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THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC
Lauren Berschler Karl, Esquire 2010 Y 28 AN l (' 26
Identification No. 88209
Park Building Attorneys for PlaintiftCU, ... 'ATY
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
Phone: (412) 232-0808
Fax: (412)232-0773
CITIZENS BANK OF PENNSYLVANIA
10561 Telegraph Road
Glen Allen, VA 23059
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY nn (
NO.: 16 - 2YS2 Gt'*.,-
v.
JESSICA STUPAK
226 Ridge Road
Jonestown, PA 17038
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
Defendant.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by
entering a written appearance personally or by attorney and filing in writing with the court your defenses
or objections to the claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the court without further notice for
any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may
lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, 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 FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013 g 2 ,OUJ
1-800-990-9108 /
717-249-3166 CK,4 .2
Stupak.Complaint.Cumberland
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC
Lauren Berschler Karl, Esquire
Identification No. 88209
Park Building Attorneys for Plaintiff
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
Phone: (412) 232-0808
Fax: (412)232-0773
CITIZENS BANK OF PENNSYLVANIA
10561 Telegraph Road
Glen Allen, VA 23059
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.:
V.
JESSICA STUPAK
226 Ridge Road
Jonestown, PA 17038
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
Defendant.
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff, Citizens Bank of Pennsylvania, by its attorneys The Law Offices of Lauren
Berschler Karl, LLC, files the within complaint in mortgage foreclosure and represents as follows:
Plaintiff, Citizens Bank of Pennsylvania, ("Citizens"), is a state chartered bank with a
place of business at 10561 Telegraph Road, Glen Allen, VA 23059.
2. Defendant, Jessica Stupak, is an adult individual who is believed to reside at 226
Ridge Road, Jonestown, PA 17038.
3. Defendant, Jessica Stupak, ("Defendant"), is the owner of record of a certain parcel
of residential real estate located in Cumberland County known by the following street address: 116
Fourth Avenue, New Cumberland, PA 17070 (the "Property").
Stupak.Complaint. Cumberland
-2-
4. On May 3, 2007, Defendant executed a Promissory Note in the original principal
amount of $105,000.00 (the "Note"). A true and correct copy of the Note is attached hereto as
Exhibit "A."
5. The Note was secured by a mortgage granting a lien upon the Property (the
"Mortgage"), made, executed and delivered to Citizens on May 3, 2007, by Defendant and was duly
recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania on May 18,
2007, as set forth in Book 1992 page 3269 et seq. A true and correct copy of the Mortgage is
attached hereto as Exhibit "B."
6. The full legal description of the Property is set forth in Exhibit "C" which is attached
hereto and incorporated herein by reference.
7. Monthly payments have not been tendered as required under the terms of the Note
and Mortgage.
8. Due to the failure to pay the Plaintiff the sums due and owing thereunder, Plaintiff
demanded complete payment and performance of all of Defendant's obligations under the terms of
the Note and Mortgage.
9. Pursuant to the terms of the Note and Mortgage, Defendant is obligated to Citizens
for the following sums as of May 13, 2010:
Principal $ 101,003.00
Accrued interest
(through 05/13/10) 4,391.53
Accrued late charges 280.00
BPO/Appraisal 400.00
Title Reports 620.00
Attorneys fees 5,050.15
Attorneys costs 250.00
TOTAL REAL DEBT $111,994.68
Interest continues to accrue at the per diem rate of $19.51.
Stupak. Compl aint.Cumberl and
-3-
10. On April 2, 2010, the combined Notice of Intention to Foreclose as set forth in the
Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983, 35 P.S. C.S.A. §1680.401 and
Act 6 of 1974, 41 Ps. 101, et seq., with respect to the Note and Mortgage was mailed to the
Defendant as evidenced by the Certificates of Mailing attached hereto and incorporated herein as
Exhibit "D."
WHEREFORE, Plaintiff, Citizens Bank of Pennsylvania, demands Judgment in Mortgage
Foreclosure in its favor and against Defendant, Jessica Stupak, in the amount of $111,994.68, plus
continuing interest at the per diem rate of $19.51, from May 13, 2010, and any and all additional
attorneys fees and costs and any other costs and charges collectible under the mortgage and for the
foreclosure and sale of the Property.
Respectfully submitted,
THE LAW OFFICES OF
LAUREN BERSCHLER KARL, LLC.
BY: ?. (W W
L n Berschl Karl, Esquire
Attorneys for Plaintiff,
Citizens Bank of Pennsylvania
Date: May 26, 2010
Stupak.Complaint.Cumberl and
-4-
VERIFICATION
1, Cheryl D. Cox, being duly sworn according to law, depose and say that I am a mortgage
foreclosure specialist with Citizens Bank of Pennsylvania and that the facts set forth in Citizens'
Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge, information
and belief. I understand that the statements therein are made subject to the penalties of 18 Pa.C.S.A.
§ 4904 relating to unsworn falsification to authorities.
CITIZENS BANK OF PENNSYLVANIA
By: ?,but,; /? Ll -
CHERY D. COX
Stupak.Complaint.Cumberland
-5-
EXHIBIT "A"
Citizens Bank
1111111 111 111noltiel III
SECONDARY MORTGAGE LOAN PROMISSORY NOTE AND DISCLOSURE
BOrrOwer(S): JESSICA STUPAK
Lender Citizens Bank of Massachusetts E] Citizens Bank of Connecticut Citizens Bank of Penns vanis
28 State Street 63 Eugene O'Neill Drive 1735 Market SiTect
Boston, MA 02109 New London, CT 06320 Philadelphia, PA 9103
Citizens Bank of Rhode Island O Citizens Bank New Hampshire Q Citizens Bank
I Citizens Plaza $75 Elm Street 919 North Market Street
Providence, RI 02903 Manchester, NH 03101 Suite 200
Wilmington, DE 19801
Principal Amount: $105.000.00 Interest Rate: 7.050 % Date of Note: 0510312001
In this Note, the words, "Borrower", "you," and "your" mean each and every person who signs this Agreement, Including
all Borrowers named above. The words "we, "us", "our" and "Leader" mean Citizens Bank of Massachusetts, Citizens
Bank of Rhode Island, Citizens Bank of Connecticut, Citizens Bank New Hampshire, Citizens Bank of Pennsylvania, or
Citizens Bank (our Delaware Bank), as indicated above, hereln after referred to as "Citizens Bank".
FOR VALUE RECEIVED, the undersigned (jointly and severally if more than ore) promise to pay to the above named Lender or
order, the principal sum of $ S 105.000.00 Dotlars with interest at the rate of 7,050 consecutive month) installments ofS 817-37 -'A per mum, payable accrued in j?_
Y each, and a final installment to include all principal and d accnred interest,
and late charges, insurance premiums and all other charges, jr any. The first such installment will be due an 06101!/2007 and
the retraining installments on the some day of each month thereafter until paid in full. All payments will be applied first to
interest, then to insurance charges, if any, and then to principal, and any remaining amount to unpaid collection costs and late
charges and any other charges you may owe. The interest rate required by this section is the rate you will pay both before and
after any default described in the default section.
Finance Charge: Interest on this Note is computed on a 365/366 simple interest basis. First we apply the ratio of the annual
interest rate over the number of days in a year (366 during Ieap years), multiplied by the outstanding principal balance, mul*ied
by the actual number ordays the principal balance is outstanding.
cost of your credit as a yearly raft _- '11,c dollar artqunl
you
7.050 % 591,168.80
credit wall cost Tk amount of credit provided The amount you will have
to you or on your betWf
r
id
paid when you have made
l
as sehedukd
$105,000.00 SIKI68.80
PAYMENTS WHEN PAYMENTS ARE DUE
Monthly beginning on
the Payment schedule and 'Total of Payments" scheduled above assume that all payments are trade on the due date. If
re made late, the amount of interest payable hereunder will continue to accrue on the unpaid principal balance and the toottal?n?
merest hereunder will increase.
PREPAYMENT: If you pay off the entire balance of your loan before the due date, you may be charged a fee as follows:
MA: If you pay off your ban within the first twelve (12) months of the date of the note, we may charge you, and you agree
to pay us, a fee equal to (a) the balance of the first year's interest, (b) three (3) months' interest as of the dale of prepayment, or
(c) $250, whichever is less. Ifyou refinance your loan with another institution within the first twenty-four (24) months of the
date of the note, we may charge you, and you agree to pay us, a ree of the lesser of a) three (3) months' interest as of the date of
prepayment or (b) $250.
CT, DE, MF, NH,SRI; If you pay off your loan within two (2) years after the date of the note, we may charge You, and you
agree to pay us, a fee .
NJ, PA: If you pay off your loan before the due date, you will not have to pay a fee.
LATE CHARGE; Your late fee will be calculated as follows, based on the state or commonwealth as indicated above:
MA: Your payment will be late if it is not received by us within 15 calendar days of the Payment Due Date shown
above. If your payment is late, we may charge you 3.000% of the regularly scheduled payment of principal and interest.
CT and RI: Your payment will be late if it is not received by us within 10 calendar days of the Payment Dot Date shown
above. If your payment is late, we may charge you 5.000% of the regularly scheduled payment of principal and interest, or
$10.00, whichever is less.
NH: Your payment will be late if it is not received by us within 10 calendar days of tbt Payment Due Date shown
above. If your payment is late we may charge you 7.0001. of the regularly scheduled payment of principal and interest or
$1250, whichever is greater.
PA and DE- Your payment will be late if it is not received by us within IS caltndar days of the Payment Due Date
shown above, If your payment is late, we may charge you 10.000% of the payment or $20.00, whichever is greater.
'ou wiL pay this late charge only once on any laic payment.
PromNiotePPr REV 07M6
Page 2 f
16 OKUPIT : Y
1 ou are giving a security interest to real estate located at
6 FOUF,H A1'ENUE NEW CUMBERLAND, PA 17070
addition to Lender's security interest alto other rights in your deposit accounts.
aUMMON: Someone buying your home cannot assume the remainder of the mortgage on its original terms.
Other related contract documents for additional information about nonpayment, default, the right to accelerate the maturity of
obligation and security interests.
ITEMIZATION OF THE AMOUNT FINANCED:
Itemization of the amount financed of ..................
......................................... $ 105.000.00
Amount givers to you directly ..........................
.......................... ... $ 55.81
...................
Prepaid Finance Charges ...................... .
Amount(s) paid to others on your behalf:
TO BANK OF AMERICA.
TO CCO MORTGAGE
TO
TO
TO
TO
TO
TO
TO
TO
TO
TO
TO -
TO
TO
TO
TO INSURANCE COMPANY
TO Settlement Fees
$ 25298.17
$ 79 656.02
$
$
$
$
$ 0.00
You authorized disbusements to lien creditors and to Citizens Bank loan or line accounts listed above and acknowledge
receipt of a filled in copy of this itemization of amount financed.
You are to make disbursements to the non-lien creditors lssted above.
In order to secure our lien position, Citizens Bank is authorized to add to the principal balance, or access deposit
accounts :o cover any shortage. In the event a pay-off sent to another creditor is insufficient, Citizens Bank is authorized
to add to :he principal balance, or access your deposit account funds held by us to cover such shorgage in order to
complete your transaction and secure our lien position. You will receive notification in the event an additional amount is
needed. This amount should not exceed $1,000.00; further remedies may apply if a greater amount is needed.
This may result in a higher final payment due.
COLLATERAL: In addition to the protections given to the Lender under this Note, this Note is s
Mortgage dated 0 510 3/2 0 0 7 , to Lender on real property located in CUMBERLAND ecured by a
of PA all the terms and conditions of which are here County, State
of this Note. by incorporated and made a part
DEFAULT: You will be in default if any of the following events happens:
(a) You fail to make a payment when it is due under this Note or any other loan you may have with Citizens Bank.
(b) You have made any false or misleading statement(s) in your application for this Note or any other loan you may
have with Citizens Bank, or there is a material adverse change in your financial condition.
(c) An assignment has been made for the benefit of your creditors or an entry ofjudgement has been made against
you, or someone tries to take or attach any of the collateral.
(d) You fail to comply fully with any term or condition of this Note or any other loan or agreement you may have
with Citizens Bank.
(e) You die or become insolvent, a receiver is appointed for any part of your property, or any proceeding is
commenced either by you or against you under any bankruptcy or insolvency laws.
Page 5
You, the undersigned, certify that you have insured the property described in the section entitled "SECURITY" on
Page l of this Note, against loss by fire in the amount sufficient to cover this lien and all superior liens, and that
the policy includes extended coverage and has a standard mortgagee clause making loss payable to Citizens as its
interest may appear.
You agree it is your responsibility to keep the premises as identified in the section entitled "SECURITY" on Page I
of this Note, insured in an amount at least equal to the replacement cost of any buildings on the above property,
and until this Note is paid in full.
You understand that you may purchase any required insurance through any duly licensed insurance agent and
insurance company that is reasonably accepuble to us. You are not required to deal with any of our affiliates when
choosing an insurance agent or insurance company. Your choice of a particular insurance agent or insurance
company will not affect our credit decision, so long as the insurance provides adequate coverage with an insurer
that meets our reasonable requirements.
All documents related to insurance for this loan should be mailed to the following address:
Citizens Bank, Consumer Finance Operations
I Citizens Drive
Riverside, RI 02915
(800)708-6680
You acknowledge that any payoff amounts referenced in the Itemization of Amount Financed section of this Note
and the HUDI-A form were estimates based an the balances listed on your credit bureau repon(s), or obtained from
the lien creditors on your behalf.
You acknowledge that you received and read, as applicable, the Home Equity disclosure statements provided to you
during the application process, which include When Your Home is On the Line, Servicing Disclosure Statement,
Good Faith Estimate, Right to Receive a Copy of an Appraisal, Citizens' Pledge Regarding the Responsible Use and
Protection of Customer Information, for MA residents only, Massachusetts Mortgage Loan Disclosure, Uniform
Mortgage Loan Cost Worksheet, Consumer Guide to Obtaining a Mortgage, for CT residents only, Mortgagor's
Right to Counsel, for RI residents only, Choice of Title Attorney Disclosure, for NJ residents only, Right to Own
Counsel Disclosure and for MD residents only. Processing your Loan Application, Settlement Services.
If there is more than one signer below, it is mylour intention that this account be a joint account.
You acknowledge that with your application, you provided your consent to us to check your employment and credit
history with any source and to answer questions about your credit experience with us.
NOTICE TO NEW JERSEY BORROWERS: READ THIS NOTE BEFORE YOU SIGN. DO NOT SIGN THIS NOTE
IF IT CONTAINS BLANK SPACES. THE NOTE IS SECURED BY A SECONDARY MORTGAGE ON YOUR REAL
PROPERTY.
SIGNATURES:
EXHIBIT "B"
U
` Prepared By:
` Citiuns Bank
Beth Romano
Retail Lending Services
480 Jefferson Boulevard
Warwick, RI 02886
1-800-8944619
Return To:
Citizens Bank
Consumer Loan Operations - RTW215
I Citizens Drive
Riverside, RI 02915
ParcellD# 25-24-0813-038
rallateral Address:
116 FOURTH AVENUE, NEW CUMBERLAND, PA 17070
2047 RY 18 AM 10 12
PENNSYLVANIA
CLOSED-END MORTGAGE
THIS MORTGAGE is given on 05/03/2007
The mortgagor is
JESSICA STUPAK
V
Page 1
ATM
FACICSM
REV. OWN
6K 1992PG3269
This Mortgage is given to Citizens Bank of Pennsylvania , whose address is
1735 Market Street, Philadelphia, PA 19103 ("Leader") or its successors or
assn pea.
1n this Mortgage, the terms "you," "your" and "yours" refer to the mortgagor(s). The terms "we," "us"
and "our" refer to the Lender. You owe us the principal sum of S 105,000.00
Dollars. This debt is evidenced by your note ("Note") dated the same date as this Mortgage, which
provides for monthly payments, with the full debt, if not paid earlier, due and payable on 05/08/2027
This Mortgage secures to us: (a) the repayment of the debt evidenced by the Note, with interest, and all
renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest,
advanced under this Mortgage to protect the security of this Mortgage; and (c) the performance of your
covenants and agreements under this Mortgage and the Note. For this purpose, you hereby mortgage,
grant and convey to us and our successors and assigns the property located in CUMBERLAND
County, Pennsylvania, and more fully described in Exhibit A which is attached hereto and made a part
hereof, which property has the address of
116 FOURTH AVENUE, NEW CUMBERLAND, PA 17070 ("Property Address");
TOGETHER WITH all the improvements now or hereafter erected on the property, and all
easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and
additions shall also be covered by this Mortgage. All of the foregoing is refereed to in this Mortgage as
the "Property".
Page 2
BK 1992PG3270
YOU COVENANT that you are lawfully seized of the estate hereby conveyed and have the right to
mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of
record. You wan-ant and will defend generally the title to the Property against all claims and demands,
subject to any encumbrances of record.
YOU AND WE covenant and agree as follows:
1. Payment of Principal, Interest and Other Charges. You shall pay when due the
principal of and interest owing under the Note and all other charges due under the Note.
2. Payments of Taxes and Insurance. You will pay, when due, all taxes, assessments,
leasehold payments or ground rents (if any), and hazard insurance on the Property and mortgage insurance (if
any). We specifically reserve to ourselves and our successors and assigns the unilateral right to require that
you pay to us on the day monthly payments are due an amount equal to one-twelfth (1112) of the yearly
taxes, and assessments (including condomimium and planned unit development assessments, if any) which
may attain priority over this Mortgage and ground rents on the Property, if any, plus one-twelfth (1112) of
yearly premium installments for hazard and mortgage insurance, all as we reasonably estimate initially and
from time to time, as allowed by and in scoridance with applicable law.
3. Application of Payments. Unless applicable law provides otherwise, all payments received
by us under the Note and Section 1 will be applied by us as permitted under the Note.
4. Prior Mortgages; Charges; Liens. You shall perform all of your obligations under any
mortgage, deed of trust or other security instruments with a lien which has priority over this Mortgage,
including your covenants to make payments when due. You shall pay all taxes, assessments, charges, fines
and impositions attributable to the Property which may attain priority over this Mortgage, and leasehold
payments or ground rents, if any. Upon our request, you shall promptly furnish to us all notices of amounts
to be paid under this paragraph and receipts evidencing any such paymenb you make directly. You shall
promptly discharge any lien (other than a lien disclosed to us in your application or in any title report we
obtained) which has priority over this Mortgage.
5. Hazard Insurance. You shall keep the Property insured against loss by fire, hazards
included within the term "extended coverage" and any other hazards, including floods or flooding, for which
we require insurance. This insurance shall be maintained in the amounts and for the periods that we require.
You may choose any insurer reasonably acceptable to us and shall include a standard mortgagee clause. If
we require, you shall promptly give us all receipts of paid premiums and renewal notices.
If you fail to maintain coverage aS required in this section, you authorize us to obtain such coverage as we in
our sole discretion determine appropriate to protect our interest in the Property in accordance with the
provisions in Section 7. You understand and agree that any coverage we purchase may cover only our
interest in the Property and may not cover your interest in the Property or any personal property therein.
You also understand and agree that the premium for any such insurance may be higher than the premium
you would pay for such insurance.
Page 3
BK 1992PG327 !
You shall promptly notify the insurer and us of any loss. We may make proof of loss if you do not
promptly do so. We may also, at our option and on your behalf, adjust and compromise any claims
under the insurance, give releases or acquittances to the insurance company in connection with the
settlement of any claim and collect and receive insurance proceeds. You appoint us as your
attorney-in-fact to do all of the foregoing, which appointment you understand and agree is irrevocable,
coupled with an interest with full power of substitution and shall not be affected by your subsequent
disability or incompetence.
Insurance proceeds shall be applied to restore or repair the Property damaged, if restoration or repair is
economically feasible and our security would not be lessened. Otherwise insurance proceeds shall be
applied to sums secured by this Mortgage, whether or not then due, with any excess paid to you. If you
abandon the Property, or do not answer within 30 days our notice to you that the insurer has offered to
settle a claim, then we may collect and use the proceeds to repair or restore the Property or to pay sums
secured by this Mortgage, whether or not then due. The 30-day period will begin when notice is given.
Any application of proceeds to principal shall not require us to extend or postpone the due date of
monthly payments. If we acquire the Property at a forced sale following your default, your right to any
insurance proceeds resulting from damage to the Property prior to the acquisition shall pass to us to the
extent of the sums secured by this Mortgage immediately prior to the acquisition.
You shall not permit any condition to exist on the Property which would, in any way, invalidate the
insurance coverage on the Property.
6. Preservation, Maintenance and Protection of the Property; Leaseholds. You shall
not destroy, damage or substantially change the Property, allow the Property to deteriorate, or commit
waste. If this Mortgage is on a leasehold, you shall comply with the lease. If you acquire fee title to the
Property, the leasehold and fee title shall not merge unless we agree to the merger in writing.
7. Protection of Our Rights In the Property; Mortgage Insurance. If you fail to
perform the covenants and agreements contained in this Mortgage, or them is a legal proceeding that may
significantly affect our rights in the Property (such as a proceeding in bankruptcy, probate, for
condemnation or forfeiture or to enforce laws or regulations), then we may do, and pay for, anything
necessary to protect the Property's value and our rights in the Property. Our actions may include paying
any sums secured by a lien which has priority over this Mortgage or any advance under the Note or this
Mortgage, appearing in court, paying reasonable attorney's fees, paying any sums which you arc required
to pay under this Mortgage and entering on the Property to make repairs. We do not have to take any
action we are permitted to take under this paragraph. Any amounts we pay under this paragraph shall
become additional debts you owe us and shall be secured by this Mortgage. These amounts shall bear
interest from the disbursement data at the rate established under the Note and shall be payable, with
interest, upon our request. If we required mortgage insurance as a condition of making the loan secured
by this Mortgage, you shall pay the premiums for such insurance until such time as the requirement for
the insurance terminates.
Page 4
BK 1992PG3272
a. Inspection. We may make entries in and upon the Property to inspect same at any
reasonable time and upon reasonable notice.
9. Condemnation. The proceeds of any award for damages, direct or consequential, in
connection with any condemnation or other taking of any part of the property, or for conveyance in lieu of
condemnation, are hereby assigned and shall be paid to us. If the Property is abandoned, or if, after notice
by us to you that the condemnor offers to make an award or settle a claim for damages, you fail to respond
to us within 30 days after the date the notice is given, we are authorized to collect and apply the proceeds, at
our option, either to restoration or repair of the Property or to the sums secured by this Mortgage, whether or
not then due. Unless we and you otherwise agree in writing, any application of proceeds to principal shall
not extend or postpone the due date of the monthly payments payable under the Note and paragraph 1 or
change the amount of such payments.
10. You Are Not Released; Forbearance by Us Not a Waiver. Extension of time for
payment or modification of amortization of the sums secured by this Mortgage granted by us to any of your
successors in interest shall not operate to release your liability or the liability of your successors in interest.
We shall not be required to commence proceedings against any successor in interest, refuse to extend time
for payment or otherwise modify amortization of the sums secured by this Mortgage by reason of any
demand made by you or your successors in interest. Our forbearance in exercising any right or remedy shall
not waive or preclude the exercise of any right or remedy.
H. Successors and Assigns Bound; Joint and Several LiablUty; Co-signers. The covenants
and agreements of this Mortgage shall bind and benefit your successors and permitted assigns Your
covenants and agreements shall be joint and several. Anyone who co-signs this Mortgage but does not
execute the Note: (a) is co-signing this Mortgage only to mortgage, grant and convey such person's interest
in the Property; (b) is not personally obligated to pay the Note, but is obligated to pay all other suns secured
by this Mortgage; and (c) agrees that we and anyone else who signs this Mortgage may agree to extend,
modify, forbear or make any accommodations regarding the terms of this Mortgage or the Note without such
person's consent
12. Loan Charges. If the loan secured by this Mortgage is subject to a law which sets
maximum loan charges, and that law is finslly 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 you which exceed permitted limits will be refunded to you. We rimy choose to make
this refund by reducing the principal owed under the Note or by making a direct payment to you. If a
refund reduces principal, the reduction will be treated as it partial prepayment without any prepayment charge
under the Note.
13. Notices. Unless otherwise required by law, any notice to you provided for in this Mortgage
shall be delivered or mailed by first class mail to the Property Address or any other address you designate by
notice to us. Unless otherwise required by law, any notice to us shall be given by fast class mail to our
address stated above or any other address we designate by notice to you.
Page 5
BX 1992PG3273
14. Governing Law; Severability. The extension of credit secured by this Mortgage
governed by federal law, which for the purposes of 12 USC Section 85 incorporates Pennsylvania law.
However, the interpretation and enforcement of this Mortgage shall be governed by the law of the
jurisdiction in which the Property is located, except as preempted by federal law. In the event that any
provision or clause of this Mortgage or the Note conflicts with applicable law, such conflict shall not
affect other provisions of this Mortgage or the Note which can be given effect without the conflicting
provision. To this end the provisions of this Mortgage and the Note are declared to be severable.
15. Transfer of the Property. If all or any part of the Property or any interest in it is sold
or transferred without our prior written consent, we may, at our option, require immediate payment in full
of all sums secured by this Mortgage. However, this option shall not be exercised by us if exercise is
prohibited by federal law as of the date of this Mortgage.
16. Sale of Agreement; Change of Loan Servicer. The Note or a partial interest in the
Note (together with this Mortgage) may be sold one or more times without prior notice to you. 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 Mortgage. There also may be one or more changes of the Loan Servicer
unrelated to the sale of the Note. If there is a change of the Loan Servicer, you will be given written
notice of the change as required by 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
information required by applicable law.
17. Hazardous Substances, You shall not cause or permit the presence, use, disposal,
storage, or release of any Hazardous Substances on or in the Property, You 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 Hazardous
Substances in quantities that are generally recognized to be appropriate to normal residential uses and to
maintenance of the Property. You shall promptly give us written notice of any investigation, claim,
demand, lawsuit or other action by any governmental or regulatory agency or private party involving the
Property and any Hazardous Substance or Environmental Law of which you have actual knowledge. If
you learn or are notified by any government or regulatory authority, that any removal or other
remediation of any Hazardous Substance affecting the Property is necessary, you shall promptly take all
necessary remedial actions in accordance with Environmental Law. As used in this Mortgage,
"Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental
Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic
pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive
materials. As used in this Mortgage, "Environmental Law" means federal laws and laws of the
jurisdiction where the Property is located that relate to health, safety or environmental protection.
Page 6
BK 1992PG3274
18. Acceleration; Remedies. We Shall give you notice prior to acceleration following
your breach of any covenant or agreement in this Mortgage (but not prior to acceleration under
Section 15 unless applicable law provides otherwise). The notice shall specify: (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 of the sums secured by this Mortgage,
foreclosure by judicial proceeding and sale of the Property. The notice shall further inform you of
the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the
non-existence of a default or any other defense you may have to acceleration and foreclosure. If the
default is not cured as specified, we may, at our option, require Immediate payment in fun of all
sums secured by this Mortgage without further demand and may foreclose this Mortgage by
judicial proceeding, We shall be entitled to collect all expenses incurred In purvuhsg the remedies
provided in this Section 18, including, but not limited to, reasonable attorneys' fees as permitted by
applicable law and costs of title evidence to the extent permitted by applicable law.
19. Discontinuance of Enforcement. Notwithstanding our acceleration of the sums secured
by this Mortgage under the provisions of Section 18, we may, in our sole discretion and upon such
conditions as we in our sole discretion determine, discontinue any proceedings begun to enforce the terms
of this Mortgage.
20. Release. Upon payment of all sums secured by this Mortgage, we shall discharge and
satisfy this mortgage without charge to you. You shall pay any recordation costs.
21. Additional Charges. You agree to pay reasonable charges as allowed by law in
connection with the servicing of this loan including, without limitation, the costs of obtaining tax searches
and subordination. Provided, however, that nothing contained in this section is intended to create and
shall not be construed to create any duty or obligation by us to perform any such act, or to execute or
consent to any such transaction or matter, except a release of the Mortgage upon full repayment of all
sums secured thereby.
22. Waivers. You, to the extent permitted by applicable law, waive and release any error
or defect in proceeding to enforce this Mortgage, and hereby waive the benefit of any present or future
laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and
homestead exemption. No waiver by us at any time of any tern, provision or covenant contained in this
Mortgage or in the Note secured hereby shall be deemed to be or construed as a waiver of any other
term, provision or covenant or of the same term, provision of covenant at any other time.
23. Reinstatement Period. Your time to reinstate provided in Section 18 shall extend to
one hour prior to the commencement of bidding at a shetifrs sale or other sale pursuant to this Mortgage.
24. Purchase Money Mortgage. If any of the debt secured by this Mortgage is lent to you
to acquire title to the Property, this Mortgage shall be a purchase money mortgage.
Page 7
BK 1992PG3275
25. Interest Rate Alter Judgment. You agree that the interest rate payable after a
judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from
time to time under the Note.
BY SIGNING BELOW, you accept and agree to the terms and covenants contained in this Mortgage
and executed by you..
Signed, sealed and delivered in the presence of;
STUPAK
Page 8
BK ! 992PS3276
CERTIFICATE OF RESIDENCE OF MORTGAGEE
I do hereby certify that the precise address and principal place of business of the within named
mortgagee is: 1735 Market Street, Philade hia, PA 19103
Citizens Bank of Penwivanla
Name: {?,
Title: I e . F.J?'?Ir t t_
SSA
Page 9
BK 1992PG3277
INDIVIDUAL ACKNOWLEDGMENT
STATE OR COMMONWEALTH OF_ 1F460r1y , 1?? n tc,
COUNTY OF oaupo to ) SS:
On the day of
MCLLJ
W
before me appeared '
JESSICA STUPAK
to me personally known to be the person(s) whose name(s) is/are
subscribed to this instrument, and such person(s) acknowledged that
he/she/they (i) executed the same for the purposes therein contained,
and (ii) executed this instrument as their free act and deed.
IN WITNESS WHEREOF, I hereu7&t't my hand an official seal.
(Official Seal)
ou c
., T
co+A+rioNweu TH OF PENHSr?vMlu
riarra.w _
EMptror. a ???r
*CMViW nEWhwNor.X%2M0
Attention Registry of Deeds/Town or City Clerk:
Mail to: Citizens Bank
Consumer Finance Operations - RJW215
1 Citizens Drive
Riverside, RI 02915 A«pA 4/05
Et i 992PG3278
E:Nat A L Deze ggL j
ALL THAT PARCEL OF LAND IN BOROUGH OF NEW CUMBERLAND, CUMBERLAND COUNTY, COMMONWEALTH OF
PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 274, PAGE 4051, ID# 25-24-0813-038, BEING KNOWN
AND DESIGNATED AS METES AND BOUNDS PROPERTY.
DEED FROM ROBERT S. MCCLEAF, SINGLE AS SET FORTH IN DEED BOOK 274, PAGE 4051 DATED 05!2412006 AND
RECORDED 05/31/2006, CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PENNSYLVANIA.
I Certify this to be recorded
In Cumberland County PA
1Recorder of Deeds
Page 3
OR 1992P&3279
EXHIBIT "C"
EXHIBIT "C"
ALL THAT CERTAIN parcel of land situated in The Borough of City of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan
thereof made by Ernest J. Walker, Professional Engineer, dated August 17, 1966, as follows, to wit:
BEGINNING at a point on the southeasterly wide of Fourth Alley, now known as Fourth Avenue,
said point being 23 feet southwest of the southeasterly side of Walnut Alley; thence extending along
premises known as 114 Fourth Alley and passing through the center of a partition wall South 51
degrees East, 50 feet to a point; thence South 39 degrees West, 51 feet to a point; thence North 51
degrees West, 50 feet to a point on the southeasterly side of Fourth Alley aforesaid; thence along the
same North 39 degrees East, 51 feet to the point and place of BEGINNING.
HAVING THEREON erected a dwelling commonly known as 1 16 Fourth Avenue, New
Cumberland, Pennsylvania.
Being the same property which Robert S. McCleaf by Deed dated May 24, 2006 and recorded on
May 31, 2006, in the Cumberland County Recorder of Deeds Office in Book 274, page 4051, granted
and conveyed unto Jessica Stupak.
Parcel ID Number: 25-24-0813-038.
Stupak.Comp] aint.Cumberland
-6-
EXHIBIT "D"
THE LAW OFFICES OF
LAUREN BERSCHLER KARL, LLC
Marla MarJlaw com Park Building licensed in PA and NJ
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
April 2, 2010
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM HEMAP may
be able to help to save your home This Notice explains how the program works
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when
you meet with the Counseling Agency.
The name address and hone number of Consumer Credit Counseling Agencies serving our Count are
listed at the end of this Notice. If you have an questions, you may call the Pennsylvania Housing Finance
Agency toll free at 1-800-342-2397 (persons with impaired hearing can call (717) 780-1869).
Stupak Act91.040210
Page 2
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENDG UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO
ARRIBA, PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR
SU CASA DE LA PERDIDA DEL DER-ECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCOUNT NO.
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
ALSO SENT TO:
JESSICA STUPAK
116 FOURTH AVENUE
NEW CUMBERLAND, PA 17070
6051450671 /21535PA09
CITIZENS BANK OF PENNSYLVANIA
CITIZENS BANK OF PENNSYLVANIA
JESSICA STUPAK
226 RIDGE ROAD
JONESTOWN, PA 17038-8145
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH
CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU
MAKE 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 CAUSE 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.
Stupak.Act9l 040210
Page 3
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 THE
NEXT (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 YOU MORTGAGE UP TO DATE
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit
counseling agency lists 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 number of designated consumer credit
counseling agencies for the county in which the propejjy is located are set forth at the end of this Notice. It is
only necessary to schedule one fact-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 with 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 HA VE A MEETING
WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE
AND FILE ANAPPLICATION 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 HA VE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME
P E R I O D S . A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUAPPLICATION IS EVENTUALLYAPPROVED AT ANY TIME
BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.
You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
A DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
Stupak Act91 040210
Page 4
HOW TO CURE YOUR MORTGAGE DEFAULT Brin it u to date
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 116 FOURTH AVENUE, NEW CUMBERLAND, PA 17070
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due. as set forth below:
Principal and Interest (overdue
from 09/25/09 through 03/25/10)
7 payments at 5817.37 S 5.721.59
Late Charges 240.00
Partial Paid (92.79
1
Total amount of Delinquency S5,868.80
Additionally, another total payment of 5817.37 becomes due on April 25, 2010.
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER.
WHICH IS S5,868.80, PLUS ANY ADDITIONAL MONTHLY PAYMENTS AND ANY LATE
CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must
be made either by cash cashier's check. certified check or money order made payable to CITIZENS
BANK OF PENNSYLVANIA and sent to:
Lauren B. Karl, Esquire
Park Building
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
412-232-0773-fax
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the
mortyi!e debt. This means that the entire outstanding balance of this debt will be considered due
immediate]), and you may lose the chance to pay the mortgage in monthly installments. If full
payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends
to instruct its attornevs to start legal action to foreclose upon your mortgage property.
siupak Aci9l 040210
Page 5
IF THE MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay
the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal
proceedings are started against you, you will have to pay all reasonable attorney's fees actually
incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount
you owe the lender, which may also include other reasonable costs. If you cure the default within
the THIRTY (30) DAY period, you will not be required to pay attornev'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) DAY period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at an time up ' to one hour before the Sheriff's Sale.
You may do so by paying the total amount then past due plus any late or other charges then due
reasonable attorney's fees and costs connected with the foreclosure sale and an other costs connected
with the Sheriff's Sale asspecified in writing b the lender and b performing an other re uirement
under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriff's Sale of the mortgage property could be held would be approximately 6 months from the
date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the
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:
Address:
Phone Number:
Fax Number:
Contact Person:
E-Mail address:
Citizens Bank of Pennsylvania
10561 Telegraph Road, Glen, Allen, VA 23059
804-627-4254
804-627-5753
Cheryl D. Cox
CherV1D.Cox(@ccomortgaoe com
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership
of the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started the
lender at any time.
ASSUMPTION OF MORTGAGE - You may or X may not (CHECK ONE) 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.
Stupak.Act9L040210
Page 6
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN
ANY CALENDAR YEAR).
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PA Interfaith Community Programs Inc
40 E High Street
Gettysburg, PA 17325
717.334.1518
Stupak Act91.040210
Page 7
PHFA
211 North Front Street
Harrisburg, PA 171 10
717.780.3940
800.342.2397
Sincere]
BY: A(u I I I ? ?i 1h( ? I I v 0j)
UREN ERSCHLER KARL
LBK/jes
Enclosure
Stupak.Act91.0402 10
Page 8
**********************************************************************************
NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT
**********************************************************************************
This communication is from a debt collector. This is an attempt to collect a debt and any
information obtained will be used for that purpose.
Unless you dispute the validity of this debt or any portion thereof, within 30 days after receipt
of this notice, the debt will be assumed to be valid by our offices.
If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any
portion thereof is disputed, our offices will provide you with verification of the debt or a copy
of the Judgment against you and a copy of such verification or judgment will be mailed to you
by our offices.
If you make a written request for it within 30 days hereof, I will also send you the name and
address of the original creditor, if different from Vericrest Financial, Inc.,
Stupak Ac t91 040210
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
~~~yxte of u~'Ktir~6e~~~~~~
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Citizens Bank of Pennsylvania
vs.
Jessica Stupak
Case Number
2010-3552
SHERIFF'S RETURN OF SERVICE
06/01/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: Jessica Stupak, but was unable to locate her in his
bailiwick. He therefore deputized the Sheriff of Lebanon County, PA to serve the within Complaint and
Notice according to law.
06/03/2010 Lebanon County Return: And now June 3, 2010 at 1500 hours I, Michael J. Deleo, Sheriff of Lebanon
County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in
Mortgage Foreclosure, upon the within named defendant, to wit: Jessica Stupak by making known unto
John Stupak, Father of defendant at 226 Ridge Road, Jonestown, PA 17038 its contents and at the same
time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $37.00
June 11, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
(ci GounfySuita SFenfl~_ 'felEmsoft. Inc.
COMPLAINT IN MORTGAGE FORECLOSURE
No. 10-3552
Return to Cumberland County
Citizens Bank of Pennsylvania
vs.
The Law Offices of Lauren Berschler Karl, LLC
Lauren Berschler Karl, Esquire
Park Building
355 Fifth Avenue, Suite 400
Pittsburg, PA 15222
412-232-0808
Jessica Stupak
STATE OF PENNSYLVANIA }
COUNTY OF LEBANON } SS:
Docket Page 32117
David Heath, Deputy Sheriff, being duly sworn according to law, deposes and says that he
served the within COMPLAINT IN MORTGAGE FORECLOSURE upon JESSICA STUPAK,
the within named DEFENDANT, by handing a true and attested copy thereof, personally to John
Stupak, he being her Father and the Person in Charge, on June 3, 2010 at 3:00 P.M., at 226 Ridge
Road, Jonestown (Union Township), Lebanon County, Pennsylvania, and by making known to
him the contents of the same.
Sworn to and subscribed before me SO ANSWERS,
This 9th day of June, 2010
'~~Votary Public DEPUTY SHERIFF
_-~
NOTARIAL SEAL ~~~~ ~-~"
.'zebra Ann.lohnson, 1Votary Public 1S
p,nba:~on C"aty~Lebanon County
~;~1~, ~tu~~ri~ission r.xpires Nov. 20, 2011 SHERIFF
SHERIFF'S COSTS IN ABOVE PROCEEDINGS
Advanced Costs paid on 06/02/10 Check No. 2177 Amount $ 100.00
Costs Incurred: ~(~ Amount $ 60.00
Amount of Refund: Check Noc~,` { -~ ~~ Amount $ 40.00
All Sheriff s Costs shall be due and payable when services are performed, and it shall be
lawful for him to demand and receive from the party instituting the proceedings, or any party
liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by
law to make return thereof.
Sec. 2, Act of June 20, 1911, P.L. 1072
~{~
o i J.
PROTHONOTARY
COURT OF COMMON PLEAS -CUMBERLAND COUNTY
CARLISLE, PA
DAVID D. BUELL
PROTHONOTARY
To: Jessica Stupak
226 Ridge Road
Jonestown, PA 17038
CITIZENS BANK OF PENNSYLVANIA COURT OF COMMON PLEAS
Plaintiff, ; CUMBERLAND COUNTY
v. NO.: 10-3552
JESSICA STUPAK
Defendant
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
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.
David D. Buell
PROTHONOTARY
X Judgment by Default ($113,106.75)
Money Judgment
Judgment in Replevin
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY LAUREN BERSCHLER KARL at this telephone number: (412) 232-0808.
Stupak.Judgment.070910
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC.
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209
Park Building Attorney for Plaintiff
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
------------------------------------------------------
CITIZENS BANK OF PENNSYLVANIA :
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
JESSICA STUPAK
Defendant
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
NO.: 10-3552
PRAECIPE TO ENTER DEFAULT JUDGMENT
TO THE PROTHONOTARY:
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.
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Please enter a judgment by default in the amount of $113,1.06.75, plus continuing interest
at the per diem rate of $19.51, from July 10, 2010, and costs of suit, in favor of Plaintiff, Citizens
Bank of Pennsylvania, ("Citizens"), and against Defendant, Jessica Stupak, ("Defendant"), for
her failure to answer or otherwise plead in response to the Complaint in Mortgage Foreclosure in
this action. In support thereof, Citizens avers the following:
1. On May 28, 2010, Citizens commenced this action by filing a Complaint in
Mortgage Foreclosure with a Notice to Defend (collectively, the "Complaint") against the
captioned Defendants.
Stupak.Judgment.070910
~'ry.lld~~ci
ck ~ ~.~ ~~
Ma~~~ ~.~i~d
2. On June 3, 2010, service of the Complaint was served by the Sheriff of Lebanon
County, as Defendant's father, John Stupak, accepted service for Defendant at their residence at
226 Ridge Road, Jonestown, PA 17038. A true and correct copy of the Affidavit of Service is
attached hereto as Exhibit "A."
3. Defendant failed to plead in response to the Complaint within twenty (20) days.
4. On June 25, 2010, a Notice of Intention to Enter Judgment By Default was served
upon the Defendant by United States first class regular mail at 226 Ridge Road, Jonestown, PA
17038. A true and correct copy of the Notice are attached hereto and labeled as Exhibit "B."
5. More than ten (10) days have elapsed since the Notices of Intention to Enter
Judgment By Default were mailed to Defendant, and to date no responsive pleading has been
filed.
6. Damages should be assessed in the amount of $113,106.75 plus per diem interest
at the rate of $19.51, from July 10, 2010, and costs of suit, which is calculated as follows:
Principal $ 101,003.00
Accrued interest
(through 07/09/10) 5,503.60
Accrued late charges 280.00
BPO/Appraisal 400.00
Title Reports 620.00
Attorneys fees 5,050.15
Attorneys costs 250.00
TOTAL REAL DEBT $ 113,106.75
7. The aforementioned sum is the amount demanded in the Complaint with interest
carried forward to July 9, 2010.
Stupak.Judgment.070910
WHEREFORE, Plaintiff, Citizens Bank of Pennsylvania, demands judgment in its favor
and against Defendant, Jessica Stupak, in the amount of $113,106.75, plus per diem interest of
$19.51, from July 10, 2010, plus any and all additional attorneys fees and costs and any other
costs and charges collectible under the mortgage and for the foreclosure and sale of the Property.
Respectfully submitted,
THE LAW OFFICES OF LAUREN
BERSCHLER KARL, LLC
BY:
uren Bers ler Karl, Esquire
Attorneys for Plaintiff,
Citizens Bank of Pennsylvania
Date: July 9, 2010
Stupak.Judgment.070910
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC.
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209
Park Building Attorney for Plaintiff
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
CITIZENS BANK OF PENNSYLVANIA
Plaintiff,
v.
JESSICA STUPAK
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 10-3552
CERTIFICATION OF SERVICE OF
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
I, Lauren Berschler Karl, Esquire, hereby certify that on June 25, 2010, I served a Notice
of Intention to Enter Judgment By Default upon Defendant, Jessica Stupak, by United States
class regular mail at 226 Ridge Road, Jonestown, PA 17038.
By:
y amtiff
Citizens Bank of Pennsylvania
~,~1 K
auren Bers hler Karl, Esquire
Attorne for 1 ' '
Stupak.Judgment.070910
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC.
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209
Park Building Attorney for Plaintiff
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
CITIZENS BANK OF PENNSYLVANIA
Plaintiff,
v.
JESSICA STUPAK
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 10-3552
CERTIFICATION OF ADDRESSES
I, Lauren Berschler Karl, Esquire, hereby certify that the address of Plaintiff, Citizens
Bank of Pennsylvania, is 10561 Telegraph Road, Glen Allen, VA 23059, and that the last known
address of Defendant, Jessica Stupak, is 226 Ridge Road, Jonestown, PA 17038.
By:
y ntiff
Citizens Bank. of Pennsylvania
uren B rschler Karl, Esquire
Attorne r Plai '
Stupak.Judgment.070910
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC.
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209
Park Building Attorney for Plaintiff
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
CITIZENS BANK OF PENNSYLVANIA
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLANI) COUNTY
v.
JESSICA STUPAK
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
Defendant.
NO.: 10-3552
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
SS
Lauren Berschler Karl, Esquire, being duly sworn according to law, deposes and states that she is
the attorney for Citizens Bank of Pennsylvania, and as such, is authorized to make this Affidavit on its
behalf; and that, to the best of her knowledge, information and belief, Defendant, Jessica Stupak, is not in
the military or naval service of the United States or its allies or otherwise within the provisions of the
Soldiers and Sailors Civil Relief Act of 1940 and/or its a endments.
auren Ber chler Karl, Esquire
Sworn to and subscribed
before me this 9 ~~ day _-~.,.ur~~ ~ ~M V`pJ~.,
of _ V, .t, I c~ , 2010. ~~~•'r~ry public
0 ~ ~~ C7iy dd Pf~~ro /~~ ~y ~z0 ~
~v L ~ ~,m~slon f~
(Notary P lic)
Stupak.Judgment.070910
EXHIBIT `~A"
COMPLAINT IN MORTGAGE FORECLOSURE
No. 10-3882
Return to Cumberland County
Citizens Bank of Pennsylvania
vs.
The Law Offices of Lauren Berschler Karl, LLC
Lauren Berschler Karl, Esquire
Park Building
3SS Fifth Avenue, Suite 400
Pittsburg, PA 15222
412-232-0808
Jessica Stupak
STATE OF PENNSYLVANIA }
COUNTY OF LEBANON } SS:
Docket Page 32117
David Heath, Deputy Sheriff, being duly sworn according to law, deposes and says that he
served the within COMPLAINT IN MORTGAGE FORECLOSURE upon JESSICA STUPAK,
the within named DEFENDANT, by handing a true and attested copy thereof, personally to John
Stupak, he being her Father and the Person in Charge, on June 3, 2010 at 3:00 P.M., at 226 Ridge
Road, Jonestown (Union Township), Lebanon County, Pennsylvania, and by making known to
him the contents of the same.
Sworn to and subscribed before me
This 9th day of June, 2010
SO ANSWERS,
~~ a. ~-~~..~~ is
Public DEPUTY SHERIFF
NOTARIAL SEAL
DebF•a Amy .Johnson, 1~Totar Public
J,^1~ar~on City. Lebanon County
i~,., Crnunissian Expires Nov. 20, 201
jZi~~~/~u~-/. GL RN~C~
~~
SHERIFF
SHERIFF'S COSTS IN ABOVE PROCEEDINGS
Advanced Costs paid on 06/02/10 Check No. 2177 Amount $ 100.00
Costs Incurred: Amount $ 60.00
Amount of Refund: Check Noc~~~~ Amount $ 40.00
All Sheriffs Costs shall be due and payable when services are performed, and it shall be
lawful for him to demand and receive from the party instituting the proceedings, or any party
liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by
law to make return thereof.
Sec. 2, Act of June 20, 1911, P.L. 1072
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
~4ti«titr ct ~~unbrr~~Jld
Jody S Smith
Chief Deputy ~•,_~'~ •.y
Richard W Stewart ~~' ~ '-
SOilcltor OFFi~E QF THE Si°ERIFF
Citizens Bank of Pennsylvania Case Number
vs.
Jessica Stupak 2010-3552
SHERIFF'S RETURN OF SERVICE
06/01/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: Jessica Stupak, but was unable to locate her in his
bailiwick. He therefore deputized the Sheriff of Lebanon County, PA to serve the within Complaint and
Notice according to law.
06/03/2010 Lebanon County Return: And now June 3, 2010 at 1500 hours I, Michael J. Deleo, Sheriff of Lebanon
County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in
Mortgage Foreclosure, upon the within named defendant, to wit: Jessica Stupak by making known unto
John Stupak, Father of defendant at 226 Ridge Road, Jonestown, PA 17038 its contents and at the same
time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $37.00
June 11, 2010
SO ANSWERS,
...
RON R ANDERSON, SHERIFF
jC~ COlinty G411C SheliH, TfifO50fl. InC
EXHIBIT "B"
THE LAW OFFICES OF
LAUREN BERSCHLER KARL, LLC
lbkarl(a,lbkarllaw.com Park Building licensed in NJ and PA
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax:412-232-0773
Jessica Stupak
226 Ridge Road
Jonestown, PA 17038
June 25, 2010
Re: Citizens Bank of Pennsylvania v. Jessica Stupak
CCP Cumberland County, Docket No. 10-3552
Dear Ms. Stupak:
Please note, this office represents Citizens Bank of Pennsylvania in the above-referenced
matter. Enclosed please find a Notice of Intention to Enter Judgment by Default.
~ncerely,
~~~ . K~
Lauren Berschler Karl
LBK/jes
Enclosure
S tupak. l Odayl tr.0625 I 0
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC.
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209
Park Building
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax:412-232-0773
CITIZENS BANK OF PENNSYLVANIA
Plaintiff,
v.
JESSICA STUPAK
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA ] 7070
Defendant.
COURT OF COMMON PLEAS
• CUMBERLAND COUNTY
NO.: 10-3552
To: JESSICA STUPAK
Date of Notice: June 25, 2010
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS 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.
Stupak.TenDayNotice.0625 l0
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 FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
1-800-990-9108
717-249-3166
Respectfully submitted,
THE LAW OFFICES OF
LAUREN BERSCHLER KARL, LLC
BY: -
en Bersc ler Karl, Esquire
Attorney for laintiff,
Citizens Bank of Pennsylvania
S tupak. TenDayNoti ce.062510
-2-
- I .- J
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
CITIZENS BANK OF PENNSYLVANIA
Plaintiff,
V.
JESSICA STUPAK
Defendant
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
------------------------------------------------------
? Confession Judgment
¦ Other - MORTGAGE FORECLOSURE
File No. 10-3552 Civil Term
Amount Due: $113,106.75, plus
Interest: $2,946.01, from 7/10/10-12/8/10
(19.51 /dUI,21us
Atty's Comm: $0.00, plus
Costs: to be added
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale,
contract, or account based on a confession of judgment, but if it does, it is based on the appropriate
original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to
Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt,
interest and costs, upon the following described property of the defendant(s)
116 Fourth Avenue
New Cumberland, PA 17070
as more fully described in Exhibit "A" attached hereto.
Date: Z
3'1.00 Cc
93.00 M
Wc>o
a .50
!w- 0 - PQ Ali
$a-00 Poe ao
.50 We w
R'? a?7Qa8
WtA3TftAQUUd
Signature:
Print Name: wren Ber chler Karl Esquire
Address: 355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
Attorney for: Plaintiff
Telephone: 412-232-0808
Supreme Court ID No.:88209
?
c2 m
CD -•c
ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan
thereof made by Ernest J. Walker, Professional Engineer, dated August 17, 1966, as follows, to
wit:
BEGINNING at a point on the southeasterly wide of Fourth Alley, now known as Fourth
Avenue, said point being 23 feet southwest of the southeasterly side of Walnut Alley; thence
extending along premises known as 114 Fourth Alley and passing through the center of a
partition wall South 51 degrees East, 50 feet to a point; thence South 39 degrees West, 51 feet to
a point; thence North 51 degrees West, 50 feet to a point on the southeasterly side of Fourth
Alley aforesaid; thence along the same North 39 degrees East, 51 feet to the point and place of
BEGINNING.
HAVING THEREON erected a dwelling commonly known as 116 Fourth Avenue, New
Cumberland, Pennsylvania.
Being the same property which Robert S. McCleaf by Deed dated May 24, 2006 and recorded on
May 31, 2006, in the Cumberland County Recorder of Deeds Office in Book 274, page 4051,
granted and conveyed unto Jessica Stupak.
Improvements: Residential Dwelling
BEING known as: 116 Fourth Avenue, New Cumberland, PA 17070
Parcel ID Number: 25-24-0813-038.
EXHIBIT "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-3552 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITIZENS BANK OF PENNSYLVANIA, Plaintiff (s)
From JESSICA STUPAK
(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 $113,106.758
L.L.$.50
Interest from 7/10/10 to 12/8/10 @ $19.51 plus -- $2,946.01
Atty's Comm % Due Prothy $2.00
Atty Paid $169.50 Other Costs
Plaintiff Paid
Date: 9/8/10
David D uell, Prot a
(Seal) By:
Deputy
REQUESTING PARTY:
Name: LAUREN BERSCHLER KARL, ESQUIRE
Address: THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC
PARK BUILDING
355 FIFTH AVENUE, SUITE 400
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-232-0808
Supreme Court ID No. 88209
t ^w
?? 11
FILE D-0'fnr PCE
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC. ('r-'P f ; 2
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209 COUNW
Park Building Attorney for PlaipwSYLL'ANlA
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
------------------------------------------------------
CITIZENS BANK OF PENNSYLVANIA
Plaintiff, :
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
V.
JESSICA STUPAK
Defendant
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
------------------------------------------------------
DOCKET NO.: 10-3552
AFFIDAVIT PURSUANT TO RULE 3129.1
LAUREN BERSCHLER KARL, ESQUIRE, attorney for 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 116 Fourth Avenue, New Cumberland, PA
17070, as more fully described in the metes and bounds description attached hereto, and made a
part hereof, and identified as Exhibit "A":
1. Name and address of Owner(s) or Reputed Owner(s):
Name
Address
Jessica Stupak 116 Fourth Avenue
New Cumberland, PA 17070
and
226 Ridge Road
Jonestown, PA 17038
2
3.
4.
Name and address of Defendant(s) in the judgment:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Jessica Stupak 116 Fourth Avenue
New Cumberland, PA 17070
and
226 Ridge Road
Jonestown, PA 17038
Name and last known address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Citizens Bank of Pennsylvania 10561 Telegraph Road
Glen Allen, VA 23059
Name and last known address of the last recorded holder of every mortgage of
record:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Citizens Bank of Pennsylvania
1735 Market Street
Philadelphia, PA 19103
PNC Bank
2730 Liberty Avenue
Pittsburgh, PA 15222
And
225 Fifth Avenue
Pittsburgh, PA 15222
Name and address of every other person who has any record lien on the property:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
None.
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
PA Dept. of Public Welfare-
Bureau of Child Support
Health & Welfare Building
P.O. Box 2675
Harrisburg, PA 17105
Domestic Relations Section
of Cumberland County
13 North Hanover Street
Carlisle, PA 17013
Name and address of every person of whom the Plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Current Occupant
116 Fourth Avenue
New Cumberland, PA 17070
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements made herein are subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsifications to authorities.
Dat LVjir6 Berschl Karl, Esquire
Sworn to and Subscribed before me
this o2' day of J .tv) J?,t r , 2010.
Notarial Seal
Abby Ferguson, Notary Pub0c
city of Wttsburgh, Allegheny County
My Commisslon Expires oct 1, 2013
ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan
thereof made by Ernest J. Walker, Professional Engineer, dated August 17, 1966, as follows, to
wit:
BEGINNING at a point on the southeasterly wide of Fourth Alley, now known as Fourth
Avenue, said point being 23 feet southwest of the southeasterly side of Walnut Alley; thence
extending along premises known as 114 Fourth Alley and passing through the center of a
partition wall South 51 degrees East, 50 feet to a point; thence South 39 degrees West, 51 feet to
a point; thence North 51 degrees West, 50 feet to a point on the southeasterly side of Fourth
Alley aforesaid; thence along the same North 39 degrees East, 51 feet to the point and place of
BEGINNING.
HAVING THEREON erected a dwelling commonly known as 116 Fourth Avenue, New
Cumberland, Pennsylvania.
Being the same property which Robert S. McCleaf by Deed dated May 24, 2006 and recorded on
May 31, 2006, in the Cumberland County Recorder of Deeds Office in Book 274, page 4051,
granted and conveyed unto Jessica Stupak.
Improvements: Residential Dwelling
BEING known as: 116 Fourth Avenue, New Cumberland, PA 17070
Parcel ID Number: 25-24-0813-038.
EXHIBIT "A"
FILED-011=1CE
VjAw
-$ PM 1: 28
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC.
Lauren Berschler Karl, Esquire C171?A3NS'?'LYAN?IAti?Y
Attorney Id. No. 88209
Park Building Attorney for Plaintiff
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
------------------------------------------------------
CITIZENS BANK OF PENNSYLVANIA ;
Plaintiff, COURT OF COMMON PLEAS
CUMBERLAND COUNTY
V.
JESSICA STUPAK DOCKET NO.: 10-3552
.
Defendant
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
ACT 6 AND ACT 91 AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF ALLEGHENY
I, Lauren Berschler Karl, Esquire, being duly sworn according to law, depose and say that
I am counsel for the Plaintiff, and that I am authorized to make this Affidavit on its behalf, and
that the provisions of Act 6 codified at 41 P.S. § 101 et seq. and the provisions of Act 91 codified
at 35 P. S. § 1680.401 c et seq. have been compli with.
(wul I [ liic"A Vws,
Q?3?11U
Date L r n Berschl r Karl, Esquire
Sworn tq and Subscribed before me
this ' 116 day of 2010.
rCOMMONWFALTM OF PENNSYLVANIA
G .. Noorml Seel Public
Ota PU lic ANN Ferguson NoU County
ry City of piasburyn, kleq y
2013
MY GOmmisatan OCL 1, county
an
F1LED-r' SCE TARY
T r, nce)- 1-
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC. w$ t 28
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209 CUMPENc.(? NANIA
Park Building Attorney for Plaintiff
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
------------------------------------------------------
CITIZENS BANK OF PENNSYLVANIA
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
JESSICA STUPAK
Defendant
DOCKET NO.: 10-3552
Mortgaged Property:
H 6 Fourth Avenue
New Cumberland, PA 17070
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
TO THE DEFENDANT: JESSICA STUPAK
DATE OF SALE: DECEMBER 8, 2010 AT 10:00 A.M.
PROPERTY TO BE SOLD: 116 FOURTH AVENUE, NEW CUMBERLAND, PA 17070
PLACE OF SALE: CUMBERLAND COUNTY COURTHOUSE,
1 COURTHOUSE SQUARE, CARLISLE, PA 17013
To prevent this Sheriff s Sale, you must take immediate action:
The sale will be canceled if you pay to Citizens Bank of Pennsylvania the sum of
$113,106.75 plus interest and costs. To find out how much you must pay, you may
call Lauren Berschler Karl, Esquire at (412) 232-0808.
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.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale (See notice on page two and 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.
If the Sheriff's Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price by calling Lauren Berschler Karl, Esquire at
(412) 232-0808.
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 occurred, you may call Lauren Berschler Karl,
Esquire at (412) 232-0808.
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.
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 real estate.
A schedule of distribution of the money bid for your real estate will be filed by
the Sheriff on a date specified by sheriff not later than thirty (30) days following
the sale. This schedule will state who will be receiving that money. The money
will be paid out in accordance with this schedule unless exceptions (reasons why
the proposed distribution is wrong) are filed with the Sheriff within ten (10) days
after the filing of the schedule of distribution.
7. You may also have other rights and defenses or ways of getting your property
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 Bedford Street
Carlisle, PA 17103
1-800-990-9108
717-249-3166
ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan
thereof made by Ernest J. Walker, Professional Engineer, dated August 17, 1966, as follows, to
wit:
BEGINNING at a point on the southeasterly wide of Fourth Alley, now known as Fourth
Avenue, said point being 23 feet southwest of the southeasterly side of Walnut Alley; thence
extending along premises known as 114 Fourth Alley and passing through the center of a
partition wall South 51 degrees East, 50 feet to a point; thence South 39 degrees West, 51 feet to
a point.; thence North 51 degrees West, 50 feet to a point on the southeasterly side of Fourth
Alley aforesaid; thence along the same North 39 degrees East, 51 feet to the point and place of
BEGINNING.
HAVING THEREON erected a dwelling commonly known as 116 Fourth Avenue, New
Cumberland, Pennsylvania.
Being the same property which Robert S. McCleaf by Deed dated May 24, 2006 and recorded on
May 31, 2006, in the Cumberland County Recorder of Deeds Office in Book 274, page 4051,
granted and conveyed unto Jessica Stupak.
Improvements: Residential Dwelling
BEING known as: 116 Fourth Avenue, New Cumberland, PA 17070
Parcel ID Number: 25-24-0813-038.
EXHIBIT «A99
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC.
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209
Park Building Attorney for Plaintiff
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
------------------------------------------------------
CITIZENS BANK OF PENNSYLVANIA
Plaintiff, .
v.
JESSICA STUPAK
Defendant '
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
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DOCKET NO.: 10-3552 ~;=+a'
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LAUREN BERSCHLER KARL, ESQUIRE, attorney for 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 116 Fourth Avenue, New Cumberland, PA
17070, as more fully described in the metes and bounds description attached hereto, and made a
part hereof, and identified as Exhibit "A":
1. Name and address of Owner(s) or Reputed Owner(s):
Name
Jessica Stupak
Address
116 Fourth Avenue
New Cumberland, PA 17070
And
226 Ridge Road
Jonestown, PA 17038
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3.
4.
Name and address of Defendant(s) in the judgment:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Jessica Stupak 116 Fourth Avenue
New Cumberland, PA 17070
And
226 Ridge Road
Jonestown, PA 17038
Name and last known address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Citizens Bank of Pennsylvania 10561 Telegraph Road
Glen Allen, VA 23059
Name and last known address of the last recorded holder of every mortgage of
record:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Citizens Bank of Pennsylvania
1735 Market Street
Philadelphia, PA 19103
PNC Bank
2730 Liberty Avenue
Pittsburgh, PA 15222
And
225 Fifth Avenue
Pittsburgh, PA 15222
5. Name and address of every other person who has any record lien on the property:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
None.
Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
PA Dept. of Public Welfare-
Bureau of Child Support
Health & Welfare Building
P.O. Box 2675
Harrisburg, PA 17105
Domestic Relations Section
of Cumberland County
13 North Hanover Street
Carlisle, PA 17013
Name and address of every person of whom the Plaintiff has knowledge who has any
interest in the property which maybe affected by the sale:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Current Occupant
116 Fourth Avenue
New Cumberland, PA 17070
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements made herein are subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unsw rn falsifications to authorities.
b o ~Inl~t ~.~
Date La n Berschler arl, Esquire
Sworn ~ and Subscribed before me
this ~ day of ~~-fr)1~C-r , 2010.
~_
Notary Publi C~MMgNWEAL'('H OF PENNSYLVANIA
Notarial Seal
Nbby Ferguson, Notary Pubik
City of Pittsburgh, ANegherry County
My Commission Expires Oct 1, 2013
J
ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan
thereof made by Ernest J. Walker, Professional Engineer, dated August 17, 1966, as follows, to
wit:
BEGINNING at a point on the southeasterly wide of Fourth Alley, now known as Fourth
Avenue, said point being 23 feet southwest of the southeasterly side of Walnut Alley; thence
extending along premises known as 114 Fourth Alley and passing through the center of a
partition wall South 51 degrees East, 50 feet to a point; thence South 39 degrees West, 51 feet to
a point; thence North 51 degrees West, 50 feet to a point on the southeasterly side of Fourth
Alley aforesaid; thence along the same North 39 degrees East, 51 feet to the point and place of
BEGINNING.
HAVING THEREON erected a dwelling commonly known as 116 Fourth Avenue, New
Cumberland, Pennsylvania.
Being the same property which Robert S. McCleaf by Deed dated May 24, 2006 and recorded on
May 31, 2006, in the Cumberland County Recorder of Deeds Office in Book 274, page 4051,
granted and conveyed unto Jessica Stupak.
Improvements: Residential Dwelling
BEING known as: 116 Fourth Avenue, New Cumberland, PA 17070
Parcel ID Number: 25-24-0813-038.
EXHIBIT "A"
r
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC.
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209
Park Building Attorney for Plaintiff
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
------------------------------------------------------
CITIZENS BANK OF PENNSYLVANIA
Plaintiff, .
v.
JESSICA STUPAK
Defendant
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
--------------------------------
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.: 10-3552
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1
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1. The written notice to the Defendants required under Pa. R.C.P. 3129.2 was served
by first class certified United States Mail return receipt requested and by first class regular
United States mail on October 14, 2010, upon Defendant, Jessica Stupak at 116 Fourth Avenue,
New Cumberland, PA 17070 and 226 Ridge Road, Jonestown, PA 17038. Proofs of mailing are
attached hereto and labeled as Exhibit "A."
2. The written notice to all persons named in Plaintiff's 3129.1 Affidavit other than
the Defendants required under Pa. R.C.P. 3129.2 was served by first class regular United States
mail on October 14, 2010, upon the following:
PNC Bank
2730 Liberty Avenue
Pittsburgh, PA 15222
And
225 Fifth Avenue
Pittsburgh, PA 15222
PA Dept. of Public Welfare-
Bureau of Child Support
Health & Welfare Building
P.O. Box 2675
Harrisburg, PA 17105
Domestic Relations Section of Cumberland County
13 North Hanover Street
Carlisle, PA 17013
Current Occupant
116 Fourth Avenue
New Cumberland, PA 17070
Proofs of mailing are attached hereto and labeled as Exhibit "B."
Respectfully Submitted,
THE LAW OFFICES OF
LAUREN BERSCHLER KARL, LLC.
BY:
auren Ber hler Karl, Esquire
Attorneys for Plaintiff
Date: October 19, 2010
EXHIBIT "A"
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'THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC.
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209
Park Building Attorney fc
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
CITIZENS BANK OF PENNSYLVANIA
Plaintiff, : COURT OF COMN
V.
JESSICA STUPAK
Defendant.
Mortgaged Property:
116 Fourth Avenue '
New Cumberland, PA 17070
CUMBERLAND C
r Plaintiff
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ON PLEAS
DOCKET NO.: 10552
OF SERVICE PURSUANT TO RULE 3129.1
I, Lauren Berschler Karl, Esquire, having been duly sworn, hereby certify that:
1. The written notice to the Defendant required under Pa. R.C.P. 3129.2 was served
by first class certified United. States Mail return receipt requested on October 18, 2010, upon
Defendant, Jessica Stupak at 226 Ridge Road, Jonestown, PA 17038. true and correct copy of
the USPS'Confirmation and signed certified mailing receipt are attach d hereto and labeled as
Exhibit "A.
Respectfully Sub fitted,
THE LAW OFFICES OF
LAUREN BERS HLER KARL, LLC.
BY:
Attorney.,
ler Karl,
Plaintiff
Date: November 2, 2010
EXHIBIT "A"
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Label/Receipt Number: 7010 0290 0000 9643 4953
Service(s): Certified Mall"'
Status: Delivered
Your item was delivered at 2:22 pm on October 18, 2010 in
JONESTOWN, PA 17038.
Detailed Results:
• Delivered, October 18,201,10,2:22 pm, JONESTOWN, PA 17038
Arrival at Unit'October 18, 2010,9:35 am, JONESTOWN, PA 17038
Track & Confirm by email
Get current event information or updates for your item sent to you or others by
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SHE,P. FF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson
RL.aa -fir"r 1
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Sheriff ` f H"C P" n-p 0 }
Jody S Smith a
Chief Deputy JAH 27 Aff $; 39
Richard W Stewart CUMBERLAND CoUtgTY
Solicitor PENNSYLVANIA
Citizens Bank of Pennsylvania
vs.
Jessica Stupak
Case Number
2010-3552
SHERIFF'S RETURN OF SERVICE
09/17/2010 Ronny R. Anderson Sheriff who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Jessica Stupak, but was unable to locate her in his
bailiwick. He therefore deputized the Sheriff of Lebanon County, Pennsylvania to serve the within Real
Estate Writ, Notice of Sale and Description according to law.
10/21/2010 08:02 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on 10/21/10 at
2002 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 Jessica Stupak, located at, 116 Fourth Avenue, New
Cumberland, Cumberland County, Pennsylvania according to law.
11/09/2010 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of
Lebanon County upon Helan Stupak, Mother, who accepted for Jessica Stupak, at 226 Ridge Road,
Jonestown, PA on 10/22/10 at 1000 hrs. So Answers: David A. Heath, Deputy Sheriff.
12/07/2010 As directed by Lauren Berschler Karl, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/5/2011
01/05/2011 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, Carlisle, PA on Januart 5, 2011 at 10:00 a.m. He sold the same for the
sum of $ 1.00 to Attorney Lauren Breschler Karl, on behalf of Citizens Bank of Pennsylvania of 10 Tripps
Lane, Riverside, RI 02915 being the buyer in this execution, paid to the Sheriff the sum of $
SHERIFF COST: $850.79
January 18, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
.9a P 04-
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a C?unty5uite 5? erfl. T`rl^os;;ft. Ir::.
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-355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
------------------------------------------------------
CITIZENS BANK OF PENNSYLVANIA :
Plaintiff, COURT OF COMMON PLEAS
CUMBERLAND COUNTY
FILED--CM- ',,E
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC. ,
Lauren Berschler Karl, Esquire f P?? ' 2
Attorney Id. No. 88209
Park Building Attorney for P. al
, ?J?$J
?PENNSYNINA
v.
JESSICA STUPAK DOCKET NO.: 10-3552
Defendant
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
------------------------------------------------------
AFFIDAVIT PURSUANT TO RULE 3129.1
LAUREN BERSCHLER KARL, ESQUIRE, attorney for 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 116 Fourth Avenue, New Cumberland, PA
17070, as more fully described in the metes and bounds description attached hereto, and made a
part hereof, and identified as Exhibit "A":
1. Name and address of Owner(s) or Reputed Owner(s):
Name
Address
Jessica Stupak 116 Fourth Avenue
New Cumberland, PA 17070
and
226 Ridge Road
Jonestown, PA 17038
2. Name and address of Defendant(s) in the judgment:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Jessica Stupak 116 Fourth Avenue
New Cumberland, PA 17070
and
226 Ridge Road
Jonestown, PA 17038
3. Name and last known address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Citizens Bank of Pennsylvania 10561 Telegraph Road
Glen Allen, VA 23059
4. Name and last known address of the last recorded holder of every mortgage of
record:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Citizens Bank of Pennsylvania
PNC Bank
1735 Market Street
Philadelphia, PA 19103
2730 Liberty Avenue
Pittsburgh, PA 15222
And
225 Fifth Avenue
Pittsburgh, PA 15222
5. Name and address of every other person who has any record lien on the property:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
None.
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
PA Dept. of Public Welfare-
Bureau of Child Support
Health & Welfare Building
P.O. Box 2675
Harrisburg, PA 17105
Domestic Relations Section
of Cumberland County
13 North Hanover Street
Carlisle, PA 17013
Name and address of every person of whom the Plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Current Occupant
116 Fourth Avenue
New Cumberland, PA 17070
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements made herein are subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsifications to authorities.
UW 1A LUCIA I A CJ
Dat L n Berschle Karl, Esquire
Sworn to and Subsc ed before me
this r1LC day of m r , 2010.
Notarial seal
Abby Ferguson, Notary Public
city of Pittsburgh, Nlegheny County
My Commission Expires Oct 1, 2013
ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan
thereof made by Ernest J. Walker, Professional Engineer, dated August 17, 1966, as follows, to
wit:
BEGINNING at a point on the southeasterly wide of Fourth Alley, now known as Fourth
Avenue, said point being 23 feet southwest of the southeasterly side of Walnut Alley; thence
extending along premises known as 114 Fourth Alley and passing through the center of a
partition wall South 51 degrees East, 50 feet to a point, thence South 39 degrees West, 51 feet to
a point; thence North 51 degrees West, 50 feet to a point on the southeasterly side of Fourth
Alley aforesaid; thence along the same North 39 degrees East, 51 feet to the point and place of
BEGINNING.
HAVING THEREON erected a dwelling commonly known as 116 Fourth Avenue, New
Cumberland, Pennsylvania.
Being the same property which Robert S. McCleaf by Deed dated May 24, 2006 and recorded on
May 31, 2006, in the Cumberland County Recorder of Deeds Office in Book 274, page 4051,
granted and conveyed unto Jessica Stupak.
Improvements: Residential Dwelling
BEING known as: 116 Fourth Avenue, New Cumberland, PA 17070
Parcel ID Number: 25-24-0813-038.
EXHIBIT "A"
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC.
Lauren Berschler Karl, Esquire
Attorney Id. No. 88209
Park Building Attorney for Plaintiff
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
CITIZENS BANK OF PENNSYLVANIA ;
Plaintiff,
V.
JESSICA STUPAK
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.: 10-3552
Mortgaged Property:
116 Fourth Avenue
New Cumberland, PA 17070
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
TO THE DEFENDANT: JESSICA STUPAK
DATE OF SALE: DECEMBER 8, 2010 AT 10:00 A.M.
PROPERTY TO BE SOLD: 116 FOURTH AVENUE, NEW CUMBERLAND, PA 17070
PLACE OF SALE: CUMBERLAND COUNTY COURTHOUSE,
1 COURTHOUSE SQUARE, CARLISLE, PA 17013
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to Citizens Bank of Pennsylvania the sum of
$113,106.75 plus interest and costs. To find out how much you must pay, you may
call Lauren Berschler Karl, Esquire at (412) 232-0808.
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.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale (See notice on page two and 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.
If the Sheriff's Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price by calling Lauren Berschler Karl, Esquire at
(412) 232-0808.
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 occurred, you may call Lauren Berschler Karl,
Esquire at (412) 232-0808.
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 real estate.
A schedule of distribution of the money bid for your real estate will be filed by
the Sheriff on a date specified by sheriff not later than thirty (30) days following
the sale. This schedule will state who will be receiving that money. The money
will be paid out in accordance with this schedule unless exceptions (reasons why
the proposed distribution is wrong) are filed with the Sheriff within ten (10) days
after the filing of the schedule of distribution.
7. You may also have other rights and defenses or ways of getting your property
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 Bedford Street
Carlisle, PA 17103
1-800-990-9108
717-249-3166
ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan
thereof made by Ernest J. Walker, Professional Engineer, dated August 17, 1966, as follows, to
wit:
BEGINNING at a point on the southeasterly wide of Fourth Alley, now known as Fourth
Avenue, said point being 23 feet southwest of the southeasterly side of Walnut Alley; thence
extending along premises known as 114 Fourth Alley and passing through the center of a
partition wall South 51 degrees East, 50 feet to a point; thence South 39 degrees West, 51 feet to
a point; thence North 51 degrees West, 50 feet to a point on the southeasterly side of Fourth
Alley aforesaid; thence along the same North 39 degrees East, 51 feet to the point and place of
BEGINNING.
HAVING THEREON erected a dwelling commonly known as 116 Fourth Avenue, New
Cumberland, Pennsylvania.
Being the same property which Robert S. McCleaf by Deed dated May 24, 2006 and recorded on
May 31, 2006, in the Cumberland County Recorder of Deeds Office in Book 274, page 4051,
granted and conveyed unto Jessica Stupak.
Improvements: Residential Dwelling
BEING known as: 116 Fourth Avenue, New Cumberland, PA 17070
Parcel ID Number: 25-24-0813-038.
EXHIBIT "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 10-3552 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITIZENS BANK OF PENNSYLVANIA, Plaintiff (s)
From JESSICA STUPAK
(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 $113,106.758
L.L.$.50
Interest from 7/10/10 to 12/8/10 @ $19.51 plus -- $2,946.01
Atty's Comm % Due Prothy $2.00
Atty Paid $169.50 Other Costs
Plaintiff Paid
Date: 9/8/10
David uell, Pro '
(Seal) By:
Deputy
REQUESTING PARTY:
Name: LAUREN BERSCHLER KARL, ESQUIRE
Address: THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC
PARK BUILDING
355 FIFTH AVENUE, SUITE 400
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-232-0808
Supreme Court ID No. 88209
On September 22, 20 10 the Sheriff levied upon the
defendant's interest in the real property situated in
New Cumberland Borough, Cumberland County, PA,
Known and numbered as, 116 Fourth Avenue, New
Cumberland, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: September 22, 2010
By:
Q?==v
state Coordinator
'
ie ?atriot-News Co.
20.20 Technology Pkwy
Suite 300 "
Mechanicsburg, PA 17050
Inquiries - 717-.255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
ZhfPatriot News
Now you know
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
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 81;? 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 unanimous)
passed
and stockholders and board of directors of the said Company and subsequently duly recorded in he office ce for the Recording dig severally Deeds
in and for said County of Dauphin in Miscellaneous Bock "M", Volume 14, Page 317.
PUBLICATION COPY
Sworn to andubscfibe?
This ad ran on the date(s) shown below:
10/15/10
10/22/10
10/29/10
?re m :7s--I 0gi"bvember, 2010 A. D.
_;- //
- . r. , ,',, `
Notary Public
-
COMMONWEgLrH t7F
PCNNSYLygNTA
Sheme L NOar Seal
L Lower P Notary Pubiic
My CbmMLSSI In Twa•, Dauphin County
Member, p res Nov 26, 2011
ennsAl ani Assor.Laeior .
of Nata?n
A010-'552 Civil Term
CNIzom bar* of
Vs
Je Alca Stupelt
Atir. Bwwhkw Karl
ALL THAT CERTAIN lot or piece of land
sittk* in the Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded
and described in accordance with a survey
and plan thereof made by Ernest 7. Walker,
Professional Engineer, dated August 17,1966,
as follows, to wit:
BEGINNING at a point on the southeasterly
wide of Fourth Alley, now known as Fourth
Avenue, said point being 23 feet southwest of
the southeasterly side of Walnut Alley; thence
extending along premises known as 114
Fourth Alley and passing through the center
of a partition wall South 51 degrees East, 50
feet to apoint;;hm> South 39 degrees West,
51 feet o a point thence North 51 degrees
West 50 feet to a point on the southeasterly
side of Fourth AliGyy,ajxD aid; thence along
the same North 39 degrees Fast, 51 feet to the
point and place of BEGINNING.
HAVING THEREON erected a dwelling
Column dyknown as 116Fbarth Avenue, New
Cumberland, Pennsylvania.
Being the same property which Robert S.
McCleaf by Deed dated May 24, 2006 and
recorded on May 31, 2006, in the Cumberland
County Recorder of Deeds Office in Book
274, page 4051, granted and conveyed unto
Jessica Stupak.'
Improvements: Residential Dwelling
BEING known as: 116 Fourth Avenue, New
Cumberland, PA 17070
Parcel ID Number: 25-24-0813.038.
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.
Lisa Marie Coyne, E itor
SWORN TO AND SUBSCRIBED before me this
5 day of November, 2010
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
CUMBERLAND LAW JOURNAL
Writ No. 2010-3552 Civil
Citizens Bank of Pennsylvania
VS.
Jessica Stupak
Atty.: Lauren Berschler Karl
ALL THAT CERTAIN lot or piece of
land situate in the Borough of New
Cumberland, Cumberland County,
Pennsylvania, bounded and de-
scribed in accordance with a survey
and plan thereof made by Ernest J.
Walker, Professional Engineer, dated
August 17, 1966, as follows, to wit:
BEGINNING at a point on the
southeasterly wide of Fourth Alley,
now known as Fourth Avenue, said
point being 23 feet southwest of the
southeasterly side of Walnut Alley;
thence extending along premises
known as 114 Fourth Alley and pass-
ing through the center of a partition
wall South 51 degrees East, 50 feet
to a point; thence South 39 degrees
West, 51 feet to a point; thence North
51 degrees West, 50 feet to a point on
the southeasterly side of Fourth Al-
ley aforesaid; thence along the same
North 39 degrees East, 51 feet to the
point and place of BEGINNING.
HAVING THEREON erected a
dwelling commonly known as 116
Fourth Avenue, New Cumberland,
Pennsylvania.
Being the same property which
Robert S. McCleaf by Deed dated
May 24, 2006 and recorded on May
31, 2006, in the Cumberland County
Recorder of Deeds Office in Book 274,
page 4051, granted and conveyed
unto Jessica Stupak.
Improvements: Residential Dwell-
ing.
BEING known as: 116 Fourth
Avenue, New Cumberland, PA 17070.
Parcel ID Number: 25-24-0813-
038.
116
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Citizens Bank of Pa is the grantee the same having been sold to said grantee
on the 5th day of January A.D., 2011, under and by virtue of a writ Execution issued on the 8th day of
September, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 10 Number
3552, at the suit of Citizens Bank of Pa against Jessica Stupak is duly recorded as Instrument Number
201103315.
IN TESTIMONY WHEREOF, I have hereunto set my hand
al of said office this
an day of
A.D.
Recorder of Deeds
ReoonW dp6W Or badand Cm rft Cackle, PA
My CbwnWon B*es the Frst Monday of Jan. 2014