendment to Amended and Restat- ed Declanation. dated September 22. 1993, recorded in the Office of the Recorder of Deeds of Cumberland ` County in Miscellaneous Book 455. page 201, Second Amendment to Amended and Restated Declamuon, dated March 7. 1998, recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellane- ous Book 515, page 400, and Third Amendment to Amended and Re- stated Declamuon. dated Apn13.19M. recorded in the Office of the Recorder of Deeds of Cumberland County In Miscellaneous Book 517, page 217. Plats and Plans-Site Plan. recorded in the office of the Recorder of Deeds of Cumberland County in Plan Book 57, page 128, First Amendment to Plats and Plans-Site Plan. recorded in the Office of the Recorder of Deeds of Cumberland County In Plan Book 61, page 102, Second Amendment to Plats and Plans-Site Plan, dated Oc- tober 1991• recorded In the Office i of the Recorder of Deeds of Cumber- land County in Plan Book 60, page 135, Third Amendment to Plats and Plans-Site Plan, dated September 18, 1995. revised March 4. 1998. re- corded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 71, page 132, and Fourth Amendment to Plats and Plans-Site Plan. dated February 9, 1006. record• r ' ed In the Office of the Recorder of Ez Deeds of Cumberland County in Plan ` Daok 72, page 1. together with pro- portionate undivided Interest in to y Common Elements (as defined In w,a said Declaration, as amended and restated) of 4.32%. s00.14.0835.082• Tax Parcel r? 620. s :x y ecr's ...5fµ.. . Comroe Hing LLP Identification No.: 25694 By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton, NJ 08618 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff VS. Leroy K. Gordon 720 Sterling Circle Enola, PA 17025 Karen E. Gordon 720 Sterling Circle Enola, PA 17025 ACTION OF MORTGAGE FORECLOSURE Term No. 99-6227 CIVIL Defendants ...........................AMENDED................. ....... AFFIDAVIT PURSUANT TO RULE 3129.1 Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc., Plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following information concerning the real property located at 7B Tory Circle, a/k/a Units # D-20 & #D-20-G, Laurel Hills North Condomininium I, Enola, Pennsylvania 17025: 1. Name and address of owner or Reputed Owner: Leroy K. Gordon 720 Sterling Circle Enola, PA 17025 Karen E. Gordon 720 Serling Clircle Enola, PA 17025 2. Name and address of Defendants in the judgment: Date Service C?d? oy K. Gordon 720 1 rling Circle, Enola, r PA 17025 Karen E. on 720 Sterling le, Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: Date Servicp?Cod_g Allfirst Bank 6/13/00 3 3607 Derry St. Harrisburg, PA 1711 4. Name an a ress n r mortgage of record: "& =VCLY Date Service Code m Wholesalers, Inc. 6/13/00 3 7 Ritner Highway r lisle, PA 17013 Household Realty Corp 6/13/00 3 Gateway Dr, Ste 107 Mechanicsburg, Pa 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Date Service Code 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. I Date I Service Code 2 w Court of Common Pleas of 3 Cumberland Co. Domestic 6/13/00 Relations Div. 13 N. Hanover st. Carlisle, PA 17013 Court of Common Pleas of 3 Cumberland Co. Domestic Relations Div. Courthouse 6/13/00 One Courthouse Sq Carlisle, PA 17103 Child Support Enforcement Agency 3 PO Box 320 Carlisle, PA 17013 6/13/00 Court of Comm. Pleas Domestic Relation Div. 3 1627 Ritner Highway Carlisle, PA 17013 Condominium Assoc. Laurel 6/13/00 Hills N. Condo. I 3 c/o Charlene Tallman 1150 Sterling Ct., Enola, PA 17025 Laurel Hills N. Condo I 6/13/00 744 Wertzville Rd 3 Enola PA 17025 East Pennsboro Twp. J'Jokd 98 S. Enola Dr. 3 Enola, PA 17025 6/13/00 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa?C.S. Sectio 4904 relating to unsworn fals'fic,?tlion to authoritie?s? DATED: -7 G' Plaintiff 3 LAW OFFICES COMROE, IIING & LLP SUITE 1400 1700 MARKET STREET PHILADELPHIA. PENNSYLVANIA 19103.3914 (215)568.0400 FAX NUMBER (215) 568.5560 wwco hin`tom DAVID R. COMROE OLENN F. IIING ROBERT J. WILSON East Pennsboro Township 98 S. Enola Drive Enola, PA 17025 RE: Allfirst Bank et als vs. Leroy K. & Karen E. Gordon Docket No: 99-6227-Civil Property Address: 7B Tory Circle aka Units #D-20 & D-20-G Laurel Hills North Condo I NOTICE OF SALE OF REAL PROPERTY Dear Sir/Madam: Please be advised that the property and improvements, if any, as set forth above, will be sold by the Sheriff of CUMBERLAND County on September 6, 2000, at 10:00 AM. in the Office of the Sheriff of Cumberland County Courthouse or such other location as the Sheriff of Cumberland County Directs . This property and improvements, if any, is being sold pursuant to a Judgment entered in favor of Plaintiff and against Defendants in the Court of Common Pleas of CUMBERLAND County. The name of the owner, real owner and reputed owner of the aforesaid property is as set forth as the Defendants above. It has come to our attention that you might be a creditor to the Defendants named herein. Sheriffs Sale of the mortgage property could adversely affect your interest if you are, in fact, a junior creditor herein. A Schedule of Distribution will be filed by the sheriff on a date specified by the Sheriff no later than thirty (30) days after said sale, and a distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date said schedule. You should check with the Sheriffs office by calling 717-240-6390 to determine the actual date of the filing of the said schedule. ??Iy yours, David B. Comroe DBC/min Comroe Hing LLP Identification No.: 25694 By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. c/o Cenlar Federal Savings Bank 425 Phillips Boulevard Trenton, NJ 08618 vs. Plaintiff Leroy K. Gordon 720 Sterling Circle Enola, PA 17025 Karen E. Gordon 720 Sterling Circle Enola, PA 17025 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 99-6227 CIVIL AFFIDAVIT PURSUANT TO RULE 3129.2 AND RETURN OF SERVICE PURSUANT TO PA R.C.P. 405 OF NOTICE OF SALE David B. Comroe, Esq., Attorney for Plaintiff, Allfirst Bank, fka First National Bank of Maryland, successor to Eastern Mortgage Services, Inc. sets forth as of the date of the praecipe for the writ of execution was filed the following information concerning the real property located above to be sold at Sheriff's Sale on 09/06/2000. As required by PA R.C.P. 3129.2 (a) Notice of Sale has been given in the manner required 5 by PA R.C.P. 3129.2 (c) on each of the persona or parties named at the addresses set forth below on the date and in the manner noted in the margin by the names of each and copies of each notice together with return receipts or proof of mailing are attached as Exhibits. The manner of service, as noted in the margin, utilizes the following codes: 1. Personal Service by the Sheriff or in accordance with Pennsylvania Rule of Civil Procedure 400.1. 2. Certified mail-return receipt attached 3. First Class Mail-Certificate 3817 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. i understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: July 14, 2000 David 4??omroe Attorney for Plaintiff 6 a, -. ?. cry ?-. .. . cV ice