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HomeMy WebLinkAbout99-06422 S L)% . of Lg y; {D N? fib n # px r u, s Ff.X, r. t'd Y a y" t rn ? u .a c p u trtr ' 1 h 3?fje•. • t 1 ? d ?" ? 3bxa fyY? t . }3 i i4VP ? J Y / Kam 4> Y , J r i S Tx;. f ;4 H _. t s`: ?? n v it ? t t .+ u _ fAEg}5 . t.? L S { ik + a v h°l .' +r a nrs t l l .. 1 f 1113} +a a i C•. /1A V :, v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PNC BANK, NATIONAL ASSOCIATION, Plaintiff No. 9f: G va a. Cu,a -F,, Vs. JOSEPH P. ALEKA IN MORTGAGE FORECLOSURE Defendant NOTICE TO DEFEND TO THE ABOVE-NAMED DEFENDANT: You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this pleading and notice are served, by enterirg a written appearance personally or by attorney and filing in writing with the Court your defenses or objections 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 pleading or for any other claim or relief requested by our client. 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. Court Administrator 411 F1., Cumberland County Courthouse Carlisle, PA 17013 DELAFIELD, McGEE, JONES & KAUFFMAN By r t dele Kauffman, Esq. orney for Plaintiff Attorney I.D. No. 50692 300 S. Allen Street, Suite 300 State College, PA 16801 (814) 237-6278 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PNC BANK, NATIONAL ASSOCIATION, ) Plaintiff ) va. ) JOSEPH P. ALEXA ) 1 Defendant ) No. Q7. 4 V.2Z 6,&Cy r,4- IN MORTGAGE FORECLOSURE 1. The Plaintiff-Mortgagee, PNC Bank, National Association, is a corporation organized under the laws of the United States of America, having an office and place of business at 1631 South Atherton Street, State College, Centre County, Pennsylvania. 2. The Defendant-Mortgagor is Joseph P. Alexa, whose last known addresses was 74 Drexel Place, New Cumberland, Pennsylvania (17070). 3. At all times material to the Plaintiff's cause of action, the Defendant has been the owner of a tract of land and the building thereon erected, herein called "land", located in the Township of Lower Allen, County of Cumberland and State of Pennsylvania. 4. The land which is the subject of this action is described as follows: ALL that certain lot or piece of ground with the building and improvements thereon, situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, being more fully described on that certain As Built Plan of Foxlea Residential Community Village One, Phase I, Lower Allen Township, Cumberland County, Pennsylvania, as prepared by Gerrit J. Betz Associates, Inc., Engineers & Surveyors, dated October 6, 1976, and last revised March 19, 1977, as recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, on March 23, 1977, in Plan Book 26, page 50, which Plan is herein incorporated by reference as is hereto attached as unit number 74 in Building "L" consisting of 5587 square feet and described on said As Built Plan by metes and bounds which description is likewise herein incorporated by reference. BEING the same premises which Keith M. Bailey and Martha J. Bailey, his wife, by their deed dated July 27, 1987, and recorded July 30, 1987, in Cumberland County Deed Book V32, Page 457, granted and conveyed unto Joseph P. Alexa. TOGETHER WITH ALL the benefits and rights of easement and enjoyment as excepted and reserved by Foxlea Nominee Corp. and Foxlea Enterprises, Inc. in its Deed to Cumberland County National Bank and Trust Company dated April 21, 1975 and duly recorded in the office of the Recorder of Deeds in and for the County of Cumberland in Deed Book A-26, Page 303. UNDER AND SUBJECT to the covenants, restrictions, easements, charges, liens, terms, rights, agreements, conditions, exceptions, reservations and exclusions as contained and more fully set forth in the Trust Deed between Foxlea Nominee Corp. and Cumberland County National Bank and Trust Company dated November 21, 1973, and recorded in the office of the Recorder of Deeds in and for the County of Cumberland in Deed book K-25, Page 912, as amended by Amendment thereto dated August 26, 1974 and duly recorded in the Office aforesaid in Deed Book A-26, Page 303, and any amendments to the foregoing as may be made from time to time. t UNDER AND SUBJECT to easements, rights granted to public utilities and other rights, covenants and restrictions of record. 5. On or about May 9, 1994, in consideration of the loan of $24,681.31, made by Plaintiff to the Defendant, the Defendant executed and delivered to Plaintiff a Direct Installment Loan Note secured by a Mortgage on the land obligating Defendant to pay Plaintiff $24,681.31 with payment of $289.78 to be made monthly until this loan, additional advances, interest and other charges covenanted were paid in full, with interest as provided therein. The Mortgage is recorded in Cumberland County Mortgage Book 1213, at page 99. A copy of this Mortgage is set forth as Exhibit "A" 6. The Defendant is in default with respect to the said Mortgage because of his failure to make the payments due for the months of March, April, May, June, July, August and September, 1999. 7. Under the terms of the loan, Defendant is obligated to Plaintiff as follows: Unpaid Principal Balance $15,387.76 Interest through October 7, 1999 747.55 Late Charge 70.00 Real Debt $16,205.31 ? A with coats to be added. 8. The Defendant is the present owner of the land. 9. Plaintiff has complied with the requirements of Act No. 6 of January 30, 1974, by forwarding a notice of intention to foreclose to Defendant on June 2, 1999, a copy of which is attached hereto as Exhibit "B". 10. Plaintiff has complied with the requirements of Act 91 of 1984 by forwarding the notice attached hereto as Exhibit "C" and Defendant has been denied Homeowners Emergency Mortgage Assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, Plaintiff requests the Court to enter judgment of mortgage foreclosure against the mortgaged property for the amount set forth above, together with interest thereon, all other amounts advanced by Plaintiff and costs of suit. DELAFIELD, McGEE, JONES & KAUFFMAN By Rosadel Kauffman, Esq. Attorn y for Plaintiff Attorney I.D. No. 50692 300 S. Allen St., Suite 300 State College, PA 16801 (814) 237-6278 Dated: /D C3940510.CQH Page 1 MORTGAGE (0o"d-End) ?i?ZSZa-? THIS MORTGAGE Isnudeon gay 9.19 94TheMortyaf;;rl9 JOSIP9 P A11IA H there is more than one, the wad Vorla&W heroin rulers to each and ell of them The Mortgagee is PNC Dank, National Association Theword'Borroweewmeane JOCIP11 P AL6XA 189 , H there Is more than one, the word'Borrowef' heraln refers to each and all of them. Borrower owaMortitagmOesumof Twenty Your Thousand Six Hundred Lighty One And 31/100 Dollars (U.S. i 24, 681.31). TMs debt to evhderwsd by Dwrowees written obl illation (referred to herein as Ilm' Wd7, dated May 9, 1994 . This MortMe secures to Mortgagee: (a) the repayment or the debt "danced by the Note, with Interest and other changes as provided Ihere In: (b) the paymenlof all other sums, with Interest thereon, advanced hereunder "he paymaridtaaes,ssseunw'As6 malnterwlce, charges, Insurance premiums and Cats Incurred to protect the socurity of" Mortgage; (c) the payment of all of Mortgac Wtoosts of coUeclkxn. Induding, costs of suit and, If permitted bylaw, rwtonabb Nlornays' lest and el?entas. Iltuh k f bed or other adbn IsU)en to cdlacl the west owing r bprdact De tecur{yol this Moregag0. (d) payyment of any refinerxJrlg, tutHlitutbrl, netenalorl, medlllulbM1 and/or nnawal d em of said kldetrladrlrs. interest, Chagas, costs and n?penses; and (e) Its performencoolMorlgagsraaro/r[torrowarawyenants.roagrmmentsunderWs rend theNole;(QUarePayytmnenlollnedablevidencedbyany nderepemlenlwh vanrefranoadhyytheNoU,folheeslenllhMwthdedlsowdto agesudhusnolDoenpald•rorUlspurpote.Mortgegwdoa hereby pant and oomey to flbrtgagee the ldbwkrg described proprly, together with all knprovementt now a henatler enecled, arty all easements, r ? and •pptstsrlarlces thereon bated et and lanwn ax 74 DRRXEL PLACE NNW CUHDIRLAND PA 170702205 M®)tALRO LOWER ALLEN 7CWtYSHIP Reoording Date of Original Deed Jul. 30, 1987 Dead Book Nualbor V32 Pago Number 157 Tax Parcel No. 13-25-8-2A-1,12-74-1 The word'Pioporte herein shall mean all of the focoeoing mortgaged property. To have and to hold the Properly u iolhe Mortgagee, ks tuccessora and aulgis, forever. PrWdd, however, that It Mortgagw and/w Donower shell payto Mortgagee the told dobt (ntoresf, and ell other wms, and pertwm stl covenants and agrmmwas secured hweby,lhen lhls Mortgage and the astatsconwird CeweMs. M or promises and agrees es lonowt: 1. Mortgagor it malntaln fie Property In good order and repair. 2. Mwtgalifor *is comply with all hew retpectIng the ownership and/or use of the 3. HthePrW topartof¦cordwnWumorpbmeduNldevelopmW,MortgagwwProperty. igcompywith allby-wra,regulatios•ndrestrictions o(reord. e. Morta pay and/or perform all obligations uroer wV mortgage, lion. or swirky agreement which has priority over this Mortgage 5. Mortpptwlli pay or cause to be paid all Uses andolherchurles assessed or levied on the PropMywhen due ar4 upon Barth request.wildeliver to Bands receipts showing the payment of such charges. 5. Morlgaga Mtl pay for and maintain Insurance cmwags Wind loss of or damage to the Property In such form and amount as MwIWWe nay masonaby require, uMll the We Is paid and the Mortgage Is satisfied Moftageeshall be named os additional Insured rd bss•paym/morlW We unders standard mortgagee clause Included In such pdkles. Morttegor shall deliver to goe a copy of the insurance polity, renewals. and evidrwe of payment uponMortpgedsrequest. Mortgagor gives Martim"therl htto sign MorlgaWsname onanycheckor draft from onInsurance comparly.ThisIslimited to& It or draft In pa of returned premiums or banal" under Insurance covering the Property. This means that Mortgagor appow" Mrlgegoo as altomey'lnfad forwith fug power to endorse chocks or drafts urdr this section 7. If Mortalgr lal s b Pedorm rry duty or obligation required by these covenants, Mortgages may, at its sole option, advance such turns ask deems and under Ihie Mortgage. ggwtgagorapmtb repay Mortgages such smountswith Interest and/r Pr IMreor? upon dertaro, and egress tha'a uch amourAs slug be Wiled b De amauns seeud M W s Mwtg?? and des under the We. nlecesuryb PnoteN Ihe tllonal sums advanced WII be at the rate provided for In the Note. on add 8. Arry Interest payeda b Mortgages after ¦ (udgrtent Is entered Proparty pperty alter gluing MaAWgor pier notice of arty such Impectioa antrles apes and Inspsttions of Oe bb rtaks ressona 10. Mortgagor wig not sell, base. lnnsfr ownrsNp In, r enter into an InWYnerlt ale contest for the ub of all or any pert of the Ropwy. bwlwmthe PropeAyor this Moftne Is transferred. epnomises. apeomenttare rights In Uds Mortgage shall be binding upon and bens' anyoro or 9. Mortgagee may II more than one Mortgagor d{nt this Mortgage, each and all of Uses an Iwund kdMdualy and sogethor. [aororn.NroquesfedMMortgagee.MMgagwwlll paybMortgages sash month namouMSgwlto]/120l lieywyIsyas andnutunanit (including ewedominlumareIlywrounitnsessmenU,Ilor?y)M"c' maybegl?onprbrityovrthisMOrlBagepplIus,l/l20llheyesdypremium forpropertyNwranceon Ns rights in IM Property IheRooppoorrlIyy. Mortgagor shall not have to male these paymeNa to Mortgages to Ile eslenl that ktorlgsgor maker them b the holder of • priormortgage. I1. Th Defallt Mortgagor will be in delwit udder Ihia MMgaag¢se (a) N then is a default uder the aide; (b) H Morlpgw breaks arty promW made In this dips; (d) H arty editor erd'dor tries to Uks lta Roperty tryI1s•Wg,aI proce ss; (e) Ilarry Modgagw fibs W nkruplcy ortl anyone tiles an Mortgage; (c) N erry Mortg ImdunUry DartkruptgragalM enOr fAorlgagor: (01f 7, Ibuy is 1'ded r made egaimtarty fAOrtt+gw orthe Properly; (v If any Mortgagor has made any lake statement In W s Mortgage; or (h) h the Prope4 destroyed, r selsd or condemned by IederN. state r but govarnnterd. be.aaggerUnless alorlgagae'e Rartlad prW +Wted byla1 M I In defwh Inter this Montgege, Mwigsge• may, N its option, eriw notice required bylaw. declers due are payable Ihs entice unpaid betance of tits sums which ere tawr•d by W c Mortgage and owing upon the Ag7sarrmrg. N Mortgages to declares such eNlro belenoe due and ppryryode. Mortgagee may tske ptxsetsbn of the property, tdbcl arty and dl reels. spdY said rents to the Indebtedness teers•d by this MorUasa.lonntosa the Morltaea or tike other aabn upon tie klortraw as permined r Prwlded by Iva to celled the Wlerlee owIng.lla mortgage lonelave arm er by or WITNESS the sknkng of this Mortsrga on the date act forth abave. Into ndng b be legacy bound orenlwceadfiyof the 3t'?yr1-+---1 -? Witness Mwttsgor Witness Mortmor M coo 00000110 few. MIC Ulli61T ^n° C3940510.CQH Page 2 DOMMONWFAITHOfKNNMVANIA ) s9: couNTY OF CL"BEAT.A1.D ) On this 9th dry of MM 19 94 . bacon the talumlped oftr (who oarUflrs M told* It not an ortlor or director of known to nw Nd Urr same to WRrdu Wheied, I IwKwWw sal rrer hrd rd oMtW "W. IktsW t'ad Slsnturo.?jllX1.J,. - Nb uRm0?aoe0.a? N7PARY ZMLIC *Ckffntxlon []?tazAM;2,1909 ThM- - Murribic.PornsyViniaAftoosionolNotarm AFFIDAVIT OF SUBSCRWN0 WrTH f (Ob not saw N Matppor(t) OClurowl*d d Ur MortPp. AMdwh mutt be taken In corny aA1re NVP" is boated.) Before nr, a notary fx b (who c" m Ual hm/ths Is not an officer or dhdw of _ ). praanaly appeared , Ur subri6Y,e witness to the WINn Mortgam wfw bMni duly own according to law, depose and mays Urt tr/she was penaWy prrrd d do execution of sold Morttaaa, saw the wMln named 4or%pcur(s) -- and sips as hk./hor/trek ad and deed, and delkw sold Mort asafor thepurposes0welnsdfonkand"Ovrwneofthkdepor MH(ixsdUuretoastulxaiDlrrgwiNeubddrporwrCsownproperhadwwkke r 8aornto andsubsalbdbefore mathis day of ,19_. CtMICATE DF RENDENCE Karns R Schaefer 1. . do hereby osnly Ural Mortgagee's pactsa roslderw k PNC Bank. NA Main & Harket Ste Mcchmicsbuxg Pa 17055 /i Lh LUa COMMONYVEiLLTHOFPEfNSYIVANIA ADW for ) SS CDUNTYOF ) RECORDEDantMa dayaf .19-.InUnOKino(OrRocwdwo(DedslnrdforsaWOouny,InMMptteBook Volume , pap WITNESS nW hw4 mW the seal of uld oMos Ua day and year sl rasld C ig ??8a? ? Consumer Loan Center 2 730 Libet ty AN enue 11imbutgh, PA 15222 PNCBA1NK June 2, 1999 Joseph P. Alexa 74 Drexel P!acc New Cumberland, PA 17070 MQt gage Loan Number: 040.01-008001781913 Mortgage Note Date: May 9, 1994 Mortgage Premises: 74 Drexel Place, New Cumberland, PA 17070 SENT BY CERTIFIED MAIL RETURN RECEIPT REQUESTED NOTICE OF INTENTION TO FORECLOSURE MORTGAGE The MORTGAGE held by PNC Bank, National Association (hereinafter we, us, or ours) on the property located at 74 Drexel Place, New Cumberland, PA 170701S IN SERIOUS DEFAULT because you have not made the monthly payments in the amounts of $289.78 for the months of March 1999 thru June 1999. Late charges and other charges have been accrued to the date of this letter in the amount of $30.00. The total amount now required to cure this default or, in other words, get caught up in your payments is $1,189.12. You may cure this default within THIRTY (30) days of the date of this letter, by paying us the above amount of $1,189.12 plus any additional monthly payments and late charges which may fall due during the period. Such payment must be made either by cash, cashier's check, ccrtified check or money order, and made at Centralized Collections, Consumer Loan Center, 2730 Liberty Avenue, Pittsburgh, PA 15222. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made with THIRTY (30) DAYS, we intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgaged debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings arc started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within thirty day period and foreclosure proceeding have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payment plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that a Sheriffs sale could be held would be approximately December 1999. A notice of the date of the Sheriffs sale will be sent to you before lire sale. Of course, that amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (412) 762-8055. This payment must be in cash, cashier's check, ccrtified check or money order and made payable to us at the address stated above. EXHIBIT "0" Consumer loan Center 2790 Liberty Avenue Pindmrgh, PA 15222 PNCBANK PAGE 2 OF 2 You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU 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. (YOU MAY HAVE THE RIGHT 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 PRIOR TO OR AT THE SALE; AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Very truly yours, Ron Fudge PNC Bank, National Association cc: regular mail Consumer Loan Center 2730 LibertyArrnue hitslxugh, PA 15222 PNCBAN K June 2, 1999 Joseph P. Alexa 74 Drexel Place New Cumberland, PA 17070 RE: Account # 040-01-008001781913 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowners Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information, call the Pennsylvania Housing Finance Agency at 1-800-342.2397. La notification en adjunto es de suma importancia, puez afecta su dcrecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamcme Ilamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos at numero mcncionada arriba. Puedes ser clegible pare un prestamo per el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cunt puede salvar su casa de la perdida del derecho a redimir su hipotcea. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Ilomeownces Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time, you roust arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work our a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next (30) days. EXHIBIT "C" Consumer Ilan Center 27301.ibetty Avenue Pitubutxh, R% 15222 PNCBANK PAGE 2 OF 3 If attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this Notice, no further proceeding In mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address, and telephone number of our representative is: Ron Fudge PNC Bank, National Association 2730 Liberty Avenue, 2nd Floor Pittsburgh, Pennsylvania 15222 (412) 762-8055 The names and addresses of the designated consumer credit counseling agencies arc shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is S1,189.12, that sum includes the following: March 1999 thru June 1999 51,159.12 Late Charges 530.00 Total $1,189.12 Your mortgage is also in default for the following reasons: If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for fmancial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must rill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked within thirty (30) days of your face-to-face meeting. It is extremely important that you frle your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105 with telephone number of (717) 780-3800 or 1.800-342-2397 (toll free number). Persons with impaired hearing can call 1.800-342.2397. • Consumer Loan Center ' 2730 liberty Avenue 1111sburgh. PA 15222 PNC ANK PAGE 3 OF 3 In addition, you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclosure". You must read both notices since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, Ron Fudge PNC Bank, National Association (412) 762-8055 Enclosure a i a KJ G A 7U 7V fill b '4? viS N to ` m ]¢p. d C C JW y iA{? ri .15 ?'•PSLY$y ? y E r, 5 14 1 ?-- mill Y 7A( M ?.7 M try f? r _ u` U S SE _.__..._?_???• j o U m 3 ? a € m IL a K K a co 6 •- N M V N m N co m O N ^ 8 LL ? ?J y a new alOpitlnnnow in _t COMMONWEALTH OF PENNSYLVANIA ) SS COUNTY OF ALLEGHENY ) Michael J. Emerling states that he is Consumer Loan Officer of PNC Bank, National Association, and that he is authorized to make this affidavit and verifies that the statements made in the foregoing Complaint are true and correct. He understands that false statements herein are made subject to the penalties of 18 Pa.C.S. 54904, relating to unsworn falsification to authorities. Michael J. Em rl ng Consumer Loan icer Date: A)-/-5---/9-f1/ y ? rl d ? ? c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PNC BANK, NATIONAL ASSOCIATION, ) Plaintiff ) VS. ) JOSEPH P. ALEXA ) Defendant ) No. 99-6422 Civil Term IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly mark your docket in the above-captioned action "discontinued." Date: // DELAFIELD, McGEE, JONES & KAUFFMAN, L.L.P. By Ros3?dele Kauffman, Esq. Attorney for Plaintiff Attorney I.D. No. 50692 300 S. Allen Street, Suite 300 State College, PA 16801-4841 (814) 237-6278 n I1 o rn c? SHERIFF'S RETURN - REGULAR CASE NO: 1999-06422 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC BANK NATIONAL ASSOCIATION VS. ALEXA JOSEPH P CHRISTOPHER EVANS Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ALEXA JOSEPH P the defendant, at 19:20 HOURS, on the 22nd day of October , 1999 at 74 DREXEL PLACE NEW CUMBELAND, PA 17070 CUMBERLAND County, Pennsylvania, by handing to JOSEPH P. ALEZA 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 10.54 Affidavit .00 Surcharge 8.00 K. Tnomas i ADO/AF?ELDJ MCGEE, JONES by , -fL 11?-, Sworn and subscribed to before me cc, - day of kP""u-Qs this d 19A.D. ?.,,.. 61. ?lueYaCI?6lTdll??