HomeMy WebLinkAbout10-5048T j.f
THE LAW OFFICES OF LAUREN BERSCHLER KARL, LLC
Lauren Berschler Karl, Esquire rj; J
Identification No. 88209 0/D autSr oZ l?/ff '9:09$
Park Building
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,
V.
CARL J. STASYSZYN
12 Tunbridge Lane
Carlisle, PA 17015
Defendant.
--------------------------------------------
Attorneys for Plaintiff ... r,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: /v-So y?r l-J
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
1-800-990-9108
717-249-3166
Stasyszyn. Compiaint.Cumber] and
s 91, d a1 °1-Q "?
'e-& )- y6 i3
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.
CARL J. STASYSZYN
12 Tunbridge Lane
Carlisle, PA 17015
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, Carl J. Stasyszyn, is an adult individual who is believed to reside at 12
Tunbridge Lane, Carlisle, PA 17015.
3. Defendant, Carl J. Stasyszyn, ("Defendant"), is the owner of record of a certain
parcel of residential real estate located in Cumberland County known by the following street address:
12 Tunbridge Lane, Carlisle, PA 17015 (the "Property").
4. On October 6, 2004, Defendant executed a Promissory Note in the original principal
amount of $118,800.00 (the "Note"). A true and correct copy of the Note is attached hereto as
Exhibit "A."
Stasyszyn.Complaint.Cumberland
-2-
5. The Note was secured by a mortgage granting a lien upon the Property (the
"Mortgage"), made, executed and delivered to Citizens on October 6, 2004, by Defendant and was
duly recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania on
November 10, 2004, as set forth in Book 1887 page 2844 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 July 15, 2010:
Principal $ 107,125.87
Accrued interest
(through 07/15/10) 8,691.77
Accrued late charges 260.00
BPO/Appraisal 400.00
Title Reports 620.00
Attorneys fees 5,356.29
Attorneys costs 250.00
TOTAL REAL DEBT $ 122,703.93
Interest continues to accrue at the per diem rate of $17.58.
Stasyszyn. Complaint. Cumberland
-3-
10. On May 27, 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, Carl J. Stasyszyn, in the amount of $122,703.93, plus
continuing interest at the per diem rate of $17.58, from July 14, 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: A(AA1AN,1hA1A6j
ren Bersc er Karl, Esquire
Attorneys for laintiff,
Citizens Bank of Pennsylvania
Date: July 26, 2010
Stasyszyn.Complaint.Cumberland
-4-
VERIFICATION
I, 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: ?4, do Le- ) 0 -
HERYL COX
Stasyszyn Complaint.Cumberland
-5-
EXHIBIT "A"
SECONDARY MORTGAGE LOAN INIIIII ICITIZENS BANK PROMISSORY NOTE
III
AND DISCLOSURE STATEMENT note
Borrower(s): I
CARL J STASYSZYN
Lender: ? Citizens Bank of Massachusetts ? Citizens Bank I Connecticut ® Citizens Bank of Pennsylvania
28 State Street 63 Eugen.0 ' etll Drive 1735 Market Street
Boston, MA 02109 New London, T 06320 Philadelphia, PA 19103
? Citizens Bank of Rhode Island ? Citizens Bank ?ew Hampshire ? Citizens Bank
1 Citizens Plaza 875 Elm Snee 919 North Market Street
Providence, 11102903 Manchester, 03101
T Suite 200
Wilmington, DE 19801
Principal Amount: $118, 800.00 Intereq Rate: 5.990 % Date of Note: 10/06/2004
In this Note, the words, "Borrower", "you," and "your" mea each and every person who signs this Agreement, including
all Borrowers named above. The words "we, "us", "our" an ' Lender" 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, hereift after referred to as "Citizens Bank".
FOR VALUE RECEIVED, the undersigned (jointly and severally if more than one) promise to pay to the above named Lender or
order, the principal sum of $ $118, 800.00 Dollars with interest at the rate of 5.990 % per annum, payable in 240
consecutive monthly installments of S 850.57 each, anp a final installment to include all principal and accrued interest,
and late charges, insurance premiums and all other charges, if an?. The first such installment will be due on 11/12/2004 and
the remaining installments on the same 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, find any remaining amount to unpaid collection costs and late
charges and any other charges you may owe. The interest rate rgquired 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/ 66 simple interest basis. First we apply the ratio of the annual
interest rate over the number of days in a year (366 during leap ears), multiplied by the outstanding principal balance, multiplied
by the actual number of days the principal balance is outstanding.
ANNUAL PERCENTAGE RATE FINANCE HARGE Amount Financed T
t
l
f P
The cost of your credit as a yearly rate
Thou dollar amount the redit will cost
The
amount of credit provided o
a
o
ayments
The amount you will have
I
i to you or on your behalf paid when you have made
all payments as scheduled
5.990 % a
$85,336.80 I
$118,800.00
$204,136.80
PAYMENT SCHEDULE:
NUMBER OF PAYMENTS AMOUNT OF PAYMENTS WHEN PAYMENTS ARE DUE
Monthly beginning on
240 850.57 Monthly beginning on 21112/2004
The payment schedule and "Total of Payments" scheduled abo a assume that all payments are made on the due date. If payments
are made late, the amount of interest payable hereunder will c tinue to accrue on the unpaid principal balance and the total
interest hereunder will increase.
REPAYMENT: If you pay off early, you will not have to pay a penalty.
ATE CHARGE: Your late fee will be calculated as foll ws, based on the state or commonwealth as indicated above:
MA: Your payment will be late if it is not received y 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 recei
cd by us within 10 calendar days of the Payment Due Date shown
above. If your payment is late, we may charge you 5.0 0% of the regularly scheduled payment of principal and interest
, or
$10.00, whichever is less.
I
?
S
NH: Your payment will be late if it is not received y us within 10 calendar days of the Payment Due Date shown
above. If your payment is late we may charge you 7.000% of the regularly scheduled payment of principal and interest or
$12.50, whichever is greater.
PA and DE: Your payment will be late if it is not rec ived by us within 15 calendar 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, whichevcr is greater
Y
.
ou will pay this late charge only once on any late payment.
SECURITY: You are giving a security interest in real est , a located at
12 7UNBRIDQE LANE, CARLISLE, PA 17013
in addition to
Lender's security interest and other rights in your deposit acc unts.
ASSUMPTION: Someone buying your home cannot assulfre the remainder of the mortgage on its original terms.
ee other related contract documents for additional informati n about nonpayment, default, the right to accelerate the maturity of
e obligation and security interests. P
1
I'mmNote REV 06104
Page 2
ITEMIZATION OF THE AMOUNT FINANCED:
Itemization of the amount financed of ............................................................ $ Ile, Boo. 00
Amount given to you directly .......................................................................... S+TO44-" I n?- • S?
Prepaid Finance Charges .................................................................................. $
Amount(s) paid to others on your behalf:
TO WAL-%ART/HBGA
TO M & T BANK
TO HOUSIMOLD
TO M & T BANK
TO
TO
TO
TO
TO
TO
TO
TO
TO
TO
TO
TO
TO INSURANCE COMPANY
TO Settlement Fees
3,151.00
$ -see, ao d 36
$ moo- I
$
$
$
$ 0.00
$ 0.00
COLLATERAL: In addition to the protections given to the Lender under this Note, this Note is secured by a
Mortgage dated 10/06/2004, to Lender on real property located in CUMBERLAND County,
State of PA all the terms and conditions of which are hereby incorporated and made
a part of this Note.
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 of judgement 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.
COLLECTION COSTS: If you fail to abide by any of the terms of this Note, and if we are permitted to do so by
applicable law, we may hire or pay someone else to help collect on the Note. You will pay all reasonable collection
costs, including reasonable attorney's fees incurred by us in the collection of amounts due under this Note as
permitted by applicable law. This includes, subject to any limits under applicable law, our legal expenses whether or
not there is a lawsuit and legal expenses for bankruptcy proceedings (including efforts to modify or vacate any
automatic stay of injunction), appeals, and any anticipated post-judgement collection services. In New Hampshire, if,
but only if, by applicable law, we are permitted to collect attorneys fees from you as part of our costs of collecting
any amounts due under this Note, then you, to the extent required by New Hampshire Revised Statutes Annotated
Chapter 361-C, as amended, shall be entitled to reasonable attorney's fees if you prevail in (a) any action, suit or
proceeding brought by us, or (b) any action brought by you. If you successfully assert a partial defense or setoff,
recoupment or counterclaim to any action brought by us, the court may withhold from us the entire amount or such
portion of the attorney's fees as the court considers equitable.
OFFSETTING DEPOSIT ACCOUNT: Unless prohibited by applicable law, we may apply money from any of your
deposit accounts with us, or our affiliates, now or in the future, to pay all or a portion of any amount overdue under
this Note. We may use this right of offset without giving you notice, unless otherwise required by applicable law.
UNIFORM SECURED NOTE: This Note is a uniform
In addition to the protections given to the Note Holder and
dated the same date as this Note, protects the Note Holder
keep the promises which you make in this Note. That Sect
conditions you may be required to make immediate payme
Some of those conditions are described as follows:
Transfer of the Property or a Beneficial Interest in
interest in it is sold or transferred (or if a benefici;
Borrower is not a natural person) without Lender'!
require immediate payment in full of all sums sect
shall not be exercised by Lender if exercise is prol
Instrument.
If Lender exercises this option, Lender shall give
a period of not less than 30 days from the date the
must pay all sums secured by this Security Instrur
expiration of this period, Lender may invoke any
further notice or demand on Borrower.
Page 3
strument with limited variations in some jurisdictions.
this Note, a Mortgage (the "Security Instrument"),
m possible losses which might result if you do not
ry Instrument describes how and under what
in full of all amounts you owe under this Note.
Borrower. If all or any pan of the Property or any
interest in Borrower is sold or transferred and
prior written consent, Lender may, at its option,
ed by this Security Instrument. However, this option
ibited by federal law as of the date of this Security
wer notice of acceleration. The notice shall provide
e is delivered or mailed within which Borrower
If Borrower fails to pay these sums prior to the
ties permitted by this Security Instrument without
PAYMENTS: All payments must be made by a check, money order, or other instrument in U.S. dollars and may
be mailed or made at any Citizens Bank office during regul ir banking hours. Payments sent by mail must be
mailed early enough to insure receipt by us on the Payment?Due Date. Inquiries and payments may be directed to:
Citizens Bank
Consumer Finance 1
1 Citizens Drive
Riverside, RI 02915
1-800-922-9999
LATE CHARGE: Your late fee will be calculated as
above:
MA: Your payment will be late if it is not received by
shown above. If your payment is late, we may charge
principal and interest.
CT and RE Your payment will be late if it is not rece
Date shown above. If your payment is late, we may cl
principal and interest, or $10.00, whichever is less.
NH: Your payment will be late if it is not received by
shown above. If your payment is late we may charge
and interest or $12.50, whichever is greater.
PA and DE: Your payment will be late if it is not rec<
Date shown above. If your payment is late, we may cl
greater.
You will pay this late charge only once on any late paymt
DOCUMENTATION: You agree to execute or
error or omission in the original Promissory Note,
limited to, Confirmatory or Corrective Mortgages.
MISCELLANEOUS: Lender may delay or forgo enfor
losing them. You and any other person who signs, guarani
waive presentment, demand for payment, protest and notii
Note, and unless otherwise expressly stated in writing, no
accommodation maker or endorser, shall be released from
or extend (repeatedly and for any length of time) this loan
impair, fail to realize upon or perfect Lender's security ini
Lender may modify this loan without the consent of or noi
modification is made.
GOVERNING LAW: This Note is governed by federal
as indicated above: The Commonwealth of Massachu
Connecticut, the State of New Hampshire, the Commo
To the extent that federal law preempts state law, this
this Note conflicts with any existing or future law, it s
comply with such law and the validity of the remaining
If you are a Maryland resident, this Note is governed
commonwealth in which the bank is located, except th
Note is not governed by the laws of the state or Comm
of Sections 12-1001 et seq. (Credit Grantor Closed E
of the Annotated Code of Maryland shall apply.
lows, based on the state or commonwealth indicated
within 15 calendar days of the Payment Due Date
t 3.000% of the regularly scheduled payment of
d by us within 10 calendar days of the Payment Due
,e you 5.000% of the regularly scheduled payment of
within 10 calendar days of the Payment Due Date
7.000% of the regularly scheduled payment of principal
d by us within 15 calendar days of the Payment Due
;e you 10.000% of the payment or $20.00, whichever is
e any document that we request in order to correct any
, or other loan related documents, including, but not
ing any of its rights or remedies under this Note without
:es or endorses this Note, to the extent allowed by law,
e of dishonor. Upon any change in the terms of this
)arty who signs this Note, whether as maker, guarantor,
iability. All such parties agree that Lender may renew
or release any party or guarantor or collateral; or
rest in the collateral. All such parties also agree that
cc to anyone other than the parry with whom the
law and by the laws of the state or commonwealth.
etts, the State of Rhode Island, the State of
wealth of Pennsylvania, or the State of Delaware.
Tote is governed by federal law. If any provision of
dl be deemed modified to the extent necessary to
terms shall not be affected.
federal law and by the laws of the state or
to the extent, but only to such extent, that this
wealth in which the bank is located, the provisions
Credit Provisions) of the Commercial Law Article
The undersigned acknowledges that before signing thi Note that all blank spaces were completed, that the
undersigned had read this Note, fully understand its provisions and approves the terms and conditions set
forth herein, and that the undersigned has received a copy of this Note as so completed.
Page 4
INSURANCE: You may obtain property insurance from anyone that is acceptable to the Lender. If your collateral
property is located in a designated Flood Zone, you must also maintain adequate flood insurance on the property.
If any required insurance on the Collateral expires or is canceled and you fail to purchase and maintain such
required insurance, the Lender may (but is not required to, except in the case of required flood insurance) purchase
insurance on the Collateral and either: (i) add the cost of the insurance to the unpaid principal balance you owe
under this Note (in which case you agree to repay the cost of the insurance in accordance with the repayment terms
of this Note), or (ii) bill you separately (in which case you agree to pay the bill immediately). In either case, the
amounts you owe for the insurance premiums will accrue interest at the interest rate provided in this Note until
repaid in full. You understand and acknowledge that any insurance obtained and maintained by the Lender may
(i) only protect the interests of the Lender and any other creditor with a prior mortgage on the Property, and
(ii) be more expensive than insurance obtained and maintained by the Borrower.
You, the undersigned, certl that you have insured the property described in the section entitled "SECURITY" on
Page I of this Note, against oss 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 1
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 acceptable 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
1 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 on the balances listed on your credit bureau report(s). By signing
below, you authorize all handwritten changes, made both to the payoff figures in this Note and the HUDI-A form,
and confirm that these changes accurately reflect the payoff figures you provided at closing.
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 Nome 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 my/our intention that this account be ajoint 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:
CARL J STkSYSZYN
EXHIBIT "B"
0 NOV 10 Am 11 08
aHLNXWOIM XAM ro,
GWER,u, SCAN CpRP,
AM GRANT ST. STE 400
Pl MDTJRGH PA 15219
Q g ?t1e ?jRiAG1r Dfip?
,,I
? ?iZdS
ID CMZEN9 R&I.
CLOSpE R?6 MORTGAGE
rm GAGE is given . tO iZpOM1
The mortnow is
CARL J STASYRzM
'ibis Mo c is g;y,en to Cities Bank of
2735 Mss P>>i3psb PA 39103 s?bae sdchrss
2mocum or awgoen. ib
pop ]
CQ%C Itoaaos
asoi+sss?.
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C'-""MMATZQN OF ADDREM
I, hereby ceTUfy that the
predr3e adtix+ese of the Grxnteea hri,
is a8 follow
Mechani ve 0?070/.
u'B, PA Z 7056
A*440*y or Agient for Grantees
COMMONWEALTH OF PENIqSyLVAMA
COUNTY OF CUJI1MMLANV SS.
RECORDEZ) ib the O,fB'* for the Recorder of Deedm iA and for said Cow
Deed Book I pap -- t3' in
W1 g.9 my hand and otReial seal thial Cer i '' blb riled
oouny
:
inumj PA
?'r of Dew
Recorder of Deeds
244 PAIWI01j;
ad "Me n* OD the Lender Yva bShE
Provides for m}y " refer to ft f)
debt y evide by yo' w uotr ('No*% dthd me tame j;; til.00
it
P ymdnbv wixb the fW1 d* ifnot paid aarfia, de tad *ii' mmvmw?
oa Whim a
sad u6: (s) *e mp"m of the debt "*mod by the Note
a ttCaWOmf
in?
? sad an
of *e Nolot „ il?M d?'+acad coder this Matt®egc b prntact ro) Iho payaat of all other anna, wfth
ra
*&?ta sad a ate mify of dtir Mme; tad c t*
V'42 fad OOCVVY end e to tad oar &t M=Iftp and the NaEa Far &" P-Mls, Yl- Pbavby we of p,
Coaaty, PMMYlTE* and topic
ray &wnlW 1 &e' P" MY 6cated in gaggge
6ereo4 Which property Est &e Wirt. a WW 6aeoa sad made t pn
121'U4y131 tjG-=' LANE, C-ARLLgLu, PA 17013
("PmPenY Addrm-1),
TOCVMR W rM eU the ia"w"'aRs now or Lereatber
' oaaeet, and noa mx*d on be „Ad
thon Y' alo b* ?+ed by thin MOr(Pp. All ??8 # ttWYW Eo to *ft Wanda
Page 2
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YOU A" Vvj tovenut and agree as follows;
1.
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aue t?
PV"Nta of TaZ- sad Isaert ,e, you will due,
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d tmdet Q?s Note.
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a? +?Dositiaas a ? ? ?°ta tivbea dae. Ydt ahaJl lam, ? ? h' °Va ? Mo?trge, up" paymeanta or grooad reme, if my.
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ou mry cfiooae T]da a tmintaioed in t +k• nrcbndmi 0004 or f whic'EWOW h
o" ??, You sb soy
pe n aii? to Us jmd sball mclaad f Stet we ngttirt. 8ic You fail to rocmpk of pW XMWms and z ! ° If
11
our sok ?? covmv es m ad in dtia Section, sot
won detmmlim m Y? fze us to obtaia Latch covenw 13
W9vi+iama in S*Ctkm 7. YOU tmdmp? PtOt= oa mumm in the propaty in amoramee a the we m
fntemn in You also °p Y sad nary not nova and ? is
tC We Mebane ran Y cover oaly our
dke
You would 1?aY fbr pm, tbo M"="m for anY wdt et MY hiShff tbim to Wa4m
page 3
8K 1887PG2846
You altall
Pronody
amder thethe dilRlmm*p o to. we =Y dao, at q?dan sod asp Yaw ? Y ?°Of of bss of you do am
Jive rekmft or JbC4jgtitja,,. to the WjW and "Wftm atnPoeoire
"ucmeY- 4 FR , 00 i°o w
-My to o 01 ?
do dl of the
CQWW
&Abik or b Pow", of u ? u mrvo?ablewt be Ifibried by ,
ewbaogtr?
e Arooeeda fttl be MM &g hWerty dw? &"Ie' ad ref t' oWd amo be if nomatipn or repair
3PP'W to sodo a t 04" twat by ft MottpW wbelbaw am °&WMme Paoceeds is
ab
oPet(y, or dot s>newv
eft ? w* ?l? ettoess
i paid to
"cured by fl; &M wr may room aad t 6e 30 days m Dome to yCC flat *0 bmaw has o ?? TV* or tastore
,lay sPP of" °? 110 then dtm The 30.&y pwx?a.aw tbo Y or to pay "Ma
MDDdklr pcj?n, IPef? da to PODO* shalt aot tegten m w eatt+md as ? wI =*o is Vvm
acqubc ft Property at a ibtocd "k ? Bono 69 due daee of
? t* gti t?+ed tr t? Mores The ft ? prior m ? t ion P a ltk.D to to to ft
amY ptiot 1b the auqui?
X' 0C a00 man ?+tion to ear on the ?'P" whpch ,vp ;a acy way.
btwliclatt tt?e the Pt+aperty
S. t'i't??rtloq M "d PMftd" of "W hVM'Ol Uft Moa?e is o®a etttttt?e am pmpe ? ea. You t ap b
hcsehold, you ba0Y to , or r
I't O Y. the lownhold and fa title d" a" ww" o? * the tease, IfYOU ?>• fa We CD The *?aaio.
7. Pro"Com of age, we eB'>!e i4 the mnger is svtida?,
Mfoms the dv t[hts fia ese
QD1? and agte r Mort I It
a d tril tom
1?at 6 tt at
?7 r4bo am epmP? '(tom"a *n ie poo°?
'8"4otak, for
tft"ycmsmwmy bi?hseawhipat chh "t6valor sad ottr ti ff s is the iha ??' do, and pry attythiag
a r prty over tlnh Y. Air stpoaa ?Y iacktde or am
to WQ under W ? P`yt% saeoamble atwavy- 'Be a4Y Ce tmdar the Nom
wwb)Ch e
&Ctkm O°VW and ash Pryhxg coy sans
are 6'PfOVe=jMr4MjM
ny
m take w4er ? y co y We not h" b Wkz are"hw
mXmPh- Any you owe na cad aamod by tbb hf sha]l
fivm m ?r? date at the _ a?MAlwd uadat lbe Not, ' Z?teso std Ab*V bmsr
Wit, W
by tills Mortgage, yon fit. ? ? p* for as a aoodid$a shall be PcYrble, *it
fma motes, such jm? W."a Such timft ty row bao for SWMV4
fags 4
SKI887PG2847
a. "Speetien. We may more fain W and rraaoaoble time and now resW able antioe. toon
?' to mBpect Sam at say
Ut1oa.
co+mxeon with any motion a wiser Uldft ?? &By
Ord Far dames, drt ar corrq?a? is
at b" ta"""d gad 4011 be to u P? of the i roperry, or for ?K /ana in ben of
by us Eo you that the Mommm oil b paid b as 1tthe Ptop?y af
to 0 notice
Wth 11* the dam an aid or
110 -10 days the notice ii OvM we S nut mized?? I ftd ' you fail to sexd
4°t
got t pfi to due. Unkae maxabm or rqmk of the Property or tO the 0011 P"0? °ede, o
ju?
Than
kiou O ?' ee w6etber or
f?
the =2a" of mmb t1<e duc date of dw ' Mramts p?iyabk P OOrb top
P?ymrun.
wKkt the 1`fe and PnaVVh 1 or
10• YOU Me Nlet RdUnd; Forbaaraasae
PsYr or cation of im of the evme awnd U0 Kat a WaFwr, $> t for
1? bmereat skall not "ereft to rela0c yont &Wi<y or ? MoebW o t you x by n0 to say of ycL procee
1uY ntor otxo&e c woe p ApMr MY wooea0ar in '? ° in mtaott
?? to n10' natirat{pa Of the a
b end time
K= by'lkii
demand nude by you or yo1 suaftwom is IatereK, out tsecured by team Ora q
no %mve or Ptec)*& the axareisa of OMY d& or remedy trarx is as 9 9Wy at rettsody 96011
and a?eemann of and Mku BO?t Mat and SevvrW L MmVW nod WOO sad o f pew bind and bq6.M you awomma" and s' ne c°verq°
sbaD D" OW
muctmo do Note. (a) is oa9;g? thin M ?? ?? who CO"°? 00 Mkt but* does OW
by k
tW& M t (b)d? ? ? PAY Me Note, ? is ob?? y moh pMW'0 sltrtat
modify, forbear or and zos ttua Odw ftm mlk* my wdmg ate 1moo's oo0eeet 0dttl°oa 9rgA tam0 of may Wee to ext+md,
thu Mortgage or the Note witheut Bach
12. L0i0A CbarIft if tie loss ""wed by ft
Maxbrum Ion duam and tha law in or
10 be waecW fn f* O th t? fib, ?Mthe w?pp is O Ot° a law 'vbi? gists
auxMW neC y to tedaee Pfd lfanta, dwn: (a) say such ooIIected Omp
1"U b r"hxW by *9
6c Obarge so tbe
ym wbwb exo°0d
M e ?" t11?t; and (b) say e
rohad ag piva ?8 oe?M > der theme Nave to You. We my h.. to m01ce
? Note.
thC
, the ft4 wM be tauW as a parttu1 pc divapay ?eD W"eymejx charge
13. Nqueft Unift omerwiee "quked law W
MOd" be d4hvrod or mailed by, gatek" to the p pep y,?d? t S'O° OVA& adds for is the MmVW 1, U111 OltrwW MT*W address Btaled ab0?vt by ?', aaY AOtioe to us tlhall be you de:ig? by
or er "dram we any ° &Wsmtr by notice to you, gift by Jht chaa mn7 to oar
Pap S
QR 1887PG2848
14. oo.er,sft jAw; ?. Tba "tt.tao of aedk
,gaverasd by federal law, wlticb far the PmpoeOa of 12 USC Seadm 85 itsaotpah i %
A te' t k ? "d m"U mt of this W2VW ''ortbe > .
Jasiaa !>, which ibe m sbdl be Bo?ottted by the law of the
PrOv4i or ctmaee of thin "
MMVW or Ow " im glut' u xanptw by &&=, law, In the evcw 6" any
a or tt Nota wjlmh ca b ' "°4 act
ca c*
l oot To *is ptq lone of &b
MwIPV wj6mA the oo W
sad 6v NoeE att dechaed to he aaverabk,
15.
f>+Is ? of the hp"' if" ar 42Y P*" of the h*Per
of IM t " pm Wd tea tit, we ?', otonr h' or way 1o yn is it is aold
"mod by Its lltoctgs?e• g?yQ. ? , 7°?e Ito payane?m in tlav
POA& W by fedorW Im ae of d o data of thin Maw 942 not be mrcimd by at if wise is
1?, We I?oaa (ng16 with M 4mame a cbi" of Lou . The Nome or a pow mbcrest in to
No (aft is a cbmr ?) may be sold tot: a moue brat wt6M P? nd6ee to You- A aak
may in Y (known as the ^I.osa Saviorl &W 000
u ader Oil to Note oad d* limip ,p, Tbmv aW mgy, be me or mote change ecthe PiY??ta due
sale of the Nape. If tbtn a ia: chow of the Loan Savioer, Yoa wM be Ffram wrjfta Lon %vm
noalct of 6' '1'"e ? toquaed by aPPRhcabke law. The ta<f" will mdste the name and sddtm of the
n of rWwred by aP*mble > whiob pytaaals sbvold be tttadc. The aatiot WM WW c MY
WWAM
17. awmr*m &btshmm You d" not CMN or
""s ?, or m4oeee of any Haul= Ica am or 0 Putt OX a++3" else lo do, aayth>ag affr ply, that b violeOoa ' You don me wr a11ow do, of my puvkv=m3
pn4loV of 4tI o w. The
Pl tOdinS in 9 km tdn ata spp)y to the prelftft, wae• ar sbmr on the
deaaad. >a wNu Or w other Yon ahatU plaav y give as wr mrmsl to *ft am and
1j to
Pretad fay Has Wow actim gel' any gvvmm=W or ee8ttlatuey ?Y of moo, vb
you kart or are aoti5ed iceor ?1 Lw of wbkh you bav W iano}vlrc' ft
renoadiatioo of i°3' Yota?eat or sejolaty IoW laow9edgc If
aecessmy rams al 4 ;t dw nWayty 4 . tsSsm,wy Wag afar
" Hasardoua "&al ? lbooe may' R° °m take
! Lat. As abed in thla Ma"
"H
Law snit the lbt*wigg nbs4taoaa M ski3osd u tmtic or hates mbe? by znvbom=
Pees had barbicide? rota a as 4Tuaaw' cam flattroaable or foxx pe,mi mb l
jttrfs ri Bb. w w is Us Mwft w' mak I.aw a ?y*, md ?, took
Y W koa *d #M nlate m tasaltb, MAY ko a o pr tf the vo
? otectiom?.
Page 6
BN 1887PG2849
I& Aooderalioa; media. We afudl g1re y" moo" prlor to sted&UL
y9*l w? *2&4
15 tilof bk 1Or?ai k Uds hUwt p (bW eet prbr to sceaierafin
(b) tboe acd= regWrod to owe fk The w efty fad td. dadtt?
to two the "Uh as i (4) Wba the d@hzk MW be Cued; IM (d) 64 Ware
aPae "Red AaT' a dt f$ ANOWOdft of do onn eaemd by thb ?AwqM
the rW to rdwb* ,tftr aeealer Nhp nd the M'c M The sotfw rbri! tYart tdbttin the
at
?rtaaoe of a dehttft or aaT other dafewe b aaaert the fonefoatl,e pro the
dehelt b apt atwd q epe or a ire Y" a" bete to aeeeiermioo and %rebveat+e. u the
on
etmta sesarai by tbta Mertgttge wkbeWlh tbw dftmuid ? hmmmme Pa?at in &M by
b We shaD be awaaw to comet ad SzPomm bmmrmd Is Pwywsisg #* t'dia
applicable 4w and cab of bat tact NM M 0% reawaable atle wpl teen as WaftW by
r?Idettce b the aataet pOWMed by appOmbb Im
19.
masse er Ea o"mevL NotwitL am &=Wastim of the edam
by thin blorWW under the pnovwm of Seadom 18, wt my, fm our sole coq end
tao"g ma as rre b ant Iola dieafton
sorb
dftnd
of this Mortgage, ' &oontis" arty PO0wftW b*M b enfome the tctmo
21L R*I"'L Upon Pariaoa of all come MMOW by t1?is MorOM eve ahatl dischgM md
6w to YOU, You AMD pay my mcordeaoa caa.
oav 21.
ofC wYau *f" to Pay mwmbls dWRO a aDowed by ba is
and ? hwAdrd? bmn%,w, xwJudmg, w oaR li oq t[u coca of obtai?g sn hei
shed not be aOSattttet! 80 ate B a0aaiued in ttds section is W eadad b create and
comma b ?' "? esatter ex??a ? ua m peQp? ?, such ? ax b trteoale or
OmM towed ti Mby. a its dthe Mortgage y4 8nU nPa}» t odalE
22. Watten, YOU, ID the extent Pm=ftW by
or defbct in t cQt t6ie Macgags, aQP able ha, tnfva and reloase eny error
1, M Mies for etay of eowm ia% ateraioa of tine wwe the brnetit of aaT Pitt or fnturo
Mead excatptioo. NO w•sira by am ai arty *w d aY t ProvLioa ? md Ode, =d
Moetgs?e or iq be Nola weaned hm y aLall be deemed to bear orcoQ
t0°°t 0f io tfoiS
. Pro?'it+icn or cnve? or of ibe sawn oo'aattoed a a of arq other
ftm Pmwiaia of cortatant at any otbtx time.
23. Iidome"O"at renal. Yom time to
one hour I*W Pd r to the ameat of biddit?p at a rbeAr, , sak?or FwvyidW in Secdm "D extend to
O&w Uk P rtlto dds .
? >?tti'base Meuey M?f? ? a M?ortXage.
to dda m fire PMP", ihit MOrOV WmW sued &h Mortgage o scat m you
tttogry age.
page 7
8X i 887PG2850
2S, b"It tote Mar l you sp= tact the WWM mt.
judPDCW n eatestid on ft Note ar to an *Xica of moftpV ibm osutz stuff be the ? ? aka a
PtY
Om bo *w under am Note. ?t1fU By SIGNM "d eaecatod by HBi panL., .
C p? sccept "d oglae to the beams and eavemn b 000kined is *j, Maw
SiS04 ee" and doUvered iti ae rtmm ot;
Page 8
8K 1887PG285 I
CIMTMCATE OF RESIDENCE OF MOWMAGU
7be prom" ? *Bd PdDm* plane of business of the MmVagae is:
PhAW PA 19103
'Ittlc: ? C.IerIC.
Clerks Plew reto.
La1mgm BAItg
Conrad -RJ1F:xI2
4" J i......
Warwtd4
Page 9
9K 1887PG2852
INDIVIDUAL ACKN CIMENT
STATE OR COMMONWEALTH OF
COUNTY OF )SS:
On the
befiore me a day of ?
-rM I M PPeare 67
CARL J STASH
to me Personally known to be the
hebsh?eJthe to this instrument, Pao Pen3on ? ms(s) isJare
and such
and ii ex y (i executed the same for the purposes therein 9 that
ed,
() ed this instrument as their free act and deed. oontain
IN WITNESS WHEREOF, I hereunto set my hand and
ci r ;
(Official Seal) af
- WW'M.VM
L tw =CM
Attention Registry of i,m
str wn or C Gierk:
Mall to: 4 ItIzns Eignk ?sumer Finance Opera
Warwick, R Qnss?,ard ons
ACM ]/Oz
B1( 1887PGZ853
Dead 61 ]rota Per: 20-09036763
Legal Da9QxfpC?quas All that certain
in the county of CO MR sad the property situated in the TP1Q73HZp op ?
fo2lorre: PARCEL 40-3t-7te-36 stnd d being of PEMMYLVAMA, be+lag desa?Da
and recorded 03/12/1993, +uaan g more fully described is a deed dated 03/11/1993.
is Dew SO 03C the land xeaardu of the county and atate set forth above,
Ok 361, page 205
,!pis to be recorded
ISrd County PA.
}
Recorder of Deeds
P09® .l of 1
uOun 18.87PG2854
? -?- ?? -?-E c
?.- ?
EXHIBIT "C"
ALL THAT CERTAIN lot or parcel of ground situate in South Middleton Township, Cumberland
County, Commonwealth of Pennsylvania, more particularly bounded and described in accordance
with Revised Final Plan-Phase 1 Greenfield Residential Development prepared by Melham
Associates, P.C. dated August 4, 1989, last revised December 17, 1990 and recorded in Cumberland
County Plan Book 62, Page 8, as follows, to wit:
BEGINNING at a point on the northern right-of-way line of Tunbridge Lane (24.00 feet wide), said
point being on the dividing line between Lot No. 103 and Lot No. 104 on the above-referenced plan;
thence continuing along the said right-of-way line by a curve to the left having a radius of 112.00
feet, the chord bearing of which is North 04 degrees 37 minutes 26 seconds West, an arc distance of
29.92 feet to a point; thence continuing along same South 07 degrees 43 minutes 24 seconds West a
distance of 6.23 feet to a point on the dividing line between Lot No. 104 and Lot No. 105 on the
above-referenced plan; thence continuing along same North 02 degrees 10 minutes 40 seconds East a
distance of 107.77 feet to a point on line of lands now or formerly of Forest Meadow Associates;
thence continuing along same South 89 degrees 12 minutes 06 seconds East a distance of 36.01 feet
to a point on the dividing line between Lot No. 103 and Lot No. 104 on the above referenced-plan;
thence continuing along same South 02 degrees 10 minutes 40 seconds West a distance of 109.82
feet to a point on the northern right-of-way line of Tunbridge Lane, the point and place of
BEGINNING.
BEING Lot No. 104 as shown on the above-referenced plan.
UNDER AND SUBJECT to Declaration of Covenants, Conditions and Restrictions Applicable to
Building Lots in "Greenfield" Phase One, Section 2 dated December 24, 1990 and record in
Cumberland County Miscellaneous Book 391, page 1034, as amended in Miscellaneous Book 435,
page 1147.
ALSO UNDER AND SUBJECT, nevertheless, to all easements, restrictions, encumbrances and other
matters of record or that a physical inspection or survey of the premises would reveal.
BEING the same premises which Greenfield Court Limited Partnership, a Pennsylvania limited
liability partnership, record owner and Marbain, Inc., a Pennsylvania business corporation, equitable
owner, by Deed date March 11, 1993, and recorded with the Cumberland County Recorder of Deeds
on March 12, 1993, in Book E36. page 205, granted and conveyed unto Carl J. Stasyszyn.
BEING COMMONLY KNOWN AS: 12 Tunbridge Lane, Carlisle, PA 17015
PARCEL NO. 40-24-0748-036
Stasyszyn.CompIaint.Cumberland
-6-
EXHIBIT 66I)"
THE LAO' OFFICES OF
LAUREL' BERSCHLER KARL, LLC
Ibkarl ?i,IbkarJla\?.com Park Building licensed m PA and N.)
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
May 27, 2010
AC'} q'i NOT1=Cli
T ARE A,CTION TO, SAVE
Y110ATE FRO n9:
1This 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 rovided in the attached ages.
The HOMEONN'NER'S EMERGENC't' MORTGAGE ASSISTANCE PROGRAM HEMAP may
be able to help to save your home. This Notice explains how the pro ram Ni-orks.
To see if HEMAP can help, you must MEET NVITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with ou when
you meet with the Counseling Agency
The name address and hone number of Consumer Credit Counseling A encies servin
listed at the end of this Notice. If you have an uestions our Count are
Agency toll fi-ee at 1-800-342-2397. (Persons NN,ith Impaired hearin ccalntcall (717 Pennsyl) Finance
Slasvsrvn Aci91 .052710
Paee 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 Nvant to contact an
attorney in your area. The local bar association may be able to help you find a lawver.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DER-ECHO A
CONTIN'UAR \/IVIENDO 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 NTUMBERO MENCIONADO
ARRIBA, PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"ROMEOVN'ER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR
SU CASA DE LA PERDIDA DEL DER-ECHO A REDIMIR SU HIPOTECA.
HOMEONN'N'ER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCOUNT NO.
ORIGINAL LEWDER:
CURRENT LENDER/SERVICER
CARL J.STASYSZYN
12 TUNBRIDGE LANE
CARLISLE. PA 17015
6050845947/04535PA09
CITIZENS BANTK OF PENTNSYLVANIA
CITIZENS BANK OF PENN'SYLVAN'IA
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 HOI\?EOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE `FACT"), 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.
Siasszyn Act9 1-052 7 10
Page 3
TEl\?PORARY 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
counselin agencies for the county in which the propert-y 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 HEAIAP APPLICATION AS SOON AS POSSIBLE. IF YOU HA VE A MEETING
11'I TH A COUNSELING A GENCY WITHIN 33 DA }'S OF THE POSTAIARX DA TE OF THIS NOTICE
AND FILE AN APPLICATION WITH PHFA 11"ITHIN 30 DA }'S OF THAT MEETING, THEN THE
LENDER 141ILL BE TEMPORARILYPREVENTED FR0111 STARTINGA FORECLOSURE A GAINST
}'OUR PROPERT}; AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORAR31 STA}" OF
FORECLOSURE. "
}'OU HA VE THE RIGHT TO FILE A HE111AP APPLICATION EVEN BE}'OAID THESE TIME
PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FR0111 STARTING A
FORECLOSURE ACTION BUTIFYOUAPPLICATIONISEVENTUALLI'APPROVEDATANPTI,IIE
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 \vill 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
i
BANKRUPTCY. THE FOLLOWING PART OF THIS NOTICE IS FOR 1NFORAIATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
A DEBT.
i
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
Stasys, yn.Ac191.052710
Page 4
HOW TO CURE YOUR MORTGAGE DEFAULT Brin it up to
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 12 TUNBRIDGE LANE, CARLISLE, PA 17015
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 01/15/09 through 05/15/10)
17 payments at 5850.57 S 14
459
69
Late Charges ,
.
260
00
Partial Paid
Total amount of Delinquency .
406.86
S 14,312.83
Additionally, another total payment of $850.57 becomes due on June 15, 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 $14,312.83, PLUS ANY ADDITIONAL MONTHLY PAYMENTS AND ANY LATE
CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must
be made either b 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 ri hts to accelerate the
mortgage debt. This means that the entire outstanding balance of this debt will be considered due
immediately and you may lose the chance to pay the mortgage in monthly installments. If full
payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends
to instruct its attorneys to start legal action to foreclose upon your mortgage property.
Stasysz?n.Act91.052110
Pagc 5
1F 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 550.00. 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 550.00. 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 attorney's fees
OTHER LEWDER RE1o1EDIES - 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 u 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 any other requirement
under the mortgage. Curing your default in the manner set forth in this notice Nvill 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: Citizens Bank of Pennsylvania
Address: 10561 Telegraph Road. Glen, Allen, VA 23059
Phone Number: 804-627-4254
Fax Number: 804-627-5711
Contact Person: Cheryl D. Cox
E-Mail address: Cheryl D.Cox(Qr ccomortga e corn
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 D123'01- X may not (CHECK ONE) sell or
transfer your home to a buyer or transferee who \vill 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.
S1a5v52yn AC191 0527)0
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 ANTY 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
888.51 1.2227
Community Action Commission of Captial Region
1514 Deny Street
Harrisburg; PA 17104
717.232.9757
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PA Interfaith Community Programs 111c
40 E High Street
Gettysburg, PA 17325
717.334.1518
Stas\sz)m Act91 052710
Page 7
PHFA
211 North Front Street
Harrisburg, PA 171 10
717.780.3940
800.342.2397
Sincerely,
S1as\57vn.Act91 012
710
BY: '?? ?
LA -N BER -CHEER KARL.
LAK/jes
Fnclosu;c
Page 8
NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT
This communication is from a debt collector. This is
I s an attempt to collect a debt and any
nformation obtained will be used for that purpose.
2. 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.'
3. 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 0r j
by our of udgment will be mailed to you
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 Citizens Bank of Pennsylvania.
,'118SVS7yn. Act9] 052710
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ~~~
Sheriff ~~~w~titr ~~ ~ rutrb~r~~~~~ Q~ ~"{~ ~~T't :°'~n~r~TARY
Jody S Smith ~ r r, ~~ ~~p _ ~ ~~ z•
Chief Deputy ~ ~ ' 2 $
Richard W Stewart ~ ~`' `"
Solicitor caFF~~ cF .hE ~~~RiFF ~~ir''H'~~~v COUIVIY
~n+rvsnvan~a
Citizens Bank of Pennsylvania Case Number
vs. 2010-5048
Carl J. Stasyszyn
SHERIFF'S RETURN OF SERVICE
08/18/2010 02:31 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on August
18, 2010 at 1431 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Carl J. Stasyszyn, by making known unto himself personally, at 12 Tunbridge Lane,
Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him
personally the said true and correct copy of the same.
RONALD HOOVER, DEP
SHERIFF COST: $38.80
August 26, 2010
SO ANSWERS,
~~~~~
RON R ANDERSON, SHERIFF
(ci CountySuite SFenff. Teleosoft. Inc.
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.
CARL STASYSZYN
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 2010-5048
PRAECIPE TO ENTER DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter a judgment by default in the amount of $124,057.59, plus continuing interest
at the per diem rate of $17.58, from October 1, 2010, and costs of suit, in favor of Plaintiff,
Citizens Bank of Pennsylvania, ("Citizens"), and against Defendant, Carl Stasyszyn,
("Defendant"), for his 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 August 2, 2010, Citizens commenced this action by filing a Complaint in
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Mortgage Foreclosure with a Notice to Defend (collectively, the "Complaint"gait tl3a abc
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2. On August 18, 2010, service of the Complaint was made personally upon
Defendant, Carl Stasyszyn, by the Sheriff of Cumberland County at his address of 12 Tunbridge
Lane, Carlisle, PA 17015. 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 September 17, 2010, a Notice of Intention to Enter Judgment By Default was
served upon Defendant by both United States first class regular mail at 12 Tunbridge Lane,
Carlisle, PA 17015. 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 $124,057.59, plus per diem interest
at the rate of $17.58, from October 1, 2010, and costs of suit, which is calculated as follows:
Principal $ 107,125.87
Accrued interest
(through 09/30/10) 10,045.43
Accrued late charges 260.00
BPO/Appraisal 400.00
Title Reports 620.00
Attorneys fees 5,356.29
Attorneys costs 250.00
TOTAL REAL DEBT $ 124,057.59
7. The aforementioned sum is the amount demanded in the Complaint with interest
carried forward to September 30, 2010.
Stasyszyn.Judgnent.093010
WHEREFORE, Plaintiff, Citizens Bank of Pennsylvania, demands judgment in its favor
and against Defendant, Carl Stasyszyn, in the amount of $124,057.59, plus per diem interest of
$17.58, from October 1, 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:
en Ber c er Karl, Esquire
Attorneys f Plaintiff,
Citizens Bank of Pennsylvania
Date: Gi'30`~D
Stasyszyn.Judgment.093010
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
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
CARL STASYSZYN
Defendant.
NO.: 2010-5048
To: CARL STASYSZYN
Date of Notice: SEPTEMBER 17, 2010
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTI
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH TI
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAIN.
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YC
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DC
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
Stasyszyn. l OdayNotice.091710
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE 1
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY O
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:
auren Ber chler Karl, Esquire
Attorney for Plaintiff,
Citizens Bank of Pennsylvania
Stasyszyn. l OdayNoti ce.091710
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.
CARLSTASYSZYN
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 2010-5048
CERTIFICATION OF SERVICE OF
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
I, Lauren Berschler Karl, Esquire, hereby certify that on September 17, 2010, I served a
Notice of Intention to Enter Judgment By Default upon Defendant, Carl Stasyszyn, by United
States first class regular mail at 12 Tunbridge Lane, Carlisle, PA 17015.
By:
auren rschler Karl, Esquire
Attorney or Plaintiff
Citizens Bank of Pennsylvania
Stasyszyn.Judgnent.093010
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 COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY
v. NO.: 2010-5048
CARL STASYSZYN
Defendant.
------------------------------------------------------
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, Carl Stasyszyn, is 12 Tunbridge Lane, Carlisle, PA 17015.
By:
Lauren rschler Karl, Esquire
Attorney or Plaintiff
Citizens Bank of Pennsylvania
Stasyszyn.Judgment.093010
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.
CARLSTASYSZYN
Defendant.
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 2010-5048
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, Carl Stasyszyn, 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 D`l~` day
of ~~~h~,,i , 2010.
~~
(Notary P blic
;o~„~gNwEALTH OF PENNSYLVANIA
Ndarial Seal
~'~bba ~9~~ Plotary Fubllc
irhti of pi~burgh, Aliey~Y County
;+ly Carnmis5lon E~~'` Od. 1, 2013
Stasyszyn.Judgment.093010
EXHIBIT "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff c.4s~~~tr ni ~urr~Gc~~~,i~
Body S Smith ~ ,.
Chief Deputy ~''- `i
Richard W Stewart ~ = r
Solicitor ~~=1c~ ~G ~h: s+<>~RtFF
Citizens Bank of Pennsylvania
vs.
Carl J. Stasyszyn
Case Number
2010-5048
SHERIFF'S RETURN OF SERVECE
08/18/2010 02:31 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on August
18, 2010 at 1431 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Carl J. Stasyszyn, by making known unto himself personally, at 12 Tunbridge Lane,
Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him
personally the said true and correct copy of the same.
SHERIFF COST: $38.80
August 26, 2010
RONALD HOOVER, DEP Y
SO ANSWERS,
RON R ANDERSON, SHERIFF
ci GounirSuite Shenft, l ele~so`l, Ins
EXgIBIT
~~8~~
THE LAW OFFICES OF
LAUREN BERSCHLER KARL, LLC
Ibkarl(a)Ibkarllaw.com Park Building licensed in NJ and PA
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
412-232-0808
Fax: 412-232-0773
September l7, 2010
Carl Stasyszyn
12 Tu .abridge Road
Carlisle, PA 17015
Re: Citizens Bank of Pennsylvania v. Carl J. Stasyszyn
CCP Cumberland County, Court No.: 2010-5048
Dear Ms. Stasyszyn:
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,
;:~.~ . ~.c;.~
Lauren B schler Karl
LBK/
Enclosure
Stasyszyn.lOdayltr.091710
PROTHONOTARY
COURT OF COMMON PLEAS -CUMBERLAND COUNTY
CARLISLE, PA
DAVID D. BUELL
PROTHONOTARY
To: Carl Stasyszyn
12 Tunbridge Lane
Carlisle, PA 17015
CITIZENS BANK OF PENNSYLVANIA
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
CARL STASYSZYN
Defendant.
NO.: 2010-5048
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 ($124,057.59)
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.
Stasyszyn.Judgment.093010
~U-5-1D
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
CITIZENS BANK OF PENNSYLVANIA
Plaintiff,
V.
CARL STASYSZYN
Defendant.
? Confession Judgment
¦ Other - MORTGAGE FOREC LOSURE
File No. 2010-5048 Civil Term
Amount Due: $124,057.59, plus d
Interest: $4,289.52, from 10/1/10 -6 11-
(17.58/dax), ylus '
Atty's Comm: $0.00, plus
Costs: to be added ?? CO
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TO THE PROTHONOTARY OF THE SAID COURT: o
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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 pibperty of the defendant(s)
12 Tunbridge Lane
Carlisle, PA 17015
as more fully described in Exhibit "A" attached hereto.
Date: 116
S 9 a ' .r
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/If,00 ! aC'y
Signature:
Print Name:
Address:
Attorney for:
Telephone:
Supreme CoL
wi,tv 6J'4Ck& kO
Lauren Berschler Karl, Esquire
355 Fifth Avenue, Suite 400
Pittsburgh, PA 15222
Plaintiff
412-232-0808
in ID No.:88209
a-a 00 kk(- Co.
ALL THAT CERTAIN lot or parcel of ground situate in South Middleton Township,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described
in accordance with Revised Final Plan-Phase 1 Greenfield Residential Development prepared by
Melham Associates, P.C. dated August 4, 1989, last revised December 17, 1990 and recorded in
Cumberland County Plan Book 62, Page 8, as follows, to wit:
BEGINNING at a point on the northern right-of-way line of Tunbridge Lane (24.00 feet wide),
said point being on the dividing line between Lot No. 103 and Lot No. 104 on the above-
referenced plan; thence continuing along the said right-of-way line by a curve to the left having a
radius of 112.00 feet, the chord bearing of which is North 84 degrees 37 minutes 26 seconds
West, an arc distance of 29.92 feet to a point; thence continuing along same South 87 degrees 43
minutes 24 seconds West a distance of 6.23 feet to a point on the dividing line between Lot No.
104 and Lot No. 105 on the above-referenced plan; thence continuing along same North 02
degrees 10 minutes 40 seconds East a distance of 107.77 feet to a point on line of lands now or
formerly of Forest Meadow Associates; thence continuing along same South 89 degrees 12
minutes 06 seconds East a distance of 36.01 feet to a point on the dividing line between Lot No.
103 and Lot No. 104 on the above referenced-plan; thence continuing along same South 02
degrees 10 minutes 40 seconds West a distance of 109.82 feet to a point on the northern right-of-
way line of Tunbridge Lane, the point and place of BEGINNING.
BEING Lot No. 104 as shown on the above-referenced plan.
UNDER AND SUBJECT to Declaration of Covenants, Conditions and Restrictions Applicable
to Building Lots in "Greenfield" Phase One, Section 2 dated December 24, 1990 and record in
Cumberland County Miscellaneous Book 391, page 1034, as amended in Miscellaneous Book
435, page 1147.
ALSO UNDER AND SUBJECT, nevertheless, to all easements, restrictions, encumbrances and
other matters of record or that a physical inspection or survey of the premises would reveal.
BEING the same premises which Greenfield Court Limited Partnership, a Pennsylvania limited
liability partnership, record owner and Marbain, Inc., a Pennsylvania business corporation,
equitable owner, by Deed date March 11, 1993, and recorded with the Cumberland County
Recorder of Deeds on March 12, 1993, in Book E36, page 205, granted and conveyed unto Carl
J. Stasyszyn.
BEING COMMONLY KNOWN AS: 12 Tunbridge Lane, Carlisle, PA 17015
PARCEL NO. 40-24-0748-036
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.
CARL STASYSZYN
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 2010-5048
ACT 6 AND ACT 91 AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
SS.
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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. §1680.401c et seq. have been compli with.
la'Nw ? ILA ?wcw ICJ
Date L r n Bersc r Karl, Esquire
Swo and Sub cribed before me
this day of , 2010.
rVe k' 114 COMMONWEALTH OF PENNSYLVANIA
Notary Pu lic Votarlal Seal i
Abby Ferguson, NoLirv Public
City of Pittsburgh, Allr ghee,,, County I
Ply Commission Expires C)) t. z, 2013 _1
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
------------------------------------------------------ C")
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CITIZENS BANK OF PENNSYLVANIA -a'
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------------------------------------------------------ -•; a
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 12 Tunbridge Lane, Carlisle, PA 17015, 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
Carl Stasyszyn 12 Tunbridge Lane
Carlisle, PA 17015
2. Name and address of Defendant(s) in the judgment:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Carl Stasyszyn 12 Tunbridge Lane
Carlisle, PA 17015
3. Name and last known address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
4.
5.
6.
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
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
Domestic Relations Section
of Cumberland County
Health & Welfare Building
P.O. Box 2675
Harrisburg, PA 17105
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)
None.
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.
Ni 0 - ?UJIW
DDate' F n Berschl r Karl, Esquire
Sworn, to and Subscribed before me
this day of 6lJiJ(`II MV 11 32010.
Notary Public
?OMNi014YYVi"AL"I'li OF PENNSYLVANIA 9
Notarial Seal Public
Abby Ferguson, Notary
L City of Pittsburgh, Allegheny 1 u 20
3
I City [xpires Oct.
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.
CARL STASYSZYN
Defendant.
NO.: 2010-5048
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
TO THE DEFENDANT: CARL J. STASYSZYN
DATE OF SALE: JUNE 1, 2011 AT 10:00 A.M.
PROPERTY TO BE SOLD: 12 TUNBRIDGE LANE, CARLISLE, PA 17015
PLACE OF SALE: CUMBERLAND COUNTY COURTHOUSE,
1 COURTHOUSE SQUARE, CARLISLE, PA 17013
To prevent this Sheriff's Sale, you must take immediate action:
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I . The sale will be canceled if you pay to Citizens Bank of Pennsylvania the sum of
$124,057.59 plus interest and costs. To find out how much you must pay, you may
call Lauren Berschler Karl, Esquire at (412) 232-0808.
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 riot 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 parcel of ground situate in South Middleton Township,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described
in accordance with Revised Final Plan-Phase 1 Greenfield Residential Development prepared by
Melham Associates, P.C. dated August 4, 1989, last revised December 17, 1990 and recorded in
Cumberland County Plan Book 62, Page 8, as follows, to wit:
BEGINNING at a point on the northern right-of-way line of Tunbridge Lane (24.00 feet wide),
said point being on the dividing line between Lot No. 103 and Lot No. 104 on the above-
referenced plan; thence continuing along the said right-of-way line by a curve to the left having a
radius of 112.00 feet, the chord bearing of which is North 84 degrees 37 minutes 26 seconds
West, an arc distance of 29.92 feet to a point; thence continuing along same South 87 degrees 43
minutes 24 seconds West a distance of 6.23 feet to a point on the dividing line between Lot No.
104 and Lot No. 105 on the above-referenced plan; thence continuing along same North 02
degrees 10 minutes 40 seconds East a distance of 107.77 feet to a point on line of lands now or
formerly of Forest Meadow Associates; thence continuing along same South 89 degrees 12
minutes 06 seconds East a distance of 36.01 feet to a point on the dividing line between Lot No.
103 and Lot No. 104 on the above referenced-plan; thence continuing along same South 02
degrees 10 minutes 40 seconds West a distance of 109.82 feet to a point on the northern right-of-
way line of Tunbridge Lane, the point and place of BEGINNING.
BEING Lot No. 104 as shown on the above-referenced plan.
UNDER AND SUBJECT to Declaration of Covenants, Conditions and Restrictions Applicable
to Building Lots in "Greenfield" Phase One, Section 2 dated December 24, 1990 and record in
Cumberland County Miscellaneous Book 391, page 1034, as amended in Miscellaneous Book
435, page 1147.
ALSO UNDER AND SUBJECT, nevertheless, to all easements, restrictions, encumbrances and
other matters of record or that a physical inspection or survey of the premises would reveal.
BEING the same premises which Greenfield Court Limited Partnership, a Pennsylvania limited
liability partnership, record owner and Marbain, Inc., a Pennsylvania business corporation,
equitable owner, by Deed date March 11, 1993, and recorded with the Cumberland County
Recorder of Deeds on March 12, 1993, in Book E36, page 205, granted and conveyed unto Carl
J. Stasyszyn.
BEING COMMONLY KNOWN AS: 12 Tunbridge Lane, Carlisle, PA 17015
PARCEL NO. 40-24-0748-036
EXHIBIT "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-5048 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 CARL STASYSZYN
(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$124,057.59
L.L.$.50
Interest $4,289.52 FROM 10/1/10 - 6/1/11 (17.58/DAY)
Atty's Comm % Due Prothy $2.00
Atty Paid $171.30
Other Costs TO BE ADDED
Plaintiff Paid
Date: DECEMBER 8, 2010
(Seal)
REQUESTING PARTY:
Deputy
Name Lauren Berschler Karl, Esq.
Address: The Law Offices of Lauren Berschler Karl, LLC., Park Building, 355 Fifth Avenue, Suite
400, Pittsburgh, PA 15222
Attorney for: Plaintiff
Telephone: 412-232-0773
Supreme Court ID No. 88209
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
,A?
r r' i
Richard W Stewart
Solicitor
0F91E ',F,. -"F€
{LELi
,NIA
Citizens Bank of Pennsylvania
vs.
Carl J. Stasyszyn
Case Number
2010-5048
SHERIFF'S RETURN OF SERVICE
03/1112011 03:07 PM - Deputy Tim Black, being duly sworn according to law, states service was performed by postinc
a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the
property located at 12 Turnbridge Lane, Carlisle, PA 17015, Cumberland County.
03/30/2011 Brian Barrick, Deputy Sheriff, being duly sworn according to law, served the requested Real Estate Writ,
Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Carl J.
Stasyszyn at the Cumberland County Sheriffs Office, 1 Courthouse Square, Carlisle, PA, Cumberland
County.
06/01/2011 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 June 1, 2011 at 10:00 a.m. He sold the same for the
sum of $ 1.00 to Atty Lauren Berschler Karl, on behalf of, Citizens Bank of Pennsylvania, 10 Tripps Lane,
Riverside, RI 02915, being the buyer in this execution, paid to the Sheriff the sum of $
SHERIFF COST: $1,150.17 SO ANSWERS,
June 23, 2011 RON R ANDERSON, SHERIFF
fel
d
ic; Count,SIrte Sherd. Teleoaoff. In;;
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.
CARL STASYSZYN
Defendant.
NO.: 2010-5048
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 12 Tunbridge Lane, Carlisle, PA 17015, 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
Carl Stasyszyn 12 Tunbridge Lane
Carlisle. PA 17015
2. Name and address of Defendant(s) in the judgment:
Name Address (if address cannot be
reasonably ascertained,
please so indicate)
Carl Stasyszyn 12 Tunbridge Lane
Carlisle. PA 17015
11
4
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 1735 Market Street
Philadelphia, PA 19103
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
PA Dept. of Public Welfare-
Bureau of Child Support
Domestic Relations Section
of Cumberland County
Address (if address cannot be
reasonably ascertained,
please so indicate)
Health & Welfare Building
P.O. Box 2675
Harrisburg, PA 17105
13 North Hanover Street
Carlisle, PA 17013
7. 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)
None.
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.
Date' ll n Berschl r Karl, Esquire
Sworn to and Subscribed before me
this day of 2010.
?/7
Notary Public
- ,!otariai seal
Abut' Ferguson, Notary Public
i City of PIMOUrch, Allegheny Coun 3 I
L -n Commission Cxpires O t. __ _. _
ALL THAT CERTAIN lot or parcel of ground situate in South Middleton Township,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described
in accordance with Revised Final Plan-Phase I Greenfield Residential Development prepared by
Melham Associates, P.C. dated August 4, 1989, last revised December 17, 1990 and recorded in
Cumberland County Plan Book 62, Page 8, as follows, to wit:
BEGINNING at a point on the northern right-of-way line of Tunbridge Lane (24.00 feet wide),
said point being on the dividing line between Lot No. 103 and Lot No. 104 on the above-
referenced plan; thence continuing along the said right-of-way line by a curve to the left having a
radius of l l 2.00 feet, the chord bearing of which is North 84 degrees 37 minutes 26 seconds
West, an arc distance of 29.92 feet to a point; thence continuing along same South 87 degrees 43
minutes 24 seconds West a distance of 6.23 feet to a point on the dividing line between Lot No.
104 and Lot No. 105 on the above-referenced plan; thence continuing along same North 02
degrees 10 minutes 40 seconds East a distance of 107.77 feet to a point on line of lands now or
formerly of Forest Meadow Associates; thence continuing along same South 89 degrees 12
minutes 06 seconds East a distance of 36.01 feet to a point on the dividing line between Lot No.
103 and Lot No. 104 on the above referenced-plan; thence continuing along same South 02
degrees 10 minutes 40 seconds West a distance of 109.82 feet to a point on the northern right-of-
way line of Tunbridge Lane, the point and place of BEGINNING.
BEING Lot No. 104 as shown on the above-referenced plan.
UNDER AND SUBJECT to Declaration of Covenants, Conditions and Restrictions Applicable
to Building Lots in "Greenfield" Phase One, Section 2 dated December 24, 1990 and record in
Cumberland County Miscellaneous Book 391, page 1034, as amended in Miscellaneous Book
435, page 1147.
ALSO UNDER AND SUBJECT, nevertheless, to all easements, restrictions, encumbrances and
other matters of record or that a physical inspection or survey of the premises would reveal.
BEING the same premises which Greenfield Court Limited Partnership, a Pennsylvania limited
liability partnership, record owner and Marbain, Inc., a Pennsylvania business corporation,
equitable owner, by Deed date March 11, 1993, and recorded with the Cumberland County
Recorder of Deeds on March 12, 1993, in Book E36, page 205, granted and conveyed unto Carl
J. Stasyszyn.
BEING COMMONLY KNOWN AS: 12 Tunbridge Lane, Carlisle, PA 17015
PARCEL NO. 40-24-0748-036
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.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
V.
CARL STASYSZYN
Defendant.
NO.: 2010-5048
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
TO THE DEFENDANT: CARL J. STASYSZYN
DATE OF SALE: JUNE 1, 2011 AT 10:00 A.M.
PROPERTY TO BE SOLD: 12 TUNBRIDGE LANE, CARLISLE, PA 17015
PLACE OF SALE: CUMBERLAND COUNTY COURTHOUSE,
I COURTHOUSE SQUARE, CARLISLE, PA 17013
To prevent this Sheriffs Sale, you must take immediate action:
The sale will be canceled if you pay to Citizens Bank of Pennsylvania the sum of
$124,057.59 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.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale (See notice on page two 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.
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 riot 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 parcel of ground situate in South Middleton Township,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described
in accordance with Revised Final Plan-Phase 1 Greenfield Residential Development prepared by
Melham Associates, P.C. dated August 4, 1989, last revised December 17, 1990 and recorded in
Cumberland County Plan Book 62, Page 8, as follows, to wit:
BEGINNING at a point on the northern right-of-way line of Tunbridge Lane (24.00 feet wide),
said point being on the dividing line between Lot No. 103 and Lot No. 104 on the above-
referenced plan; thence continuing along the said right-of-way line by a curve to the left having a
radius of 112.00 feet, the chord bearing of which is North 84 degrees 37 minutes 26 seconds
West, an arc distance of 29.92 feet to a point; thence continuing along same South 87 degrees 43
minutes 24 seconds West a distance of 6.23 feet to a point on the dividing line between Lot No.
104 and Lot No. 105 on the above-referenced plan; thence continuing along same North 02
degrees 10 minutes 40 seconds East a distance of 107.77 feet to a point on line of lands now or
formerly of Forest Meadow Associates; thence continuing along same South 89 degrees 12
minutes 06 seconds East a distance of 36.01 feet to a point on the dividing line between Lot No.
103 and Lot No. 104 on the above referenced-plan; thence continuing along same South 02
degrees 10 minutes 40 seconds West a distance of 109.82 feet to a point on the northern right-of-
way line of Tunbridge Lane, the point and place of BEGINNING.
BEING Lot No. 104 as shown on the above-referenced plan.
UNDER AND SUBJECT to Declaration of Covenants, Conditions and Restrictions Applicable
to Building Lots in "Greenfield" Phase One, Section 2 dated December 24, 1990 and record in
Cumberland County Miscellaneous Book 391, page 1034, as amended in Miscellaneous Book
435, page 1147.
ALSO UNDER AND SUBJECT, nevertheless, to all easements, restrictions, encumbrances and
other matters of record or that a physical inspection or survey of the premises would reveal.
BEING the same premises which Greenfield Court Limited Partnership, a Pennsylvania limited
liability partnership, record owner and Marbain, Inc., a Pennsylvania business corporation,
equitable owner, by Deed date March 11, 1993, and recorded with the Cumberland County
Recorder of Deeds on March 12, 1993, in Book E36, page 205, granted and conveyed unto Carl
J. Stasyszyn.
BEING COMMONLY KNOWN AS: 12 'Tunbridge Lane, Carlisle, PA 17015
PARCEL NO. 40-24-0748-036
EXHIBIT "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-5048 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 CARL STASYSZYN
(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$124,057.59
L.L.$.50
Interest $4,289.52 FROM 10/1/10 - 6/1/11 (17.58/DAY)
Atty's Comm % Due Prothy $2.00
Arty Paid $171.30
Plaintiff Paid
Date: DECEMBER 8, 2010
(Seal)
REQUESTING PARTY:
Other Costs TO BE ADDED
Dav . ue , Protho otary
By:
Deputy
Name Lauren Berschler Karl, Esq.
Address: The Law Offices of Lauren Berschler Karl, LLC., Park Building, 355 Fifth Avenue, Suite
400, Pittsburgh, PA 15222
Attorney for: Plaintiff
Telephone: 412-232-0773
Supreme Court ID No. 88209
,RtM CO" MQM RECORD
In 1 i? unto set my hand
ofad frsirlisie;Ra.
WWI , 1
dad; '• r?-??' 2C ..
Lt
On March 3, 2011 the Sheriff levied upon the
defendant's interest in the real property situated in
South Middleton Township, Cumberland County, PA,
Known and numbered as, 12 Turnbridge Lane,
Carlisle, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: March 3, 2011
By:
Real Estate Coordinator
V,01 -3N OLI
CUMBERLAND LAW JOURNAL
Writ No. 2010-5048 Civil
Citizens Bank of Pennsylvania
VS.
Carl J. Stasyszyn
Atty.: Lauren Berschler Karl
ALL THAT CERTAIN lot or parcel
of ground situate in South Middle-
ton Township, Cumberland County,
Commonwealth of Pennsylvania,
more particularly bounded and
described in accordance with Re-
vised Final Plan-Phase 1 Greenfield
Residential Development prepared by
Melham Associates, P.C. dated Au-
gust 4, 1989, last revised December
17, 1990 and recorded in Cumber-
land County Plan Book 62, Page 8,
as follows, to wit:
BEGINNING at a point on the
northern right-of-way line of Tun-
bridge Lane (24.00 feet wide), said
point being on the dividing line
between Lot No. 103 and Lot No.
104 on the above-referenced plan;
thence continuing along the said
right-of-way line by a curve to the
left having a radius of 112.00 feet,
the chord bearing of which is North
84 degrees 37 minutes 26 seconds
West, an arc distance of 29.92 feet
to a point; thence continuing along
same South 87 degrees 43 minutes
24 seconds West a distance of 6.23
feet to a point on the dividing line
between Lot No. 104 and Lot No. 105
on the above-referenced plan; thence
continuing along same North 02 de-
grees 10 minutes 40 seconds East a
distance of 107.77 feet to a point on
line of lands now or formerly of Forest
Meadow Associates; thence continu-
ing along same South 89 degrees 12
minutes 06 seconds East a distance
of 36.01 feet to a point on the dividing
line between Lot No. 103 and Lot No.
104 on the above referenced-plan;
thence continuing along same South
02 degrees 10 minutes 40 seconds
West a distance of 109.82 feet to a
point on the northern right-of-way
line of Tunbridge Lane, the point and
place of BEGINNING.
BEING Lot No. 104 as shown on
the above-referenced plan.
UNDER AND SUBJECT to Decla-
ration of Covenants, Conditions and
Restrictions Applicable to Building
Lots in "Greenfield" Phase One,
Section 2 dated December 24, 1990
and record in Cumberland County
Miscellaneous Book 391, page 1034,
as amended in Miscellaneous Book
435, page 1147.
ALSO UNDER AND SUBJECT,
nevertheless, to all easements, re-
strictions, encumbrances and other
matters of record or that a physical
inspection or survey of the premises
would reveal.
BEING the same premises which
Greenfield Court Limited Partner-
ship, a Pennsylvania limited liability
partnership, record owner and Mar-
bain, Inc., a Pennsylvania business
corporation, equitable owner, by
Deed date March 11, 1993, and re-
corded with the Cumberland County
Recorder of Deeds on March 12,
1993, in Book E36, page 205, granted
and conveyed unto Carl J. Stasyszyn.
BEING COMMONLY KNOWN
AS: 12 Tunbridge Lane, Carlisle, PA
17015.
PARCEL NO. 40-24-0748-036.
76
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
April 22, April 29, and May 6, 2011
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.
U Lisa Marie Coyne, ditor
SWORN TO AND SUBSCRIBED before me this
da of Ma 2011
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My COMMISSion Expires Apr 28, 2014
The Patriot-News Co.
~2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-:255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
ZhePatriot 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 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-!News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; cnd
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
04/22/11
04/29/11
05/06/11
Sworn to and s?i:rbscribed befbre_?e this 23 clay of May, 2011 A. D_
- i
Notary Public
COMMONWEALTH OF PENNSYLVANIA
J - Notarial Seal
I Sherrie L Klsner, Notary Public
L lower Paxton Temp., Dauphln County
My Commisslon Expires Nov. 26, 201:!
Member, Pennsylvania Association of Natarie?
20104*a GvH Term
CWZWW Bw* of POMWOnnia
1!a
Carl J. StaaysZyn
AW. Lauren 136?r Karl
ALL THAT CERTAIN lot or, parcel
of ground situate in South Middleton
Township, Cumberland County,
Commonwealth of Pennsylvania, more
particularly bounded and described in
accordance with Revised Final Plan-Phase
1 Greenfield Residential Development
Prepared by Melham Associates, P.C. dated
August 4, 1989, IAt revised December 17,
1990 and recorded in Cumberland County
Plan Book 62, Page 8, as follows, to wit:
BEGINNING at a point on t1f3 northern
right-of-way line of Tunbridge Lane
(24.00 feet wide), said point being on the
dividing line between Lot No. 103 and Lot
No. 104 on the above-referenced plan;
thence continuing along the said right-
of-way line by a curve to the left having a
radius of 112.00 feet, the chord bearing of
which is North 84 degrees 37 minutes 26
seconds West, an arc distance of 29.92 feet
to a point; thence continuing along same
South 87 degrees 43 minutes 24 seconds
West a distance of 6.23 feet to a point on
the dividing line between Lot No. 104
and Lot No. 105 on the above-referenced
plan; thence continuing along same North
02 degrees 10 minutes 40 seconds East a
distance of 107.77 feet to a point on line of
lands now or formerly of Forest Meadow
Associates; thence continuing along same
South 89 degrees 12 minutes 06 seconds
East a distance of 36.01 feet to a point
on the dividing line between Lot No, 103
and Lot No. 104 on the above referenced-
plan; thence continuing along same South
02 degrees 10 minutes 40 seconds West
a distance of 109.82 feet to a point on the
northern rightof-Way line of llOridge
Lane, the point and place of BEGINNING.
BEING Lot No. 104 as shown
on the above-referenced plan.
UNDER AND SUBJECT to
Declaration of Covenants, Conditions
and Restrictions Applicable to Building
Lots in "Greenfield" Phase One, Section
2 dated December 24, 1990 and record
in Cumberland County Miscellaneous
Book 391, page 1034, as amended in
Miscellaneous Bbok 435, page 1147.
ALSO UNDER AND SUBJECT;
nevertheless, to all easements, restrictions,
encumbrances and other matters of
record or that a physical inspection or
survey of the premises would,, reveal
BEIN esame premises which arez?Meld
Court led Parts ?h
limited ility partneemrshrp,arecod owner
and Marbain, Inc., a Pennsylvania business
corporation, equitable owner, by Deed
date March 11, 3993, and recorded with the
Cumberland County Recorder of Deeds
on March 12,1993, in Book E36, page 205,
g'anW And conveyed unto Carl J. Stasysgn.
BEING COMMONLY KNOWN AS:
12 ? Lam, Carlisle, PA 17015
PARCEL N0. 40.2W48-036
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
I 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 Pennsylvania is the grantee the same having been sold to
said grantee on the 1 day of June A.D., 2011, under and by virtue of a writ Execution issued on the 8 day
of December, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2010
Number 5048, at the suit of Citizens Bank of Penns lyaania against Carl Stasyszm is duly recorded as
Instrument Number 201117748.
IN TESTIMONY WHEREOF, I have hereunto set my hand
4/
day of
and seal of said office this 7
A.D. c7 O
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