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Home My WebLink About01-6606MIDFIRST BANK VS. JEANNE K. RITTER AND DONALD L. R/TTER Plaintiff Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THI~ PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so ~ ~se may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, ,.~TRELCON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION AS QUEJAS EN ESTA DEMANDA CUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU vHCIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE y QUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISION'ES DE ESTA DEMANDA. POR RAZON DE ESA ~EQiSION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. ~: ~' ' ,,' ' SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADoS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 MIDFIRST BANK, VS. JEANNE K. RITTER AND DONALD L. RITTER, Plaintiff Defendants : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE . : THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attomey is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff MIDFIRST BANK, VS. JEANNE K. RITTER AND DONALD L. RITTER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CML ACTION - LAW : ACTION OF MORT G FORECLOSURE . Defendants : COMPLAINT IN MORTGAGE FORECLOSURE :Plaintiff is MIDFIRST BANK, a corporation whose address is 3232 WEST RENO, OKLAHOMA CITY, OKLAHOMA 73107. Defendant, JEANNE K. RITTER, is an adult individual whose last known address is 402 NORTH FILBERT STREET, MECHANICSBURG, PENNSYLVANIA 17055. Defendant, DONALD L. RITTER, is an adult individual whose last known address is 402 NORTH FILBERT STREET, MECHANICSBURG, PENNSYLVANIA 17055. On or about, August 26, 1983, the said Defendants executed and delivered a Mortgage Note in the sum of $46,900.00 payable to PB MORTGAGE CORPORATION, which Note is attached hereto and marked Exhibit "A". Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 735, Page 381 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to MERRILL LYNCH MORTGAGE CORP. and was recorded in the aforesaid County in Book 297, Page 1025. The Mortgage was further assigned to MIDFIRST BANK and was recorded in the aforesaid County in Book 619, Page 188. Said Mortgage and Assignments are incorporated herein. The land subject to the Mortgage is: 402 NORTH FILBERT STREET, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on June 01, 2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $35,236.12 Interest at $12.55 per day From 05/01/2001 To 12/01/2001 ( based on contract rate of 13.0000%) $2,685.70 Accumulated Late Charges Late Charges $30.68 From 06/01/2001 to 12/01/2001 $184.08 Escrow Deficit $65O.58 Attorney's Fee at 5% of Principal Balance TOTAL $1,761.81 $40,518.29 **Together with interest at the per diem rate noted above after December 01, 2001 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. No judgment has been entered upon said Mortgage in any jurisdiction. Plaintiffhas complied with the notice procedures required by Pennsylvania Act 160 of 1998 by sending to each Defendant, by regular mail, a copy of the Combined Act 6/91 Notice. A true and correct copy of the Combined Act 6/91 Notice is attached hereto as Exhibit "C". 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. i0. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiffhas complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 13.0000% ($12.55 per diem), together with other charges and :~psts including escrow advances incidental thereto to the date ~heriff's Sale and for foreclosure and sale of the property within described. _ ~ ~/ : ' By: -- /,' L,/' PURCELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) MORTGAGE NOTE 37052891 PENNSYLVANIA CUMBERLAND , Pennsylvania. ~ /+6900.00 August: 26, , 19 8~, FOR VALUE I~ECEII/ED, the undersikmed, DONALD L. R~TTER AND JEANNE K. RITTER HIS WIFE ,heretna~tersalledtheMaker, pmmlsaatepayto PE I'IORTCAGE CORPORATION a corporation organized and existing under the laws of the THE STATE OF NEW JERSEy or order, hereinafter deeik~latsd aa the Payee, the principal sum of Forl:y Six Th ousand Nine Hundred and No/100 Dollars with interest from date at the t"ate of Th ir c een per cesium (13.0 0~Y~) per annum on the unpaid balance until paid. The said principal and interest shall be payable at the office of PB bIORTOAGE CORPORATION in HADDOHFIELD, HJ 08033 76 EUCLID AVENUE at ~i;§~ or such Place as the holder may designate in writinsr in monthly installments of }t~ahceen Dollars ($518.811 commencing on the first day of O c c ob e r , 19 8,3and on the first day of each month thereafter until the princi- pal and interest are fully paid, except that the final payment of the entire indebteduess evidenced hereby, if uot sooner paid, shell be due and payable on the first day of September ,2 013 Privilege is reserved to prepay at any time. without premium or fee, the entire indebtedness or any part thereof not less than the amount of one installment, or One Hundred Dollars ($100.001, whichever is less. Prepayment in full shall be credited on the date received. Partial prepayment, other than on an installment due date, need n'ot be credited until the next following installment due date or thirty days after such prepayment, whichever is earlier. Simultaneously with the execution of this Note the Maker has executed and delivered to the Payee a Mortgage secured upon certain premises situalid in the County of CUI4EERLAND Commonwealth of Pennsylvania, more particn ar y described in the MortEa~e. All of the terms, cove- naars, provisions, conditions, stipulations and agreements contained itt said MortgaEe to be kept and performed by the Maker are hereby made a part of this Note to the same extent and with the same force end effect as if they were fully ~t forth herein, ami the Maker covenants and agrees to perform the same, or cause the same to be kept and performed, stl'i¢%ly in ac~ordauee with the terms and pt~0- visions thereof. The whole of the principal sum or any pat't thereof, and of auy other sums of money secured by the Mort~'age given to secure this Note, shall, forthwith, at ihs optiol~ of the Payee or any subsequent holder thereof, become due and payable immediately, without unties or denmnd, if default be mede in any payment under this Note, and if the default is not made lrood prior to the due date or the next such installment; or upon the happening of any' default which, by the terms of the Mortgage given to secure this Note, shall entitle the Pa¥co, or any subsequent holds1- hereof, to dec]are the same, m' any part thereof, to be due and payable. The Maker does hereby empower any attorney of any court of record within the United States or elsewhere to appe.~r ~or Maker, with or without a declaration flied, and confess jndgment or judg'- meats against said Maker in favor of the Payee or an). subsequent holder hereof, 0.$ of any term, for the entire unpaid principal of this Note, and all other sums paid by tee holder hereof to or on behalf of the Maker pttrsuuat to the terms of this Note os' said Mortgalte, and all,nrrearages of interest there- on, together with costs of suit, attorney's commission of 5 ~ for collection, aud a release of all errors, on which judzment execution or executions may issue forthwith. The Maker hereby waives the right of inquisition on all propexty levied upon to collect the indebtedness evidenced hereby and does voluntarily condemn the ,same and authorizes the Prothonotary to enter such condemnation, and waives and releases all laws, now in force or hereafter enacted, relatin~ to exemption, appraisement or stay of execution. The agreements herein contained shall bind, and the benefits sad advantages shall inure to, thc respective successors and assigns of the parties hereto. Wherever used, the slng~dnr number shall in- clude the plural, the plural the sinEular, and the use of any zender shall be allplisable to all genders. IN WITNESS WHEREOF, the Maker has caused these presents to be executed under seal the day and year first above written. ~ , .~/] ~-~ ~ in the or: S AL) - ~ .................................................................... (SEAL) THIS IS TO CEaTXI~¥ that this is the Note described in and secured by Mortgage of even date here- with secured on real estate situate in CUI4SKRLAND //.County Commonwealth of Pennsylwoaia WTTZO:~? ~COURS~, PAY 'A'O IIER~II.!. ~';:':~,H ?~TGAGF,.CO~P. :-I0 H2(]tlO ~]H.L O.L ALL THAT CERTAIN tract or parcei of land with the improvements thereon erected, situate in the Borough of Mechanicsburg, County of Cum- berland and Coa~aonwealth of Pennsylvania, being more particularly bounded and described as followsg BEGINRING at a point on the easterly line of Flibert Street; which point is 78 feet north of the northeasterly corner of Portland and Filbert Streets; thence alon~ the easterly line of Filbert Street North 21 degrees 40 minutes West 58 feet to a point; thence North 68 degrees 20 minutes East 12q.55 feet to a point; thence South 21 degrees 40 minutes EAst 20 feet to a point; thence South 33 degrees 39 minutes West 66.77 ~eet to a point; thence South 68 degrees 20 minutes West 69.65 feet to a point, place of BEGINNING. BEING premises known aa 402 North Filbert Street and having thereon erected a b~lck stucco ~anch type dwellin~ house. BEING the same p~emlse$ which Helen L. Lowe, unremarried widow by her deed dated August 26, 1983 and intended to be recorded herewith, granted and conveyed unto Donald L. Ritter and Jeanne E. Ritter, his wife. PR0¥1DED, that in case default shall be made in the payment of any installment of prise pal and interest, or any other payraent hereinabove or in the conditions of said recited Note provided for, or in the keeping and performance by the. Mortgagor of any covenant or agreement contained therein or in this Mortgage to be by said Mortgagor kept and performed in the manner and at the time specified for the performance thereof, such default wiJl entite Mortgagee forthwith to bring and sue out an Action of Mortgage Foreclosure upon this Indenture of Mortgage, or to institute any other appropriate action or proceeding' to foreclose a mortgage, and to proceed thereon to judgment and execution, for recovery of said principal debt or sums and all interest thereon and all other sum together with an attorney's .... :._:_.. ~ ,, ...... s hereby secured, ceed~ng, and to pursue any and all o~her ,~ppropriste legal or equitable remedies in such cases provided Nov-OS-01 O$:0gpm From-MIDLAND MORTGAGE REFERRAL T-?4I P.O$/IZ F-$$g. CONTENIDO - DE £STA NOTIFICAC[ON OBTENGA UN^ TRADUCCION INMEDITAMENTE LLAMANDO EST% AG£NCI~ (PENNSYLVANIA HOU£SNG FrNANCE AGENCY) SIN CARGOS AL NUMERO MENC1ONADO ARRIBA. PUED£$ SER £LEGIBLE PA.RA UN PR~STAMO PR EI.. PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PEtLOIDA DEL DEKECHO A RED[MIR SU HI~OTECA. Homeowner's Nam:(s): Property Address- Loan Account No.: Lender/S~rv~cer: DONALD L RITT£R JEANNE K RITT£R 402 R FILBERT ST N~CRANICSBURO PA 4&23~500 Midland Mortgage Co. 17055-3329 HOlvfF-OWNER'S E _IV~_ RGENC¥ MORTGAGE ASSISTANCE PROC.RAM YOu NL4,¥ BE EL~GIBI.E. FOR FfN,e~CIA. I..~SS[ST.~,NC£_W~'~C.n_ CnN SAVE HOM-E FROM FORECI.osLqcE AND liEI.P YOU M ~K.E FLrflf~,F.-_ N£ORTCAC~ IF YOU COMPL g WlT/R TC~' PROVISIQNS OF TI~I~ ROM]~OV;NER'S E1VCrRGENC'Y MORTGAGE ASSISTANCE ACT OF 1983 (Tm: '~ACT"), YOU MaY BE ELIGIBLE FOR EM2ERGENCY MORTGAGE ASS[STp,.NCE: EF YOUR DEFAULT I:~S BEEN CAUSED BY CIRCUblSTAMCES BEYOND YOUR CONTROL, IF YOU [[AVE A REASONABLE PROSPECT OF llEl~lG ABLE TO YOUR MORTGAGE PAYMENTS, AND IF YOU M~ET OTR~'R EL1GIBD.ITY REQUIREMENTS ESTA.BLISltED BY Tm~ pENNSYLVANIA ROUSING FINANCE AGENCY. T£M'PORAR¥~TAY OF FORECI. O-qURE - Under ~e Act, you ~e stay of foreclo~c on yo~ ~ge tbr ~ (30) ~ys ~om ~c ~te of~ No,cc. D~mg time you must ~.mg~ and auend a "~ce-to-thc~" mee~g wi~ on~ of the cons~ credit co~cl~g agenc~:s lis~d a~ ~e cnd offs No,cc. T~S ~E~O ~1' OCCIFR ~ ~ N~XT/3q) D~YS. ~ YOU DO NOT ~PPLY FOR ~RG~CY MORTG6G~ ~fllSTANC~. YOU ~)ST ~O YO~ MO~TOAOE ~ TO.DArt TItF ~T OF ~IS N~IC~ C~ t [~ -BOW TO Ct~ Y0[~ MORTGAGS ~L~S ~OW TO gR~G YOI~ MORTGAG~ ~ TO DAT~ CONSUMER CICEDIT COUNSE. I.I~G ACRN{~IES - If you me=t w~th one of the consumer cred~ co~nsehng agencics hstcd at th~ end of d~s Nouce, thc lender may NOT ~ke acnon against you for thtrty (30't days after ~hc dam ofth~s meeung. Thc names, addresses and t_cleoho~ RECEIVED TIMENOV,, 5, 5:12PM PRINT TIMENOV. 5. 5:17PM Nov-05-OI 05:0gpm Front-MIDLAND MORTGA~ REFERRAL T-?41 P.O4/IZ F-SEg. 'numbers of detiffnaled consumer tree]st counsc mR agencies for th~ coun~ m which the p~ooc~ i~ located ace set forth at the e~d ofth~s Noqce It is only neces~ [o sc~dule one face-to-face meeting. Ad~c yO~ lender i~mcdmtelv ofyo~ retentions. APPLICATION [OR MORTGACE A.~SIST~A~{C£ - Your to~rtgage ts m defautt for ~c reasons set forth lab:r m thls Notice (see following pages for specific mform'.-tmn about the nature of your defa,,h.) If you have Il'ted and are uriable to resolve tlxis probleto with the lender, you have thc right to apply for f'mancz~l assistance I~'oto the ltomeowncr's £m~gency Murtgage Assistance Program. To do so, you mull fill out, sign and filc a completed Hotoeown~r'$ Emergency Mortga~;e Assistance Program Appl~catlon ~lth one of thc dciigr~tcd cmaum~r credit counseling agencies listed at the end of Qus Notice. Only consumer credit counseling agencies have appheadons for the program and they will assist you ua submiaing a complete application to the P,:m'~lVama 1-Iousmg Finance Agency. Your applzcat~on MUST l:~ filed or posmaarked within Thirty (30) days ofyonr face-to-face meeting. YOU M'LIST FI]~. YOUR APPLICATION PROMlrI'L¥. ]iF YOU Fa.IL TO DO SO OP, IF YOU DO NOT FOLLOW TI~ OTI~R TllVIR PER.IOBS SET FORTE AN Tn'~R LETTER, FORECLOSURE iVIAY PROCEED AGAINST YOUR HOlVl]g IIvIIVIEDIATIILY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL RE D£NEgD. ~_~..¢.~fi~N - Ava~ablc funds for emergency mortgage asszstance are very l-,nimd. They w~l! be disbtuGed by the Agency under the eligibdi~y criteria established by'the Act- The Pennsylvania Housing Fm.~nce Agency has sixty (60) days to make a decision after ~t receives your application. During ri,az time, no foreclosure proceedings wa'Il be pursued against you ii'you have met the time z~quirements set forth above. You will be notified directly by th~ Pennsylvania Housing Finance Agency of i~s decismn on l, our applicanon. NOT~: IF YOU AR]E CURR.~NTLY PPtOTECT~-r} BY TWe ~.rNG OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TuTS NOTIC]E IS FOR IlCFORMATION PURPOSES ONLY A/CD SItOULD NOT B£ CONSIDERED AS A2,1 ATTEMlrf TO CO~ J.I~.CT T~. DEBT. (Lfyot~ have filed b~nl:ruptcy you can still apply for ]Emergency Mortgage AssL~ta.~ce.) RECEIVED TIMENOV, 5, 5:12PM PRINT TIMENOV, 5, 5:I?PM Nov-O5-01 O$:0gpm From-MIDLAND MORTGAGE REFERRAL T-741 F.OS/1Z HOW-TO CURl:_ YOUR MOR. TGACE DF-FAUI.T (Bria~ it up r0 date), NATURE OgTELgDEF^IrL. T-ThcMORTGAGE dcbtheldbytheabovelenderonyoat property located g. 402 N FILBERT £T MEC~ICSBURG Pa 17055-3329 IS SERIOUSLY IN DEFAULT because YO[I [L~VE NOT MADE MON'Iq:H ¥ MORTGAGE PAIqVlXNTS tbr the following months and the following amounts arc now due: · To~alDue$3iT1.46 UHICIt INCLUDES: (a) Monthlypaymcntsfro;a t/1/Ol {brough 101.11ol _ (at $'613 . 66 PER a0N'rlt) (b) Uncollected Late Charges and Fccs HOW TO CI/R~ _TH3E B£}~AULT - You may curt the default w~r. hm ~'L'Y (30) DAYS of ~c ~ce or.ts nohce BY PAnG ~ TOT~ ~0~ PA~ D~ TO T~ ~ICH IS } . PLUS ~ MORTGAG~ PA~E~S ~ LA~ C~GES ~ICH BECO~ PAST 1)~ D~G ~ ~ (30) DAY P~OD. P~enzs must he ma~e either ~v cash c~hicr's ch~k. g~fi~d ch~or money or~r ~ ~avabl~aM s~t ~: Ama: CasMcrs M~dlaad Mortgage Co. P.O Box 268888 Oklahoma C~ty, OK 73126 IF YOU DO NOT CURE TIKE DEFALfI.T - If you do not care the der'auk within THIRTY (30) DAYS ofthe date of flus Notice, the le~der intends to exercise irs .riohts to accelerate Cbc mort_ease debt. '~s means that the ennrc 6utscandmg balance Of this debt Wdl b~ considered due ~mmcd~aIcly :,nd you may lose thc chance rD pay thc motngagc in monthly mstallmenm 1£ full paymcm of cbc total amo,,,~ pas~ due ts not made w~thin THIILTY (30) DAYS, the lender olio Iotcad$ to tll~llq, l¢l its atxoille~$ to Sr.,~rI legal actiun to foreclose u_noo Your mor?aeed Drone _r~v. ~L,~_.i~_~IAC F- {.q. gORE. CI.OS._~D UPON - T~e mortgaged propervy will be sold by the Shcnffto pay offthe mo~gage dcbL If the lcndeT refers your case to tts attocuey$, but you cure thc delinquency b.~forc ~e lender begins legal proceedings agam$] you, you will sull bc rcqutrcd to pay the reasonable auomey's fccs chat were actually mcurr~d, up to $50.00. However, tf l~gal procced,ags are star,ed against you, you Wql have m pay all reasonable atlomey's fees actually incm-rcd by thc lender even if chcy exceed $50.00. wdl b= added to thc amount you ow~ thc lcnd~r, which may include other reasonable costs If you cure the default wkhia the TH3[I~'I~¥ t301 DAY period. ¥otl will uet be required ¢0 p.~ arcorqe .v.'s fees. QTFEER LENDER REMEDIES - The lender may also sac you personally lbr the unpmd Pnnmpal balance and all other sums due under ~he motxgallc 1~ (CI'~T TO L~RtJE TI~ DI~FAIIt. T PRIOR TO S~RIFF*S S~E -If you have aDC ct,rca ~c default ~tr. ~e ~ffi~ (30) DAYjp~od ~d tbrccl~ pcocccdinas have bc~, y~ S~][ have thc fi!bi I9 c~c rhc dcfa~}t and hrcv~g the sale at ~nv nme up to.one hour bci~c che Shed's Sale. Yo~ ~v do soby pgyin~ the to~l amn~t th~ oas[ duc. olt~ any lace or oth~ 9harRes then due re~onable aaom,v's fees and coscq conn~cmd ~th th~ lbrcclosm'e sal~ ;m4 any olher costs c,mn~cte~ w,~ ~hc ~l,~s Silo as s~fied in ~nne by thc len~ ~ ~ pcrfomme any e,~ber reomremeq~ ~der ~h~ mo~aage. Coring your aefault ia the ~am~er a~: F-{~6g RECEIVED TIMENOV..5, §:12PM PRINT TIMENOV, 5. 5:17PM Nov-05-01 05:lOpm From-MIDLAND MORTGAGE REFERRAL T-?41 P.O$/IZ F-$6~ forth iu this uotic-~ will re,'tore your mortg~§c to the $:tme position 2s if you bad never defaulted. F..~.I~ I_I~.ST POSSIBLE such a Shcn~s S~Ie of ~c mortgaged prop~ could be held woulU he approx~ately moaths from ~he date of lhi~ ~nt to you before ~he sale Ofco~. ~e amo~ nc~ded zo c~e &~ d=fault ~11 mcre~s= the loag~ you ~i[ You may ~nd out exactly wha~ ~e required pa~ or action wdl bc by con.cilag thc t~nder. ~_OW TO CON'I ACT TM btidland Mortgage Co. P O. Bo~c 26648 Gldahoma City, OK 73126 Phone (800) 552-3000 Fax (-'I0~) 946-267'/ £I~'C'T OF RRRRIFI~'S SAI ~ - You !hould rcahze t~c = Sh~ffs SaIc wi~ end yo~ o~e~p of ~e mo~ed prop~ and yo~ nSht to occupy tr. If yoo conRnae to liv~ h~ u~e prope~ afi~ ~ Shea~s Sale. a [a~suR ~o remove you and yo~ ~is~gs a~ o~cr belon~ngs could be s~aed by ~ I~d~ at any nme. . ASSUMpTION OF' MORTCAC£ - You may or may not be able m s~ll or transfer your home to a buyer or transferee who vail assume mc n,ortguge debt. depending on thc terms ~nd condmons outlir~:d m your mot-tgag~ and prowd~d that all tile outstanding paymc~t~, cha~gcs m,d a~xomey's fees a~d costs are paid prior to or at ~c sale and a~at ~e o~cr rcqusrcments of~hc mo~gage ~= sa~sfied. '1 yOU M~-¥ ~[.SO RAVE- T]R~ RIGHT: TO SELL THE PROPERTY TOOBTAIN MONEY TO PAY OFF THE MORTGAGE DHI~T OR TO BORROW MONEY FROM ANOTHER I_ENDIIqG INSTrl'UTION TO PAY OFF TI.Ltl DEBT. TO HAVE THI.'; DEFAULT CURED BY ANY ~ PARTY ACTING ON YOUR BEHALF. TO HAVE ~ MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF,~.LfLT H.~D OCCUR.RED. It: YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS KIGI-rf' TO ~ YOLrR DEFAULT MORE ~ TI. tI~E 'liMES 1}4' C~.LENDAR YEAR.) TO ASSERT TFIE NObFE~ClRTENCE OF A DEFAULT [~I ANY FO~CLOS~ PROCEFD~G OR ~ O~ L~WSUIT ~S~TED ~ER~ MORTGAGE TO ~SERT A~ O~K D~ENSE ~GLI BEL~ YOU MAY 1~ TO SUCH AC~ON BY ~HE LENDE~ TO SEEK PRCTECTION UNDER FEDER_M_ BA. NrK=R.UPTCY LAW RECEIVED TIMENOV..5. 5:I2PM PRINT TIMENOV. 5. 5:lTPM Nov-05-01 05:10pm From-MIDLAND MORTGAGE REFER,.RAL T-?41 P.0?/IZ F-569- Midland Mortgage Co. P.O. ]~ox Oklahoma City, Oklahon~a 7312& OC~OB£R ~, 2001 JgAl~£ k RITI'£~ 402 N FILg£RT ST 17055-3329 ACT91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an ol~ficlal aonc= zhat the mnr~ea~c on your home is itl dcfa~lt, and the Itnd~ ;ot~ds to fo~reclosc. R~cific info~a~on about the na~ of&e ~fs~llt iS provided in the a~acl~ed ~e HOMEO~R'S MO~TQAGE ASSIRTANCE PROG~ [HEM~ n~av be abl~ heln ro save ~o~r home l~s nt~ce ~x~laias how ~e vromm works. To ~ee if ~M~P c~ h~lp. you must ~ ~ A CONS~ER C~I~ CO~REL~G ~G~CY ~ 30 DAYS OF THE DA~ OF '~IS NO~CE Take ~iS Nonce with you w~en you me~I wi& the Cotmsehne Agency. ~e nonce ad~s. ~d nhone num~ of~onsum~ Credit Coag~ehne A~eneics s~R Co~ ~e .istc~ at ~he ,n~ of lh~s No,ce- If voa ~vc a~v o[~e,~ions you may call the Pc~svlvanm ~gusine Finnncc Ae~cv ~oll flee at I-8~-34~-2397 (P~n~ ~th hc~ng cun call (71T~ 780-1g69. ~ss Noecc co~s ~po~nt legal mf~don. If you haw my qu~6ons, r~rcscnrarives ~ Consumer t.~ir Co~sglmg Agen~ may be able to help explain lt. You may also wmt to contact ~ a~mey in yo~ ~. ~c l~al b~ ~s~anon rosy bc able to help you find a LA NOTIFICA,2ION £N ADJ'UNTO £g DE SUM.~..LM,.LaORTtx.NCL~., PLIES ,a,.FECT^ gU DER.ECHO ,,% CON'rI'NUA.R V1VIENDO EN SU C.~.$^. SI NO COMPII. E'NDE EL . RECEIVED TIMENOV.,5. 5'I2PM PRINT TIMENOV. 5, 5:lTPM "-'- Nov-05-01 F-$6~ 05:I0pm From-MIDLAND MORTGAGE REFERR, AL T-?41 P.OII/I?, forth in this aj0nc,- will restore your mortg-ge to the szme position as if you lsd never defaulted. £~RLIEST POSmIRLK SI:tER11~F'S SA[Ii' DATE - It ts est~at=d tha~ ~e carhest da~ ~at such a Shen~s Sa,e of thc mortgaged pro~ could be held would be appro~ately S~ months from the date ofth~ Notice. A notice o[~c ~c~l ~te o~che Shed,s Salt wdl ~ to you ~ore ~ sale O~course, ~c amount needed to c~c th~ default wdl increase the longer ~o~ wait. ~'ou m~y find out e~fly w~t m~ rcqmrcd pa~t or denon will ~ by conmcnng the l~er. FlOW TO CONTACT TH~ LENI)ER: M~dland Mortgage Co P.O. Box 26648 Odahoma City, OK 73126 Phort¢ (800) 552-3000 Fax (405) 946-2677 £FFECT OF SI:[£RI~'Ir'S SALR - You should realize that a S~fifrs Saic o~hip of ~, monga~d pro~ ~d yo~ fight m occupy it. lfyou prope~ after thc Sheriffs Sale, a lawsuit m remove you ~d yom ~ishmgs ~lon~ngs could ~ s~e~ ~y me l~der at any ~SS~PTION OF MORTCACE - You may or may not ~ able m sell or ~sfer your homr m a buyer or ~.f~e who ~11 assu~ ~ mongag~ debt. depending on mc m~s and con~lfi0ns ouffined m yo~ mortgage md pro, dod ~hat all ~h~ ou~mding pa~en~. a~omey's fees ~d costs ~ paid prior to or at ~ ~le ~d ~t me omar ~qmremenm YOU M.~¥ M~$t') HXv~ TH~ POGRT.: TO SELL THE PROPERTY TO OBTAIN MONEY TO P^ ¥ OFF TI-IE MORTGAGE DI?..fiT OR TO BOP, ROW MONEY FROM ANOTHER LEND'lNG INSTITUTION 'fO PAY OFF TH£ DEBT. TO HAVE TI-lIS DEFAULT CURED BY ANY TH]RD PARTY ACTING ON YOUR BEHALF. 1:O HAVE 't'ltE MORTGAGE RESTORED TO THE SAME. POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CUI~ TEE DEFAULT. (HOW"EVEP-, YOU DO NOT HAVE THIS RIGHT TO CURE YOIj'K DEFALrLT MORE THAN TH2~E TIMES IN ANY CALENDAR TO ASSERT T}[E NONEXISTENCE. OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT A2qY OTHER DEFENSE YOU BELIEVE YOU MAY FAME TO SUCH ACTION BY/~{]~ LENDER. I TO SEEK PRO'rECTiON UNDER FEDERAL BANKRLIP'rCY LAW RECEIVED TIMENOV., 5. 5:lPPM PRINT TIMENOV. 5. 5'1?PM Nuv-O$-OI 05:llpm From-MIDLAND MORTGAGE REFERRAL T-741 P.09/I~ F-56~ LA NOTR~ICACION EN A~)JlJKTO ES DE SUIvtA b%~PORT~CL% PLrI~S ~A SU DE~CHO A CO~ ~I~O EN SU CASA. Si NO CO~E EL CON~O DE ESTA NO~ICACION OBTENGA ~A T~UCCION ~EDIT~N~ LLanO ESTA AGENC~ ~E~S~V~ HOUS~G F~CE AG~C~ S~ C~GOS ~ ~PKO ~NCION~O ~A. PUEDES ELEG~LE P~ ~ P~ST~O PR EL PROG~ ~O "HOMEO~R'S E~RG~CY MORTGAGE ASSIST~CE PROG~W' EL CU~ PU~E S.~V~ SU CASA DE ~ PE~A DEL D~CHO A ~D~ SU ~O~CA. Homeowner's Name(s) · Proper~ Address. Lo~ Accoun~ No.' LcndedScrvicer: DONALD ~ RITTER JEAI~NE K RITTER 402 N FILBERT ST HECP,~ICSBURC PA' t9055-3329 44234500 ~ldland Moag~ge Co. HOMEOWNER'S EIVEE RGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BF-- ~L[GIB~E FOR I~ANCI~.~ ASSISTANCE.W'KIC~ C~ SAvE YOIfR HOME FROM FORECLOSLn[~ ~ gfl?~ .p yOU MAKE FUTUR.~ MORTGAGE IF YOU COtVLI'LY WITH TEE PROVISIONS O$' T~rF EIOMEOWNER'S EMXRGENC¥ MORTGAGE ASSISTANCE ACT OF 1983 (Tgr~ ".n. Cl'"), YOU M.~¥ BE ELIGIBLE FOR EM~RGI~2NCY MORTGAGE ~,SSt-,-'TANCE: 1~ YOL~ DEFAULT HAS BE£N CAUSED BY CIRCUMST.'-~NC£S BE¥O~fD YOUR CONTROl, IF YOU RAVE A REASONA-~LE PROSPEC£ OF BEING ABLE TO PAY YOUR MORTG.,kCE PAYNIENTS, AND ~ YOIl M~EET OTI~ER ELICI'BDL~ i~EQLIII~4~EL~I'S EST.~.BLISHED BY ~ PEN~NSYLV.~Nv~A ROUSING .4.GENCY. TEM'PORARY STAY OF FOR F..CLOSURIg - Under thc ~ct, you are enrided to a t~mporm5 s~y of ~o~clos~e on yo~ mo~gsge for ~ (30) ~ys ~om ~mg you m~t ~,~gc ~ a~G a "~cc-~-fuce" ~cc~g co--cling agencies li~m~ ~t ~e end of t~s No,cc. ~S ~ET~C ~ l~ OC~ ~'N ~ ~ {301 D~YS. ~ ~OU DO NOT ~PPLY FOR EMERG~CY p~ORTGAGE ,kSSIgT~CE. YOU ~.IST B~G YOI~ MORTGAGE t~ TO D.~. TH'E P~T OF T~S NO~CE CAI ~ ~ "HOW TO C~ ~L~R ~(~W TO B~G YO~ MORTGAGE UP TO DA~. RECEIVED TIMENOV, ,5. 5:12PM PRINT TIMENOV, 5. 5:I?PM No¥-05-01 05:llp~n Frms-tdIDLAND MORTGAGE REFERRAL T-?41 P.IO/I;. F-$$~ CONS1 ,fME, R 'CREDIT COUNSELING AGENCIES - If yo~ ~v. cer wl~h one of the consumer credit counseling ag:ncics listed at the end of this Notice, file lender may NOT take action against you thc thirty (30) a~ys attar the date ofthss meeting. The names addresses anti tcleohonc pumbcl',~ of dee;tinseled colasumcr er. edit counseling R~enci~ foe t~c eotmrv in which thc nfo@rely i-~ located are set fn.rttLat t~.e encl ufO,s Notice It is only necessary to ~chedule one face-to-face meeting. Ad~s~ yotu' lender tmmedtqt¢l¥ ofyo~ intentions. ApPLIC.~,TION I~OR MORTG,AGI~ ASSISTANCE - Yo~ montage is m det~ulr for the rea~on~ sc~ fo~ la~ m ~ Nonce (see tbllowmg p~ge~ the ~ec~fic i~o~ahon ~bou~ ~e na~c ofyo~ def~lt.) If you have mod and are ~able to reioNe ~s problem with ~e len~, you have the dCM tO apply for fm~c~al assisl~ce ~om ~c Homeo~er's Em~gency Montage ~s~st~c~ ~o~. To do ~, you mc~ ~11 out, si~ and file a comple~d Homeowner's Emergency Monroe A~st~c= ~o~ applicanon ~Ih one of the d~si~ted consumer ~ed:t co~ehng al:enctes listed at the end oftMs No,ce. ~ly cons~er credit co~sehng agencies have applica~ons for ~e pro~m and they ~ll ~sist you m subm~ulng a complet~ applieatmn to ~ Pe~ylv~ia Housm$ Finance Agency. Yo~ apphcation ~s'r ee filed or pos~arked ~tn ~ (30) days of yo~ face-to-~e m~ung. YOU M~I-~,T FILl: YOUR APPLICATION PROMPTLY. fl; YOU Fall TO DO SO ORIi: YOU DO NOT £O~ LOW Tm?. OTI~R TIME P£RIODS .~T FORT~ IN LETT£R, fOReCLOSURE MAY PROCEED AGM'NST AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WII.L BE'DENIED. &GENCY ACTIO..~N - Available funds for emergrncy mortgage ass:stance are veo bruited. They will b,- disb,,'sed by the Agency under me eligibility criteria estabhshecl by thc Act. The Permsylvama Hou,..mg Finance Agency has smt~, (60) days m make a decision al:~r ~t receives your application During that time, tm fbrcclosure procecdhigi will be pursued against you ifyoti have met the rime -equlrementi set forth aboye. You will be notified directly by the Pennsylvama I-'lousing Finance/.gency of ~ts deciiion on l/our applieanon. NOTE: IF YOU AI~ CURRENTLY PROTXCTED BY T _n~" FILING OF A PETITION IN 8ANItRUPTCY, ~ FO~_ ~-OWING P.~'ZT OF THIS NOT1C£ IS FOR [NFOI~TION PURPOSES ONLY AND SHOLr~ n NOT BE CONSIDERED AS AN ATTEMPT TO COLt-~rcT T~rV DEBT. (If you have fund bankruptcy you can slut apply for Emergency Mortgage Assistance.) RECEIVED TIMENOV.,5. 5'12PM PRINT TIMENOV. 5. 5'lTPM Nov-05-01 05:llpm From-MIDLAND MORTGAGE REFERRAL T-?41 P.11/I~ F-g6g HOW-TO (:LIRE YOUR MO'RTCACE DEFAULT ('Briup it up ro d'~(e). N_..~[~I~_~/~:: DEFA[ILT - The MORTGAGE deOt held by the above lcnd,'r on your proper~ located at: ~,02 N FILBERT ST ~C~ICS~U~ PA 17055-3329 KS SEKIOUSLY IN DEFAULT because YOU I:La, VE NOT M.~OE/vlONTfll. Y ~vtORTCAGE PAY~vtlrNTS for thc following months and the foll'~wing amounts ate now past due: · Total Due $ 31/1. 46 I~ItlCH INCLUDES: Ca) Monthly pi,yments from 6/1/01 0'wough 10/1/0l OrS 613.66 per mon£h) ~) Unco~lecr~J Lzt~ Charges and Fe~ How TO CURE THE D£FAULT - You may cure the default within THIRTY (30) DAYS of thc date of this no~:ce BY PA~q~NC TKE TOTAL AlvlOUNI' PAST DUE TO TIlE LENDER, ~rl/1CK IS $ ~ PLUS ANY MORTGAGE PAYlVIENTS AND LATE CHARGES WHICIi BECOME PAST DUE DURING THE THIRTY (30) DAY PERIOD, Payments must be made either by ca~h, ca$1~'~ chc. ck, cccttKcd cheek or money order trade navablc and ~ent Arm. Casl,icrs Mialand Mortgage Co P.O. Box 268888 Oklahoma City. OK 73126 IV YOU DO NOT CUR~ THE DEFAULT - tfyo~ do not c~ thc default w~th~n ~ (30) DAYS oft~ ~ oft~s Noucc, the lender ~ntegds to exercise its rieb[~,to ~c~ier~te tb~ mo~age deb~ ~s me~s t~t ~c cn~re ~u~ndm8 bal~ce offs debt ~11 bc coat.cd due t~edtatcl~ ~d you may lose ~c ch~cc tO pay ~c mortgage m monody ins~en~ ff full pa~t afdc m~l ~o~t ~ duc is nor ma~ ~m ~ (30) DAYS, the l~dcr also mtcn~ to ins~ i~ a~cys [o s~ legal acuon to foreclose a~oR your m~tPg~e~O~'u~er[y. ~:AC£ IS FORECLOSED UPON -T~e mortgaged property ~11 Oc sold by thc She~ffm pay afire mo~gagc dcb~. If~e lend~ r~ yo~ c~e to ~ a~omcys, but you c~e the dehnq~acy ~fore thc tender beans lck~l pt~ings ago:asr you, you will sail required to pay ~e rc~ouablc a~omcy's fees ~at were a~lly me.cd, up m $50.00. However,//legal pr~ee~gs are ~ncd asai~ you, you ~11 ~ve to ~y all re~onable a~mey's f~s ac~lly mc~ed by ~c lender even iI~y ~xc~d $50.00. ~y anom~y's fe=~ ~I1 be added to mc ~o~ you ow= ~e I~der, w~ch ~y mcl~ o~er r=~onable cos~. yoU cure thedef~ult ~tyn the T~ [~ DA~ ~eriad~ y9u ~ll eot be rqquired to aqor~ev'~ ~T~R LE~ER ~D~S - ~e len~ may al~ sue you p~onally for the ~pa~d pnncipal balmce ~d all o&~ su~ duc ~er ~e rnon~ge. RICHT TO qTURE THE DEF~IILT PR(OR TO SKERiIr~'S .~ALE - If you have not cured the default va~m th~ TH/KTY (30) DAYiPenUd and foreclosm-= procecdmgo- have bcg~n, you ~rill have the right to cv, g~ the default and ~fCv_cnt th= sale at any !qme un to one hoqr beforr Sheriff's, Sqle Yo,, may do so by pqyir~g, thc total amount then nas~ duc. nlus any late or charees then due. reasonable atzome¥'s, fees aqt~ costs ca~necp:d wntll t..he tbr=closure sale ~p¥ other cost} corrected ~i~ the Sttenfz's Sale as soectfied in writing bY Ibc l~nder and oer_formln~I any ,)th~' requirements under ~he/noneagc Caring your default ia the manner set RECEIVED TIMENOV. '5. 5'12PM PRINT TIMENOV. 5. 5ri?PM From-MIDLAND MORTGA~ REFEP.,RAL T-M1 P.1Z/IZ F-$6§ Midland Mortgage Co. P.O. Box 26648 Oklahomz City, Oklahoma 73126 Phou, c {aOO) $5"J--)flO0 Fax (~05) ~'~&-l&77 OCTOB£R 1, 2001 DONALD L RITTER &02 g F1LB£R~ ST I~CBA~ICSBUI~ PA 17055-3329 ACT91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Th~s ~s an officnd nonce that thc mortgage Oo your home is m default, and tile le.nd~r intends tc~ foreclose Soec~ fic informat/on abotlt t[le natul'e of the default ~s prqvided ,n thc attached pa_~c~. Thc HOMEOWNER'S .MORTG,~.GE ASSISTANCE PROGRAM (HEMI~.P) may be. able to h_.~l~ to Save your home Tbs nonce explains }iow thc ~roe~ran) works. To see ffHEMAP can help you must ME.I~Tr WITH A CONSUMER CREDIT C.t~[ ,]~ISELING AGENCY. WII'HI~ 30 DAYR OF THE OATE OF THIS NOTICE. Take ~}ns Nouce w~th when you me~ w~th the Counseling A~enc~. The name. ad,tre,~s and phone nu~.bcr of Consumer Credit Coanseline Agencies Set'ring your Count~ are listed at the end of this Notice. if you have {mY quesuons, you may call thc Pcnnsvlvan/a Hou.,/m~ Fina0ce A~cncy toll free at 1-R00-'t42-2397. {?er~ons with ~moatre. d. heanng ca~ call (717) 780-1869, Thss Nottce c, mtams important legal information. Ii'you ha,re any qu~:efions, represcnrauvca at the Consumer Credit Counseling Agency may be able to help explain it. You may also wa0t to contact an atto,ney in your area. The local bar association may be able to help you find a lao~yer. RECEIVED TIMENOV. '5. 5'12PM PRINT TIMENOV, 5. 5'ITPM VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for the Mortgage Foreclosure are tree and correct to the best of my knowledge, infom~ation, and belief based upon information provided by MIDFIRST BANK, Said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: November 21, 2001 Leon P. Haller, Esquire SHERIFF'S RETURN - ~ASE NO: 2001-06606 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDFIRST BANK VS RITTER JEANNE K ET AL REGULAR DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE was served upon RITTER JEANNE K the DEFENDANT , at 1840:00 HOURS, at 402 NORTH FILBERT STREET MECHANICSBURG, PA 17055 JEANNE K RITTER a true and attested copy of COMPLAINT - on the 5th day of December , 2001 by handing to MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.50 Affidavit .00 Surcharge 10.00 .00 34.50 Sworn and Subscribed to before me this /3~ day of ~~ j~f A.D. , tProthonotary ~ So Answers: R. Thomas Kline i2/i0/2001 PURCELL KRUG HALLER Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2001-06606 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERL/kND MIDFIRST BANK VS RITTER JEANNE K ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RITTER DONALD L the DEFENDANT , at 1840:00 HOURS, on the 5th day of December , 2001 at 402 NORTH FILBERT STREET MECHANICSBURG, PA 17055 by handing to JEANNE K RITTER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her 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 ~ ~ day of /P~othonotary ' So A~swers: R. Thomas Kline 12/lO/2OOl PURCELL KRUG HALLER By: Deputy Sheriff MIDFIRST BANK, PLAINTIFF VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 6606 IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants JEANNE K. RITTER AND DONALD L. RITTER for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $12.55 from 5/1/01 to 12/1/01) Late charges ($30.68 per month to 12/01) Escrow Deficit 5% Attorney's Commission TOTAL $35,236.12 $ 2,685.70 $ 184.08 $ 650.58 $ 1,761.81 $40,518.29.*~' ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & ~~ _ Le0n P-~. H ~/1<~ ~I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKF\DOCS\CUM BERLA\RII-FER.P MIDFIRST BANK, PLAINTIFF VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 6606 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on January 9, 2002 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By. ~/~_ Leon P. Haller PA I.D. #15700 Attorney for Plaintiff Purcell, Krug &Haller 1719 North Front St. Harrisburg, PA 17102 MIDFIRST BANK, VS. Plaintiff JEANNE K. RITTER AND DONALD L. RITTER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : NO. 01-6606 . : : CML ACTION LAW : IN MORTGAGE FORECLOSURE : DATE OF THIS NOTICE: January 9, 2002 TO: JEANNE K. RITTER 402 NORTH FILBERT STREET MECHANICSBURG, PA 17055 DONALD L. RITTER 402 NORTH FILBERT STREET MECHANICSBURG, PA 17055 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING ~ DEBT. IMPORTANT NOTICE YoU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE, CARLISLE, PA 17013 LEON P. HALLER, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2001 6606 MIDFIRST BANK, PLAINTIFF VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANT(S) TOTAL AMOUNT OF JUDGMENT $40,518.29 / Interest at $12.55 per diem to sale date $ 2,334.30 Late charges at $30.68 per month to sale date $ 153.40 Escrow Deficit $ 2,000.00 TOTAL $45,005.99* *SALE DATE: WEDS.,June 5, 2002 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above c apt i on, case. Date: March 12, 2002 Attorney for Plaintiff 1719 North Front Street Leon P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND : TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 402 North Filbert Street, Mechanicsburg, PA 17055. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY ~! THAT CERTAIN tract or parcel of-land with the improvements thereon erected situate in the Borough of Mechanicsburg, County of Cumberland and Commonwealth of Pennsylvania, being.more particularly bounded and described as follows, BEGINNING at a point on the easterly line of Filbert Street. which point is 78 feet North of the northeasterly corner of Portland and Filbert Streets~ thence along the easterly line of Filbert Street North 21 degrees 40 minutes West 58 feet to a point; thence North 68 degrees 20 minutes East 124,55 feet to a point~ thence Sou~h 21 degrees 40 minutes East 20 feet to a point; thence South ~ degrees 39 minuteSWest 66.?? feet to a point~ thence South degrees 20 minu~es West 69.65 feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS402 NORTH FILBERT STREET, MECHANICSBURG, PA 17055 BEING THE SAME PREMISES WHICH Helen L. Lowe by deed dated 8/26/83 and recorded 8/29/83 in Deed Book 1-30, Page 837 granted and conveyed unto Donald L. Ritter and Jeanne K. Ritter. TO BE SOLD AS THE PROPERTY OF DONALD L. RITTER AND JEANNE K. RITTER ON JUDGMENT NO. 2001 6606. PARCEL: 18-822-0519-148 MIDFIRST BANK, PLAINTIFF VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 6606 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUA/~T TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug &Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 402 NORTH FILBERT STREET, MECF~%NICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): Jeanne K. Ritter 402 North Filbert Street Mechanicsburg, PA 17055 Donald L. Ritter 402 North Filbert Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: First Deposit National Bank 219 Main Street Tilton, NH Valerie Park Rosenbluth, Esquire 25 E. State Street P. O. Box 1779 Doylestown, PA 18901 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I ~erify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. /~ Leon P. Haller PA I.D. #15700 Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 12, 2002 MIDFIRST BANK, PLAINTIFF VS. JEANNE K. RITTER AND DONALD L. RITTER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2001 6606 : : IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, June 5, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 402 North Filbert Street Mechanicsburg CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2001 6606 THE NAME(S) OF THE OWNER(S) OR REPUTED OW1FERS of this property is: JEANNE K. RITTER AND DONALD L. RITTER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE Tt~E AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights ~o prevent your property from being taken away. A lawyer can advise you more specifically of these rmghts. If you wish to exercise your rights, YOU" MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the CourE of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment agamnst you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution-is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Al! THAT CERTAIN tract or parcel of-land with the imprOvements thereon erected situate in the Borough of Mechanicsburg, County of Cumberland and Commonwealth of Pennsylvania, being.more particularly bounded and described as follows, BEGINNING at a point on the easterly line of ?ilbert Street, which point is 78 feet North of the northeasterly corner of Portland and Filbert Streets; thence along the easterly line of Filbert Street North 21 degrees 40 minutes West 58 feet to a point; thence North 68 degrees 20 minutes East 124.55 feet to a pointl thence South 21 degrees 40 minutes East 20 feet to a Pointl thence South 3~~ degrees 39 minuteS West 66.?? feet to a point; thence South 68 degrees 20 minutes West 69.65 feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS402 NORTH FILBERT STREET, M~CHANICSBURG, PA 17055 ~BEING THE SAME PREMISES WHICH Helen L. Lowe by deed dated 8/26/83 and recorded 8/29/83 in Deed Book 1-30, Page 837 granted and conveyed unto Donald L. Ritter and Jeanne K. Ritter. TO BE SOLD AS THE PROPERTY OF DONALD L. RITTER AND JEANNE K. RITTER ON JUDGMENT NO. 2001 6606. PARCEL: 18-822-0519-148 Midfirst Bank VS Jeanne K. Ritter and Donald L. Ritter In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6606 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Leon P. Haller. Sheriffs Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 25.20 Mileage 13.80 Levy 15.00 Advertising 15.00 Certified Mail 1.44 Poundage 12.12 Law Joumal 265.40 Patriot News 193.75 $618.21 Sworn and subscribed to before me This 2002, A.D. , L9 Prothonotary So Answers: R. Thomas Kline, Sheriff Real Estate ~Jepu~y