HomeMy WebLinkAbout09-7132LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
1310 INDUSTRIAL BOULEVARD
I" FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
ATTORNEY FOR PLAINTIFF
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY AS
TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
800 STATE HIGHWAY 121 BYPASS
LEWISVILLE, TX 75067-4180
PLAINTIFF
VS,
VICKIE A. THORSON,
A/K/A VICKIE L. THORSON
111 WEST SOUTH STREET
CARLISLE, PA 17013
DEFENDANTS
NOTICE
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. D2 -'1'l3;L,
t'_7i, 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 defense 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEF, OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
800-990-9108
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C § 1692 et 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.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30)
DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO
COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER
TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS,
YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF
THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF
YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE
ORIGINAL. CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON
YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS
SUIT.
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
1310 INDUSTRIAL BOULEVARD
I s' FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
ATTORNEY FOR PLAINTIFF
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY AS
TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
800 STATE HIGHWAY 121 BYPASS
LEWISVILLE, TX 75067-4180
PLAINTIFF
VS.
VICKIE A. THORSON,
A/K/A VICKIE L. THORSON
1 1 I WEST SOUTH STREET
CARLISLE, PA 17013
DEFENDANTS
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. O ?- ?132 6,?t I
COMPLAINT IN
MORTGAGE FORECLOSURE
CIVIL ACTION MORTGAGE FORECLOSURE
1. EMC Mortgage Corporation, Attorney-in-fact for Deutsche Bank National Trust
Company as Trustee, f/k/a Bankers Trust Company of California, N.A. as
Custodian or Trustee for UCFC Loan Trust 1998-D (hereinafter referred to as
"Plaintiff') is an Institution conducting business under the Laws of the
Commonwealth of Pennsylvania with a principal place of business at the address
indicated in the caption hereof.
2. Vickie A. Thorson, a/k/a Vickie L. Thorson (hereinafter referred to as
"Defendant") is an adult individual residing at the address indicated in the
caption hereof.
3. Plaintiff brings this action to foreclose on the mortgage between Defendant and
itself as Mortgagee by Assignment. The Mortgage, dated November 2, 1998,
was recorded on November 5, 1998 in the Office of the Recorder of Deeds in
Cumberland County in Mortgage Book 1495, Page 548. A copy of the Mortgage
is attached and made a part hereof as Exhibits `A'.
4. The Mortgage secures the indebtedness of a Note executed by the Defendant on
November 2, 1998 in the original principal amount of $55,700.00 payable to
Plaintiff in monthly installments with an interest rate of 9.25%. A copy of the
Note is attached and made a part hereof as Exhibit `B'.
5. The land subject to the mortgage is 111 West South Street, Carlisle, PA 17013.
A copy of the Legal Description is attached as part of the Mortgage as
Exhibit `A' and incorporated herein.
6. The Defendant is the Record Owner of the mortgaged property located at
I 1 1 West South Street, Carlisle, PA 17013.
7. The Mortgage is now in default due to the failure of Defendant to make payments
as they become due and owing. As a result of the default, the following amounts
are due:
Principal Balance $66,993.09
Interest to 10/6/2009 $2,666.94
Accumulated Late Charges $242.14
Escrow Advance $658.92
Recoverable Balance $1,107.58
Cost of Suit and Title Search $1,400.00
Attorney's Fees $1,300.00
TOTAL $74,368.67
plus interest from 10/7/2009 at $16.98 per day, costs of suit and attorney's fees.
8. 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 purchase at Sheriffs sale. If the Mortgage is reinstated prior to the Sale,
reasonable attorney's fees will be charged.
9. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a
defaulting mortgagor with a Notice of Intention to Foreclose ("Act 6 Notice") 41
P.S. Section 403 and Notice of Homeowners' Emergency Mortgage Assistance
("Act 91 Notice") 35 P.S. Section 1680.403c.
10. The Notice of Intention to Foreclose and Notice of Homeowners' Emergency
Mortgage Assistance were required and Plaintiff sent the uniform notice as
promulgated by the Pennsylvania Housing Finance Agency to the Defendant by
regular and certified mail on July 13, 2009. A copy of the Notice is attached and
made a part hereof as Exhibit `C'.
WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale
of the mortgaged property in Plaintiff's favor and against the Defendant, in the sum of $74,368.67
together with the interest from 10/7/2009 at $16.98 per day, costs of suit and attorney's fees.
Law Offices of Gregory Javardian
BY: Torne Ja r a
y ID 55669
y for aintiff
EXHIBIT `A'
-d?f
Loan No: 034401057566
Borrower: VICKIE A THORSON
Tax Parcel Identification Number:
Data ID: 627
0i OEFw? (b,
+4
' VP:. , . "i0 COUNTY- F'A
'98 NOU S PM 3 111
Return to: UNITED COMPANIES LENDING CORPORATION*
750 E. PARK DRIVE
HARRISBURG, PA 17111
[Space Above This Line For Recording Data]
MORTGAGE
NOTICE TO ASSIGNEE
NOTICE: This is a mortgage subject to special rules under the federal Truth in Lending Act. Purchasers or
assignees of this mortgage could be liable for all claims and defenses with respect to the mortgage that the borrower
could assert against the creditor.
THIS MORTGAGE ("Secy ty Instrument") is given on thel <Ovtcox m er, 1The mortgagor is VICKIE A1?SON , A SINGLE WOMAN 0- rC Z /f .L.?
whose address is 111 W SO STREET, CARLISLE, PENNSYLVANIA 17013
("Borrower").
This Security Instrument is given to UNITED COMPANIES LENDING CORPORATION, A CORPORATION, which
is organized and existingyder the laws of the State of LOUISIANA, and whose address is 4041 ESSEN LANE, BATON
ROUGE, LOUISIAN 70809
("Lender").
Borrower owes der the principal sum of FIFTY-TIVE THOUSAND HUNDRED and NO/100-----Dollars
(U.S. $ 55,700. . This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"),
which provides for monthly payments, with the full debt, if not paid earlier, due and payable on December 1, 2028. This
Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all
renewals, extensions and modifications of the Now, (b) the payment of all other sums, with interest, advanced under
paragraph 7 to protect the security of this Security Instrument, and (c) the performance of Borrower's covenants and
agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and
convey to Lender the following described property located in the City of CARLISLE, CUMBERLAND County,
Pennsylvania:
SEE LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF
PENNSYLVANIA - single Family-MODIFIED Fermis Mee/Froddie Mac UNIFORM INSTRUMENT
Farm 303a 3/98
(Page 1 of 8 Pages)
*Which has the address of 111 W SOUTH
Pennsylvania [AP Ul
Toom Wrrx all the improvements now
and fixtures now or hereafter a part of the propert;
Instrument. All of the foregoing is referred to in
BORROWER CovENANTS that Borrower is
mortgage, grant and convey the Property and tha
Borrower warrants and will defend generally the
encumbrances of record.
THIS SEcuRrrY INSTRUMENT combines unifo
variations by jurisdiction to constitute a uniform s
UNIFORM CovENAm. Borrower and Lenc
1. Payment of Principal and Interest Pr
the principal of and interest on the debt evidenced '
2. Funds for Taxes and Insurance. Subj
pay to Lender on the day monthly payments are d
(a) yearly taxes and assessments which may attain
yearly leasehold payments or ground rents on the 1
yearly flood insurance premiums, if any, (e) yeart
Borrower to Lender, in accordance with the prov
premiums. These items are called "Escrow Items.
to exceed the maximum amount a lender for a fed(
under the federal Real Estate Settlement Procedl
seq. ("RESPA"), unless another law that applies
collect and hold Funds in an amount not to excee
on the basis of current data and reasonable estima
with applicable law.
The Funds shall be held in an institution w
(including Lender, if Lender is such an institution,
to pay the Escrow Items. Lender may not charge
escrow account, or verifying the Escrow Items, ut
permits Lender to make such a charge. Howev
independent real estate tax reporting service used
otherwise. Unless an agreement is made or applic
pay Borrower any interest or earnings on the Fun(
shall be paid on the Funds. Lender shall give to 1
credits and debits to the Funds and the purpose f
as additional security for all sums secured by this
If the Funds held by Lender exceed the an
Borrower for the excess Funds in accordance with
by Lender at any time is not sufficient to pay the I
in such case Borrower shall pay to Lender the an
the deficiency in no more than twelve monthly pa
Upon payment in full of all sums secured t
any Funds held by Lender. If, under paragraph
acquisition or sale of the Property, shall apply air
against the sums secured by this Security Instrumc
3. Application of Payments. Unless app]
paragraphs 1 and 2 shall be applied: first, to any I
under paragraph 2; third, to interest due, fourth, 1
4. Charges; Liens. Borrower shall pay at
Property which may attain priority over this Sec
Borrower shall pay these obligations in the mane
shall pay them on time directly to the person owe
amounts to be paid under this paragraph. If Borr
to Lender receipts evidencing the payments.
Borrower shall promptly discharge any lien
agrees in writing to the payment of the obligation,
good faith the lien by, or defends against enforce
operate to prevent the enforcement of the Hen; of
Lender subordinating the Hen to this Security Insti
to a lien which may attain priority over this Securil
Borrower shall satisfy the lien or take one or more
t?
r
icevl CARLISLE,
("Property Address");
it hereafter erected on the property, and all easements, appurtenances,
All replacements and additions shall also be covered by this Security
this Security Instrument as the "Property."
awfully seised of the estate hereby conveyed and has the right to
the Property is unencumbered, except for encumbrances of record.
title to the Property against all claims and demands, subject to any
m covenants for national use and non-uniform covenants with limited
curity instrument covering real property.
;r covenant and agree as follows:
payment and Late Charges. Borrower shall promptly pay when due
y the Note and any prepayment and late charges due under the Note.
ct to applicable law or to a written waiver by lender, Borrower shall
e under the Note, until the Note is paid in full, a sum ("Funds' for.
priority over this Security Instrument as alien on the Property; (b
roperty, if any, (c) yearly hazard or property insurance premiums; (d)
mortgage insurance premiums, if any; and (f) any sums payable by
dons of paragraph S, in Heu of the payment of mortgage insurance
Lender may, at any time, collect and hold Funds in an amount not
-ally related mortgage loan may require for Borrower's escrow account
-es Act of 1974 as amended from time to time, 12 U.S.C. $ 2601 et
J the Funds sets a lesser amount. If so, Lender may, at any time,
the lesser amount. Lender may estimate the amount of Funds due
z of expenditures of future Escrow Items or otherwise in accordance
ose deposits are insured by a federal agency, instrumentality, or entity
or in any Federal Home Loan Bank. Lender shall apply the Funds
Borrower for holding and applying the Funds, annually analyzing the
ess Lender pays Borrower interest on the Funds and applicable law
r, Lender may require Borrower to pay a one-time charge for an
y Lender in connection with this loan, unless applicable law provides
Lble law requires interest to be paid, Lender shall not be required to
Borrower and Lender may agree in writing, however, that Interest
orrower, without charge, an annual accounting of the. Funds, showing
r which each debit to the Funds was made. The Funds are pledged
ecurity Instrument.
)unts permitted to be held by applicable law, Lender shall account to
he requirements of applicable law. If the amount of the Funds held
crow Items when due, Lender may so notify Borrower in writing, and,
)unt necessary to make up the deficiency. Borrower shall make up
ments, at Lender's sole discretion.
r this Security Instrument, Lender shall promptly refund to Borrower
Z1, Lender shall acquire or sell the Property, Lender, prior to the
Funds held by Lender at the time of acquisition or sale as a credit
able law provides otherwise, all payments received by Lender under
epayment charges due under the Note; second, to amounts payable
principal due; and last, to any late charges due under the Note.
taxes, assessments, charges, fines and impositions attributable to the
irity Instrument, and leasehold payments or ground rents, if any.
provided in paragraph 2, or if not paid in that manner, Borrower
payment. Borrower shall promptly furnish to Lender all notices of
wer makes these payments directly, Borrower shall promptly furnish
vhich has priority over this Security Instrument unless Borrower: (a)
%cur'` by the lien in a'lnarnneX acceptable to Lender; (b) contests in
cent of the lien in, legal proceedings which in the Lender's opinion
(c) secures from the holder of the lien an agreement satisfactory to
iment. If Lender determines that any part of the Property is subject
Instrument, Lender may give Borrower a notice identifying the lien.
of the actions set forth above within 10 days of the giving of notice.
n Pact i?J"?v Form 3039 3198 (Page 2 of 8 Pages)
8eoKi4 v
R fy
Loan No: 034401057566 ` Data ID: 627
5. Hazard or Property Insuranm Borrower shall keep the improvements now existing or hereafter erected on
the Property insured against loss by fire, hazards included in the term "extended coverage" and any other hazards, for
which Lender requires insurance, including, but not limited to, floods or flooding, earthquakes or hurricanes (whether or
not such hazards are required to be insured against at the time the Loan is made). All insurance required by Lender shall
be maintained in the amounts and for the periods that Lender requires. The insurance carrier providing the insurance
shall be chosen by Borrower subject to Lender's approval, which shall not be unreasonably withheld. In the event the
Property improvements are now, or at any time during the term of this Security Instrument are determined to be, in a
Special Flood Hazard Area, Borrower must obtain and maintain flood insurance.
Borrower acknowledges and agrees that failure to insure the Property, which is the security for this agreement,
according to the terms and conditions of this paragraph 5 is an event of default subject to the remedies available to
Lender under this agreement. If Borrower fails to obtain or maintain any coverage described herein, Lender may, but
shall have no duty to, obtain such coverage or substantially equivalent coverage with an insurance carrier of Lender's
choice, protecting only bender's interest in the Property in accordance with paragraph 7, all at Borrower's expense.
Lender shall have no duty or obligation to obtain any insurance protecting Borrower's interest in the Property, or covering
risks for which Lender has not requited insurance, as described in the first paragraph of this paragraph 5, even if Borrower
has previously obtained or maintained such insurance coverage, including, without limitation, a homeowners policy. Lender
may, in its sole discretion, obtain insurance in whatever amounts and types Lender deems adequate to protect Lender's
interest in the Property, regardless of the unpaid balance remaining under the Note or the amounts remaining due under
this Security Instrument. For this purpose, Lender will deem its interests to be adequately protected by an insurance
policy with coverage equal to the value of the improvements located on the Property securing Borrower's loan. Lender
may determine the value of the improvements by assuming as accurate the value assigned to the improvements in the
insurance policy that Lender's records reflect was most recently held by Borrower prior to the insurance policy obtained
by Lender. Borrower acknowledges and agrees the amount may not be equal to the actual value or replaecment value
of the improvements, and any such insurance Lender obtains may not protect Borrower's interest in the Property.
Borrower acknowledges and agrees that the cost of the insurance coverage so obtained by Lender may significantly
exceed the cost of insurance Borrower could have obtained, as described in the first paragraph of this paragraph 5, if
Borrower had purchased the insurance directly, and further may provide Borrower with less or no insurance coverage
protecting Borrower's interest in the Property. Borrower further acknowledges and agrees that Lender may obtain any
such insurance directly or through an insurance agency or insurer affiliated with Lender and Lender or Lender's affiliate
may receive a commission or other compensation in connection with obtaining such insurance.
All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgagee clause.
Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender
all receipts of paid premiums and renewal notices. In the event that Borrower cancels a policy on the Property and
Borrower replaces it with a different policy, Lender may charge Borrower a reasonable fee (subject to applicable law, if
any) to change its records to reflect the new policy. In the event of loss, Borrower shall give prompt notice to the
insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. In the event Lender
acquires the Property through foreclosure or otherwise, Borrower assigns to Lender its rights to any refund of unearned
premiums and any other rights of Borrower under the insurance policy.
To the extent Borrower obtains any form of insurance coverage for the Property without being directed to do so
by Lender, such as flood, earthquake or hurricane coverage, such policy shall include a standard mortgagee clause and
shall name Lender as mortgagee. Any insurance proceeds from such policy shall be additional security for the Note and
Lender shall have the same rights to such policy and proceeds as it has with regard to Lender-required insurance policies
discussed in this paragraph S.
Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair
of the Property damaged, if, at Lender's sole discretion, the restoration or repair is economically feasible and Lender's
security is not lessened. During such repair and restoration period, Lender shall have the right to hold such insurance
proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to
Lender's satisfaction. Lender shall have the right to deduct fees for such inspections from the insurance proceeds unless
prohibited by applicable law or regulation. Fees for public adjusters or other third parties retained by Borrower shall not
be deducted from the proceeds and shall be the sole and separate obligation of Borrower. If, in Lender's sole
determination, the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance
proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid
to Borrower. Borrower shall remain responsible for any sums remaining due and payable under the Note and this Security
Instrument. If Borrower abandons the Property, or does not answer within 30 days a notice from Lender that the
insurance carrier has offered to settle a claim, then the proceeds will be automatically assigned to Leader. Lender may
use the proceeds to repair or restore the Property or to pay sums secured by this Security Instrument, whether or not
then due. The 30-day period will begin when the notice is given.
Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend
or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of the
payments of principal and interest due under the Note. If under paragraph 21 the Property is acquired by Lender,
Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior to the acquisition
shall pass to Lender to the extent of the sums secured by this Security Instrument immediately prior to the acquisition.
The provisions contained in this paragraph 5 are subject to limitations under applicable law, if any.
eoox 1495 PACE •54150 Form 3039 3/98 (Page 3 of 8 Pages
tI
6. Occupancy, Preservation, Malntenan
* ? and'P&teciion of the Property; Borrower's Loan Application;
eholds. Borrower shall occupy, establish, an
as use the Property as Borrower's principal residence within sixty days
afte
the execution of this Security Instrument and hall continue to occupy the Property as Borrower's principal residence
for at least one year after the date of occupancy, ess Lender otherwise agrees in writing, which consent shall not be
unreasonably withheld, or unless extenuating circa ristances exist which are beyond Borrower's control. Borrower shall
not destroy, damage or impair the Property, all w the Property to deteriorate, or commit waste on the Property.
Borrower shall be in default if any forfeiture action r proceeding, whether civil or criminal, is begun that in Lender's good
faith judgment could result in forfeiture of the Pr erty or otherwise materially impair the lien created by this Security
Instrument or Lender's security interest. Borrowe may cure such a default and reinstate, as provided in paragraph 18,
by causing the action or proceeding to be dismiss with a ruling that, in Lender's good faith determination, precludes
forfeiture of the Borrower's interest in the Proper or other material impairment of the lien created by this Security
Instrument or Lender's security interest. Borrower also be in default if Borrower, during the loan application process,
gave materially false or inaccurate information or tatements to Lender (or failed to provide Lender with any material
information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning
Borrower's occupancy of the Property as a princip 1 residence. If this Security Instrument is on a leasehold, Borrower
shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee
title shall not merge unless Lender agrees to the erger in writing.
7. Protection of Lender's Rights in the P roperty. If Borrower fails to perform the covenants and agreements
contained in this Security Instrument, or there is legal proceeding that may significantly affect Lender's rights in the
Property (such as a proceeding in bankruptcy, pro te, for condemnation or forfeiture or to enforce laws or regulations),
then Lender may do and pay for whatever is n sary to protect the value of the Property and Lender's rights in the
Property. Lender's actions may include paying any secured by a Gen which has priority over this Security Instrument,
appearing in court, paying reasonable attorneys' f and entering on the Property to make repairs. Although Lender
may take action under this. paragraph 7, Lender d es not have to do so.
Any amounts disbursed by Lender under t ' paragraph 7 shall become additional debt of Borrower secured by
this Security Instrument. Unless Borrower and Ls er agree to other terns of payment, these amounts shall bear interest
from the date of disbursement at the Note rate and shall be payable, with interest, upon notice from Lender to Borrower
requesting payment.
8. Mortgage Insurance. If Lender requir ed mortgage insurance as a condition of making the loan secured by
this Security Instrument, Borrower shall pay the emiums required to maintain the mortgage insurance in effect. If,
for any reason, the mortgage insurance coverage r aired by Lender lapses or ceases to be in effect, Borrower shall pay
the premiums required to obtain coverage substant' equivalent to the mortgage insurance previously in effect, at a cost
substantially equivalent to the cost to Borrower of mortgage insurance previously in effect, from an alternate mortgage
insurer approved by Lender. If substantially equiv ent mortgage insurance coverage is not available, Borrower shall pay
to Lender each month a sum equal to one-two of the yearly mortgage insurance premium being paid by Borrower
when the insurance coverage lapsed or ceased to a in effect. Lender will accept, use and retain these payments as a
loss reserve in lieu of mortgage insurance. Loss r erve payments may no longer be required, at the option of Lender,
if mortgage insurance coverage (in the amount and for the period that Lender requires) provided by an insurer approved
by Lender again becomes available and is obtain . Borrower shall pay the premiums required to maintain mortgage
insurance in effect, or to provide a loss reserve, u ntil the requirement for mortgage insurance ends in accordance with
any written agreement between Borrower and Len er or applicable law.
9. Inspection. Lender or its agent may ke reasonable entries upon and inspections of the Property. Lender
shall give Borrower notice at the time of or prior an inspection specifying reasonable cause for the inspection.
10. Condemnation The proceeds of any ward or claim for damages, direct or consequential, in connection with
any condemnation or other taking of any part of t he Property, or for conveyance in lieu of condemnation, are hereby
assigned and shall be paid to Lender.
In the evtnt'of h total taking of the Prope , the proceeds shall be applied to the sums secured by this Security
Instrument, whether or not then due, with any ex " paid to Borrower. In the event of a partial taking of the Property
in which the fair market value of the Property ' ately before the taking is equal to or greater than the amount of
the sums secured by this Security Instrument imm ely before the taking, unless Borrower and Lender otherwise agree
i
in writing, the sums secured by this Security Instru shall be reduced by the amount of the proceeds multiplied by the
t
following fraction: (a) the total amount of the sums secured immediately before the taking, divided by (b) the fair market
value of the Property immediately before the takin . Any balance shall be paid to Borrower. In the event of a partial
taking of the Property in which the fair market v lue of the Property immediately before the taking is less than the
amount of the sums secured immediately before a taking, unless Borrower and Lender otherwise agree in writing or
unless applicable law otherwise provides, the pro shall be applied to the sums secured by this Security Instrument
whether or not the sums are then due.
If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor offers
to make an award or settle a claim for damages, rrower fails to respond to Lender within 30 days after the date the
notice is given, Lender is authorized to collect an apply the proceeds, at its option, either to restoration or repair of
the Property or to the sums secured by this Secu Instrument, whether or not then due.
Unless Lender and Borrower otherwise agr, a in writing, any application of proceeds to principal shall not extend
or postpone the due date of the monthly payment s referred to in paragraphs 1 and 2 or change the amount of such
payments.
' . ' BOOK U95 Form 3039 3/98 (Page 4 of 8 Pages)
Pace 1551'
Loan No: 034401057566 Data ID: 627
11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for pamnent or
modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest
of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender
shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or
otherwise mod fi y amortization of the sums secured by this Security Instrument by reason of any demand made by the
original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall
not be a waiver of or preclude the exercise of any right or remedy.
12. Successors and Assigns Bound; Joint and Several Liability; Co-sers. The covenants and agreements
of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the
provisions of paragraph 17. Borrower's covenants and agreements shall be joint and several. Any Borrower who co-
signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage,
grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally
obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may
awe to extend, modify, forbear or make any accommodations with regard to the terns of this Security Instrument or the
Note without that Borrower's consent.
13. Loan Charges, If the loan secured by this Security Instrument is subject to a law which sets maximum loan
charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in
connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount
necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded
permitted limits will be refunded to 'Borrower. Lender may choose to make this refund by reducing the principal owed
under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated
as a partial prepayment without any prepayment charge under the Note.
14. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or
by mailing it by first class mail unless applicable law requires use of another method The notice shall be directed to the
Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by
first class mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any
notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given
as provided in this paragraph.
15. Governing Law; Severability. This Security Instrument shall be governed by federal law and the law of the
jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the
Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note
which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and
the Note are declared to be severable.
16. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument.
17. Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any
interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a
natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in full of
all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is
prohibited by federal law as of the date of this Security Instrument.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a
period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums
secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender
may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower.
I& Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower shall have the right to have
enforcement of this Security Instrument discontinued at any time prior to the earlier of- (a) 5 days (or such other period
as applicable law may specify for reinstatement) before sale of the Property pursuant to any power of sale contained in
this Security Instrument; or {b) entry of a judgment enforcing, this Security Instrument. Those conditions are that
Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no
acceleration d occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in
enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees; and (d) takes such action as
Lender may reasonably require to assure that the lien of this Security Instrument, Lender's rights in the Property and
Borrower's obligation to pay the surns secured by this Security Instrument shall continue unchanged. Upon reinstatement
by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration
had occurred However, this right to reinstate shall not apply in the case of acceleration under paragraph 17.
19. Sale of Note; Change of Loan Servicer. The Note or a partial interest in the Note (together with this
Security Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change
in the entity (known as the "Loan Servicer") that collects monthly payments due under the Note and this Security
Instrument. There also may be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is
a change of the Loan Servicer, Borrower will be given written notice of the change in accordance with paragraph 14 above
and applicable law. The notice will state the name and address of the new Loan Servicer and the address to which
payments should be made. The notice will also contain any other information required by applicable law.
20. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release
of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything
affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the
presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to
be appropriate to normal residential uses and to maintenance of the Property.
BoodM racy x552 Form 3039 3198 (Page 5 of 8 Pages)
V ,
Borrower shall promptly give Lender vvritte notich bf any investigation, claim, demand, lawsuit or other action
by any governmental or regulatory agency or pri ate pparty involving the Property and an Hazardous Substance or
Environmental Law of which Borrower has actual owledge. If Borrower learns, or is notified by any governmental or
regulatory authority, that any removal or other mediation of any Hazardous Substance affecting the Property is
necessary, Borrower shall promptly take all necess ry remedial actions in accordance with Environmental Law.
As used in this paragraph 20, "Hazardou Substances" are those substances defined as toxic or hazardous
substances by Environmental Law and the follo ' substances: gasoline, kerosene, other flammable or toxic petroleum
products, toxic pesticides and herbicides, volatile so ents, materials containing asbestos or formaldehyde, and radioactive
materials. As used in this paragraph 20, "Bnviro ntal Law" means federal laws and laws of the jurisdiction where the
Property is located that relate to health, safety or nvironniental protection.
NON-UNIFORM COVENANTS. Borrower and icier her covenant and agree as follows:
21. Acceleration; Remedies, Lender shall give notice to Borrower prior to acceleration following Borrower's
breach of any covenant or agreement in this S ty Instrument (but not prior to acceleration under paragraph
17 unless applicable law provides otherwise). Leader shall notify Borrower of, among other things: (a) the default;
(b) the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the
default as specified may result in acceleration f the sums secured by this Security Instrument, foreclosure by
judicial proceeding and sale of the Property. Le der shall further inform Borrower of the right to reinstate after
acceleration and the right to assert in the forecloi am proceeding the non-existence of a default or any other defense
of Borrower to acceleration and foreclosure. If the default is not aired as specified, Lender at its option may require
immediate payment in full of all sums secured by this Security Instrument without further demand and may
foreclose this Security Instrument by judicial pr eding. Lender shall be entitled to collect all expenses Incurred
in pursuing the remedies provided In this p h 21, including, but not limited to, reasonable attorneys' fees and
costs of title evidence to the extent permitted by applicable law,
22. Release. Upon payment of all sums s cured by this Security Instrument, Lender shall release the Security
Instrument to Borrower. To the extent permitted applicable law, Borrower is responsible for all costs associated with
cancelling this Security Instrument including, but t limited to, any fee paid to a third party for the preparation and
recordation of any legal documents as well as any ee paid to a public official.
23. Waivers. Borrower, to the extent per 'tted by applicable law, waives and releases any error or defects in
proceedings to enforce this Security Instrument, a d hereby waives the benefit of any present or future laws providing
for stay of execution, extension of time, exemptio from attachment, levy and sale, and homestead exemption.
24. Reinstatement Period. Borrower's tun to reinstate provided in paragraph 18 shall extend to one hour prior
to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument.
25. Purchase Money Mortgage. If any o 'the debt secured by this Security Instrument is lent to Borrower to
acquire title to the Property, this Security Instrum nt shall be a purchase money mortgage.
26, Interest Rate After Judgment. Bono er agrees that the interest rate payable after a judgment is entered
on the Note or in an action of mortgage foreclosu a shall be the rate payable from time to time under the Note.
27. Agreement to Mediate or Arbitrate. THIS AGREEMENT CAREFULLY. IT LIMITS CERTAIN
OF YOUR RIGHTS, INCLUDING YOUR RIG TO GO TO COURT. In this agreement to mediate or arbitrate
(this "eement' , (1) 'Transaction" means any (a) ayment of money, (b) transfer or exchange of property or any other
thing o value, (c) any one or more past, present, o future extensions of, advertisement, solicitation, applications for, or
inquiries about, credit, or forbearance of payment, uch as a loan, a credit sale, or otherwise, from Lender to Borrower,
including this Transaction, (d) gift, or e) pro' e to enter into a Transaction, and (2) "Claim" means any case,
controversy, dispute, tort, disagreement, lawsuit, cl , or counterclaim, and other matters in question now or hereafter
existing between Lender and Borrower. A Claim in Ludes, without limitation, anything arising out of, in connection with,
or relating to: (a) this Agreement; (b) to the advert went, solicitation, application, processing, closing or servicing of this
Transaction or any instruments executed in conjunction with it (collectively the "Loan Agreements" including but not
lirnited to the terms of the loan, representations, pr miles, undertakings or covenants made relating to the Loan, or Loan
Agreements executed in conjunction with the Noe and this Security Instrument, services provided under the Loan
Agreements, and the validity and construction of the Loan Agreements); (c) any Transaction; (d) the construction,
manufacture, advertisement, sale, installation or s ' g of any real or personal property which secures this Transaction,
(e) any past, present, or future insurance, service, o product that is offered or sold in connection with a Transaction; (fl
any documents or instruments that contain informati n about or document any Transaction, insurance, service, or product;
and (g) any act or omission by Lender regarding a Claim.
Mediation. Bmpt as set forth below, all C , shall be M MIATED prior to the filing of any legal proceeding
related to any dispute relating to this Transaction. Borrower and Lender cannot agree on the selection of a mediator
for a dispute, the mediator shall be selected as fo : within 5 business days of the notice that either Borrower or Lender
have decided to mediate, Borrower and Lender sha each name a mediator and notify that mediator and the other party
of the selection. Within 5 business days of theirs lection the mediators shall jointly select an independent mediator to
mediate the dispute. The mediation shall occur not later than 30 days after the mediator is selected at a time and place
mutually convenient to all parties within a fifty-mil radius of Borrower's residence.
Borrower and Lender agree to participate in the mediation in good faith with the intention of resolving the dispute,
if possible. Legal counsel may, but is not require to represent Borrower or Lender at the mediation. All mediation
sessions will be private and all information disclosed luring the mediation will be confidential. The mediator may prescribe
other rules for the mediation. Expenses of themediation including the mediator's fee shall be shared equally between
Lender and Borrower. Attorneys' fees and related expenses are each party's responsibility.
This Agreement to mediate is specifically a orceable.
If for any reason the mediation is not completed within 45 days after the mediator is selected, or if after the
mediation, any Claim is still unresolved, such Cla' shall be resolved solely and exclusively by arbitration in accordance
with this Agreement.
ROOK 149Y- PAGE 4553 Form 3039 3/96 (Page 6 of 8 Pages)
Loan No: 034401057566 T Data ID: 627
Arbitration. To the extent allowed by appHcallle law, any Claim, except those set forth below, shall be resolved
by binding arbitration in accordance with (1) the Federal Arbitration Act, 9 U.S.C §§ IA; (2) the Expedited Procedures
of the Commercial Arbitration Rules of the American Arbitration Association (the "Arbitration Rules' then in effect; and
(3) this Agreement. If the terms of this Agreement and the Arbitration Rules are inconsistent, the terms of this
Agreement shall controL A copy of the Arbitration Rules, free of charge, may be obtained by calling (800) 779-7879. The
laws applicable to the arbitration proceeding shalt be the Laws of the state in which the property which secures the
Transaction is located. The parties agree that the arbitrator shall have all powers PION, ided by law, this Agreement, and
the Loan Agreements. However, the arbitrator shall have no power to vary or modify any of the provisions of the Loan
Agreements. Any party to this Agreement may bring an action in any court having Jurisdiction, including a summary or
expedited proceeding, to specifically enforce this Agreement, or to compel arbitration of any Claim. An action to
specifically enforce this Agreement, or a motion to compel arbitration may be brought at ark time, even after a Claim
has been raised in a court of law or a Transaction has been completed, discharged, or paid in full
Place of Arbitration. The arbitration shall be conducted in the county of Borrower's residence, or at any other
place mutually acceptable to the Lender and the Borrower.
Timing of Hearing. The arbitration hearing shall commence within forty-five (45) days of the demand for
arbitration.
NO CLASS ACTIONS; NO JOINDER OF PARTIES; WAIVER OF RIGHT TO JURY TRIAL. THE
ARBITRATION WILL TARE THE PLACE OF ANY COURT PROCEEDING INCLUDING A TRIAL BEFORE A
JUDGE OR A JUDGE AND JURY. ANY SUCH ARBITRATION SHALL BE CONDUCTED ON AN INDIVIDUAL
BASIS, AND NOT AS PART OF A' COMMON OR Cl" ACTION. IT IS EXPRESSLY ACKNOWLEDGED AND
AGREED BY BORROWER AND LENDER THAT ANY PURPORTED COMMON ISSUES OF LAW OR FACT
SHALL BE RESOLVED ON SUCH AN INDIVIDUAL BASIS. IF THE APPOINTED ARBITRATOR SHOULD
AWARD ANY DAMAGES, SUCH DAMAGES SHALL BE IRvff ED TO ACTUAL AND DIRECT DAMAGES AND
SHALL IN NO EVENT INCLUDE CONSEQUENTIAL, PUNITIVE, EXEMPLARY OR TREBLE DAMAGES AS
TO WHICH BORROWER AND LENDER EXPRESSLY WAIVE ANY RIGHT TO CLAIM TO THE FULLEST
EXTENT PERMITTED BYLAW.
Judgme t. The award rendered by the arbitrator shall be final, nonappealable and judgment may be entered upon
it in accordance with applicable law in any court having jurisdiction thereof The laws applicable to the arbitration
proceeding shall be Subchapter A of Chapter 73 of Title 42 of the Pennsylvania Consolidated Statutes.
Confidentiality. Borrower and Lender agree that the mediation and arbitration proceedings are confidential. The
information disclosed in such proceedings cannot be used for any purpose in any other proceeding.
Claims Excluded from Mediation and Arbitration. Notwithstanding the foregoing, neither Borrower or Lender
can require the other to mediate or arbitrate (i) foreclosure proceedings, whether pursuant to judicial action, power of
sale, assent to a decree or otherwise, proceedings pursuant to which Lender seeks a deficiency judgment, or any
comparable procedures allowed under applicable law pursuant to which -a lien holder may acquire title to, or possession
of any property which is security for this Transaction and any related personal property (irtcludutg an assignment of rents
or appointment of a receiver), upon default by the Borrower on the Transaction or (u) an application by or on behalf
of the Borrower for relief under the federal bankruptcy laws or any other similar laws of general application for the relief
of debtors, through the institution of appropriate proceedings; or (fti) any Claim where Lender seeks damages or. other
relief because of Borrower's default under the terms of a Transaction. Enforcement of this section will not waive the right
to arbitrate any other Claim, including a Claim asserted as a counterclaim in a lawsuit brought under.this -section.,
Effect of Rescission. If Borrower has the right to rescind this Transaction, rescinding it will not rescind this,
Agreement.
No Other Arbitration Agreements. This Agreement is the only agreement between Lender and Borrower
regarding alternative dispute resolution, and supersedes any prior agreements to mediate or arbitrate Claims This
Agreement may only be modified by a written agreement between Lender and Borrower.
BORROWER AND LENDER AGREE TO WAIVE ANY RIGHTS TO TRIAL BY JURY OF ANY AND ALL,',
CLAIMS.
28, Riders to this Security Instrument. If one or more riders are executed by Borrower and recordedtogether
with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into and shall amend
and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security
Instrument. [Check applicable box(es)]
? Adjustable Rate Rider
[? Graduated Payment Rider
? Balloon Rider
? Other(s) [specify]
? Condominium Rider
? Planned Unit Development Rider
? Rate Improvement Rider
Bood495 FAGS 1554
? 1-4 Family Rider
? Biweekly Payment Rider
? Second Home Rider
Form 3039 8/88 (Page 7 of 8 Pages)
BY StonttNa 13m nw, Borrower accepts agrees to the terms and covenants contained in this Security Instrument
in any rider(s) ex by Borrower and r corded with it.
Witn, ac `, •' vi '
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known to me (or satisfactorily proven) to be .,,, r,.'..,.,;;_
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a person whose name is subscribed to the wi ia'."* truin°` t att?`f
acknowledged that she executed the same for the purposes therein contained rr :
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In witness whereof I hereunto set my hand and fficial s
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My commission expires:
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I certify that the precise residence and address f the within-named Lender is: UNITED COMPANIES LENDING
CORPOR ??, 4041 ESSEN LANE, BATO OUGE, LOUISIANA 70809
"CE ,555
Form 3039 3/98 (Page 8 of 8 Pages)
.
marten d.d..k
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Tax Parcel No. 04-21-0320-281
THIS DEED
Made the 3day of 16(ti4Q1&4 , in the year Nineteen
hundred and ninety-e& (1996).
Between CARLISLE OPPORTUNITY HOMES, INC., a non-profit
corporation, organized under the laws of the Commonwealth
of Pennsylvania, of P. O. Box 517, Carlisle, Cumberland
County, Pennsylvania,
and
Grantor
VICKIE A. THORSON, of 111 West South Street, Carlisle,
Cumberland County, Pennsylvania,
Grantee
Witnessetli, that in consideration of FORTY-SEVEN THOUSAND FTVE
HUNDRED and 00/100 DOLLARS ($47,500.00), in hand paid, the receipt
whereof is hereby acknowledged, the said grantor does hereby grant
and convey to the said Grantee, her heirs and assigns,
ALL THAT CERTAIN TRACT OF LAND situate in the Third Ward of the
Borough of Carlisle, Cumberland County, Pennsylvania, bounded and
described as follows:
0EG{NN1NG at the southeastern corner of land now or formerly of
Ann Leonard Estate, said point being 30 feet, more or less, East of
the 10 foot alloy which runs from West South Street to Chapel Alley
and said point being on the northern side of West South Streets
thence eastwardly along West South Street, 20 feet 2 inches, more
or less, to land now or formerly of John Boyd; thence northwardly
along said land, 32 feet to a point; than to eastwardly by the same,
6 feat 6 inches to a pointj thence northwardly along the same, 24
fast, more or less, to land now or formerly of Mrs. M. Duncan;
thence westwardly along said land 26 feet, more or less, to land
now or formerly of the Ann Leonard Estate; thence southwardly 60
feat, more or Lase, to the Place of BEGINNING.
BEING improved with a two-atory frame dwelling house known as No.
111 West South Street.
600f 134 F1cE 424
sood495 rw 656
BEING the same premises which Terry S. Leiby, Rodger C. Diehl, Jr.
and Rodger C. Diehl, Sr., by Dead dated August 17, 1990, and
recorded in the Office of
Cumberland County, the Recorder of Deeds in and for 738, Pennsylvania, in Deed Hook S, Volume 34, page
granted and conveyed unto Carlisle Opportunity Homes, Inc.,
Grantor herein.
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And the Said Grantor hereby covenants and agrees that it will warrant
speciAlly the property hereby conveyed.
In %littte;s Whereof, said Grantor has hereunto sat ate hand and goal
Rbi? gnd yaar first above written.
CARLISLE OPPORTUNITY HOMES, INC.
ayC. R.f
eBrUCe R. Andrews, Vice P si ent
QOMONWZALTH OF PENNSYLVANIA s
s on
COUNTY OF CUX3aRI.ANA
On this, the ?lF?h day of -1lanuRr , I9960 before me, the
undersigned ottioer, persona y a ears Bruce R. Andrews, who
acknowledged himself to be the Vice President of Carlisle
Opportunity Homes, Inc., and that he as such officer, being
authorized to do no, executed the foregoing instrument for the
purposes therein contained by signing the name of the corporation
by himself am Vice President.
IN WITNESS WHEREOF, I have hereunto set My hand and notarial seal.
Hao.Wi s.?i
Kuon F Bye a Koury pubno
Cr flow Has wn0?n?rd County
m v GomnMtlt-Or F• n w March l k s ass
I hereby certify that the precise residence and complete poet
office address of the Grantee hsrei? is 111 West South Street,
Carlisle, PA 17013. ??
Attorney oor GrAntees
Stato of Pennsylvania 86
County of Cusnbariandj
Pfxo,drsd i e office for the recording of Deeds
:;r... and f rland County
u, _ 3 k _ Vof - Pa
wiui s, ny h seal of offs
Carlisle, dyif 19_..
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EXHIBIT `B'
Loan No: 034401057566
Borrower: VICKIR A THORSON
NL?ember 2, 1998
NOTE
CARLISLE
[0hyl
111 W SOUTH STREET
CARLISLE, PENNSYLVANIA 17013
[Properly Addreee]
Data ID: 627
PENNSYLVANIA
[fie]
L BORROWER'S PROAUSE TO PAY
In return for a loan that I have received, I promise to pay U.S. $ 55,700.00 (this amount is called "principal',
plus interest, to the order of the Lender. The Lender is
UNITED COMPANIES LENDING CORPORATION.
I understand that the Leader may transfer this Note. The Lender or anyone who takes this Note by transfer and who
is entitled to receive payments under this Note is called the "Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest
at a yearly rate of 9150%.
The interest rate required by this Section 2 is the rate I will pay both before and after any default described in
Section 6(B) of this Note.
3. PAYNnRM
(A) Time and Place of Payments
I will pay principal and interest by making payments month
I will make my monthly payments on the first day of eac month beginning on January I, 1999.
I will make these payments every month until I have paid all of the principal and interest and any other charges
described below that I may owe under this Note. My monthly payments will be applied to interest before principal. If,
on December 4 202% I still owe amounts under this Note, I will pay those amounts in full on that date, which is called
the "maturity date."
I will make my monthly payments at P.O. Box 215, Memphis, Tennessee 38101-0215, or at a different place if
required by the Note Holder.
(B) Amount of Monthly Payments
My monthly payment will be in the amount of U.S. $ 456.23.
4. BORROWER'S RIGHT TO PREPAY
I have the right to maim payments of principal at any time before they are due. A payment of principal only is
known as a "prepayment." When I make a prepayment, I will tell the Note Holder in writing that I am doing so.
I may make a full prepayment or partial prepayments without paying any prepayment charge. If this Note is not
in default, the Note Holder will use all of my prepayments to reduce the amount of principal that I am under this Note.
If I make a partial prepayment, there will be no changes in the due date or in the amount of my monthly payment unless
the Note Holder agrees in writing to those changes.
5. LOAN CHARGES
If a law, which applies to this loan and which sets maximum ban charges, is finally interpreted so that the interest
or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (i) any
such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (h) any
sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose
to make this refund by reducing the ppdncipaI I owe under this Note or by making a direct payment to me. If a refund
reduces principal, the reduction will be treated as•a partial prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge far Overdtm Payments
If the Note Holder has not received the full amount of any monthly payment by the end of 10 calendar days after
the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.00% of the payment.
I will pay this late charge only once on any late payment.
(B) De&ult
If I do not pay the full amount of each monthly payment on the date it is due, f will be in default.
(G) Accekrallon
If I am In default, the Note Holder may without notice or demand, unless otherwise required by applicable law,
require me to pay immediately the full amount of principal that has not been paid and all the interest that I owe on that
amount.
(D) No Waiver By Note Holder
Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as
described above, the Note Holder will still have the right to do so if I am in default at a later time.
(T) Payment of Note Haildees C oM and Expenses
If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have
the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by
applicable law. Those expenses include, for example, reasonable attorneys' fees.
PENNSYLVANIA FIXED RATE NOTE - single Family . MODIFIED
11/96
ism???rnseen?te
034401057 185
7. GIVING OF NO'T'ICES
Unless applicable law requires a differet method, any notice that must be given to me under this Note will be
given by delive rig it or by mailing it by first class mall to me at the Property Address above or at a different address if
I give the Note Holder a written notice of my erent address.
Any notice that must be given to the N to Holder under this Note will be given by mailing it by first class mait
to the Note Holder at the address stated in S ion 3(A) above or at a different address if I am given a notice of that
different address.
S. OBLIGATIONS OF PERSONS UNDER TI
If more than one person signs this Note,
made in this Note, including the promise to pay 1
of this Note is also obligated to do these things.
of a guarantor, surety or endorser of this Note, i
Holder may enforce its rights under this Note a;
that any one of us may be required to pay all c
9. WAIVERS
I and any other person who has oblige
dishonor. "Presentment' means the right to req
dishonor" means the right to require the Note I
paid
10. UNIFORM SECURED NOTE
This Note is a uniform instrument with
given to the Note Hokler under this Note, a Mor
the same date as this Note, protects the Note
promises which I make in this Note. That Se
required to make immediate payment in full o
described as follows:
Transfer of the Property or a Bei
or any interest in it is sold or transferred
Borrower is not a natural person) withi
require immediate payment in full of all i
shall not be exercised by Lender if exer
Instrument
If Lender exercises this option, Lei
pprovide a period of not less than 30 day
Borrower must pay all sums secured by th
to the expiration of this period, Lender ?
without further notice or demand on Bu
Wrimiss THE HAND(S) AND SEAL(S) OF
4I.
IS NOTE
inch person is fully and personally obligated to keep all of the promises
e full amount owed Any person who is a guarantor, surety or endorser
Any person who takes over these obligations, 'including the obligations
also obligated to keep all of the promises made in this Note. The Note
iinet eam person individually or against all of us together. This means
the amounts owed under this Note.
s under this Note waive the rights of presentment and notice of
the Note Holder to demand payment of amounts due. "Notice of
x to give notice to other persons that amounts due have not been
mited variations in some jurisdictions. In addition to the protections
age, Deed of Trust or security Deed the 'Security Instrument', dated
Iolder from possible losses which might result if I do not keep the
tity Instrument describes how and under what conditions I may be
all amounts I owe under this Note. Some of those conditions are
octal Interest in Borrower. If all or any part of the Property
it if a berieCicial interest in Borrower is sold or transferred and
t Lender's prior written consent, Lender may, at its option,
ms secured by this Security Instrument However, this option
e is prohibited by federal law as of the date of this Security
er shall give Borrower notice of acceleration. The notice shall
from the date the notice is delivered or mailed within which
Security Instrument If Borrower faits to pay these sums prior
cy invoke any remedies permitted by this Security Instrument
UNDEPMONED.
...............................(Seat)
r L• ?ho?'S ?lKla.,VICKIE A THORSON -Borcoww
NOTICE: This is a mortgage subject to sped
assignees of this mortgage could be liable for all
could assert against the creditor.
Pay to the order of Bankers Trust Company
of California, NA-, as custodian or trustee
under the applicable custodial or trust
agree t, without recourse.
UNIT 0 G C Q WON
BY
Name: Brandt Ra urn
Title: Assistant Secretary
CE TO ASSIGNEE
rules under the federal Truth in Lending Act Purchasers or
ims and defenses with respect to the mortgage that the borrower
EXHIBIT `C'
1111111111111111111111111
7104 5400 =100 22=0 9441
July 13, 2009
1Vickie A Thorson
111 W South St
Carlisle, PA 17013-3434
EMC
Mortgage
Corporation
Po Box 660753 Dallas, TX 75266-0753
Re: Loan No:
Property Address:
EMC
;{farts"ge C' rp?rrke;nor
Ills W Street
Carlisle, PA 17013
Your house is your home. We want to keep it that way.
We need to talk - call 1-888-609-2379 today.
You're going through tough times - we can help. In fact, we believe your home may be eligible for a loan
modification program - we may be able to change the term of your loan, the interest rate, and maybe even the
principal due date, to reduce the monthly payment to an amount you can afford.
Call us today at 1-888-609-2379 so we can help you turn things around. We'll discuss
your current situation (outlined in the enclosed letter) and the options available to you.
But we cannot stress enough that the longer you delay calling us - the fewer chances you
may have to keep your home.
It will only take a few minutes on the phone - one of our Loan Specialists will work with you to determine the
option that best fits your needs. There are several options available - call us now and let's see which one will
work best for you.
We are committed to working with you to find a way to help you keep your home, but you must call us
immediately at 1-888-609-2379 - the longer you delay the fewer options you may have.
Homeowner's Assistance Department
EMC Mortgage Corporation
1-888-609-2379
(800) 582-0542 TDD / Text Telephone
P.S. The enclosed legal letter outlines, in detail, your current situation and the consequences that
will occur unless we receive the required financial information from you and can approve you
for a modification. Once you call us with the information needed, then we can work together to
determine the option that will work best for you. We cannot guarantee that you will be
approved, but your only chance of saving your home is by contacting us immediately. Please
don't delay-call us now at 1-888-609-2379.
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES BY COUNTY REVISED AUGUST 1, 2008
July 13, 2009
T 1 N
TAKE OE FIR OMNFOTIC
9 0I
H
SURE L , 0 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.
IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ONPAGE THREE
The HOMEOWNER'S EMERGENCYMORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. Thu notice
explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 33 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 1-800-341-2397. (Persons with impaired hearing can
call (717) 780-1869).
Imm sk-1 .
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 NOTIFICACIO'N EN ADJUNTO ES DE SUMA IM[PORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN
SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO-N OBTENGA UNA TRADUCCIO'N
INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO 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.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Vickie A Thorson
Ills W Street
Carlisle, PA 17013
UNITED COMPANIES LEN
EMC Mortgage Corporation
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCLIL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOUMAKE 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 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 (plus three (3) days for mailing). 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 THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE
CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT"; EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
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.
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). 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. To temporarily stop the lender from filing a foreclosure action,
your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to face meeting with the counseling
agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED
FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED
"TEMPORARY STAY OF FORECLOSURE. "
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR
APPLICATION IS E VENTUA LL Y APPR 0 VED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL
BE STOPPED.
AGENCYACTION - 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 YOUARE CURRENTLYPROTECTED BY THE FILING OFA PETITIONINBANKRUPTCY, THE FOLLOWING
PART OF THIS NOTICE IS FOR INFORMATIONPURPOSES ONLYAND 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 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:
l l is W Street, Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHL Y MORTGA GE PA YMENTS for the following months and the following amounts are now past
due.
(a) Monthly payments from 05/01/2009:
(b) Late charge(s):
(c) Other charge(s): NSF and Advances
(d) Less: Credit Balance
(e) Total amount required as of 07/09/2009:
$2,439.54
$121.98
$1,004.58
$0.00
$3,566.10
HOW TO CURE THE DEFAULT - You may cure this default within 771IRT'Y (30) DAYS from the date of this Notice BY PAYING
THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ $3,56610, PLUS ANY MORTGAGE PAYMENTS AND
LATE CHARGES (and other charges) WHICH BECOME DUE DURING 771E THIRTY (30) DAYPERIOD. Payments must be made
either by cash, cashier's check certified check, or money order made payable and sent to:
EMC Mortggaagge Uo ration
Po Box 660753 galas, TX 75266-0753
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the
lender intends to exercise its right to accelerate the mortgage debt7his 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. Iffull 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 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.lf
you cure the default within the THIRTY (30) DAYperiod, you will not be 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.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30)
DAYperiod 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 Sheriffs 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 Sheriffs 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 Sheriffs Sale of the mortgaged
property could be held would be approximately five (5) months from the date of this Notice.A notice of the actual date of the
Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER
Name of Lender: EMC Mortgage Corporation
Address: Po Box 660753 Dallas, TX 75266-0753
Telephone Number: 1-888-609-2379
Fax Number. 214-626-5999
Contact Person: Loan Resolution Department
E-mail Address: emcpaact9l@jpmorgan.com
EFFECT OF SHERIFF'S SALE - 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.
ASSUMPTION OF MORTGAGE You may not 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.
YOUMAYALSO 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 COUNSELINGAGENCIES SERVING YOUR COUNTY
CAN BE FOUND ON PAGES 4-6.
An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability
and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee
for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." EMC offers loan modification
assistance free of charge (i.e., no modification fee required). Please call us immediately at 1-888-609-2433 to discuss your options. The
longer you delay the fewer options you may have.
EMC Mortgage Corporation is attempting to collect a debt, and any information obtained will be used for that purpose.
Sincerely,
EMC Mortgage Corporation
Po Box 660753 Dallas, TX 75266-0753
r
Acorn Housing Corporation
846 North Bread Street
Philadelphia, PA 19130
(215) 765-1221
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Action Housing Inc
425 6th Avenue, Suite 950
Pittsburgh, PA 15219
(412) 281-2102
'Allegheny, Beaver, Butler, Fayette, Greene,
Washington, Westmoreland
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
(717) 3341518
'Adams, Cumberland, Franklin, York
Advocates for Financial independence
1806 S Broad Street, Suite 1B
Philadelphia, PA 19145
(215) 369-2810
'Philadelphia
Advocates for Financial Independence
202 East Hinkley Avenue
Ridley Park, PA 19078
(215)389-2810
'Delaware
Allegheny County Acorn
5907 Penn Avenue, Suite 300
Pittsburgh, PA 15206
(412) 441-0551
'Allegheny
American Credit Counseling institute
21 S Church Street
West Chester, PA 19380
(888)212.6741
`Chester
American Credit Cousekng Institute
526-528 Dekale Street
Norristown, PA 19401
(610) 971-2210
(888) 212-6741
'Montgomery, Delaware
American Credit Counseling Institute
530 W Street Road, Suite 201
Warminster, PA 18974
(215) 4449429
(888) 212-6741
'Bucks, Montgomery, Philadelphia
American Credit Counseling Institute
937 North Hanover Street
Pottstown, PA 19460
(888) 212-6741
'Becks, Bucks, Montgomery
American Credit Counseling Institute
229 East Chestnut Sheet
Coatesville, PA 19320
(888) 212-6741
'Chester, Lancaster
" Indicates Counties Serviced
American Financial Counseling Services
871 N. Easton Road
Glenside, PA 19038
(267) 228-7903
'Mifflin
American Financial Counseling Services
405 West Gemrantown Pike
Norristown, PA 19403
(267) 228-7903
'Mifflin, Montgomery
American Financial Counseling Services
2880 Bergey Road Suite 4
Hatfield, PA 19440
(267) 228-7903
'Bents, Chester, Montgomery
American Financial Counseling Services
175 Strafford Avenue, Suite one
Wayne, PA 19087
(610) 971-2210
(888) 212-6741
'Bucks, Chester, Delaware, Mongomery,
Philadelphia
American Financial Counseling Services
906 Penn Avenue
Wyomissing, PA 19610
(267) 228-7903
(800) 490-3039
Terks,
American Financial Counseling Services
871 N. Easton Road
Glenside, PA 19038
(267) 228-7903
'Montgomery
American Financial Counseling Services
1917 Walsh Road
Philadelphia, PA 19115, PA 19610
(267) 228-7903
'Bucks, Montgomery, Philadelphia
American Red Cress - Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
(717) 637-3768
'Adams, Franklin, York
American Red Cross of Chester
1729 Edgemont Avenue
Chester, PA 19013
(610) 874-1484
'Chester, Delaware
APM
2147 Norht Sixth Street
Philadelphia, PA 19122
(215) 235-6788
`Chester, Delaware, Philadelphia, Bucks
Armstrong CO Community Action Agency
124 Armsdals Road, Suite 211
Kittanning, PA 16201
(724)548-3405
'Armstrong
Base, Inc.
447 South Prince Street
Lancaster, PA 17603
(717) 392-5467
'Lancaster
Blair County Community Action Agency
2100 6th Avenue, Suite 102
P.O. Box 1833
Altoona, PA 16602
(814) 946-3651
'Blair
Booker T. Washington Center
1720 Holland Street
Erie, PA 16503
(814) 453-5744
'Crawford, Erie, Warren
Bucks County Housing Group
200 West Bridge Street
Morrisville, PA 19067
(866) 866-0280
'Burks
Bucks County Housing Group
2324 Second Street Pike, Suite 17
Wrightslown, PA 1894D
(866) 666-0280
'Bucks
Bucks County Housing Group
470 Old Dubin Pike
Doylestown, PA 18901
(866) 866-0280
'Bucks
Bucks County Housing Group
349 Durham Road
Peondel, PA 19047
(866) 866-0280
'Bucks
Bucks County Housing Group
515 West End Blvd
Quakertown, PA 18951
(866) 866-0280
'Bucks
Budget Counseling Carter
247 North Fifth Street
Reading, PA 19601
(610) 375-7866
'Barks, Chester, Schuylkill
Carron Park Community Council, Inc.
5218 Master Street
Philadelphia, PA 19131
(215) 877-1157
'Chester, Delaware, Philadelphia
Catholic Social Services
Saint Catherine Manor
5 Knox Road
Scranton, PA 18505
(570) 558-3019
'Wyoming, Wayne, Bucks, Lackawanna,
Monroe, Philadelphia
CCCS of Delaware Valley
1230 New Rodgers Road, Suite F1
Bristol, PA 19007
(215) 563-5665
'Bucks
CCCS of Delaware Valley
1777 Sentry Parkway W, Suite 200
Blue Bell, PA 19422
(215)563.5665
'Montgomery
CCCS of Delaware Valley
280 North Providence Road
Media, PA 19063
(215) 563-5665
'Chester
CCCS of Delaware Valley
Marshal Building
790 E Market St, Suite 170
West Chester, PA 19382
(215) 563-5665
`Chester, Bucks
CCCS of Delaware Valley
Catholic Social Services Building
7340 Jackson Street
Philadelphia, PA 19136
(215) 563-5665
'Bucks, Philadelphia
CCCS of Delaware Valley
One Cherry Hill, Suite 215
Cherry Hill, PA 08002
(215)563.5665
'Philadelphia
CCCS of Lehigh Valley
3671 Crescent Court East
Whitehall, PA 18052
(610) 821-4011
(800) 837-9815
'Bert s, Bucks, Carbon, Lancaster, Lehigh,
Northampton, Schuylkill
CCCS of Northeastern PA
201 Basin Street, Suite 6
Williamsport, PA 17701
(570) 323-6627
'Centre, Clinton, Lycoming, Northumberland,
Union
CCCS of Northeastern PA
202 W Hamilton Avenue
State College, PA 16801
(814) 238-3668
'Blair, Centre, Clearfield, Clinton, Huntingdon,
Juniata, Mifflin
CCCS of Northeastern PA
401 Laurel Street
Pittston, PA 18640
(570) 602-2227
'Bradford, Carbon, Columbia, Lackawanna,
Lycoming, Monroe, Montour, Northumberland,
Pike, Sullivan, Twga, Union, Wayne, Wyoming
CCCS of Northeastern PA
411 Main Street. Suite 104
Stroudsburg, PA 18360
(570) 420-8980
'Bradford, Carbon, Monroe, Pike, Wayne
CCCS of Western PA
1 North Gate Square#2
Garden Center Dr
Greensburg, PA 15601
(888)511-2227
'Fayette, Greene, Indiana, Somerset,
Washington, Westmoreland
CCCS of Western PA
55 Clover Hill Road
Dallastown, PA 17313
(888) 511-2227
'Fulton, Crawford, Lancaster
r
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
(888)511-2227
'Adams, Cumberland, Dauphin, Franklin, Perry,
Synder, York
CCCS of Western PA
312 Chestnut Street, Suite 227
Meadville, PA 16335
(888)511-2227
'Lawrence
CCCS of Western PA
41 East Chestnut Street
Washington, PA 15301
(888)511-2227
'Westmoreland
CCCS of Western PA
4402 Peach Street
Erie, PA 16509
(888) 511-2227
'Crawford, Erie, Warren
CCCS of Western PA
524 Franklin Avenue
Aliquippa, PA 15001
(888)511-2227
'Cambria
CCCS of Western PA
917 A Logan Boulevard
Altoona, PA 16602
(888) 511-2227
'Armstrong, Bedford, Blair, Cambria, Centre,
Clearfield, Huntingdon, Juniata, Mifflin, Union
CCCS of Western PA
Pullman Commerce Center
112 Hollywood Or
Butler, PA 16001
(888) 511-2227
'Butler, Clarion, Jefferson, Mercer, Venango
CCCS of Western PA
River Park Commons
2403 Sidney Street
Pittsburgh, PA 15203
(888)511-2227
'Allegheny .
Center for Family Services, Inc.
213 Center Street
Meadville, PA 16335
(814) 337-8450
'Columbia, Venango
Centro Pedro Clever, Inc
627 West Erie Avenue
PhBadelpia, PA 19140
(215) 227-7111
'Philadelphia
" Indicates Counties Serviced
Chester Community Improvement Project
412 Avenue of the States
P.O. Box 541
Chester, PA 19016
(610) 876-8663
'Chester, Delaware, Montgomery, Philadelphia
Diversified Community Service
Dixon House
1920 South 20th Street
Philadelphia, PA 19145
(215) 336-3511
'Bucks, Chester, Delaware, Philadelphia
Indiana Co. Community Action Prog.
827 Water Sheet Box 187
Indiana, PA 15701
(724) 465-2657
'Armstrong, Cambria, Clearfield, Indiana,
Jefferson, Westmoreland
Comm. On Econ Opportunity of Luzeme Co.
163 Amber Lane
Wilkes-Barre, PA 16702
(570) 826-0510
'Carbon, Luzeme, Schuylkill, Wyoming
Community Action Commission of Capital
Region
1514 Derry Sheet
Harrisburg, PA 17094
(717) 232-9757
'Cumberland, Dauphin, Franklin, Perry, Synder
Community Action Committee of the Lehigh
Valley
1337 Fast Fft Street
Bethlehem, PA 18015
(610) 691-5620
•Berk&, Carbon, Lehigh, Monroa,
Northhampton
Community Action Development Comm -
CADCOM
113 E Main Street
Norristown, PA 19401
(610) 2773363
'Montgomery
Community Adorn Southwest
150 W Beau Street, Suite 304
Washington, PA 15301
(724) 225-9550
'Monroe
Community Action Southwest
58 E Greene Street
Waynesburg, PA 15370
(724) 852-2893
•Alegherry, York, Fayette, Greene,
Washington, Westmoreland
Comm. on Econ. Opportunity of Luzame
County
163 Amber Lane
WilkesBarre, PA 18702
(570)826-0510
(800) 822-0359
*Wyoming
Congreso
216 West Somerset Street
Philadelphia, PA 19133
(215)763.9870
• hitadelphia
Council of Spanish Speaking Organization
705-09 North Franklin St
Philadelphia, PA 19123
(215) 6273100
'Philadelphia
Credit Counseling Center
832 Second Street Pike
Richboro, PA 18964
(215) 396-1880
'Backe
Fair Housing Partnership of Greater Pittsburgh, Intercultural Family Services Inc.
Inc. 4225 Chestnut Street
2840 Liberity Ave., Suite 205 Philadelphia, PA 19104
Pittsburgh, PA 15222 (215) 3136-1298
(412) 391-2535 •Phladelphia
'Allegheny
Fayette Co. Community Action Agency Inc
137 North Beeson Avenue
Uniontown, PA 15401
(724) 437-6050
'Fayette, Somerset
Korean Comm. Develop. Services Center
6055 North 5th Street
Philadelphia, PA 18505
(215) 276-W30
*Philadelphia
FOB CDC
1201 West Only Avenue
Philadelphia, PA 19141
(215) 549-8755
*Bucks, Chester, Delaware, Philadelphia
Garfield Jubilee Associates
5138 Penn Avenue
Pittsburgh, PA 15224
(412) 665-5200
'Allegheny
Germantown Settlement
5538 Wayne Avenue Bldg C
Philadelphia, PA 19144
(215) 849-3104
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Greater Erie Commun. Action Committee
18 West 9th Street
Erie, PA 16501
(814) 459-4581
'Crawford, Erie, Venango, Warren
HACE
167 W Allegheny Ave., 2nd Floor
Philadelphia, PA 19140
(215) 426-8025
'Bucks, Chester, Delaware, Philadelphia
Hispanic Alliance for Community Advancement
2740 North Front Street
Philadelphia, PA 19133
(215) 667-8932
'Monroe
Housing Assoc, of Delaware Valley
658 North Watts Street
Philadelphia, PA 19123
(215) 978-0224
'Philadelphia, Monroe
Housing Opportunities of Beaver Co.
320 College Avenue, Unit 1
Beaver, PA 15009
(724) 728-7511
'Beaver, Lawrence
Housing Partnership of Chester County
41 West Lancaster Avenue
Downingtown, PA 19335
(610)518-1522
'Chester, Delaware, Montgomery
Lawrence County Social Services, Inc.
241 West Grant Street
P.O. Box 189
New Castle, PA 16103
(724) 658-7258
'Lawrence
Liberty Resources
714 Market Street, Stilts 100
Philadelphia, PA 19106
(215) 634-2000
`Philadelphia
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 1711
(717) 232-2207
'Cumberland, Dauphin, Perry
Lycom-Clntn Co Comm fo Comm Action
2138 Lincoln Street
P.O. Box 3568
Williamsport, PA 17703
(570)326.0587
'Centre, Clinton, Lycoming, Union
Marenatha
43 Philadelphia Avenue
Waynesboro, PA 17268
(717) 762-3285
'Adams, Cumberland, Franklin, Fuiton, Perry
Media Fellowship House
302 South Jackson Street
Media, PA 19063
(610) 565-0434
'Chester, Delaware
Mon Valley Unemployment Committee
1800 West SL, 3rd Floor
Homestead, PA 15120
(412)462-9962
•Allagheny, Washington, Westmoreland
Mt Airy, USA
6703 Germantown Ave., Suite 200
Philadelphia, PA 19119
(215)844.6021
'Philadelphia
Nazareth Housing Services
301 Bellevue Road
Pittsburgh, PA 15229
(412) 931-6996
'Allegheny
It
r
Neighborhood Housing Services of Reading
213 N 5th SL, Suite 1030
Reading, PA 19601
(610) 372-8433
'Barks
Neighborhood Housing Services, Inc.
710 5th Avenue, Suite 1000
Pittsburgh, PA 15219
(412) 281-9773
`Allegheny
New Kensignton Community Development
2515 Franldord Avenue
Philadelphia, PA 19125
(215) 427-0350
'Warren
The NORCAM Group
4200 Crawford Avenue Suite 200
Northam Cambria, PA 15714
(814) 948-4444
'Cambria, Clearfield
Northam Tier Community Action Corp.
135 West 4th Street
P.O. Box 389
Emporium, PA 15834
(814) 4861161
*Camemn, Elk, Mckean, Potter
Northwest Counseling Service
5001 North Broad Street
Philadelphia, PA 19141
(215) 324-7500
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Nueva Esperanza
4251 North 5th Street
Philadelphia, PA 19140
(215) 324-0746
*Philadelphia
Opportunity Inc.
301 East Market Street
York, PA 17403
(717) 424-3645
'Montgomery
The Partnership CDC
4020 Market Street, Suite 100
Philadelphia, PA 19104
(215) 662-1612
*Monroe
Pennsylvania Housing Finance Agency
2275 Swallow Hill Rd., Bldg 200
Pittsburgh, PA 15220
(412) 429-2842
`Allegheny
Indicates Counties Serviced
PHFA
211 North Front Street
Harrisburg, PA 17110
(500-) 342-2397
'Cumberland, Dauphin
Philadelphia Council for Comm. Advmnt
100 N 17th St, Suite 600
Philadelphia, PA 19103
(215) 567-7803
(800) 930-4663
'Chester, Delaware, Montgomery, Philadelphia
Philadelphia Senior Center
509 South Broad Street
Philadelphia, PA 19147
(215) 546-5879
'Philadelphia
Schuylkill Community Action
225 N. Centre Street
Pottsville, PA 17901
(570) 622-1995
'Barks, Carbon, Lebanon, Lehigh, Luzeme,
Northumberland, Schuylkill
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrel, PA 16121
(724) 981-5310
`Crawford, Lawrence, Mercer
South Philadelphia H.O.M.E.S.
1444 Point Breeze Avenue
Philadelphia, PA 19146
(215) 334-4430
*Philadelphia
Southwest Community Development Corp.
6368 Paschall Avenue
Philadelphia, PA 19142
(215) 729-0800
'Montgomery
SL Martin Center
1701 Parade Street
Erie, PA 16503
(814) 452-0113
*Crawford, Erie, Venargo, Warren
Tableland Services Inc.
535 East Main Street
Somerset, PA 15501
(814) 446-9628
`Cambria, Fayette, Somerset, Westmoreland
Tabor Community Services
308 E King Street, Suite 1
Lancaster, PA 17602
(717) 397-5182
(800)788-5062
*Chester, Lancaster, Lebanon
The Trehab Center of Northeastern PA
10 Public Avenue
P.O. Box 366
Montrose, PA 18801
(570) 278-3338
(800)982.4045
'Susquehanna
The Trehab Center of Northeastern PA
115 SR 92S
Tunkhannock,PA 18657
(570) 836-0840
(800)982.4045
'Wyoming
The Trehab Center of of Northeastern PA
1225 Main Street
Honesdale, PA 18431
(570) 253-8941
(800) 982-4045
'Bradford, Sullivan, Susquehanna, Tioga,
Wayne, Wyoming
The Trehab Center of Northeastern PA
144 E East Avenue
Wellsboro, PA 16901
(570) 724-5252
(800) 982-4045
*Tioga
The Trehab Center of Northeastern PA
German Street
P.O. Box 389
Dushore, PA 18614
(570) 928-9667
(800) 98211045
'Sullivan
The Trehab Carder of Northeastern PA
The Enterprise Center
703 S. Elmer Ave., Suite M-6
Sayre, PA 18840
(570) 888-0412
(800) 982-4045
`Bradford
United Communties Southeast Philadelphia
2029 South Sth Street
Philadelphia, PA 19148
(215) 467-8700
`Philadelphia
United Neighborhood Centers of Northeastern
PA
425 Alder Street
Scranton, PA 18505
(570) 346-0759
'Lackawanna, Wyoming, Wayne, Luzeme
Urban League of Philadelphia
1818 Market Street
Philadelphia, PA 19103
(215) 561-6070
`Bucks, Delaware, Philadelphia
Urban League of Philadelphia
610 Wood Street
Pittsburgh, PA 15229
(412) 931.6996
'Allegheny
Voices for Independence
1107 Payne Avenue
Erie, PA 16503
(814) 874-0064
(800)838-9890
*Erie
Warren-Forest Counties Economic Opportunity
Council
1209 Pennsylvania Ave W.
P.O. Box 547
Warren, PA 16365
(614) 726-2400
*Forest, Waren
West Oak Lane CDC
6259 Limekiln Pike
Philadelphia, PA 1914
(215) 224-0880
'Monroe
Y
An important message from the Federal Trade Commission
Facing foreclosure? Scammers are targeting people having trouble paying their mortgages.
Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan
modifications - for a fee. The Federal Trade Commission, the nation's consumer protection
agency, wants you to know how to avoid scams that could make your housing situation go from bad to
worse.
Don't Get Hit by a Pitch.
"We can stop your foreclosure!"
"97% success rate!"
"Guaranteed to save your home!"
These kinds of claims are the tell-tale signs of
a foreclosure rip-off. Steer clear of anyone
who offers an easy out.
Don't Pay for a Promise.
Don't pay any business, organization, or
person who promises to prevent foreclosure or
get you a new mortgage. These so-called
"foreclosure rescue companies" claim they
can help save your home, but they're out to
make a quick buck. Some may request hefty
fees in advance - and then stop returning your
calls. Others may string you along before
disclosing their charges. Cut off all dealings if
someone insists on a fee.
Send Payments Directly.
Some scammers offer to handle financial
arrangements for you, but then just pocket
your payment. Send your mortgage payments
ONLY to your mortgage servicer.
Don't Pay for a Second Opinion.
Have you applied for a loan modification and
been turned down? Never pay for a "second
opinion."
Imitations = Frustrations.
Some con artists use names, phone numbers,
and websites to make it look like they're part
of the government. If you want to contact a
government agency, type the web address
directly into your browser and look up any
address you aren't sure about. Use phone
numbers listed on agency websites or in other
reliable sources, like the Blue Pages in your
phone directory. Don't click on links or open
any attachments in unexpected emails.
Talk to a HUD-Certified Counseling
Agency - For Free.
If you're having trouble paying your mortgage
or you've already gotten a delinquency notice,
free help is a phone call away. Call 1-888-995
-HOPE for free personalized advice from
housing counseling agencies certified by the
U.S. Department of Housing and Urban
Development (HUD). This national hotline -
open 24/7 - is operated by the
Homeownership Preservation Foundation, a
nonprofit member of the HOPE NOW
Alliance of mortgage industry members and
HUD-certified counseling agencies. For free
guidance online, visit www.hopenow.com.
For free information on the President's plan to
help homeowners, visit
www.maldnghomeaffordable.gov.
Federal Trade Commission
ftc.gov/MoneyMatters
Call
1-888-995-HOPE
for free personalized guidance from housing counseling agencies certified
by the U.S. Department of Housing and Urban Development. The
Homeowner's HOPETM Hotline - open 24/7 - is operated by the
Homeownership Preservation Foundation, a nonprofit member of the
HOPE NOW Alliance of mortgage industry members and
HUD-certified counseling agencies. Or visit
www.hopenow.com
For free information on the President's plan to help homeowners, visit
www.makinghomeaffordable.gov
i3rHOPENOw
Support d Guidance For Homeowners
???, SM
MAKING HOME AFFORDABLE.GOv
I It
VERIFICATION
I, Gregory Javardian, attorney for Plaintiff, verify that all statements of fact in the
foregoing are based on representations and documents of my client, and that such are true
and correct to the best of my information and belief. I further verify that I was unable to
obtain my client's written verification prior to the filing of the foregoing pleading, but
intend to obtain such verification and substitute it for my own herein in due course. I
make this verification subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to
unsworn falsification to authorities.
Dated: /b ?fo d ???
l
Gr ory J ar a , Esquire
A torney for P tiff
?i [a
CK?- 5.Z?roy
p--o- a3zi97
Sheriffs Office of Cumberland County
R Thomas Kline
Sheriff
:i.
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
EMC Mortgage Corporation
vs.
Vickie A. Thorson
° I +
r
Case Number
2009-7132
SHERIFF'S RETURN OF SERVICE
10/20/2009 07:00 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on October 20,
2009 at 1900 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Joe Davis occupant, by making known unto Vickie Thorson, wife of
occupant at 111 West South Street Carlisle, Cumberland County, Pennsylvania 17013 its contents and at
the same time handing to her personally the said true and correct copy of the same.
10/20/2009 07:00 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on October 20,
2009 at 1900 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Vickie A. Thorson, by making known unto herself personally, at 111 West
South Street Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handinc
to her personally the said true and correct copy of the same.
SHERIFF COST: $49.40
October 21, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
Deputy eriff
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
1310 INDUSTRIAL BOULEVARD
SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
Attorney for Plaintiff
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY
AS TRUSTEE F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
Plaintiff
vs.
VICKIE A. THORSON
A/K/A VICKIE L. THORSON
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No. 09-7132
PRAECIPE TO SUBSTITUTE VERIFICATION
TO PLAINTIFF'S COMPLAINT
TO THE PROTHONOTARY:
Kindly substitute the verification that was attached to the Complaint for that of
the plaintiff's personal verification, as it relates to the above-referenced matter.
Respectfully submitted,
/Attorney gory J ard' , Esquire
for P ' Ztiff
'_'I ----I
VERIFICATION
The undersigned hereby states that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge, information and belief. The
undersigned understands that the statements therein are made subject to the penalties of 18
Pa.C.S. Section 4904, relating to unworn falsification to authorities.
Rose Hunter
Specialist
EMC Mortgage Corporation, Attorney-
in-fact for Deutsche Bank National
Trust Company as Trustee, f/k/a
Bankers Trust Company of California,
N.A. as Custodian or Trustee for UCFC
Loan Trust 1998-D
BLED-CF, ICE
OF THE FF')'NONOTARY
2009 NOY -2 PM 3: 10
PENNSYLVANIA
FILED-~~i-iCE
c~F THE E~~ i ~±!~~!(~1'ARY
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215)942-9690
Za~o JUP~ 24 A~! ~~~ 06
CUL`~ti3w:r,~,~~:~~u ~~;EJi~MY
PEr JPJ~'fLV~iA
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY
AS TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A., AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
7301 BAYMEADOWS WAY
JACKSONVILLE, FL 32256
vs.
VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
111 WEST SOUTH STREET
CARLISLE, PA 17013
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 09-7132 CIVIL TERM
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against VICKIE A. THORSON,
A/K/A VICKIE L. THORSON, Defendant, for failure to file an Answer to Plaintiff s Complaint
within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and
assess Plaintiff s damages as follows:
As Set forth in Complaint $74,368.67
Interest 10/07/09 to 06/22/10 4,380.84
TOTAL $78,749.51
I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown
above, and (2) that notice has been given in accordance with Rule 237.1, copy attached.
GRE R JAVARDIAN, ESQUIRE
Atto y r Plaintiff
Damages are hereby assessed as indicated.
~ s/y ~ p°~ °.~~
DATE: o2.y old/G ~(G~'3'~y7~
PRO PROTH
~~« ~~~~
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE BANK
NATIONAL TRUST COMPANY AS TRUSTEE
F/K/A BANKERS TRUST COMPANY OF
CALIFORNIA, NA. AS CUSTODIAN OR
TRUSTEE FOR UCFC LOAN TRUST 199$-D
Plaintiff
v.
VICKIE A. THORSON
A/K/A VICKIE L. THORSON
Defendants
In The Court of Common Pleas
Cumberland County
No. 09-7132 CV
TO:
VICKIE A. THORSON
A/K/A VICKIE L. THORSON
111 WEST SOUTH STREET
CARLISLE, PA 17013
VICKIE A. THORSON
A/K/A VICKIE L. THORSON
111 SOUTH WEST STREET
CARLISLE, PA 17013
DATE OF NOTICE: JUNE 9, 2010
NOTICE, RULE 237.1
A~IPORTANT 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 se forth against you. Unless you act
within ten (10) days from the date of this notice, a judgment maybe entered against you without a hearing
and you may lose your properly 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 Baz Association
32 South Bedford Street
Cazlisle, PA 17013 "
(800)990-910
(717) 249-31 t ~" ;~~"~ ^~`.
~~'
Gregory Javazdian, Esquire
1310 Industrial Boulevazd
1~` Floor, Suite 101
Southampton, PA 18966
(215)942-9690
Attorney for Plaintiff
Usted se encuentra en estado de rebeldia por no haber tornado la action requiida de su parte en este caso.
Al no tomaz la action debida dentro de un termino de diez (10) dial de esta notification, el tnbunal pods,
sin necesidad de compararecer usted en torte o escuchaz prueba alguna, dictar sentencia en su contra, usted
puede perder bienes y otros derechos importantes. Debe llevaz esta notification a un abogado
immediatemente si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona
o llame por telpfono a la oficina, cuya direction se encuentra escrita abajo pars averiguaz donde se puede
conseguir assistencia legal.
"NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE"
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY
AS TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A., AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 09-7132 CIVIL TERM
vs.
VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
VERIFICATION OF NON-MILITARY SERVICE
GREGORY JAVARDIAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of
the following facts, to wit:
(a) Defendant, VICKIE A. THORSON, A/K/A VICKIE L. THORSON, is not in
the Military or Naval Service of the United States or its Allies, or otherwise within the provisions
of the Servicemembers' Civil Relief Act of Congress of 1940, as amended.
(b) Defendant, VICKIE A. THORSON, A/K/A VICKIE L. THORSON, is over
18 years of age, and resides at 111 WEST SOUTH STREET, CARLISLE, PA 17013.
(c) Plaintiff, EMC MORTGAGE CORPORATION, ATTORNEY-IN-FACT
FOR DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS
TRUST COMPANY OF CALIFORNIA, N.A., AS CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D , is an institution conducing business under the Laws of the
Commonwealth of Pennsylvania with an address of 7301 BAYMEADOWS WAY,
JACKSONVILLE, FL 32256.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
GREG R JAVARDIAN, ESQUIRE
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
TO: VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
111 WEST SOUTH STREET
CARLISLE, PA ] 7013
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY
AS TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A., AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 09-7132 CIVIL TERM
Plaintiff
vs.
VICKIE A. THORSON, AIK/A
VICKIE L. THORSON
Defendant
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
X Judgment by Default
_ Money Judgment
_ Judgment in Replevin
_ Judgment for Possession by Default
Judgment on Award of Arbitration
- Judgment on Verdict
- Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY: Gregory Javardian, Esquire at this telephone number: (215) 942-9690.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY
AS TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
7301 BAYMEADOWS WAY
JACKSONVILLE, FL 32256
vs.
VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
11 I WEST SOUTH STREET
CARLISLE, PA 17013
PRAECIPE FOR WRIT OF EXECUTION
MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly issue Writ of Execution in the above matter.
Amount Due
Interest from 06/22/10 to Date of Sale
@ $12.94 per diem
Subtotal
(Cost be added)
5
- a4. oo P0 A'r't'/
S 1ti-Do II It
Q4/
s4.y? Cas; Q?
/&K q6 0 A-
f I- 06 tie Co
4, 5-6 7)L,-e J-4-
C* 5553a
0'Q4T541{
RE u)'La l
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 09-7132 CIVIL TERM
$78,749.51
Rlr.? f 3
tb t
AVARDIAN, ESQUIRE
Plaintiff
I.D. #.55669
1310 Industrial Boulevard
1 st Floor, Suite 101
Southampton, PA 18966
(215) 942-9690
.A - .s
ALL THAT CERTAIN tract of land situate in the Third Ward of the Borough of Carlisle,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at the Southeastern corner of land now or formerly of Ann Leonard Estate, said point
being 30 feet, more or less, East of the 10 foot alley which runs from West South Street to Chapel
Alley and said point being on the northern side of West South Street; thence eastwardly along West
South Street, 20 feet 2 inches, more or less, to land now or formerly of John Boyd; thence
northwardly along said land, 32 feet to a point; thence eastwardly by the same, 6 feet 6 inches to a
point; thence northwardly along the same, 24 feet, more or less, to land now or formerly of Mrs. M.
Duncan; thence westwardly along said land 26 feet, more or less, to land now or formerly of the Ann
Leonard Estate; thence southwardly 60 feet, more or less, to the place of BEGINNING.
BEING improved with a two-story frame dwelling house known as No. 111 West South Street
BEING THE SAME PREMISES which Carlisle Opportunity Homes, Inc., a non-profit corporation,
by Deed dated and recorded January 30, 1996 in the Office of the Recorder of Deeds of Cumberland
County, Pennsylvania, in Deed Book Volume 134 Page 424 granted and conveyed unto VICKIE A.
THORSON.
PARCEL NO.: 04-21-0320-281
0 1
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY AS
TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
COURT OF COMMON PLEAS _ P 91
CUMBERLAND COUNTY, t Y?
Lr ?.J
No.: 09-7132 CIVIL TERM cf
O
vs.
VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
AFFIDAVIT PURSUANT TO RULE 3129.1
Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution
was filed the following information concerning the real property located at 111 WEST SOUTH
STREET, CARLISLE, PA 17013:
1. Name and address of Owner(s) or reputed Owner(s):
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
VICKIE A. THORSON, A/K/A 111 WEST SOUTH STREET
VICKIE L. THORSON CARLISLE, PA 17013
2. Name and address of Defendant(s) in the judgment:
VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
111 WEST SOUTH STREET
CARLISLE, PA 17013
3. Name and last known address of every judgment 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 indicate)
Northwest Consumer Discount Co.
4813 Jonestown Road, Suite 107
Harrisburg, PA 17109
t
4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Plaintiff.
United Credit Card Bank NA
8550 United Plaza Boulevard, Suite 203
Baton Rouge, LA 70809
Carlisle Opportunity Homes, Inc.
Carlisle Opportunity Homes, Inc.
Redevelopment Authority of the
County of Cumberland for the
Borough of Carlisle
Administering for CDBG Program
P.O. Box 517
Carlisle, PA 17013
60 West Penn Street
Carlisle, PA 17013
114 North Hanover Street, Suite 104
Carlisle, PA 17013
5. 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 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 (if address cannot be
reasonably ascertained, please indicate)
Cumberland County Domestic Relations
Cumberland County Tax Claim Bureau
PA Department of Public Welfare
Bureau of Child Support Enforcement
13 N. Hanover Street
Carlisle, PA 17013
1 Courthouse Square
Carlisle, PA 17013-3387
Health and Welfare Building - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
W
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:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenants/Occupants 111 WEST SOUTH STREET
CARLISLE, PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are subject to the
penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities.
G RY JAVARDIAN, ESQUIRE
tt ey for Plaintiff
August 30, 2010
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
I ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY
AS TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
vs.
COURT OF COMMON PLEAS
_
? rya
CUMBERLAND COUNTY m ?
: 09-7132 CIVIL TERM
No
sw
-'
.
?
r
VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY
AS TO THE SALE OF REAL ESTATE
I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action
and further certify this Property is:
() FHA
() Tenant Occupied
O Vacant
O Commercial
O As a result of Complaint in Assumpsit
(X) Act 91 complied with
t
JAVARDIAN, ESQUIRE
- Plaintiff
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
EMC MORTGAGE CORPORATION, COURT OF COMMON PLEAS
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY AS CUMBERLAND COUNTY
TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
vs.
VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
No.: 09-7132 CIVIL TERM
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NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
111 WEST SOUTH STREET
CARLISLE, PA 17013
Your house (real estate) at 111 WEST SOUTH STREET. CARLISLE PA 17013, is
scheduled to be sold at Sheriffs Sale on DECEMBER 8, 2010 at 10:00 A.M., in the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of
$78,749.51, obtained by EMC MORTGAGE CORPORATION, ATTORNEY-IN-FACT FOR
DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS
TRUST COMPANY OF CALIFORNIA, N.A. AS CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D, against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs 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
942-9690.
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.
N
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 below 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) 942-9690.
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 Gregory Javardian, Esquire at (215) 942-9690.
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. 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.
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 BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
(800) 990-9108
ALL THAT CERTAIN tract of land situate in the Third Ward of the Borough of Carlisle,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at the Southeastern corner of land now or formerly of Ann Leonard Estate, said point
being 30 feet, more or less, East of the 10 foot alley which runs from West South Street to Chapel
Alley and said point being on the northern side of West South Street; thence eastwardly along West
South Street, 20 feet 2 inches, more or less, to land now or formerly of John Boyd; thence
northwardly along said land, 32 feet to a point; thence eastwardly by the same, 6 feet 6 inches to a
point; thence northwardly along the same, 24 feet, more or less, to land now or formerly of Mrs. M.
Duncan; thence westwardly along said land 26 feet, more or less, to land now or formerly of the Ann
Leonard Estate; thence southwardly 60 feet, more or less, to the place of BEGINNING.
BEING improved with a two-story frame dwelling house known as No. 111 West South Street
BEING THE SAME PREMISES which Carlisle Opportunity Homes, Inc., a non-profit corporation,
by Deed dated and recorded January 30, 1996 in the Office of the Recorder of Deeds of Cumberland
County, Pennsylvania, in Deed Book Volume 134 Page 424 granted and conveyed unto VICKIE A.
THORSON.
PARCEL NO.: 04-21-0320-281
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N009-7132 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EMC MORTGAGE CORPORATION, ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, FWA
BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS CUSTODIAN OR TRUSTEE FOR
UCFC LOAN TRUST 1998-D Plaintiff (s)
From VICKIE A. THORSON AfK/A VICKIE L. THORSON
(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
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due$78,749.51
L.L.$.50
Interest FROM 06/22/10 TO DATE OF SALE @ $12.94
Atty's Comm % Due Prothy $2.00
Atty Paid $168.40
Plaintiff Paid
Other CostsTO BE ADDED
Date: SEPTEMBER 1, 2010
(Seal)
REQUESTING PARTY:
Name GREGORY JAVARDIAN, ESQUIRE
Deputy
Address: POWERS, KIRN & JAVARDIAN, LLC, 1310 INDUSTRIAL BOULEVARD, SUITE 101,
SOUTHAMPTON, PA 18966
Attorney for: PLAINTIFF
Telephone: 215-942-2090
Supreme Court ID No. 55669
21t/;
,D) D. uell, Prothonotary
By:
r
• SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FILED-CI: I" ICE
Sheriff r, I KE P R 0 T H 0 N 0 TA ??`t?tty a1 ?nvrrbrMf?j??
Jody S Smith
Chief Deputy z- 21j', ! APR I I Aft ICJ: 391
Richard W Stewart CUMBERLAND COUN1- Y
Solicitor OFFI OFT"` MFF PENNSYLVANIA
EMC Mortgage Corporation
vs. Case Number
.
Vickie A. Thorson 2009-7132
SHERIFF'S RETURN OF SERVICE
10/14/2010 Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-14-10 at 1654
hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above
entitled action, upon the property of Vickie A. Thorson, located at, 111 West South Street, Carlisle,
Cumberland County, Pennsylvania according to law.
10/18/2010 12:33 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 10-18-10
at 1223 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above
entitled action, upon the within named defendant, to wit: Vicki A. Thorson, by making known unto, Vickie
A. Thorson, personally, at, 111 West South Street, Carlisle, Cumberland County, Pennsylvania its
contents and at the same time handing to her personally the said true and correct copy of the same.
12/01/2010 As directed by Gregory Javardian, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/2/2011
01/26/2011 As directed by Gregory Javardian, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/6/2011
04/05/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney Javardian on 4/5/11.
SHERIFF COST: $769.69 SO ANSWERS,
April 08, 2011 RON R ANDERSON, SHERIFF
V6 ?a ac?zx
eIl,&? &I Al II
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ici Count, Suite S henft. 7e,easoft . Inc.
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT,FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY
TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS
CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
VS.
VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
COURT OF COMMON PLEAS
AS CUMBERLAND COUNTY
No.: 09-7132 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129.1
Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution
was filed the following information concerning the real property located at 111 WEST SOUTH
STREET, CARLISLE, PA 17013:
1. Name and address of Owner(s) or reputed Owner(s):
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
VICKIE A. THORSON, A/K/A 111 WEST SOUTH STREET
VICKIE L. THORSON CARLISLE, PA 17013
2. Name and address of Defendant(s) in the judgment:
VICKIE A. THORSON, A/K/A 111 WEST SOUTH STREET
VICKIE L. THORSON CARLISLE, PA 17013
3. Name and last known address of every judgment 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 indicate)
Northwest Consumer Discount Co.
4813 Jonestown Road, Suite 107
Harrisburg, PA 17109
4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Plaintiff.
United Credit Card Bank NA
8550 United Plaza Boulevard, Suite 203
Baton Rouge, LA 70809
Carlisle Opportunity Homes, Inc.
Carlisle Opportunity Homes, Inc.
P.O. Box 517
Carlisle, PA 17013
60 West Penn Street
Carlisle, PA 17013
Redevelopment Authority of the 114 North Hanover Street, Suite 104
County of Cumberland for the Carlisle, PA 17013
Borough of Carlisle
Administering for CDBG Program
5. 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 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 (if address cannot be
reasonably ascertained, please indicate)
Cumberland County Domestic Relations
Cumberland County Tax Claim Bureau
PA Department of Public Welfare
Bureau of Child Support Enforcement
13 N. Hanover Street
Carlisle, PA 17013
1 Courthouse Square
Carlisle, PA 17013-3387
Health and Welfare Building - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
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:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenants/Occupants 111 WEST SOUTH STREET
CARLISLE, PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are subject to the
penalties of 18 Pa. C.S.A. 4904 relating to unworn falsification to authorities.
G RY JAVARDIAN, ESQUIRE
Ty for Plaintiff
August 30, 2010
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY
AS TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS
CUSTODIAN OR TRUSTEE FOR UCFC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 09-7132 CIVIL TERM
LOAN TRUST 1998-D
vs.
VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY
AS TO THE SALE OF REAL ESTATE
I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action
and further certify this Property is:
() FHA
() Tenant Occupied
() Vacant
O Commercial
() As a result of Complaint in Assumpsit
(X) Act 91 complied with
JAVARDIAN, ESQUIRE
r Plaintiff
iI
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE
BANK NATIONAL TRUST COMPANY
TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS
CUSTODIAN OR TRUSTEE FOR UCFC
COURT OF COMMON PLEAS
AS CUMBERLAND COUNTY
No.: 09-7132 CIVIL TERM
LOAN TRUST 1998-D
VS.
VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: VICKIE A. THORSON, A/K/A
VICKIE L. THORSON
111 WEST SOUTH STREET
CARLISLE, PA 17013
Your house (real estate) at 111 WEST SOUTH STREET, CARLISLE, PA 17013, is
scheduled to be sold at Sheriffs Sale on DECEMBER 8, 2010 at 10:00 A.M., in the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of
$78,749.51, obtained by EMC MORTGAGE CORPORATION, ATTORNEY-IN-FACT FOR
DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS
TRUST COMPANY OF CALIFORNIA, N.A. AS CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D, against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs 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: 2{ 15)
942-9690.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale
for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice below 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) 942-9690.
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 Gregory Javardian, Esquire at (215) 942-9690.
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. 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.
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 BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
(800) 990-9108
ALL THAT CERTAIN tract of land situate in the Third Ward of the Borough of Carlisle,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at the Southeastern corner of land now or formerly of Ann Leonard Estate, said point
being 30 feet, more or less, East of the 10 foot alley which runs from West South Street to Chapel
Alley and said point being on the northern side of West South Street; thence eastwardly along West
South Street, 20 feet 2 inches, more or less, to land now or formerly of John Boyd; thence
northwardly along said land, 32 feet to a point; thence eastwardly by the same, 6 feet 6 inches to a
point; thence northwardly along the same, 24 feet, more or less, to land now or formerly of Mrs. M.
Duncan; thence westwardly along said land 26 feet, more or less, to land now or formerly of the Ann
Leonard Estate; thence southwardly 60 feet, more or less, to the place of BEGINNING.
BEING improved with a two-story frame dwelling house known as No. 111 West South Street
BEING THE SAME PREMISES which Carlisle Opportunity Homes, Inc., a non-profit corporation,
by Deed dated and recorded January 30, 1996 in the Office of the Recorder of Deeds of Cumberland
County, Pennsylvania, in Deed Book Volume 134 Page 424 granted and conveyed unto VICKIE A.
THORSON.
PARCEL NO.: 04-21-0320-281
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N009-7132 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EMC MORTGAGE CORPORATION, ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A
BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS CUSTODIAN OR TRUSTEE FOR
UCFC LOAN TRUST 1998-D Plaintiff (s)
From VICKIE A. THORSON A/K/A VICKIE L. THORSON
(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
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due$78,749.51
L.L.$.50
Interest FROM 06/22/10 TO DATE OF SALE @ $12.94
Atty's Comm % Due Prothy $2.00
Atty Paid $168.40
Plaintiff Paid
Other CostsTO BE ADDED
Date: SEPTEMBER 1, 2010
(Seal)
I
David thono ry
By:
Deputy
REQUESTING PARTY:
Name GREGORY JAVARDIAN, ESQUIRE
Address: POWERS, KIRN & JAVARDIAN, LLC, 1310 INDUSTRIAL BOULEVARD, SUITE 101,
SOUTHAMPTON, PA 18966
Attorney for: PLAINTIFF
Telephone: 215-942-2090
Supreme Court ID No. 55669
On September 22, 2010 the Sheriff levied upon the
defendant's interest in the real property situated in
Carlisle Borough, Cumberland County, PA,
Known and numbered as, 111 West South Street,
Carlisle, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: September 22, 2010
By:
4
Real Estate Coordinator ?? L
• k. • 1
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 22, October 29, and November 5, 2010
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Marie Coyne,
SWORN TO AND SUBSCRIBED before me this
5 da of November, 2010
Notary
NOTARIAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
r
CUMBERLAND LAW JOURNAL
Writ No. 2009-7132 Civil
EMC Mortgage Corporation,
Attorney in Fact for Deuutsche
Bank National Trust Company
as Trustee, f/k/a Bankers Trust
Company of California, N.A., as
Custodian or Trustee for UCFC
Loan Trust 1998-D
VS.
Vickie A. Thorson
Atty.: Gregory Javardian
ALL THAT CERTAIN tract of land
situate in the Third Ward of the
Borough of Carlisle, Cumberland
County, Pennsylvania, bounded and
described as follows:
BEGINNING at the Southeastern
corner of land now or formerly of
Ann Leonard Estate, said point be-
ing 30 feet, more or less, East of the
10 foot alley which runs from West
South Street to Chapel Alley and said
point being on the northern side of
West South Street; thence eastwardly
along West South Street, 20 feet 2
inches, more or less, to land now
or formerly of John Boyd; thence
northwardly along said land, 32
feet to a point; thence eastwardly by
the same, 6 feet 6 inches to a point;
thence northwardly along the same,
24 feet, more or less, to land now or
formerly of Mrs. M. Duncan; thence
westwardly along said land 26 feet,
more or less, to land now or formerly
of the Ann Leonard Estate; thence
southwardly 60 feet, more or less, to
the place of BEGINNING.
BEING improved with a two-story
frame dwelling house known as No.
111 West South Street.
BEING THE SAME PREMISES
which Carlisle Opportunity Homes,
Inc., a non-profit corporation, by
Deed dated and recorded January
30, 1996 in the Office of the Recorder
of Deeds of Cumberland County,
Pennsylvania, in Deed Book Volume
134 Page 424 granted and conveyed
unto VICKIE A. THORSON.
PARCEL NO.: 04-21-0320-281.
121
The Patriot-News Co.
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
ZhePahiot-News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is
interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time,
place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
10/15/10
10/22/10
10/29/10
(7 f 1
Sworn to and subscribed b re me this 19Aa of November, 2010 A.D.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sherrie L. Kisser, Notary Put)ilr a
I Lower Paxton Twp., Dauphin 03unLy
L My Commission Expires Nov. 26, 2011 i
Member, Pennsylvania Association cf Notaries
2009-7,1*,CWH 7brtn
9 Thist Con4wny
as*^*to% f0Wq fankars 7hW
of Via, N.A., as
Cmm"mbn or' hnfto 4M
Loan Twat 19WO
Vs
Vldit A. Thorson
Attlr: any iwmrcftn
ALL THAT CERTAIN tract of land situate
in the Third Weed of the Borough of Carlisle,
Cumberland County, Pennsylvania, bounded
and described as follows: '
BEGINNING at the Southeastern comer of
land now or formerly of Ann Leonard Estate,
said point being 30 feet, more or less, East of
the 10 foot alley which runs from West South
Street to Chapel Alley and said point being
on the northern side of West South Street;
thence eestwardly along West South Street,
20 feet 2 inches, more or less, to land now or
formerly of John Boyd; thence northwatdly
along said land, 32 feet to a point; thence
eastwardly by the same, 6 feet 6 inches to a
point; thence northwardty along the same, 24
feet, more or less, to land now or formerly of
Mrs. M. Duncan; thence westwardly along
said land 26 fect, more or less, to land now or
formerly of the Ann Leonard Estate; thence
southwardly 60 feet, more or less, to the place
of BEGINNING.
BEING improved with a two-story frame
dwelling house (mown as No. 111 West South
Street
BEING THE SAME PREMISES which
Carlisle Opportunity Homes, Inc., a non-
profit corporation, by Deed dated and
recorded January 30,19% in the Offte`of the
Recorder of Deeds of C1mWW County,
Pennsylvania, in Deed Book Volume 134 Page
424 granted and conveyed unto VICKIE A.
THORSON.
PARCEL NO.: 04-21-0320-281
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
EMC MORTGAGE CORPORATION, ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE, F/K/A BANKERS TRUST IN THE COURT OF COMMON PLEAS
COMPANY OF CALIFORNIA, N.A. AS CUSTODIAN
OR TRUSTEE FOR UCFC LOAN TRUST 1998-D of Cumberland County
c/o 3415 Vision Drive
Columbus, OH 43219 CIVIL ACTION - LAW
VS.
Plaintiff
VICKIE A. THORSON, A/K/A VICKIE L. THORSON
Mortgagor(s) and Record Owner(s)
I 1 I West South Street
Carlisle, PA 17013
Defendant(s)
TO THE PROTHONOTARY:
ACTION OF MORTGAGE FORECLOSURE
No. 09-7132 CV
:1; _
PRAECIPE FOR WRIT OF EXECUTION
Issue Writ of Execution in the above matter:
O
461$.5o Pir-? ATrY
14-40 car
7109.94
98-50 k
14.00
ay. 00
- 9to 39 - PI) A-rrj
$ol.a5 DUE Cp
&7as5o(o
?o o28yy?7
Amount Due
Interest from
6/23/2010 to Date of
Sale per diem at
$12.94
(Costs to be added)
$78,749.51
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
a_
ALL THAT CERTAIN tract of land situate in the Third Ward of the Borough of Carlisle, Cumberland
County, Pennsylvania, bounded and described as follows:
BEGINNING at the Southeastern corner of land now or formerly of Ann Leonard Estate, said point being
30 feet, more or less, East of the 10 foot alley which runs from West South Street to Chapel Alley and
said point being on the northern side of West South Street; thence eastwardly along West South Street,
20 feet 2 inches, more or less, to land now or formerly of John Boyd; thence northwardly along said
land, 32 feet to a point; thence eastwardly by the same, 6 feet 6 inches to a point; thence northwardly
along the same, 24 feet, more or less, to land now or formerly of Mrs. M. Duncan; thence westwardly
along said land 26 feet, more or less, to land now or formerly of the Ann Leonard Estate; thence
southwardly 60 feet, more or less, to the place of BEGINNING.
BEING improved with a two-story frame dwelling house known as No. 111 West South Street.
BEING THE SAME PREMISES which Carlisle Opportunity Homes, Inc., a non-profit corporation, by Deed
dated and recorded January 30, 1996 in the office of the Recorder of Deeds of Cumberland County,
Pennsylvania, in Deed Book Volume 134 Page 424 granted and conveyed unto VICKIE A. THORSON.
MUNICIPALITY THIRD WARD OF THE BOROUGH OF CARLISLE
BEING PREMISES: 111 West South Street, Carlisle PA 17013
SOLD as the property of VICKIE A. THORSON, A/K/A VICKIE L. THORSON
TAX PARCEL #04-21-0320-281
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attornev for Plaintiff
EMC MORTGAGE CORPORATION, ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA, N.A. AS CUSTODIAN OR
TRUSTEE FOR UCFC LOAN TRUST 1998-D
c/o 3415 Vision Drive
Columbus, OH 43219
Plaintiff
vs.
VICKIE A. THORSON, A/K/A VICKIE L. THORSON
Mortgagor(s) and Record Owner(s)
111 West South Street
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
NO. 09-7132 CV
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real
property in question is not subject to the Act.
By:
KML t,-Ak'F GROUP, P.C. ,
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
-
Lisa Lee Pa. ID 78020
.:
--
Kristina Murtha Pa. ID 61858 o
David Fein Pa. ID 82628
_Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047 -
Jill P. Jenkins Pa. ID 306588 l
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CU
EMC MORTGAGE CORPORATION, ATTORNEY-IN-FACT
FOR DEUTSCHE BANK NATIONAL TRUST COMPANY
AS TRUSTEE, F/K/A BANKERS TRUST COMPANY OF
CALIFORNIA, N.A. AS CUSTODIAN OR TRUSTEE FOR
UCFC LOAN TRUST 1998-1)
Plaintiff
vs.
VICKIE A. THORSON, A/K/A VICKIE L. THORSON
Defendant(s)
WBERLAND COUNTY, PENNSYLVANIA
NO. 09-7132 CV
VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL
RELIEF ACT AS AMENDED
1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter, does hereby state to the best of his/her information and belief, as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website
operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do)
for the following individual(s): VICKIE A. THORSON, A/K/A VICKIE L. THORSON, has a last
known residence of 111 West South Street, Carlisle, PA 17013. The following information was used to
search the DMDC (check all that apply):
X Last Name
X First Name
X__ Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18 Pa.
u o ies.
C.S.A. 4904 rela ing to unsworn falsification W
Date By:
KML LA , P.C.
Michael cK ever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa_ ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gomall Pa. ID 92382
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
Department of Defense Manpower Data Center
Status Report
/want to Servicemembers Civil Relief Act
Last Name: THORSON
First Name: VICKIE
Middle Name: A.
Active Duty Status As Of: Dec-07-2012
Results as of : Dec-07-2012 09:05:00
SCRA 2.3
On Active Duty On Active Duty Status Date
Active Duty Start Date. Active Duty End Date Status Service Component
NA NA No NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects when: the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her'Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notfication End Date status Service component
NA NA No NA
This response reflects whether the individual or his/her and has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
W
fit
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: hftp:/twww.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA maybe invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty. Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: OSTJERVB45
Department of Defense Manpower Data Center
Status Report
Pursuant to Servicernembers Civil Relief Act
Last Name: THORSON
First Name: VICKIE
Middle Name: L.
Active Duty Status As Of: Dec-07-2012
Results as of : Dec-07-2012 09:05:34
SCRA 2.3
On Active Duty On Active Duly Status Date '.'
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Wahl n 367. Days of Active Duty Statue Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-1$r to Active Duty on Active Duly Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA NA. No NA
This response reflects whether the individual or hislher unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
W LAa..j-
fol _4?m_
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: 7VTQ8MF06E
rs
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
EMC MORTGAGE CORPORATION, ATTORNEY-
IN-FACT FOR DEUTSCHE BANK NATIONAL
TRUST COMPANY AS TRUSTEE, F/K/A
BANKERS TRUST COMPANY OF CALIFORNIA,
N.A. AS CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
c/o 3415 Vision Drive
Columbus, OH 43219
vs.
Plaintiff
VICKIE A. THORSON, A/K/A VICKIE L.
THORSON
(Mortgagor(s) and Record Owner(s))
1 I 1 West South Street
Carlisle, PA 17013
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 09-7132 CV
EMC MORTGAGE CORPORATION, ATTORNEY-IN-FACT FOR DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS CUSTODIAN OR
TRUSTEE FOR UCFC LOAN TRUST 1998-D, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth
as of the date the praecipe for the writ of execution was filed the following information concerning the real property located
at:
111 West South Street
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s): ?-?
VICKIE A. THORSON, A/K/A VICKIE L. THORSON
111 West South Street ° r .
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
VICKIE A. THORSON, A/K/A VICKIE L. THORSON
111 West South Street
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
/0
NORTHWEST CONSUMER DISCOUNT CO
4813 Jonestown Road Suite 107
Harrisburg, PA 17109
4. Name and address of the last recorded holder of every mortgage of record:
UNITED CREDIT CARD BANK NA
8550 United Plaza Blvd, Ste 203
Baton Rouge, LA 70809
CARLISLE OPPORTUNITY HOMES INC
60 West Penn Street
Carlisle, PA 17013
CARLISLE OPPORTUNITY HOMES INC
POBox 517
Carlisle, PA 17013
REDEVELOPMENT AUTHORITY OFTHECOUNTY
OF CUMBERLAND FOR THEBOROUGH OFCARLISLE
114 North Hanover Street Suite 104
Carlisle, PA 17013
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
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/OCCUPANTS
I I 1 West South Street
Carlisle, PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my 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 authodties. 6
DATED:
By:
KML W UP, P.C.
Michae MeK ver Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua L Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
09-1 132 CV
gML Law Group, P.C. Suite 5000- BNY Independence Center
701 Market Street
19106
Philadelphia>
(215) 627-1322
Attorney for Plaintiff
EMC MORTGAGE CORPORATION, BANK
PADN DEUTSCHE TRUSSTEE,
ATTORNEY-IN-FACT FOR
NATIONAL TRUST COM
F/K/A BANKERS TRUST CUSTODIAN OR
CALIFORNIA, N A AS
TRUSTEE FOR UCFC LOAN TRUST 1999-D
c/o 3415 Vision Drive
Columbus, OH 43219
Plaintiff
VS.
VICKIE A. THORSON, A/K/A VICKIE L.
THORSON
Mortgagor(s) and Record Owner(s)
111 West South Street
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
Defendant(s
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Docket No. 09-7132 CV
'C
( 3
FV
a
ATTEMPTING AW FIRM IS A DEBT COLLECTOR TNODY U IN AN ATTEMPT TO O
THIS L
COLLECT A DEBT. THIS NOTICE IS SENT
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: THORSON, AIKIA VICKIE L. THORSON, VICKIE A-
VICKIE A. THORSON, AIKJA VICKIE L. THORSON
111 West South Street
Carlisle, PA 17013
Sheriffs Sale
se at 111 West South Street, Carlisle, PA 17013 is Hear . a Rm scheduled 2nd to ORATION, FL be ATTORNEY-IN-
49-51 at Courthouse to enforce
your hou Commissione
on Wednesday, June 05, 2013, at obtained A in
d EMC MORTGAGE COR TRUSTEE, FK/ BANKERS
the court judgment of $78,7 BANK by
FACT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY AS
TODIAN OR TRUSTEE FOR
TRUST COMPANY OF CALIFORNIA, N.A. AS CUS UCFC LOAN
TRUST 1998-D against you-
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
09-7132 CV
1. The sale will be cancelled if you pay to EMC MORTGAGE CORPORATION, ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS
TRUST COMPANY OF CALIFORNIA, N.A. AS CUSTODIAN OR TRUSTEE FOR UCFC LOAN
TRUST 1998-D, the back payments, late charges, costs and reasonable attorney's fees due. To find out how
much you must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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.
4. 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never
happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the
buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid
for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 schedule of distribution is tiled.
7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.12hiladell2hiafed.org/foreclosure/
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 BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGALSF,RVICF,S INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
A.
09-7132 CV
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
116992FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
CIVIL ACTION
EMC MORTGAGE CORPORATION, ATTORNEY-
IN-FACT FOR DEUTSCHE BANK NATIONAL
TRUST COMPANY AS TRUSTEE, F/K/A
BANKERS TRUST COMPANY OF CALIFORNIA,
N.A. AS CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
c/o 3415 Vision Drive
Columbus, OH 43219
Plaintiff
vs.
VICKIE A. THORSON, A/K/A VICKIE L.
THORSON
111 West South Street
Carlisle, PA 17013
Defendant(s)
Term
No. 09-7132 CV
ACTION OF MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: VICKIE A. THORSON A/K/A VICKIE L. THORSON
Your house (real estate) at (address) 111 West South Street Carlisle PA 17013
is scheduled to be sold at Sheriff's Sale on (date): 6/5/2013 (time): 10:00 a.m.
(place of sale):_ Commissioners Hearing Room - 2nd floor Cumberland County Courthouse
to enforce the court judgment of $78,749.5 1, obtained by the judgment creditor
against you.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 09-7132 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EMC MORTGAGE CORPORATION, ATTORNEY-
IN-FACT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY as Trustee, f/k/a BANKERS
TRUST COMPANY OF CALIFORNIA, N.A., as Custodian or Trustee for UCFC LOAN TRUST
1998-D, Plaintiff (s)
From VICKIE A. THORSON a/k/a VICKIE L. THORSON
(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
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $78,749.51 L. L.:
Interest from 6/23/10 to Date of Sale per diem at $12.94
Atty's Comm: Due Prothy: $2.25
Atty Paid: $964.39 Other Costs:
Plaintiff Paid:
Date: 12/20/12
David D. Buell, Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name: JILL P. JENKINS, ESQUIRE
Address: KML LAW GROUP, P.C.
SUITE 5000 - BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 306588
KML LAW GROUP,P.C. 116992FC
Suite 5000 CF: 10/19/2009
BNY Mellon Independence Center SD: 06/05/2013
701 Market Street $78,749.51.----.
Philadelphia,PA 19106-1532
215-627-1322
Attorney for Plaintiff
EMC MORTGAGE CORPORATION, IN THE COURT OF COMMON PLEAS
ATTORNEY-IN-FACT FOR DEUTSCHE BANK
NATIONAL TRUST COMPANY AS TRUSTEE, of Cumberland County
F/K/A BANKERS TRUST COMPANY OF
CALIFORNIA,N.A.AS CUSTODIAN OR CIVIL ACTION—LAW
TRUSTEE FOR UCFC LOAN TRUST 1998-D
c/o 3415 Vision Drive ACTION OF MORTGAGE FORECLOSURE
Columbus, OH 43219
Plaintiff Term
vs. No. 09-7132 CV
VICKIE A. THORSON,A/K/A VICKIE L.
THORSON
Mortgagor(s)and .a
Record Owner(s) "C
rn
,1
111 West South Street --
Carlisle,PA 17013 �.�. ° °-4 C
Defendant(s) ["C c�ri
.�
CERTIFICATE OF SERVICE `�� -- `
PURSUANT TO Pa.R.C.P.3129.2 (c) (2)
Robert Murray, an employee of KML Law Group,P.C.,counsel of Plaintiff,hereby certifies that service
on the Defendants of the Notice of Sheriff Sale was made by:
(X) Personal Service by the Sheriffs Office/competent adult(As per Sherry at the so,def. personally
served at the property on 4/3/13).
( ) Certified mail by KML Law Group,P.C. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by KMI,Law Group,P.C. to Attorney for Defendant(s)of record(proof of mailing
attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s)(proof of acknowledgment attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s)of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult(copy of return attached).
( ) Certified Mail&ordinary mail by Sheriffs Office(copy of return attached).
( ) Certified Mail&ordinary mail by KML Law Group,P.C. (original receipt(s)for Certified Mail
attached).
( ) Published in accordance with court order(copy of publication attached).
Pursuant to the Affidavit under Rule 3129(copy attached),service on all lienholders(if any)has been made by
ordinary mail KML Law Group,P.C.(copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A.
Section 4904.
Res ctfully submitted,
BY: Ro rt ay
Legal Assistant
Name and Address of Sender Check type of man or servfoe: - Affix Stamp HemPO�,
GOLDBECK ❑Certified ❑ Recorded DeWery9memational) �N�ficatteoafmaling.
SUITE-5000 ❑Coo ❑ Registered . or for addroonalcopies
701 MARKET STREET wfy
❑Delivery Confirmation ❑Return Receipt for Merchandise of this bill) �
PHILADELPHIA,PA ❑Evress Mal ❑signature Confirmation Postma*and
19106-1532 Date of Recelot 02 1M 'S 03.52
HeMSng A OOQ4285957: .JAN03_20.13
Ankle Number Addressee(Name,Sheet,ay,State,&ZIP Code) Postage Fee tUM 7JP.L:77lDE t®1,06
1• DOMESTIC RELATIONS OF CUMBERLAND UNITED CREDIT C ARD BAt IK °
COUNTY 8550 United Plaza Ivd,Ste 03 Ct>rtTfry
PO Box 320 - Baton R ugh;lA 7 09
Carlisle,PA 17013
2' PA DEPARTMENT OF PUBLIC WELFARE- 60 West Penn Stre A
Bureau of Child Support Enforcement Carlisle,PA 17013
Health and Welfare Bldg.-Room 432 d;
>; 3. Harrisburg,PA 17105-2675 POBox 17
Carlisle,PA 17013
NORTHWEST CONSUMER DISCOUNT CO
4813 Jonestown Road Suite 107 REDEVELOPMEN AUTHO ITY
Hanisbuig,PA 71109
4 THEBO OUGH OFCARLISLE
114 Not h Hanover Street Sue 104
Carlisle,PA 17013
�4 5• TENAN S/OCCUP NTS
ty 111 W t South Sti set
Cadisle,PA 17013
6.
7•
i
8.
Total Number of Piece Toted Number of Pieces Postmaster,Per(Name of recelvi oyee) -
Usted by Sander Recehmd at Post Office See Privacy Act Statement on Reverse -
,,S
PS Forth 3877,Feb ) Com
ntary 2002(Page 1 of 1 P Y Typewriter,Ink,br Ball Point Pen
.116992FC Cumberland County Sale Date:06/05/2013
VICKIE A.THORSON.A/K/A VICKIE L:THORSON
KML LAW GROUP,P.C.
Suite 5000—BNY Mellon Independence Center
701 Market Street
Philadelphia,PA 19106
215-825-6320
Attorney for Plaintiff
EMC MORTGAGE CORPORATION,ATTORNEY- IN THE COURT OF COMMON PLEAS
IN-FACT FOR DEUTSCHE BANK NATIONAL
TRUST COMPANY AS TRUSTEE,F/K/A of Cumberland County
BANKERS TRUST COMPANY OF CALIFORNIA,
N.A.AS CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D CIVIL ACTION-LAW
c/o 3415 Vision Drive
Columbus,OH 43219
Plaintiff ACTION OF MORTGAGE FORECLOSURE
vs. Term
No. 09-7132 CV
VICKIE A.THORSON,A/K/A VICKIE L.
THORSON
Mortgagor(s)and Record Owner(s)
111 West South Street
Carlisle,PA 17013
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
EMC MORTGAGE CORPORATION, ATTORNEY-IN-FACT FOR DEUTSCHE BANK NATIONAL
TRUST COMPANY AS TRUSTEE,F/K/A BANKERS TRUST COMPANY OF CALIFORNIA,N.A.AS
CUSTODIAN OR TRUSTEE FOR UCFC LOAN TRUST 1998-D,Plaintiff in the above action, by and through
an authorized employee of its attorneys,KML Law Group,P.C., sets forth as of the date the praecipe for the writ
of execution was filed the following information concerning the real property located at:
111 West South Street
Carlisle,PA 17013
l.Name and address of Owner(s)or Reputed Owner(s):
VICKIE A. THORSON,A/K/A VICKIE L. THORSON
111 West South Street
Carlisle,PA 17013
2.Name and address of Defendant(s)in the judgment:
VICKIE A. THORSON,A/K/A VICKIE L. THORSON
111 West South Street
Carlisle,PA 17013
3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be
sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle,PA 17013
PA DEPARTMENT OF PUBLIC WELFARE
Bureau of Child Support Enforcement
Health and Welfare Bldg. -Room 432
P.O.Box 2675
Harrisburg,PA 17105-2675
NORTHWEST CONSUMER DISCOUNT CO
4813 Jonestown Road Suite 107
Harrisburg,PA 17109
4.Name and address of the last recorded holder of every mortgage of record:
UNITED CREDIT CARD BANK NA
8550 United Plaza Blvd, Ste 203
Baton Rouge,LA 70809
CARLISLE OPPORTUNITY HOMES INC
60 West Penn Street
Carlisle,PA 17013
CARLISLE OPPORTUNITY HOMES INC
POBox 517
Carlisle,PA 17013
REDEVELOPMENT AUTHORITY OF THE COUNTY
OF CUMBERLAND FOR THEBOROUGH OFCARLISLE
114 North Hanover Street Suite 104
Carlisle,PA 17013
5.Name and address of every other person who has any record interest in or record lien on the property and
whose interest may be affected by the sale:
6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in
the property which may be affected by the sale.
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/OCCUPANTS
111 West South Street
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
18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
DATED: May 9,2013
KML La ro I.C.
BY: Robert Mu y
Legal Assistant
KML LAW GROUP, P.C. `' P ;'0
Suite 5000—BNY Mellon Independence Center
701 Market Street '' ` I� �} All 1/:
Philadelphia, PA 19106 CUltlBERL 1
Attorney for Plaintiff PENNSYLVANIA ��
EMC MORTGAGE CORPORATION,ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE, F/K/A BANKERS TRUST IN THE COURT OF COMMON PLEAS
COMPANY OF CALIFORNIA,N.A. AS CUSTODIAN OR
TRUSTEE FOR UCFC LOAN TRUST 1998-D OF Cumberland COUNTY
c/o 3415 Vision Drive
Columbus,OH 43219 CIVIL ACTION—LAW
Plaintiff
vs. ACTION OF MORTGAGE FORECLOSURE
VICKIE A. THORSON, A/K/A VICKIE L. THORSON
(Mortgagor(s)and Record Owner(s)) No. 09-7132 CV
111 West South Street
Carlisle, PA 17013
Defendant(s)
Y
PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF
UNDER Pa.R.C.P.2352
TO THE PROTHONOTARY:
Kindly file of record the Praecipe of DEUTSCHE BANK NATIONAL TRUST COMPANY
FORMERLY KNOWN AS BANKERS TRUST COMPANY OF CALIFORNIA,N.A., AS TRUSTEE
FOR THE CERTIFICATEHOLDERS OF UCFC LOAN TRUST 1998-D for Voluntary Substitution
under Pa.R.C.P. 2352 due to Assignment of Mortgage and attached Statement of Material Facts in
Support of Voluntary Substitution, Verification, Certification of Service. The address for the new
Plaintiff is 7757 Bayberry Road, Mail Stop- 171-5-7701,Jacksonv' e FL, 922
By:
V�KRXIL LAW GROUP,P.C.
ichael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Attorneys for Plaintiff
Q Q.Sd -
�� P do
P il # -73 goc", o`-
�.#-
KML LAW GROUP,P.C.
Suite 5000—BNY Mellon independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
EMC MORTGAGE CORPORATION,ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST IN THE COURT OF COMMON PLEAS
COMPANY AS TRUSTEE,F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA,N.A. AS CUSTODIAN OR OF Cumberland COUNTY
TRUSTEE FOR UCFC LOAN TRUST 1998-D
c/o 3415 Vision Drive CIVIL ACTION—LAW
Columbus,OH 43219
Plaintiff ACTION OF MORTGAGE FORECLOSURE
vs.
VICKIE A,THORSON, A/K/A VICKIE L.THORSON No.09-7132 CV
(Mortgagor(s)and Record Owner(s))
I I 1 West South Street
Carlisle, PA 17013
Defendant(s)
i STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER
Pa.R.C.P.2352
DEUTSCHE BANK NATIONAL TRUST COMPANY FORMERLY KNOWN AS
BANKERS TRUST COMPANY OF CALIFORNIA,N.A.,AS TRUSTEE FOR THE
CERTIFICAT'EHOLDERS OF UCFC LOAN TRUST 1998-D,by counsel,hereby voluntarily substitutes
itself as Plaintiff in the above-captioned matter and in support thereof represents as follows:
1. The above-captioned Action of Mortgage Foreclosure relates to a property located at I 1 I West
South Street Carlisle,PA 17013("Property").
2. Plaintiff holds a mortgage on the Property which is recorded at Mortgage Book 1495, Page 548 in
the Office of the Recorder of Deeds for Cumberland County.
3. The original Plaintiff in this action is EMC MORTGAGE CORPORATION,ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST
COMPANY OF CALIFORNIA,N.A.AS CUSTODIAN OR TRUSTEE FOR UCFC LOAN TRUST 1998-D.
4. DEUTSCHE BANK NATIONAL TRUST COMPANY FORMERLY KNOWN AS
BANKERS TRUST COMPANY OF CALIFORNIA,N.A.,AS TRUSTEE FOR THE
CERTIFICATEHOLDERS OF UCFC LOAN TRUST 1998-D is the successor in interest to the Plaintiff by
an assignment of mortgage recorded in land records of Cumberland.County on February 26,2010 in Instrument#
201024952 and is hereby voluntarily substituted as Plaintiff in the above-captioned matter.
Respectfully submitted,
By:
L LAW G , P.C.
ichael McKeever Pa.ID 56129
Jay E.Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
_ Thornas Puleo Pa. ID 27615
Jill P. Jenkins Pa.1D 306588
Alyk L.Oflazian Pa. ID 312912
Attorneys for Plaintiff
KML LAW GROUP, P.C.
SUITE 5000—BNY MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
215-627-1322
ATTORNEY FOR PLAINTIFF
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE BANK
NATIONAL TRUST COMPANY AS TRUSTEE, IN THE COURT OF COMMON PLEAS
F/K/A BANKERS TRUST COMPANY OF OF Cumberland COUNTY
CALIFORNIA,N.A. AS CUSTODIAN OR
TRUSTEE FOR UCFC LOAN TRUST 1998-D CIVIL ACTION - LAW
c/o 3415 Vision Drive
Columbus, OH 43219 ACTION OF MORTGAGE
Plaintiff FORECLOSURE
vs.
VICKIE A. THORSON, A/K/A VICKIE L. Term
THORSON No. 09-7132 CV
(Mortgagor(s)and Record Owner(s))
1 11 West South Street
Carlisle, PA 17013
Defendant(s)
CERTIFICATE OF SERVICE
Doris Guzman, hereby certifies that he/she did serve true and correct copies of Praecipe
for Voluntary Substitution and all supporting papers attached hereto upon Defendant, by first
class mail, postage pre-paid, on—MA_' w_
VICKIE A. THORSON, A/K/A VICKIE L. THORSON
111 West South Street
Carlisle, PA 1.7013
By:
KM*Law up, P.C.
Doris Guzman, Legal Assistant
Dguziiiaii@kmilawgroup.com
215-825-6402 (Direct Phone)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson '
Sheriff
q,,y'Vi'# 01I3�i9P}f�,r1Q ?r fib f1�J �l'1f�tk.
Jody S Smith *)N Chief Deputy 23 Arl 10: 1
Richard W Stewart
Solicitor OPPME OF THE SHERIFF ��MBLRLA?4D Lou 4i
PEMNs YLVAMA
EMC Mortgage Corporation
Case Number
vs.
Vickie A. Thorson 2009-7132
SHERIFF'S RETURN OF SERVICE
04/01/2013 07:53 PM - Deputy Jason Kinsler, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 111 West South Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County.
04/03/2013 10:35 AM -Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Vickie A. Thorson at 111 West South Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County.
06/05/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on June 5, 2013 at 10:00 a.m. He
sold the same for the sum of$1.00 to Attorney Jill Jenkins, on behalf of Deutsche Bank National Trust
Company, F/K/A Bankers Trust Company of California, N.A., as Trustee for UCFC Loan Trust 1998-D,
being the buyer in this execution, paid to the Sheriff the sum of
SHERIFF COST: $814.43 SO ANSWERS,
July 01, 2013 RONNY R ANDERSON, SHERIFF
�f.OD p'l• a�6
a�3
(c)CounrySuite Sheriff,Teleosoft,Iro.
KML Law Group,F.C.
Suite 5000—BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
EMC MORTGAGE CORPORATION,ATTORNEY-
IN-FACT FOR DEUTSCHE BANK NATIONAL IN THE COURT OF COMMON PLEAS
TRUST COMPANY AS TRUSTEE,F/K/A
BANKERS TRUST COMPANY OF CALIFORNIA, of Cumberland County
N.A. AS CUSTODIAN OR TRUSTEE FOR UCFC
LOAN TRUST 1998-D
c/o 3415 Vision Drive CIVIL ACTION-LAW
Columbus, OH 43219
Plaintiff
vs. ACTION OF MORTGAGE FORECLOSURE
VICKIE A. THORSON,A/K/A VICKIE L.
THORSON
(Mortgagor(s) and Record Owner(s)) No. 09-7132 CV
111 West South Street
Carlisle, PA 17013
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
EMC MORTGAGE CORPORATION,ATTORNEY-IN-FACT FOR DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE,F/K/A BANKERS TRUST COMPANY OF CALIFORNIA,N.A.AS CUSTODIAN OR
TRUSTEE FOR UCFC LOAN TRUST 1998-D,Plaintiff in the above action,by counsel, KML Law Group,P.C., sets forth
as of the date the praecipe for the writ of execution was filed the following information concerning the real property located
at:
111 West South Street
Carlisle,PA 17013
1.Name and address of Owner(s)or Reputed Owner(s):
VICKIE A.THORSON,A/K/A VICKIE L.THORSON
111 West South Street
Carlisle,PA 17013
2.Name and address of Defendant(s)in the judgment:
VICKIE A. THORSON,A/K/A VICKIE L.THORSON
111 West South Street
Carlisle, PA 17013
3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement
Health and Welfare Bldg. -Room 432
P.O.Box 2675
Harrisburg,PA 17105-2675
09-7132 CV
1. The sale will be cancelled if you pay to EMC MORTGAGE CORPORATION,ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE,F/K/A BANKERS
TRUST COMPANY OF CALIFORNIA,N.A.AS CUSTODIAN OR TRUSTEE FOR UCFC LOAN
TRUST 1998-D,the back payments,late charges,costs and reasonable attorney's fees due.To find out how
much you must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if
C>
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.
4. 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.To find
out if this has happened,you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never
happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the
buyer.At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid
for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs 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 schedule of distribution is filed.
7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale.
8. You may contact the Foreclosure Resource Center! http://www.philadelphiafed.orgiforeclosure/
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 BAR ASSOCIATION
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
09-7132 CV
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender(and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
hU://www.j2hfa.org/consumers/homeowners/real.a.spx.
5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention @kmllaworoup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
116992FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
09-7132 CV
KMI,Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106
(215)627-1322
Attorney for Plaintiff
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR DEUTSCHE BANK IN THE COURT OF COMMON PLEAS
NATIONAL TRUST COMPANY AS TRUSTEE,
F/K/A BANKERS TRUST COMPANY OF of Cumberland County
CALIFORNIA, N.A. AS CUSTODIAN OR
TRUSTEE FOR UCFC LOAN TRUST 1998-D
c/o 3415 Vision Drive CIVIL ACTION-LAW
Columbus, OH 43219
Plaintiff ACTION OF MORTGAGE
FORECLOSURE
VS.
VICKIE A. THORSON,A/K/A VICKIE L.
THORSON Docket No.09-7132 CV
Mortgagor(s) and Record Owner(s)
111 West South Street
Carlisle,PA 17013
Defendants
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: THORSON,A/K/A VICKIE L THORSON,VICKIE A.
VICKIE A. THORSON, A/K/A VICKIE L. THORSON
111 West South Street
Carlisle,PA 17013
Your house at 111 West South Street,Carlisle,PA 17013 is scheduled to be sold at Sheriff s Sale
on Wednesday,June 05,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of$78,749.51 obtained by EMC MORTGAGE CORPORATION,ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE,F/K/A BANKERS
TRUST COMPANY OF CALIFORNIA,N.A. AS CUSTODIAN OR TRUSTEE FOR UCFC LOAN
TRUST 1998-D against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
09-7132 CV
1. The sale will be cancelled if you pay to EMC MORTGAGE CORPORATION,ATTORNEY-IN-
FACT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE,FIKIA BANKERS
TRUST COMPANY OF CALIFORNIA,N.A.AS CUSTODIAN OR TRUSTEE FOR UCFC LOAN
TRUST 1998-D,the back payments,late charges,costs and reasonable attorney's fees due.To find out how
much you must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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.
4. 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 below 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 NOT TAKE PLACE.
I.- If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the fall amount due in the sale.To find
out if this has happened,you may call the Sheriff of 717-240-6390.
4, If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never
happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the
buyer-At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid
for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs 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 schedule of distribution is filed,
7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale.
8. You may contact the Foreclosure Resource Center: hypwwww.philadelphiafed. zT
-r o eclosu
o -L
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 FIND HER U CAN GET LEGAL
'LEpHONE THE OFFICE LISTED BELOW To OUT WHERE YOU
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
09-7132 CV
Resources available for Homeowners in Foreclosure
ACT NOW'.
Even though your lender(and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
116992FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND) NO. 09-7132 Civil
CIVIL ACTION-LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EMC MORTGAGE CORPORATION,ATTORNEY-
IN-FACT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY as Trustee, f/Wa BANKERS
TRUST COMPANY OF CALIFORNIA,N.A.,as Custodian or Trustee for UCFC LOAN TRUST
1998-D, Plaintiff(s)
From VICKIE A. THORSON a/k/a VICKIE L. THORSON
(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
GARNISHEE(S)as follows:
and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant
(s)or otherwise disposing thereof;
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $78,749.51
L.L.:
Interest from 6/23/10 to Date of Sale per diem at$12.94
Atty's Comm: Due Prothy: $2.25
Atty Paid: $964.39
Other Costs:
Plaintiff Paid:
Date: 12/20/12
David D. Buell,Prothonotar
(Seal)
REQUESTING PARTY: Deputy
Name: JILL P.JENKINS,ESQUIRE
Address: KML LAW GROUP,P.C.
SUITE 5000-BNY INDEPENDENCE CENTER TRUE COPY FROM RECORD
In Tastimony whereof,I here unto set my hand
701 MARKET STREET and the seal of said ter`-urt'at Carlisle,Pa.
PHILADELPHIA,PA 19106-1532 This d f �p-„� 20 (-
Attorney for:PLAINTIFF e�ocp��\_= ,. Prothonotary
Telephone: 215-627-1322 \
Supreme Court ID No.306588 ”
On March 12, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
Carlisle Borough, Cumberland County, PA,
Known and numbered as, 111 West South Street,
Carlisle, Exhibit "A" filed With this Writ
and by this reference incorporated herein.
Date: March 12, 2013
By:
Real Estate Coordinator
V 1 Z 330 ZIOZ
V *f\{ '.`. ۥ
IL
CUMBERLAND LAW JOURNAL
Writ No. 2009-7132 Civil
EMC MORTGAGE CORPORATION
vs.
VICKIE A.THORSON
a/k/a Vickie L.Thorson
Atty.:Jill Jenkins
IMPROVEMENTS consist of a
residential dwelling.
BEING PREMISES: 111 West
South Street,Carlisle,PA 17013.
SOLD as the property of VICKIE A.
THORSON a/k/a VICKIE L. THOR-
SON.
TAX PARCEL#04-21-0320-281.
76
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
April 12, April 19 and April 26, 2013
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time,place and character of publication are true.
Lis Marie Coyne, Edit
SWORN TO AND SUBSCRIBED before me this
26 day of April, 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
The Patriot-News Co.
2020 Technology Pkwy the atr1*otwXtws
Suite 300
Mechanicsburg,"PA 1`1050 Now you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s)shown below:
04/16/13
i 2009-7132 Civil 04/23113
EMC MORTGAGE
CORPORATION C— - 04/30/13
VS.
VICKIE A.THORSON,,a/k/a
VickleL.Thorson , , , , , , , , , , , , , , , , , , , , , ,
Atty: Jill Jenkins
IMPROVEMENTS consist of a residential
dwelling. Sworn t a d subscribed be a this 13 day of May, 2013 A.D.
BEING PREMISES:ill west south street
Carlisle,PA 17013
SOLD as the property of VICKIE
A. THORSON, A/K.I A VICKIE L. N tary Public J�lu
T HORSON.
TAX PARCEL#04-21-0320-281
COMMONWEALTH OF PENNSYLVANIA
Notarial seal
Holly Lynn Warfel,Notary Public
Washington Up.,Dauphin County
My Commission Expires Dec.12,2016
MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which UCFC Loan Trust 1998-D is the grantee the same having been sold to said
grantee on the 5th day of June A.D., 2013, under and by virtue of a writ Execution issued on the 20th
day of December, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2009
Number 7132, at the suit of UCFC Loan Trust 1998-D tr/aif against Vickie A aka Vickie L Thorson is
duly recorded as Instrument Number 201324167.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this day of
A.D.
corder of Deeds
tecorder of Deeds, umbedand County;Carfisle,pA
My Commission Expires the Rrst Monday of Jan.2014