HomeMy WebLinkAbout99-06856v
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1, EDERNIAN AND PI IELAN
By: PRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO, 12148
TWO PENN CL'NTER PLAZA, SUITE 900
i'lill.:\DHLPFII:1, 1':1 19102
elf >G3-7000
CI'T'ICORP MORTGAGE, INC.
15851 CLAYTON ROAD
BALLWIN, NIO 63011
Plaintiff
ARTHUR A. UNANGST
5.105 OXFORD DRIVE4
NIECIIANICSBURG, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OP COMMON PLEAS
CIVIL DIVISION
TERM
NO. Z?g5& `f
CUMBERLAND COUNTY
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
PLEASE HE ADVISED .I'BAT 77IIS FIRM IS,, DEBT COLLE000R1%11 DTI- YNG TO OI.I.ECI'., UEIt'1'. ,\N,
'
INFOR]TATION REUMUD 1% ILL HE ISED FOR l IIAY' PGRPOSI:. IP,YID ?A\'1? PRE IM: SIA' It E B,'ED N
DISCHARGE IN BANERIT1:CY AND TInS DEOT R'.,S S'O'1' RI?,\PEIR\IE:U,'1'1115 CORRESPOSIR'.AC7i ISM I• AND
NI 101 n.D oT BE CONSI.IWED'r0 BE AN ATTE.NB''r TO COLLECrA DEIn'IIU'r ONLY P:SI+ORCE?IIiN'I'OP.\
LIEN AGAINST PROPERTY.
You have been sued in Court. If roil wish to defend against the claims set forth in the following
pages, yon mnst take action within hycnty (20) days after this 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 tail to
do so the case may proceed ,yithout you and ajudgmcnt may be entered against you by the court
without further notice for an}• money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. Yon 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
I LAVE A LAWYER OR CANNOT AFFORD ONE, GO I'D OR TELEPT ZONE THE OFFICE
SET FORTH BELOW TO FIND OUTWI ERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Plaintiff is
CITICORP MORTGAGE. INC.
15851 CLAYTON ROAD
BALLWIN, MO 63011
2. The nannc(s) and last known address(es) of the Delcndant(s) are:
ARTHUR A. UNANGST
5405 OXFORD DRIVE 4
NIECHAMCSBURG, PA 17055
mho is/are the mortgagor(s)and real owner(s) of the property hereinafter described.
3. On 9/17/97 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to EASTERN SAVINGS BANE, FSB which mortgage is recorded
in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1406,
Page 512. By Assignment of Mortgage dated 9/17/97 the mortgage %%as assigned to
PLAINTIFF which Assignment is recorded in Assignment of illortgage Book No. 557,
Page 1140.
4. The premises subject to said mortgage is described as attached.
The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 7/1/99 and each month thereafter arc due and unpaid, and by the terms of
said mortgage, upou failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith. A cope of such notice is attached as Exhibit "A."
6. The following amounts are due on the mortgage:
Principal Balance $67,424.69
Interest 2,155.05
6/1/99 through II/1/99
(Per Diem 514.09)
Attorney's Pees 3,371.00
Cumulative Late Charges 182.60
9/17/97 to 11/1/99
Cost of Suit and Title Search 550.00
Subtotal 73,683.34
Escrow
Credit 0.00
Deficit 132.43
Subtotal 132.43
TOTAL 573,815.77
7. Tile attorney's fees set forth above are in conformity with the Nfortgage documents and
PennsvIvania Law, and will be collected in the event of a third party purchaser at
Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. y 1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
9. This action does not come under Act 91 of 1983 because the mortgaged premises is not the
principal residence of the defendant(s).
10. Pursuant to the Pair Debt Collection Practices Act, 15 U.S.C. § 1692 ct seq.
(1977), Defendant(s) may dispute the validity of the debt or any portion thereof.
If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading,
Counsel for Plaintiff will obtain and provide Defendant(s) with written
verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if
requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff
will send Defendant(s) the name and address of the original creditor if different
from above.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
S73,8 15.77, together with interest from 1 I/I99 at the rate of S 14.09 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged properb.
/s/ Prank Palen»an
PRANK FEDERMAN. ESQUIRE
Attorney for Plaintiff
09/09/99
ARTHUR A UNANGST
5405 OXFORD DR 4
MECHANICSBURG PA 17055-5439
RE: Citicorp Loan #: 7080058806
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
_.._? __ an c notice that the mortgage on your home is in
default, and the lender intends to foreclose. Specific information
about the nature of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to
help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take
this Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling
Agencies serving your County are listed at the end of this Notice. if
you have any questions, you may call the Pennsylvania Housing Finance
Agency toll free at 1-800-342-2397. (Persons with impaired hearing can
call (717)780-1869).
This Notice contains important legal information. If you have any
questions, representatives at the Consumer Credit Counseling Agency
may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help
you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO
DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LL-1ANDO
ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL
PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM"
EL CUAL PUEDE SALVAR SU CASA DE LA PEP.DIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
t:A
.r :.... .. y ,. ' !? ;i???i-mr .•? ?.v?.fi:cdt.'?'t.:!?' ??`M ,. Y.:.. ^'t. q tFr,, f, ??? :11 m ?? 7 ?11T??'2r:.
09/09/99
ARTHUR A UNANGST
4 COURTLAND ROAD
CAMP HILL PA 17011
RE: Citicorp Loan 4: 7080058806
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in
default, and the lender intends to foreclose. Specific information
about the nature of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to
help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER. CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take
this Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling
Agencies serving your County are listed at the end of this Notice. If
you have any questions, you may call the Pennsylvania Housing Finance
Agency toll free at 1-800-342-2397. (Persons with impaired hearing can
call (717)780-1869).
This Notice contains important legal information. If you have any
questions, representatives at the Consumer Credit Counseling Agency
may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help
you find a lawyer.
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 IN-0EDITAMENTE LLAMANDO
ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL
PROGRAMA LLA14ADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM"
EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
Page Two
09/09/99
7080058806
HOMEOWNER'S NAME(S) :
PROPERTY ADDRESS
LOAN ^T. NO.:
V:.w_:.rw ..::'UER:
CURRENT LENDER/SERVICER:
HO:"EOniiER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAXI 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 BEING ABLE TO PAY '.OUR
MORTGAGE PAYMENTS, AND
' IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENITSYLVANIA HOUSING FINANCE AGENCY.
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 one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING
MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGEE UP TO
DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
EXNlICTA .4
Arthur A Unangst
4 Courtland Road
CAMP H111,2A 17011
7090058906
Eastern Savings Bank
Citicorp Mortgage, Inc. is providing this notice
as lender or servicing agent for the lender.
na..J U[SlL1'(?T?S.. SLG:'.:P19 _'A [`f_S^_WTU\F
Page Three
09/09/99
7080058806
CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the
consumer credit counseling agencies listed at the end of this notice,
the lender may NOT take action against you for thirty (30) days after
the date of this meeting. The names, addresses and telephone numbers
of designated consumer credit counseling agencies for the county in
which the property is located are set forth at the end of this Notice.
it is only necessary to schedule one face-to-face meeting. Advise
your lender immediately of your intentions.
"-'"--'---"'- - -.. -'?E ASSISTANCE-'lour mortgage is in default for
the reasons set forth later in this Notice (see following pages for
specific information about the nature of your default). If you have
tried and are unable to resolve this problem with the lender, 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 at the end of this Notice. 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. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it
receives your application. During that time, no foreclosure
proceeding 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 its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR !NFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT. (If you have filed bankruptcy you can still apply for
Emergency Mortgage Assistance.)
EVO'T FK
Page Four
09/09/99
7080058806
HOW TO CURE YOUR. MORTGAGE DEFAULT(Bring it up to date).
NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your
property located at: 4 Courtland Road„ Camp Hill, PA
1:'C11 IS SERIOUSLY IN DEFAULT because YOU
HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
07/01/99 thru 09/01/99 3 9 $1,035.07/month
2 ri) $45.65/late charge/month $3,196.51
Previous late charge(s) $0.00
TOTAL AMOUNT PAST DUE: $3,196.51
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 LENDER, WHICH IS $3,196.51, PLUS ANY MORTGAGE PAYMENTS AND LATE
CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments
must be made either by cashier's check, certified check or money order
made payable and sent to:
Citicorp Mortgage, Inc.
PO Box 8003
South Hackensack, NJ 07606-8003
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 lender intends to
exercise 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 lender also intends to instruct its
attorneys to start legal action to foreclose 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 lender refers
your case to its attorneys, but you cure the delinquency before the
lender 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
Exi IQI ,,
Page Five
09/09/99
7080058806
against you, you will have to pay all reasonable attorney's faes
actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default
.'.. <'•:^ t'•e 'r>*RTy (30l DAB ceriod. you 1411 not Le recurred to pay
OTHER LENDER REMEDIES-The lender may also sue you personally for the
unpaid principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR. TO S'r.ERIFF'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 then past due, plus
any late or other charges then due, reasonable attorney's fees and
costs connected with the foreclosure sale and any other costs
connected with the Sheriff's Sale as specified in writing by the
lender and by performing any other requirements under the mortgage.
Curing your default in the manner set forth in this notice will
restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the
earliest date that such a Sheriff's Sale of the mortgaged property
could be held would be approximately six (6) months from the date of
this Notice. A notice of the actual date of the Sheriff's Sale will
be sent to you before the sule. 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 lender.
HOW TO CONTACT THE LENDER
Name of Lender:
Address:
Phone Number:
Fax Number:
Contact Person:
Citicorp Mortgage, Inc
15851 Clayton Road
Ballwin, MO 63011
1-800-723-7906•
1-314-256-5461
Kevin Leucanen
Calls are randoml;• monitored and recorded to ensure quality service.
? ?--? i ) t ! rte!
171
Page Six
09/09/99
7080058806
EFFECT OF SHERIFF'S SALE-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 Sheriff's Sale,
a lawsuit to remove you and your furnishings and other belongings
could be started by the lender at any time.
ASSUMPTION OF MORTGAGE-Please refer to your original loan documents to
determine whether or not you may sell or transfer your home 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 of the
mortgage are satisfied. You may also call the 1-800 Number above to
find out whether your loan is assumable.
YOU (JAY 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 HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
* TO HAVE T=E MORTGAGE RESTORED TO THE SAME POSITION DO INOT F NO DDEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, 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 LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Under IRS regulation, we must report any foreclosure to the IRS
on form 1099-A. The foreclosure ma}- result in income tax
consequences to you. Consult the IRS or your tax advisor for
further information.
Enclosure: Consumer Credit Counseling Agencies, including those for
your county.
99090900000098
Eye? 1?? ° 1k
Pennsylvania Housing Finance Agency
Homeowner's Emergency Mortgage Assistance Program
Consumer Credit Counseling Agencies
(Rev. 5199)
C=1ON COLN=
Lyc?r_i.g-r;p ;;ter Cau:•_,? CCCS of Yorheas;er_ R%,
Col:Lmission r or Cac=iuni:y Ac=oa (Si =?) 1631 S Ather -on Sc
2138 Lincoln Scee: Suite !GO
P. 0. Box 1329 State College, PA. 1620 !
W lllian:stor ?A _..o3 State College,
(570) 326i-156-. -A:: (811) 238.3663
F.*-Y (570) 322.2197
CCCS of Yor_heastem ?A
201 Bas's, st-e:
Wii13.^s?r P.7, 1..C3
(5 i 0) 32d-662-
FAX (570)3_3.4626
COLA?d3L4 COL?-If
CCCS of yor_^eavara ?ennsv(-:aria
1+C0 A:-Anran =secs:ve ?arx
31 W. ?(a:4a: Sc: °e: a u :e 1
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PO 11_-
Cla:'ss Su?ir ?-k 1?4--
Wlues-3a_:_. ?.4 ! ST02 (5.0) 52.•3163 or (3CO) 9'2-253--
(570) 321-7837 o `.500) 922•3-=3. FAX -10)5 =.9134,913 -
FAX(570) 3:1.1.85
Cacsaissioc on Ecacoc[a 0?corsair/ of Lu=er_e Coua-+
163 Aa:ber Lana
Wilkes-Ba.:_, ?A 1370-
(5,0)3264510 or (SOO) 322-0359
F.4C (5 i O1 329-1665--CAL L BEF OR - A=G
(570) 355994 ^ a6 -LTON
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F.,,:( (570) 455.5631--CAL-L BEFORE
(570) 336.4090 TT"V+---kN [OC%
Booker T. Washiag-•on Center
1710 FuBard Sr:--:
Ere, PA 16503
(814) 453.574
FA:( (814) 453-5.49
John F. Kdnnedy Center, L=-
2021 East 220&1 Scree:
Ere, PA 16510
(814) 3984400
F.A:( (814) 396.1243
CCCS of western ?ensylvan3, Inc
2000 Litgiesrw . -lad
Hzr.:sbu-;. PA 17102
(71.) 541.1.57
Urban Uagse of ?[ecaFaliu-a F3risbu_;
N. Eta SLl:et
F.ar :sbu g, PA 1'101
(71.)2_34-592_5
FAX (717)234.9453
CR4.WFO11D COLNTY
Greater Ere Coln==:=%Ca"-
:'tee-18 West St: Sc^_ec
E e, PA 16501
(81:4) 359-1581
F aL (814) 456-0151
Shena go'iaLey Urban Leagse. L^.c
601 Indiana Aveane
Farrell- PA 16121
(413) 981-5310
CL'IeIDERL1.r-D COU' iTY
F3anGa1 Counseling Services of F=2?"=
31 West 3rd SL-eec
Waynesboro, PA 1-1263
(717)762.3295
YWCA of Carlisle
301 G SL-ee:
Carlisle, PA 17013
(717) 243-3813
F4:( (717) 731.9u9
Co?.unity Aeon Coca of ti:e Ca?ital IRZg:on
1514 Oer:7 Sreec
Fin..-'sbu3, P?. 17104
(717) 232•3757
F.kx( 1,)'234.2_22'
.k&,= Counr/ Fousirg Au".or.-:
134-143 Carlisle S
Ce--ySbur3, PA 17, 325
(717) 334-1519
FAX (717) 334-8325
PENNSYLVANIA SULLEMN, VOL 29. NO. M. NNE 5, 1999
EXHIBIT -A"
ALL TBAT CIR'rA2N place or parcel of land with the buildings and imprwement¦ thereon
erected, situate in LOwMt ALLEN TOWN8917, Cumberland County, Pannsyl.aaia, and
described according to survey mada oscember 11, 1974, by Hichaol C. C-Angelo,
]teglstered surveyor, and bounded and described as follows,
DEOINNING at a pipe actuated on the northeasterly side of Courtland Rand (fifty 1301
fast wide), which pipe is an a course North twonty-four (24) degrees Fifteen (15)
ninute¦ thirty (30) seconds west and measured ninety-five and no ona-hundredth.
(95.00) feet fr® the northwesterly aide of Cumberland Road (fifty (50) feet wide))
thence from said baginninq point by the northeasterly side of Courtlaad Noad,• Narth
twenty-four (24) degrees fifteen (15) minutes thirty (30) seconds west, At diatmnca of
sixty-four and ninety-sewn ona-hundredth. (64.97) feet (erroneously referred to in
prior deeds es sixty-four and seven anc-hundredths (64.07) feet) to a pin on the
north¦astarly side of Courtland road) thence by the southeasterly line of Lot No. 68
on the hereinattar mentioned plan, North sixty-five (65) degrosa forty-Lour (44)
minutes thirty (30) seconds East, one hundred twenty and no-tenths (110.0) Lost to a
pin; thence by the aouthwestarly line of Lot No. 106 on the hereinafter mentioned
plan, south twenty-four (24) degrees fifteen (15) minutes thirty (30) seconds Nast,
twenty-saven and fifty-eight one-hundredths (27.58) feet to a pipe; thence by the
northwesterly line of Lot No. 12 as shown on said hersinafter mentioned plan, South
twenty-seven (27) degrees twenty-four (24) minutes forty-seven (47) seconds West,
forty-four and eighty-eight ons-hundredths (44.88) feet to a pipe; thence by Lot No.
13 as shown an the hereinafter mentioned plan, South fifty-mine (59) degrees eighteen
(19) minutes forty (40) seconds west, eighty-five and thirty-three one-hundredths
(85.33) feat to a pipe on the northeasterly line of ccu--tland Road, the place of
BEGINNING. BEING Lot No. 67,* Tract No. 3, Cumberland Park as recorded in cunberland
county Recorder of Deeds office in Plan Book 6, at Pago 3.
The improvements thereon being known as 4 Courtland Road.
VERIFICATION
hereby states that he/she is
of
mortgage servicing agent for Plaintiff in this matter, that he/she
is authorized to take this Verification, and that the statements
made in the foregoing Civil Action in Mortgage Foreclosure are true
and correct to the best of his/her knowledge, information and
belief. The undersigned understands that this statement is made
subject to the penalties of 18 Pa. C.S. Sec. 9904 relating to
unsworn falsification to authorities.
DATE: I I- - "I_
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06856 '
COMMONWEALTH OF PENNSYLVANIA.:
COUNTY OF CUMBERLAND
CI'i IC'ORP MOR'CGAGE I?4C-_.--_--
--- VS.
UNANGST ARTHUR -l SHANNON SUNDAY _-____ ---'
Sheriff of Deputy Sheriff. of
:0 ny dilly s-olzu according
CUMB-ERLA.ND Cou. ,
to saps, tine FOR°-- '::as served
_ :?L,AIIJT - :OR'P
la4i, :•utilin COT, --
goon UNANGST ARTHUR A the
defendant, at 16:05 :TOURS, 0:1 tl:e 75ti1 day of November
--
1999 ar 5405 OXFORD DRIVE
CUMBERLAND
MECF?ANICSBURG, PA 17055
County, Pennsylvania, by handing to ARTHUR A. UNANGST
a true and attested copy of the COMPLAINT - MORT FORE
NOT
togeCi'cr 411tH NO1CE
and at the same t'_n1C- dire-cLing 'ils attel LioI: to the contents thereof.
Sherit_'s costs: So ansWels:
Docketing 13.00 y
Service 6.:?%.c/' s??' L2
Affidavit .00 homas n11ne,?5neil f---
Surcharge 8.00
a d F TEDER:-'Y%N F: MELAN
11/15/1999
by ?
n7eput'/ ?neryl
S4:orr: and subscribI!d' to before me
this /3=` day of
A.D.
9
' 7lu?cw ?-
l e jac._?•roLno:?oL•?u's'-----
FGDERMAN AND N IELAN
By: PRANK PL'•DLRNIAN
Identification No. 12215
Two Penn Center Plaza - SUite 900
Philadelphia, PA 19102
(215) 563-7000
Citicorp Mortgage, Inc.
1-5851 Clavtoo Road
Ballwin, MO 63011
Plaintiff,
ys.
Arthur A. Unangst
5405 Oxford Drive 94
Nlechaniesburg, PA 17055
Defendant(s)
Attorney lin• Plaintill'
: Cumberland COUNTY
: COURT OF COMNION PLEAS
CIVIL DIVISION
: NO. 99-68-56-CIVIL
PRAECIPE FOR.IUDGMENT FOR FAILURETO
ANSWER AND ASS ESSNI ENT OF DAMAGES
TO TIIE PROTI IONOTARY:
Kindly enter judgment in lavor ol'thc Plaintil7'and against Arthur A. Unangst.
Delenclant(s), for failure to f ile an Answer to Plaintif'f's Complaint within 20 clays from service
thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintifl's darnages as
follows:
As set forth in Complaint 573,815.77
lmcl'cst H/1/99 10 12/23/99 5746.77
TOTAL 574,562.54
I hereby certify that (1) the addresses ol'the Plaintill and Defendant(s) are as shown above.
and (2) notice has been uiven in accordance with Rulc 337.1. copy attached.
PRANK PEDEWMAN, I-SQUIR17
Attorney for Plaintill'
DAMAGES ARE IIEREBY ASSESSED AS INDICATED.
PRO PROTIIY
'•11 i Is Fm>I Is A mart COLLECt OR A IA0IPI ISG'to ('OLLIX "r A Drtn.\ND ANY IN FOUMA1ION OR IA INrD \yn.l, at:
rsro rou'rn:vr rrurosr. m vuD u.tvr. nu;ciOrst.v w;crn•t:D :? Disrunacr is unst:urrrcv A?u'rnts oru'r e•As
NO r REA 1Fm.w:O. 1 nsCORtu:SPONDLN(TIsSOI A%DsnO1 t.D.Trrart ONSIM 1;0t0ttt:AS.vrrt:atrr 10CoLLU.'r
ADear.aVrONIA LNFOaCENI EN rOFAt.n:NA AnsrraOrrtrrv..•
P.
FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
CITICORP MORTGAGE, INC.
Plaintiff
Vs.
ARTHUR A. UNANGST
Defendant
TO: ARTHUR A. UNANGST
5405 OXFORD DRIVE #4
MECHANICSBURG, PA 17055
DATE OF NOTICE: DECEMBER 7, 1999
FILE COPY
PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL
BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN
AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of 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
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
ATTORNEY FOR PLAINTIFF
. COURT OF COMMON PLEAS
. CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-6856-CIVIL
Frank Federman, Esquire
Attorney for Plaintiff
p? c
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EEDERMAN and PHELAN
By: PRANK PEDERNIAN
Identification No. 13248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
Citicorp IN9ortgage, Ilse.
Plaintiff
y5.
Arthur A. Unangst
Defendant(s)
Attorney I'm- Plaintiff
: Cumberland COUN'T'Y
: Court of Couunon Pleas
CIVIL DIVISION
NO. 99-68i6-C I V I L
VERIFICATION OPNON-\71LI"1'ARl'SI?RVIC1:
PRANK PEDERNIAN. ESQUIRE, hereby verifies that he is attorney 1'or the
Plaintiff in the above-captioned matter.and that on information and belief. he has knowledge of the
following facts, to wit:
(a) that the defendant(s) is/are not in the Nlilitary or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Sofcliers' and Sailors Civil Relief Act
of Congress of 1940, as amended
(b) that del'enclant Arthur A. Unangst is over 18 years of age and resides at
5405 Oxford Drive 94, t?Icch:micsburg, PA 17055.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn I:rlsiflcation to authorities.
PRANK PEDERMAN
Attorney for Plaintill'
r
(Rule of Civil Procedure No. 236 - Revised)
Citicorp Mortgage, Inc. : Cumberland COUNTY
Plaintiff : Court of Conunon Pleas
vs. : CIVIL DIVISION
ArlhurA. Unangst : NO. 99-6856-CIVIL
Defendant(s)
Notice is given that a .lodgment in the above captioned matter has been enteral against you on
December ?27 . 1999.
)EPUfY
Ifyou have any questions concerning this matte'. please contact:
PRANK MDERMAN. ESOUIRE
Attorney I'or Piling Parly
SUITE 900
TWO PENN CENTER PLAZA
PHILADELPHIA. 13A 19102
(215)563-7000
"'TII1S FIRM IS A DEBT COLLECTOR ATIMNIYTRYC •ro COLLECT A DEBT AND ANN'
INFORMATION OBTAINED WILL BE. USED FOR TI IAT PURPOSE. IF YOU HAVE PREVIOUSLY
Rr•.CEIVE.D A DISCIIARCE IN BANKRUPTCY AND TIIIS oElrr WAS NO•r IZEAFFIRiNiI?D, •rII1S 1S NOT
AND SHOULD NOT IRE CONSTRUED TO BE, AN ATIT'NIPT •1.O COLLECT A DEBT, RUT ONLY
ENFORCEMENT OF,. Lu:N ,u:ALNS r rtulrl:R rY.
M
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B CUTI 1'1lAIX11'17, FOR WRIT OF EXEI C I'. 301511-3183 RTGAGE FORECLOSURE)
Citicorp Morlgoge, Inc.
1'luintiff,
Cumberland Count).
?'. No. 99.6856 Cieil
Arthur A. Un:nitst
Derendmu(s).
11.0 THE DIRECTOR OF THE OFFICE OF THE PROTFIONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest front 12/23/99 - 6/7/00
(Per diem - 512.26)
$74.562.54
52.047.42 and Costs
576.609.96 TOTAL
PRrW K FBDERb1AN, ESQUIRE
'rwG, PENN CENTER PLAZA
SUITE 900
PHILADELPHIA, PA 19102
Attorney for Plaintiff
Note: Please attach description of property.No.
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DESCRIPTION
ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon erected
situate in Lower .Alen Township, Cumberland County, Pennsylvania, and described according to
survev made December 11, 1974, by Michael C. D'Angelo. Registered Surveyor and bounded and
described as follows.
BEGINNING at a pipe situated on the northeasterly side of Courtland Road (50 feet wide) which
pipe is on a course North 24 degrees 15 minutes 30 seconds West and measured 95.0 feet from the
northwesterly side of Cumberland Road (50 feet wide); thence from said beginning point by the
northeasterly side of Courtland Road North 24 degrees 15 minutes 30 seconds West a distance of
64.97 feet(erroneousiv referred to in prior deeds as 64.07 feet) to a pin on the northeasterly side of
Courtland Road; thence by the Southeasterly line of Lot No. 63 on the hereinafter mentioned plan
North 63 degrees 44 minutes 30 seconds East 120.0 feet to a pin; thence by the Southwesterly line
of Lot No. 106 on the herein after mentioned plan South 24 degrees 15 minutes 30 seconds East
27.53 feet to a pipe; thence by the Northwesterly line of Lot No. 13 as shown on said hereinafter
mentioned plan South 27 degrees 24 minutes 47 seconds West 44.33 feet to a pipe; thence by Lot
No. 13 as shown on the hereinafter mentioned plan South 59 degrees 13 minutes 40 seconds West
35.33 feet to a pipe on the Norhteasterly line of Courtland Road, the place of Beginning.
BEING Lot No. 67, Tract No. 3, Cumberland Park as recorded in Cumberland County Recorder of
Deeds Office in Plan Book 6. at page 3.
BEING improved with a one story frame dwelling house known as No. 4 Courtland Road.
Cumberland Park, Camp Hill, Pennsylvania. 17011.
TAX PARCEL #13-23-0-557-040
TITLE TO SAID PREMISES IS VESTED IN Arthur A. Unangst, single man, by Deed from Ralph
V. Zampogna and Eileen M. Zampogna. his wife, dated 11'13/79, recorded U509', in Deed Book F
23, Page 776.
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Plaintiff,
Defendant(s).
CUMBERLAND COUN'T'Y
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-6856 Civil
AFFIDAVIT PURSUANT" I'O RULE 3129
(Affidavit No. 1)
Citicorp Mortgage, Inc.
V.
Arthur A. Unnngst
Citicorp Mortgage, Inc., Plaintiff in the above action, by its attorney, FRANK FEDERMAN,
ESQUIRE, sets forth as of the date the Praccipe for the Writ of Execution was filed the following
information concerning the real property located at 4 Courtland Road Camn Hill. PA 17011.
Namc and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Arthur A. Unangst 5405 Oxford Drive H4
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME LAS'r KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
"I
4. Name and address of the last recorded holder ofevery mortgage of record:
NAME LASTKNOWN ADDRESS (Ifaddress cannot be
reasonably ascertained, please so indicate.)
Green Tree Consumer 332 Minnesota Street
Discount Company Suite 610
St. Paul, NIN 55101
5. Name and address of every other person who has any record lien on the property:
NAME LAST KNOWN ADDRESS (11'address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME LAST KNOWN ADDRESS (11'address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
'renant/Occupant 4 Courtland Road
Camp Hill. PA 17011
Domestic Relations of 13 North Hanover Street
Cumberland Count), Carlisle, PA 17013
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 IS Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Februarv 14. 2000
DATE FRANK FEIJERt AN, ESQUIRE -
Attorney for Plaintiff
I
FEDERMAN and P111MAN
By: FRANK ITI)LRMAN
Identification No. 12248
ATTORNEY FOR PLAINTIFF
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
Citicorp Mortgage, Inc.
Plaintiff,
CUMBERLAND COUNTY
COU111'01-7CONINION PLEAS
Arthur A. Unangst
Defendant(s).
CIVIL DIVISION
NO. 99.68i6 Civil
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
O an FHA mortgage
O non-owner occupied
O vacant
(a) Act 91 procedures have been fullillcd
'this certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
FRA?lI FGDGRMAN: ESQUIRE
Attorney for Plaintiff
Citicorp Mortgage, Iuc.
Plaintiff,
V.
Arthur A. Un:mgst
Defendant(s).
CUMBERLAND COUNTY
No. 99.6856 Civil
February 1=4.2000
'1'0: Arthur A. Unangst
5405 Oxford Drive 414
Mechanicsburg, PA 17055
"*THIS FIRM IS A DEBT COLLECTOR ATTENIPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
ROPER"
BANKRUPTCY AND TO BE N ATTEMPT TO COLLECT A DEBT, Bur ONLY ENFORCE ION'r OF AILIO NLAGAIINS B T P ED
Your house (real estate) at 4 Courtland Road Camp Mill. PA 17011, is scheduled to be sold at
the Sheriffs Sale on .tune 7.2000 at 10:00 a.m. in the Cumberland County CourhlOUSe , South Hanover
Street, Carlisle, PA 17013, to enforce the courtjudgment obtained by Citicorp Mortgage, Inc. (the
mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the
Sheriff's Sale.
Nonce. OF OWNER'S RIGHTS
YOU MAY BE ABLE- TO PRrVLNT •l-I I1S SI-Ir:RIFF'S SALE-
To prevent this Sheriffs Sale, ),on must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. "ro find out how much YOU nmst pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entereul. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sherift's Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your properly.
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 (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 the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY 13AR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
1
ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon erected
situate in Lower Allen Township, Cumberland County, Pennsylvania, and described according to
survey made December 11, 1974, by Michael C. D'Angelo, Registered Surveyor and bounded and
described as follows.
BEGINNING at a pipe situated on the northeasterly side of Courtland Road (50 feet wide) "hick
pipe is on a course North 24 degrees 15 minutes 30 seconds West and measured 95.0 feet from the
northwesterly side of Cumberland Road (30 feet wide); thence from said beginning point by the
northeasterly side of Courtland Road North 24 degrees 15 minutes 30 seconds West a distance of
64.97 feet (erroneously referred to in prior deeds as 64.07 feet) to a pin on the northeasterly side of
Courtland Road; thence by the Southeasterly line of Lot No. 68 on the hereinafter mentioned plan
North 65 degrees 44 minutes 30 seconds East 130.0 feet to a pin; thence by the Southwesterly line
of Lot No. 106 on the herein after mentioned plan South 24 degrees h minutes 30 seconds East
27.53 feet to a pipe; thence by the Northwesterly line of Lot No. 13 as shown on said hereinafter
mentioned plan South 27 degrees 24 minutes 47 seconds West 44.88 feet to a pipe: thence by Lot
No. U as shown on the hereinafter mentioned plan South 59 degrees 13 minutes 40 seconds West
85.33 feet to a pipe on the Norhteasterly line of Courtland Road, the place of Beginning.
BEING Lot No. 67, Tract No. 3, Cumberland Park as recorded in Cumberland County Recorder of
Deeds Office in Plan Book 6. at page 3.
BEING improved with a one story frame dwelling house known as No. 4 Courtland Road,
Cumberland Park. Camp Hill, Pennsylvania, 17011.
TAX PARCEL y13-23-0??7-040
TITLE TO SAID PREMISES IS VESTED IN Arthur A. Unangst, single man, by Deed from Ralph
V. Zampogna and Eileen M. Zampogna. his wife, dated 1, 13i 79, recorded 1 5i79, in Deed Book F
28, Page 776.
FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000
CITICORP MORTGAGE, INC
V.
ARTHUR A. UNANGST
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-6856 CIVIL
CUMBERLAND COUNTY
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PURSUANT TO P.R.C.P., 404(2)/403
FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby
certifies that service of the Notice of Sheriff's Sale was made by
sending a true and correct copy by certified mail to Defendant,
ARTHUR A. UNANGST at 5405 OXFORD DRIVE 44 MECHAINICSBURG, PA 17055
which notice of Sheriff's Sale was received by Defendant, ARTHUR A.
UNANGST on FEBRUARY 18, 2000 as evidenced by the attached return
receipt.
The undersigned understands that this statement is made
subject to the penalties of 18 PA C.S. s 4904 relating to unsworn
falsification to authorities.
?2aIf:C FED_L u , ESQUIRE
Date: FEBRUARY 26, 2000
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CITICORP MORTGAGE, INC.
Plaintiff
CIVIL DIVISION
vs.
ARTHUR A. UNANGST
Defendants
No. 99-6856 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
SS:
CUMBERLAND COUNTY
I, FRANK FEDERMAN, ESQ., attorney for CITICORP MORTGAGE. INC.,
hereby verify that on FEBRUARY 16. 2000, true and correct copies of the Notice of
Sheriffs Sale were served by certificate of mailing to the recorded lienholder(s), and any
known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was
sent to defendant(s) on FEBRUARY 16, 2000 by first class mail and certified mail return
receipt requested, see Exhibit "B" attached hereto.
FRANK FEDERMAN, ESQUIRE-.
/ Attorney for Plaintiff
Date: April 28, 2000
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PS FORM 3811, December 199•I
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S'FA'1'1; OF PENNSYLVANIA, l SS.
COUNTY OF CUMBERLAND
Robert P Ziegler
1+ -----------'--------------------------------- ---- Recorderof
need in and for said County and State do hereby certify that the Sheriff's Dced in which ----------------
Federal Natl Mtg Assoc
-------------------------------------- is the grantee
--------°--° -------------------
tile the same having been sold to said grantee on tile ----------- ZJ;jL -------------------------------- day of
June xx 00
---------------------------------------- A. D., 19--------,under and by virtue ofa writ --------------
execution l6th
----------------------issued on the ------------------------------------
--------------------------
Februrary x 00
day of __________________________ A. D., I_--- out of the Court of Cotnntan Pleas of said County as of
civil 99
-------- -------------------------------------------------- Term, 19-------
----------------------
6856 Citicorp kitg Inc
Number --------------- atthe suit of---------------------------------------------------------------
Arthur A Unangst
----------------------------------- against-------------------------------------------------- is
224 428
duly recorded in Sheriffs Dced Book No. ------------+ Page -------------
IN TESTUNIONY WHEREOF, I have hereunto
set my hand and seal of said office this ------ day
of -------------------- A. D.,
/?--?-?--f-- -- ? ----------------
Recorder of Deeds
Recorder of Deeds, Cumberland County. Carlisle, PA
My Commission Expires the First Monday of Jan. 2002
Citicorp Mortgage. Inc. In the Court of Common Pleas of
-as_ Cumberland County, Pennsylvania
Arthur A. Unangst No. 99-6856 Civil
Kathy ,l Clarke, Deputy Sheriff. who being duly sworn according to law, says on
February 23, 2000 at 726 o'clock PA,I. EST. she serval a true copy of real Estate Writ
Notice and Description in the above entitled action upon the within named defendant to
wit: Arthur Unangst, by making known unto Arthur Unmtgst at 5404 Oxford Drive 5,
Mechanicsburg Cumberland Count, Pennsyb•ania, its contents and at the some time
handing to him personally the said true and attested copies of the some.
David McKinncy. Deputy Sheriff. who being duly sworn according to law, says on
March 29, 2000 at 2:05 o'clock P.M. EST he posted a copy of Real Estate Writ Notice
Poster and Description in the above entitled action upon the property of Arthur A.
Unangst located at 4 Courtland Road. Camp I lill. 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 Billowing manner: The
Sheriff mailed a notice of the pendency of the action to the defendant Arthur Unangst by
First Class Mail to his last known address 5404 Oxford Drive ;t 5, Mechanicsburg,
Pennsylvania. This letter was mailed under the (late of \larch 10. 2000 and never
returned to the Sheriffs Oft-ice.
R. Thomas Kline. Sheriff, who being duly sworn according to law, says that after due and
legal notice had been given according to haw, exposed the within described premises at
public venue or outcry at the Court House. Carlisle, Cumberland County. Pennsylvania,
Oil June 7, 2000 at 10:00 o'clock A.M. EDST and sold the same for the sum of S 1.00 to
Attorney Dale Shughart, JR for Federal National Mortgage Association. It being the
highest bid and best price received I'or the same Federal national Mortgage Association of
1900 Market Street, Suite 800, Philadelphia Pennsylvania being the buyer in this
execution paid to Sheriff R. Thomas Kline the SUM or $ 926.39 it being costs.
Sheriffs Costs:
Docketing 30.00
Poundage 18.16
Posting Bills 15,00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 1=4.89
Certified Mail 1.97
Levy 15.00
Surcharge 20.00
Low Journal 372.35
Patriot News 306.23
Share of Bills 224.80
Distribution of Proceeds 25.00
Sheriffs Decd 26.50
$926.39 Pd by Atty
6/21/00
Sworn and Subscribed To Before plc So Answers: .1 'his Day of C r'
R.'I'homas Kline. Sheriff
2000. A.D. ?Jklflt 0.
Proth notary 13y lz/ /j .?j
Real Estate Deputy
I
J?• J
ClL,?•f ly7
?Ccc, (/ -/ l
r1
Citicorp Mortgage, Inc.
Plaintiff,
V.
Arthur A. Unangst
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-6856 Civil
AFFIDAVIT PURSUANT TO RULE 3139
(Affidavit No. I)
Citicorp Mortgage, Inc., Plaintiff in the above action, by its attorney, FRANK FEDERMAN,
ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following
information concerning the real property located at 4 Courtland Road, Camp Hill. PA 17011.
1. Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Arthur A. Unangst 5405 Oxford Drive #4
Mechanicsburg, PA 17055
3. Name and address of Defendant(s) in the judgment-.
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of everyjudgment creditor whose judgment is a record lien on the real
property to be sold:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
4.
5.
6.
Name and address of the last recorded holder of every mortgage of record:
NAME LAST KNOWN ADDRL-SS (If address cannot be
reasonably ascertained, please so indicate.)
Green Tree Consumer 332 Minnesota Street
Discount Company Suite 610
St. Paul, AIN 55101
Name and address of every other person who has any record lien on the property:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant 4 Courtland Road
C:uup Hill. PA 17011
Domestic Relations of 13 North Hanover Street
Cumberland Count), Carlisle, PA 17013
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 IS Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Pebruarv 14.2000
DATE (RANK FEDERIMAN. ESQUIRE
Attorney for Plaintiff
OF..
r
VEe I ; e (3 iii "33
Citicorp Mortgage, Inc.
Plaintiff,
Arthur A. Unangst
Defcod;uu(s).
TO: Arthur A. Unangst
5405 Oxford Drive ii4
Mechanicsburg, PA 17055
February 14, 2000
-THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORNIATION
OBTAINED WILL BE USED FOR 'I HAT PURPOSE. IF YOU HAVE. PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THis IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATI'ENiPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at a Courtland Road, Camp Mill. PA 17011, is scheduled to be sold at
the Sheriffs Sale on.June 7, 2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover
Street, Carlisle, PA 17013, to enforce the courtjudgment obtained by Citicorp MortgaRt Inc. (the
mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the
Sheriffs Sale.
CUMBERLAND COUNTY
No. 99-6856 Civil
NOTICE OF OWNER'S RIGFITS
YOU MAY BE ABLE TO PREVENT-fI-11S SFIERIFFS SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. 'file sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (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 the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9103
DESCRIPTION
ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon erected
situate in Lower Allen Township. Cumberland County, Pennsylvania, and described according to
survev made December It. 1974, by Michael C. D'Angelo. Registered Surveyor and bounded and
described as follows.
BEGINNING at a pipe situated on the northeasterly side of Courtland Road (50 feet wide) which
pipe is on a course North 24 degrees 15 minutes 30 seconds West and measured 95.0 feet from the
northwesterly side of Cumberland Road (50 feet wide); thence from said beginning point by the
northeasterly side of Courtland Road North 24 degrees 15 minutes 30 seconds West a distance of
64.97 feet (erroneously referred to in prior deeds as 64.07 feet) to a pin on the northeasterly side of
Courtland Road; thence by the Southeasterly line of Lot No. 63 on the hereinafter mentioned plan
North 65 decrees 44 minutes 30 seconds East 120.0 feet to a pin; thence by the Southwesterly line
of Lot No. 106 on the herein after mentioned plan South 24 degrees 15 minutes 30 seconds East
37.53 feet to a pipe; thence by the Northwesterly line of Lot No. 12 as shown on said hereinafter
mentioned plan South 27 degrees 24 minutes 47 seconds West 44.33 feet to a pipe: thence by Lot
No. 13 as shown on the hereinafter mentioned plan South 59 degrees 13 minutes 40 seconds West
85.33 feer to a pipe on the Norhteasterly line of Courtland Road, the place of Beginning.
BEING Lot No. 67, Traci No. 3. Cumberland Park as recorded in Cumberland County Recorder of
Deeds Office in Plan Book 6. at page 3.
BEING improved with a one story frame dwelling house known as No. 4 Courtland Road,
Cumberland Park. Camp Hill, Pennsylvania, 17011.
TAX PARCEL #13-23-0557-040
TITLE TO SAID PREMISES IS VESTED IN Arthur A. C;nan_st, single man. by Deed from Ralph
V. Zampogna and Eileen M. Zampogna, his wife, dated 1;13179, recorded L5,79. in Deed Book F
28, Page 776.
FED 11 4 no Pit 'CJ
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO, 99-6856 CIVIL W Term
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due _ Citicorp Mortgage, Inc.
PLAINTIFF(S)
from Arthur A. Unangst, 5405 Oxford Drive 44, Mechanicsburg, PA 17055
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
ISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any properly of the defendant(s) or otherwise disposing
thereof;
(3) If properlyof the defendant(s) not leviedupon an subjectlo attachment isfound in the possessionof anyoneother
than a named garnishee, you are directed to notify him he r that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due 574,562.54
Interest from 12/23/99-6/7/00 $2,047.42
Ally's Comm
Any Paid $104 82 _
Plaintiff Paid
Date: Februayy 1.6, 2000
REQUESTING PARTY:
Name Frank Federman, Esq.
Address: Two Penn Center Plaza, Suite 900
Philadelphia, PA 19102
Attorney for: plain iff
Telephone: _215-563-7000
Supreme Court ID No. -12298__
L. L. $.50
Due Frothy $1.00
Other Costs
Curtis R. Long
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LANV .IOURNAL
(Under Act No. 5S7, approved May 16, 1929), P. L.1 7S4
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 swom, 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'), 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,
APRIL 28, MAY 5. 12, 2000
Affiant further deposes that lie 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.
REAL ESTATE SALE NO. 15
Writ No. 99-6556 Ch91
Citicorp Mortgage. Inc. Ro=c,cf M. Morgenthal, Editor
VS.
Arthur A. Unangst
Atty.: Frank Federman
DESCIUMON
ALLTHATCERTAIN piece or par-
eel of land with the buildings and
improvements thereon erected situate
in Lower Allen Tonaiship. Cumlierland
County, Pennsylvania. and desenlwd
according to survev made December
11, 1974, by Mlchacl C. D'Angelo. Reg-
istered Surveyor and bounded and
described as follows.
BEGINNING at a plpe situated on
the northeasterly side of Conrl Lllld
Roast (50 feel wide) which pipe Is on
SWORN TO A\M SUBSCRIBED before me this
12 day of MAY. 2000
na. CroT.:,i'u:.. rp^i'» Ertl
TIDE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under 8c 597, 112 tied Mau 16. 1929
commonwealth of Pennsylvania, County Of Dauphin) ss
Michael Morrow being duly sworn according to law, deposes and says:
existing und the laws
place corporation organized at 812 and
to 816 MarketrStreet, in
That he is the r of THE PATRIOT-NEWS
of the Commonwealth otf Penfnslylvania, with its principal office CO.,
f THE
PATR City rPATRIOT-NEWS newspapers soflgene al circul tion, pri ted and publlishedoat 812 to 8 BI Ma ketNStreet,
the
THE SUNDAY
in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established
That the printed and published in
March '1 1854,
or publication which es l securely attached hereto isnexactly Iasp l
printed notice September
their regular daily and/or Sunday and Metro editions/issues which appeared on the 2nd, 91h and 16th day(s) of May said printed
notice 2000. That neither he nor said Company is interested in the s alndt matter o of publication are true advertising, and
that all of the allegations of this statement as to the time, place
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this reso
ion unanimously
board of virtue and
of the aid Company andl slubseq ently duly preco ded in
assed adopted nseverally aby Patriot-News Co. aforesid by
the office for the Recording of Deeds in and for said County (f ?auphin in Miscellaneous Book "M",
Volume 14, Page 317. I 1 A I-•h
PUBLICATION - -----
---------------
i this 2nd day o Jun 2 0 A.D.
COPY Notanal seal n
Pool
S A L E #15 Tmry L. Russell, Nolary
Dauphin County
Hanism,g
OTE Y PUBLIC
toy Commission Eapues June 6.200 N
Association of NotpAiscommission expires June 6, 2002
Memoer, Pennsylvama
REAL ESTATE SALE No
15 CUMBERLAND COUNTY SHERIFFS OFFICE
.
Writ NO.9MB56 CUMBERLAND COUNTY COURTHOUSE
Cfvil Tarm
- CfUcorp Mortgage, Inc. CARLISLE, PA. 17013
vs
r`Arthur A.unao t
`Alfr Frank an
Statement OI Advertising Costs
. DESCRIP N
ALL THAT CERT,„
iece
To THE PATRIOT-NEWS CO., Dr.
p
or parcei of
land ,nth the building, and improcemenls
thereon ere
t
d For publishing the notice or publication attached
$ 304.73
c
e
situate in Lmcer Allen
Township, Cumberland Counh; IFnnspIania,
and d hereto on the above stated dateNotar
Fee(s) $ 1.50
escribed acconfin to sun,,,• mad,
,
December it, 1974, fry Isichael C
D'A y
probating same $ 306.23
.
ngelo,
• •
Total
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 cT is and Icertifies that OT-NEWS CO.e same have
been duly paid.
By ....................................................................
Real Estate No 15
$ 1000.00 advance costs paid 2/22/00 Any Prank Federman
Assessed Valuation $ 4620
Writ No. 99-6856 Civil Term
Citicorp Mortgage, Inc.
-VS-
Arthur Unangst
5404 oxford Drive 114
Mechanicsburg, PA
Real Debt $74.562.54
Interest fir 12/23/99-6/7/00 2,047.42
Atty's Pees
Atty's writ costs 104.82
Escrow
Late Charges
Sheriffs Costs
Docketing 30.00
Poundage 18'16
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 14'88
Certified Mail 1.97
Levy 15.00
Surcharge 20.00
Postpone sale
Out of County
Legal Search
Law Journal X72.>>
Patriot News 306.23)
Share of Bills 24.80
Distribution of Proceeds 25.00
Sheriffs Deed 26.50
TAXES