HomeMy WebLinkAbout03-3862MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Citicorp Trust Bank, FSB,
f/k/a Travelers Bank & Trust,
FSB
7467 New Ridge Road
Suite 222
Hanover, MD 21076
Plaintiff
V.
Joseph A. Bechtel
Dawn M. Ferris a/k/a
Dawn M. Bechtel
15 South Enola Drive
Enola, PA 17025
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. p3 -
COMPLAINT IN MORTGAGE FORECLOSURE
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 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.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
AVISO
Le ban demandado a usted an la corte. Si usted quiere defenderse
de estas demandas expuestas an las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita o an
persona o con un abogado y entregar a la corte an forma escrita sus
defensas o sus objeciones a las demanders an contra de su persona.
Sea avisado qua si usted no as dafiende, la corte tomara medidas y
puede continuar la demanda an contra suya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere qua usted cumpla con todas las provisiones de
esta demands. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
LAW OFFICES OF MARK J. UDREN
/s/ Mark J. Udren, Esquire
1040 N. Kings Highway, Suite 500
Cherry Hill, NJ 08034
(856) 482-6900
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. If Plaintiff is an assignee then it
is such by virtue of the following recorded assignments:
Assignor: N/A
Assignments of Record to: N/A
Recording Date: N/A
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 15 South Enola Drive
MUNICIPALITY/TOWNSHIP/BOROUGH: East Pennsboro Twp.
COUNTY: Cumberland
DATE EXECUTED: 03/04/98
DATE RECORDED: 03/06/98 BOOK: 1436 PAGE: 228
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
08/06/03:
Principal of debt due $72,458.70
Unpaid Interest at 10.163%
from 01/09/03
to 08/06/03
(the per diem interest accruing on
this debt is $20.46 and that sum
should be added each day after
08/06/03) 2,393.82
Title Report 250.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Late Charges
(monthlyy late charge of $00.00
should be added in accordance
with the terms of the note
each month after 08/06/03) 00.00
Corporate Advance 2,245.26
Attorneys Fees (anticipated and actual
to 5% of principal) 3,622.94
TOTAL $81,250.72
7. The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be collected
in the event of a third party purchaser at Sheriff's Sale. If the
mortgage is reinstated prior to the sale, reasonable attorney's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A", and made part
hereof, and defendant(s) have failed to proceed within the time
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $81,250.72 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
Ma A J?ren, ESQUIRE
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
Attorney I.D. No. 04302
ALL THAT CERTAIN piece of ground situate in East Pennsboro
Township, Cumberland County, Pennsylvania, more particularly
bounde.9 and described as follows, to wit:
BEGINNING at a point on the West side of Brick Church Road;
THENCE in a:Westwardly direction along land now or formerly
of Francis J. Kelater, and through the center of a partition
wall botween 6-welling on lot hereby conveyed and dwelling on
lot ad:oining on the South and beyond, a distance of one hundred
twenty-five fast (125) to a sixteen foot alley; THENCE
Northwe.rdly along the Eastern line of said alley, seventeen
and one-half (17-1/2) feet, more or less, to an eighh foot alley,
as shown on]Moltz Plan, which Plan is recorded In Plan Book
1, Page 2; THENCE Lastwardly along the South side of said eight
foot alley, one hundred twenty-five (125) feet to Brick Church
Road; THENCE Southwardly along the Western line of said Brick
Church Road, seventeen and one-half (17-1/2) feet, more or less,
to a point, the place of BEGINNING. -
HAVING thereon erected an all-brick, two-story, half double
dwelling house known and numbered as 15 South Encla Drive, Snola,
Pennsylvania.
r
.y
April 15, 2003
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mort& 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 pW.r.
The HOMEOWNER'S MORTGAGE ASSTSTANCF PROGRAM (RFMAP) many he able
to help to save your home. This Notice explains how the prVrom works.
To see if HF.MAP can heap, you mnct MFF,T WITH A CONSTiMFR CRFDTT
COUNSELING AGENCY WITHIN 30 DAYS OF THF. DATE. OF THIS NOTICE. Take
this Notice with you when you meet with the Counseling Agr.ney.
The name„ address and phone number of Consumer Credit Counseling AZgpncies serving
your County are listed at the end of this Notice. If you have any questions, You msty call the
Penn.sylvania Honcing Finance Agpney toll free at 1-800-342-2397. (Persona 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
CONTENDO 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 PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
Po
Page 1 of 6 V ° xlal
HOMEOWNER'S NAME(S): Joseph A. Bechtel
Dawn M. Ferris, AKA: Dawn M. Bechtel
PROPERTY ADDRESS: 15 S. Enola St.
Enola PA 17025
AKA: 15 S. Enola Dr.
Enola PA 17025
LOAN ACCT. NO.: 4508879
ORIGINAL LENDER: Travelers Bank & Trust, FSB
CURRENT LENDER: Citicorp Trust Bank, fsb-fka-Travelers Bank &
Trust, fsb
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BF ELIGIBLE FOR FiNANCiAi, ASSISTANCE
WHICH CAN SAVE VOTTR HOME FROM FORECLOSURE AND
HELP VOiT MAKE FiTTITRF 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 YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA 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 MiTST OCCUR WITHIN
THE NEXT (10) DAYS. IF VOTT DO NOT APPLY FOR FMFRGFNCY MORTGAGF.
ASSTSTANCF YOTT MTTST RRTNCi YOTTR MORTGAGE UP TO DATF THE. PART OF THTS
NOTTCF CATJ FD "HOW TO CURF. YOUR MORTGAC;F. DF.FATTr.T", F.XPT.ATNS HOW TO
RRTNC; YOTTR MORTC?AC:F.ITP TO DATF.
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 anll telephone numbers
of designated consumer credit c nn-eling agencies for the eonnty 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.
APPLICATION FOR MORTGAGE 'ASSISTANCE - Your 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
Page 2 of 6
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.
AGFNC'V 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 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 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 INFORMATION
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.)
HOW TO CTTRF, YO1JR MORTGAGE DFFATTT.T (Bring it up to date).
NATTTRF OF THE. DEFAULT - The MORTGAGE debt held by the above lender on your property
located at:
15 S. Enola St.
Enola PA 17025
AKA: 15 S. Enola Dr.
Enola PA 17025
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
Partial Payment of $185.88 for February 9, 2003 = $185.88
Monthly Payments of $696.47 for March 9. 2003 through April 9. 2003 = $1392.94
Monthly Late Charges of $0.00 for February 9. 2003 through April 9. 2003 = $0.00
Other charges (explain/itemize): Non-Sufficient Funds = $20.00
Property Inspection = $23.25
TOTAL AMOUNT PAST DUE:
P7622.n7
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable.): jy[A
HOW TO CTTRF 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 $1522.02 PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments mnst he made either by rash, cashier's rherk, rentified rherk or mnney order made rayahle.
Mark.T. Tldren & Assnriates
1046 N. King,% Highway, Snite 506
Cherry Hill, NJ 09034
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
Page 3 of 6
this letter: (Do not use if not applicable ): Na
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 rjok to accelerate the mortgAff 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 mortgWd 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 against
you, you will have to pay all reasonable attorney's fees 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 within the THIRTY 4'40) DAY periotL you will not he
required to pay attorney's fees.
OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without
your having reaffirmed it, then lender cannot pursue this remedy.
RIGHT TO LITRE THE DFFATTLT PRIOR TO SHFRTFF'S SATE - 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 salest anytime up to one, hour before the Sheri ffs Sale Yrm may do m by
paying the total amount then past doe, pins any late or other charges then due, reasonable attorney's fees and
cnats connected with the foreclosure sale and any other costs ennnected with the Sheriff's Sale as s'pecified
in writing by the lender and by performing any other requirementp 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 SHRRTFF'S SALE DATE. - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately 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 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 lender.
HOW TO CONTACT THE LENDER!
Name of Lender/Servicer: Citicorp Trust Bank, fsb
Address: 7467 New Ridge Rd.
Suite 222
Hanover MD 21076
Phone Number: (800) 446-7876
Fax Number: (410) 689-1610
Contact Person: Stephanie Garland
EFFECT OF SHF.RTFF'S SALF. - You should realize that a Sheriffs 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 lender at
any time.
LALSSI MPTION OF MORTGAGE - You may not 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.
Page 4 of 6
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
LAW OFFICES OF MARK J. UDREN
/s/ Mark J. Udren, Esquire
1040 N. Kings Highway, Suite 500
Cherry Hill, NJ 08034
(856) 482-6900
Page 5 of 6
VOLT MAV 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 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 LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SF,RVLNG VOITR COITNTV
CUMBERLAND COUNTY
CCCS of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
FAX (717) 5414670
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
FAX n/a
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
Community Action Comm of the Capital Region
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
FAX (717) 234-2227
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St.
Gettysburg, PA 17325
(717) 334-1518
FAX (717) 334-8326
Page 6 of 6
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now pouN"a
V E R I F I C A T I O N
Mark J. Udren, Esquire, hereby states that he is the attorney
for the Plaintiff, a corporation unless designated otherwise; that
he is authorized to take this Verification and does so because of
the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he has
personal knowledge of some of the facts averred in the foregoing
pleading; and that the statements made in the foregoing pleading
are true and correct to the best of his knowledge, information and
belief and the source of his information is public records and
reports of Plaintiff's agents. The undersigned understands that
this statement herein is made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
Mark J. Udren, SQUIRE
MARK J. UDREN & A CIATES
P
Cv-) I
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-03862 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITICORP TRUST BANK
VS
BECHTEL JOSEPH A ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
BECHTEL JOSEPH A the
DEFENDANT , at 1623:00 HOURS, on the 18th day of August , 2003
at 15 SOUTH ENOLA DRIVE
ENOLA, PA 17025
by handing to
JOSEPH A. BECHTEL
a true and attested copy of COMPLAINT - MORT FORE
NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 10.35
Affidavit .00
Surcharge 10.00
.00
38.35
Sworn and Subscribed to before
me this ?Q -7 day of
l_Ll.. ?. t M ?i A. ID'.,
I?rotha ota 7
So Answers:
R. Thomas Kline
08/19/2003
MARK UDREN
By ( /
?n
Deputy She ft
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-03862 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITICORP TRUST BANK
VS
BECHTEL JOSEPH A ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
FERRIS DAWN M A/K/A DAWN M BECHTEL the
DEFENDANT , at 1623:00 HOURS, on the 18th day of August 2003
at 15 SOUTH ENOLA DRIVE
ENOLA, PA 17025 by handing to
JOSEPH BECHTEL, HUSBAND OF DEFENDANT
a true and attested copy of COMPLAINT - MORT FORE together with
NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this a.7 ? day of
lu. F avU3 A.D.
Prothonotary
So Answers:
R. Thomas Kline
08/19/2003
MARK UDREN
By. 4 Den Den Dt?
`uty She ff
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Citicorp Trust Bank, FSB,
f/k/a Travelers Bank & Trust,
FSB
7467 New Ridge Road
Suite 222
Hanover, MD 21076
Plaintiff
V.
Joseph A. Bechtel
Dawn M. Ferris a/k/a
Dawn M. Bechtel
15 South Enola Drive
Enola, PA 17025
Defendant(s)
SUGGEST -0N (
To the Prothonotary:
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 03-3862 Civil Term
)F BANKRUP?I'CY
Kindly note on the record that the above Defendants, Joseph A.
Bechtel and Dawn M. Bechtel have filed Chapter 13 Bankruptcy in the
Middle District of Pennsylvania on September 19, 2003, Bankruptcy
Case No. 03-05541.
Mark J. Udren, Esquire
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
(J
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Curtis R. Long
Prothonotary
Office of the Protbonotarp
Cumbertanb CQuntp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
Q - 38 1-2 _ CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573