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Home My WebLink About01-1489STATE OF PI~NNSYLVANIA, C_~UNTY OF CUMBERLAND Robert: P Ziegler I, .............................................................................. Recorder of Deeds in und for said County and State do'hereby certify that the Sheriff's Deed in which ................ Altegra Credit Co .................................................................................... ~s the grantee the same having been sold to said grantee on the ..... _~_~__h ...................................... day of Dec 01 ........................................ A. D., 7 ..... , under and by virtue of a writ gxecut ion 11 th ................................................ i~ued on thc ..................................... 01 day of ..... ~J-u.l-Y ................ A.D., ..... ~ out of the Court of Comman Plea~ o[ said County'a~ of 1489 Altegra Credit Co Nmnher .............. , at the suit of ............................................................... Seannet ta Rudy ................................... against .................................................... 249 4820 duly recorded in SherifCs Deed Book No ............. , Page IN TESTIMONY WHEREOF, I have hereunto set my~mld and sea] of said office th~s ___/_/__.~_.__ day o, ....... = ...... Altegra Credit Company In The Court of Common Pleas of VS Cumberland County, Pennsylvania Jeannetta Rudy Writ No. 2001-1489 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made diligent search and inquiry for the within named defendant, to wit: Jeannetta Rudy, but was unable to locate her in his bailiwick. He therefore deputized the sheriff of Perry County, Pennsylvania, to served the within Real Estate Writ, Notice and Description, according to law. Perry County Return: Now, September 12, 2001 at 2:50 o'clock P.M., served the within Real Estate Writ, Notice and Description upon Jeanette Rudy, at 12-B Pfautz Rd., Penn Township, Duncannon, PA 17020 by handing to Jeanette Rudy a tree and attested copy of the original Writ, Notice and Description and made known to her the contents thereof. So Answers: James C. Wilson, Deputy Sheriff of Perry County, Pennsylvania. Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 28, 2001 at 3:45 o'clock P.M., E.D.S.T., he posted a tree copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jeannetta Rudy, located at 515 Herman Ave., Lemoyne, PA, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Jeannetta Rudy, by regular mail to her last known address of 13 B Pfautz Rd., Duncannon, PA 17020. This letter was mailed under the date of October 2, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 5, 2001 at 10:00 A.M., EST. He sold the same for the sum orS1.00 to Attorney Richard Stem for Altegra Credit Company. It being the highest bid and best price received for the same, Altegra Credit Company of 150 Allegheny Center, Pittsburgh, PA 15212, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $649.51, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 12.74 Advertising 15.00 Posting Bills 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Out of County 9.00 Perry County 30.35 Mileage 10.40 Certified Mail 4.56 Levy 15.00 Surcharge 20.00 Postpone Sale Law Journal 218.90 Patriot News 188.25 Share of Bills 25.66 Distribution of Proceeds 25.00 Sheriff's Deed 27.50 $688.86 Sworn and subscribed to before me So Answe~rs: ~,~ ,/~ This/~t~ dayof~ ~~ R. Thomas Kline, Sheriff vPfothonotary Real Estffte Deputy COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 ALTEGRA CREDIT COMPANY VS. NO. 01-1489 CIVIL JEANNETTA RUDY AFFIDAVIT PURSUANT TO RULE 3129.1 RICHARD F. STERN, attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 515 HERMAN AVE., LEMOYNE, PA 17043. 1. Name and address of Owner(s) or Reputed Owner(s): Jeannetta Rudy 13 B Pfautz Road Duncannon, PA 17020 2. Name av~ addres: ef Defendant(s) in the judgment: Jeannetta Rudy 13 B Pfautz Road Duncannon, PA 17020 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: N/A 4. Name and address of the last recorded holder of every mortgage of record: Farmers Trust Co. P.O. Box 220 Carlisle, PA 17013 AVCO Financial Services, CDC 3542 Gettysburg Pk. Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: N/A 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: N/A 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Commonwealth of Pa. Inheritance Tax Division 1400 Spring Garden Street Phila., PA Internal Revenue Service Federated Investors Tower 13~ Fl., Ste. 1300 1001 Liberty Ave. Pittsburgh, P3 1 q222 Tax Claim Bureau Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Occupant 515 Herman Ave. Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: 5/30/01 STERN AND STERCHO ~cH~A~ F. STERN, Attorney for Plaintiff L~GAL DESCRIPTION A ~.L THAT CERTAIN piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland and Stat~ of Pennsylvania, more particularly bounded and described as follows, to wit: BEING western section of Lot No. 41, Section 'D~ in a Plan of Lots known as Plan No. 1 Riverton, Pennsylv~; said plan being r~corded in the Recorder's Office in ~d for Cumberland County, Pennsylvan~al Carlisle, pennsylvania, inDeed Book 'I', Volumn4, Page40. Thc said western section of lot starting at a point on the northern line of Herman Avenue in the center of Lot No. 41 and thence through the center walls or partitions of double house known as $13-$15 Herman Avenue on a parallel. line with Fifth Street, formerly known as Clinton Street, one hundred fif/y (150) feet to the southern line' of Peach Alley; thence westwarclly seventeen feet six inches (17'6 '), thence sou~wardly one hundred fifty (150) feet to northern line of Herman Avenue; thence eastwardly seventeen feet and six inches (17'6") to point of BEGINNING. ERECTED THEREON dwelling house No. :~15 Herman Avenue. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 ALTEGRA CREDIT COMPANY : VS. : NO. 01-1489 CIVIL JEANNETTA RUDY : NOTICE OF SItERIFY'S SALE OF REAL PROPERTY TO: JEANNETTA RUDY 13 B PFAUTZ ROAD DUNCANNON, PA 17020 Your real estate at 515 HERMAN AVE., LEMOYNE, PA 17043 is scheduled to be sold at Sheriff's Sale on DECEMBER 5, 2001 at 10:00 A.M., in the Cumberland County Cour~ouse, Carlisle, PA, to enforce the court judgment of $51,505.43 obtained by Altegra Credit Company against you. NOTICE OF OWNER'S RIGItTS YOU MAY BE ABLE TO PREVENT THIS sHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: I. The sale will be cancelled if you pay to Stern and Stercho thc back payments, late charges, costs and reasonable attorney's fees due. To f'me out how much you must pay, you may call Stem and Stercho, telephone (215) 572-8111. 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 on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may fred out the price bid by calling Stern and Stercho, telephone (215) 572-811 i. 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 mount due in the sale. To fred out if this has happened you may call Stern and Stercho, telephone (215) 572-8111. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date. 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 date of filing of said schedule. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house 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. LAWYER REFERENCE SERVICE COURT ADMINISTRATION CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 L~GA.L DESCRIPTION ~i ,IJ THAT CEI~TAIH piece or parcel of land situate in ~e Borou~ of L~, Co~ of C~erl~ ~ S~ of P~n~lv~a, more p~ly bo~ed ~d desc~bed ~ follows, ~ wk: BErG wea~ s~on of Lot No. 41, S~on 'D' ~ a P~ of Lo~ ~ as ~ No. 1 ~v~on. Pe~ylv~; said pl~ berg reco~ ~ ~e R~or~'s Office ~ ~na for ~berl~ Co~, Pe~ylv~i'~;al C~le, Pe~ylv~, ~ De~ Book "l', Vol~ 4, Page 40. ~e said wesmm section of lot s~ at a po~ on ~e no.em ~e of He~ Ave~e ~ ~e cen~r of Lot No. 41 ~ou~ ~e ce~r w~s or p~o~ of double ho~e ~o~ as ~13-~1~ He~ Av~e on a p~Bel. ~ wi~ Fi~ S~t. fo~erly ~o~ ~ Cllnton S~eet, one ~ f~ (l J0) f~t to of Peach ~ey; ~ westbay seve~en f~t s~ ~cMs (17'6"), ~ence sou~w~dly one ~d (lJ0) f~t to no.em 1~ of H~n Avenue; ~ence e~dly seventh feet ~d s~ ~c~s (17'6") to po~ of BEG~G. ~C~D ~ON dweH~g ho~e No. ~lJ He~ Avenue. _,,~::,'.. ... .. ., ......,,.. . .... :: . : ....,.. . ..,. :,.. ~...:,.. ,,~ .. ,,-... ~:.,'~,-, ....... . ........ .. ~ ,, ..... .. y ....:.. ,,.. . ....... -..., .. :,' .~..' ~ .?.. ,..~ .... . ..... . PLAINTIFF'S ~ EXHIBIT WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-1489 _ CIVIL 1~ TEI~i COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF _ . Cumber!.~a~q~ ..... COUNTY To satisfy the debt, interest and costs due A].tegra Cz'~:]it Ccrrrpany PLAINTIFF(S) fromJeanetta Rudy, 515 Herman Ave., Lemoyne, PA 17043 DEFENDANT(S) (1) YOU are directed to levy upon the properly of the defendant(s) and to sell__ See Legal Descriptions (2) You are also directed Io 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/are 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 t ban a named garnishee, you are directed to notify him/ber that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $51,505.43 L.L. $.50 from date of judgment at the per di6m nterest z~te of $ $10.14 Due Prothy $1.00 Atty's Comm_ __% Other Costs Atty Paid ~ Plaintiff Paid Date: ..... ~3.u.~t.~.~_.Q01 ........ Curtis R. Long Prothonotary, Civil Division Deputy REQUESTING PARTY: Name .... R~cha_--d F ._~_ S~e:rn~, ~.~Cr_o . Address: _4~.0 __~ae AHorney for: Telephone: _ Supreme Cou~ ID No. 03315 REAL ESTATE SALE No. F un ~/'),i. ~'0 / ~0 1 tl~esneriflleviedu~m~e(lmen~m~ interest in the r~l pr~ situated in Cum~rland Count, Pa., known and num~md as: ./~/~ ~ ~ ~ and more fully described on ~hibll "A" fll~ with this writ and by this reference incorporated ~min, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of thc County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 12, 19, 26, 2001 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. Writ No. 2001-1489 Clvll al, Editor~" Altegra Credit Company vs. SWORN TO AND SUBSCRIBED before me this deannetta Rudy 26 day of OCTOBER. 2001 Atty.: Richard F. Stern EXHIBIT A ALL THAT CERTAIN piece or ~_ parcel of land situate in the Bor- Nnt~W ough of Lemoyne, County of Cum- berland, and State of Pennsylvania. IqOTAR~.AL $~:J~l- more particularly bounded and de- [.O~S 5, S}'~, ~!t)~3~' ~Ubl~0 scra~d as follows, to vdt: t,o~i~*.t~ ~:,~r~, C~:~;~g [~} C,~Z~ BEING westem secaon of Lot No. My ~ ~ ~ 5, 2005 41, Section "D" In a Plan of Lots known as Plan No. 1 Rlverton, Perm- sylvania, saJd plan belng recorded in the Recorder's Office in and for Qttmberland County, Pensylvanla, at THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Jamea L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of October and the 6th day(s) of November 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he 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 Mis. pellaneous Book "M", Volume 14, Page 317. PUBLICATION V.~ COPY swoin to and subscno~'fu,= .... II,i~,19th daY/of I~ber 2001 A D REAL ~AI'~ ~ NO, $ ~ My C-4Xt~liSSio~ Expires June 6, Idem~, Penna~van~a Assooation ~ ~ ~y commission expires June 6, 2002 A~: R~ F,~ OUMBER~ND COU~ SHERI~S OFF~E D~O~ ~ CUMBERED ~U~ COU~SE ~i~of~,_ CARLISLE, PA. 17013 I wit: Statement of Advertising Costs ,~ ,~ a ~ ~ ~ No, I ToTHE PATRIOT-NEWS CO., Dr. ~,~y~;~ For publishing the notice or publication attached ~, ~ ~, ~ hereto on the above stated dates $ 186.75 in~ ~,~4,~.~d Probating same Nota~ Fee(s) $ 1.50 Total $ 188.25 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQ. STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 215-572-8111 I.D. #03315 ALTEGRA CREDIT COMPANY 116 Allegheny Center Pittsburgh, PA 15212 VS. No. JEANNETTA RUDY 515 Herman Avenue Lemoyne, PA 17043 CIVIL ACTION- MORTGAGE FORECLOSURE This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Civil Action or for any other claim or relief requested by the plaintiff. You may lose money or property of other rights important to you. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 1-800-990-9108 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQ. STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 215-572-8111 I.D. #03315 ALTEGRA CREDIT COMPANY 116 Allegheny Center Pittsburgh, PA 15212 VS. NO. JEANNETTA RUDY 515 Herman Avenue Lemoyne, PA 17043 CIVIL ACTION- MORTGAGE FORECLOSURE 1. Plaintiff is Altegra Credit Company, with registered offices located at 116 Allegheny Center, Pittsburgh, PA 15212. 2. Defendant is JEANNETTA RUDY, individuals residing at 61 Village Court, Mechanicsburg, PA 17055. 3. Under date of July 19, 1996, Defendant and WALTER RUDY executed and delivered to American Mortgage Reduction, Inc. a mortgage upon the premises 515 Herman Avenue, Lemoyne, PA 17043 to secure the payment of the sum of $48,825.00. The said mortgage is recorded in the Department of Records in and for the County of CUMBERLAND in Mortgage Book 1335, page 723, and is incorporated herein by reference. A copy of the legal description of the premises is attached hereto and made a part hereof as Exhibit "A". 4. By Assigmnent dated July 19, 1996, the said mortgage was assigned to ALTEGRA CREDIT COMPANY. The said Assignment is recorded in the Office for the Recording of Deeds in and for CUMBERLAND County in Mortgage Book No. 527, page 516, recorded August 9, 1996, and is incorporated herein by reference. 5. And the said WALTER RUDY has since departed this life. 6. Defendant is the real owner of said premises. 7. In accordance with Section 403 of Act No. 6 of 1974, thirty days notice of intention to foreclose was sent by certified mail, return receipt requested. A copy of said notice is attached hereto as Exhibit "B". 8. In accordance with Act 91 of 1983, notice was sent to Defendant and no response was made in the appropriate period of time. A copy of said notice is attached hereto as Exhibit "C". 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. §1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. 10. The said loan is in default as a result of the failure to pay the monthly installments of $442.67 due on December 24, 1998, and on the 24th day of each month thereafter. 11. The following is due on the loan: PRINCIPAL BALANCE $35,100.00 INTEREST (accrued thru 2/26/01 at the per diem rate of 12,262.75 of $10.14. Interest shall continue to accrue at said per diem rate after 2/26/01 until judgment is paid in full.) LATE CHARGES (accrued thru 2/01 at the monthly late 420.47 of $22.13. Late charges after 2/01 shall accrue at the said monthly late fee.) OTHER FEES DUE 612.80 COSTS 300.00 ATTORNEY'S FEE 1,800.00 TOTAL $50,496.02 The attorney fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to Sale, reasonable attorney fees will be charged based on work actually performed. WHEREFORE, Plaintiff, ALTEGRA CREDIT COMPANY requests this Court to enter judgment for foreclosure of the mortgaged property for the sum of $50,496.02 plus interest thereon of $12,262.75 plus $10.14 per day from February 26, 2001, until judgment is paid in full, late charges of $420.47, plus late charges of $22.13 per month from February, 2001, until judgment is paid in full, fees of $612.80, costs of $300.00, attorney's fees of $1,800.00 and record costs. STERN A/~/STERCHO RICHARD F. STERN, Attorney for Plaintiff VERIFICATION KAREN FINNEGAN is the For~losare Specialist of ALTEORA CREDIT COMPANY, and is authorized to sign this Verification on behalf of same, and states that he verLfies the foregoing Civil Action against IEANNETTA RUDY anti avers the statements of fact therein contained are made subject to the penalties of 18 PA C.S. Section 4904 relating to the unsworn falsification to authorities, and that same axe true upon the signer's personal k~aowledge or information and belief. LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Lemoyne, Counv/of Cumberland and $~ate of Pennsylvania, more particularly bounded and described as follows, to wit: BEING western section of Lot No. 41, Section "D" in a Plan of Lots known as Plan No. I Rivc~on, Pennsylvania, said plan being recorded in the Recorder's Office in and for Cumberland County, Pennsylvania, at Carlisle, Pennsylvania, in Deed Book "~'", Volumn 4, Page 40. The said western section of lot starting at a point on the northern line of Herman Avenue in the center of Lot No. 41 and thence through the center walls or partitions of double house known as $13-$15 Herman Avenue on a parallel line with Fifth $~'eet, formerly known as Clinton Street, one hundred fifty (150) feet to the southern line of Peach Alley; thence westwardly seventeen feet six inches (17'6"), thence southwardly one hundred fif~ (150) feet to northern line of Herman Avenue; ~ence eastwardly seventeen feet and six inches (17'(~") to point of BEGINNING. ERECTED THEREON dwelling house No. 515 Herman Avenue. / ll 'O_'Credit Company Ptt'L~.burgh, PA I5230-1838 April 2, 1999 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Jeannette Rudy 61 Village Court Mechaniceburg, PA 17055 Dear Mrs. Rudy: The MORTGAGE held by ALTEGRA CREDIT COMPANY (hereinafter 'we', "us", or "ours') on your property located at 515 Herman Avenue, Lemoyne, PA 17043 is SERIOUS DEFAULT because you have not made the monthly payment of $442.67 for December, 1998, January, February, and March, 1999. Late charges (and other charges) have also accrued to this date in the amount of $88.52. Total amount n°w squired to cure this default, or in other words, to get caught Up on your payments, as of the date of this ieffer, is $1,859.20. You may cure the default wffifin thirty (30~ days of the date of this letter by pavirtg to us the above amount of $1,859.20 plus anv additional rnonthlv payments and late c~naroes which may fall due durina this pedod. Suoh payment must be made either by cash, cashier's check, certified check or money order and made payable to Altegra Credit Company, IDC 23-571,150 Allegheny Center Mall, Pittsburgh, PA 15212. If you do not cure the default within THIRTY (30) DAYS, we intend to exeroise our right to accelerate the mortgage payment. This means that whatever is owing on the original amount borrowed will be considered due Immediately and you may lose ~e chance to pay off the odginai mortgage in monthly installments. If full payment of the amount of default Is not made within THIRTY (30) DAYS, we also intend to instruct our attorney to ......... ._st~rt._._a ~ ..ws_u.~.t.9. fo.m. c!oee your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold [~y th& sh&riff th' pa~'off the r~6rtgn~ di~bt, If we refer your eaee to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal procaedlngs are started against you, you will have to pay the reasonable attorney's fees to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty (30) day Pen'od, you will not be required to pay attorney's fees. We may also sue you,persortell~, for~. ,,r~j~i~ -~cipal balance and all other sums due under the mortgage. P~8 If you have not ¢;urecl the default within the thirty (30) day period and foreclosure procc-...dings have i:~egun, you still have the right to cure the default and prevent the sale at any time up to one hour before the sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). A notice of the date of the shedff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you walt. You may find out at any time, exactly what the required payment will be by calling us at 800-745-1787. This payment must be made by cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a sheriff's sale will end your ovvrtomhip of tthe mor~e~,d property and your right to remain in it. If you continue to live in the property after the sheriff's sale, a lawsuit could be started to evf~ you. You have additional rights to help prote=t your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPER'P( TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEST, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEST (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND A'i'I'ORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT F_.XIST.} YOU ALSO HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. YOU HAVE THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDINGS, THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION OR FORECLOSURE. If you cum the default, the mortgage w~l be restored to the same s~a:us as if no default had occurred, However, you are not entitled to this right to cure your default more than three times in any calendar year. Ve.ry truly you~,, Collections Manager Company Pi~t~bu.tgh, PA 15230-1838 April 2, 1999 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Jeannette Rudy 515 Herman Avenue Lemoyne, PA 17043 Dear Mrs. Rudy: The MORTGAGE held by ALTEGRA CREDIT COMPANY (here/naffer "we', 'us", or 'ours") on your property located at 515 Herman Avenue, Lemoyne, PA 17043 is in SERIOUS DEFAULT because you have not made the monthly payment of $442.67 for December,*1998, January, Februa~, and March, 1999. Late charges (and other charges) have also accrued to this date in the amount of $88.52: Total amount now requi~ed to cure this default, or in other words, to get caught up on your payments, as efthe date of this letter, is $1,859.20. You may cure the default within thirty (30) days of the date of this letter by ~avin9 to us the above amount of $1.859,20.r31us any additional monthN Davmerffs and late charees which may fall due durincl this period. Such payment must be made either by cash, cashier's check, certified check or money order and made payable to Altegra Credit Company, IDC 23-~71,150 Allegheny Center Mall, FiF~urgh, PA 15212. If you do not cure the default within THIRTY (30) DAYS, we intend to exemiae our rigl'~ to accelerate the mortgage payment. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the charge to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorney to start a lawsu.it to foreclose your_ rpo .r~g.a_ge~l._p__mPe.rt~:.. !f_~the___mortgage is foreclosed, y.o. ur mortgaged property Will be sold by the sheriff to pay off the mortgage debt. ............. If we refer your case to our attorneys, hut yOU cum the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees tO whatever you OWe us, which may also include our reasonable costs. If you cure the default within the thirt7 (30) day period, you will not be required to pay attorney's fees. We may also sue you, personally, for the unpaid principa! balance and all other sums due under the mortgage. if you have not Gure(;I tile 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 any time up to one hour before the sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). A notice of the date of the sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wail You may find out at any time, exactly what the required payment will be by calling us at 800-745-1787. This payment must be made by cash, cashier's check, certh9ed check or money order and made payable to us at the address stated above. You should realize that a sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you ~onfinue to live in the property after the sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU 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 (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST,) YOU ALSO HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BYANY THIRD PARTY ACTING ON YOUR BEHALF. YOU HAVE THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDINGS, THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION OR FORECLOSURE. If you cure the default, the mortgage will be restored to the same status as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Vew truly yo rs, i-Jle~n onzaleS Collections Manager /yb IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983. PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL A~ISTANCE TOWARDS YOUR MORTGAGE PAYMENTS. RE: 6019590146708 Apdl 2, 1999 Jeannette Rudy 61 Village Court Mechanic~burg, PA 17055 FROM: Altegra Credit Company IDC 06-571 1~]0 Allegheny Center Mall Pittsburgh, PA 15212 YOUR MORTGAGE IS IN SERIOUS DEFAULT because you have failed to pay promptly installments of principal and interest as required, for a pedod of at least sixty (60) days.. The total amount of delinquency is $1,859.20. This sum inu'ludes the following: Four (4) payments at $442.87 each plus late charges of $88.52. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE THAT WILL PREVENT FORECLOSURE ON YOUR MORTGAGE, if you comply with the provisions of the Homeowners' Emergency Mortgage Assls~ance Act of 1983 (the 'Act'). You may be eligible for emergency temporaly assistance if your default has been ceueed by circumstances beyond your control and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. PLEASE READ ALL OF THIS NOTIGE. IT CONTAINS Al'4 EXPLANATION OF YOUR RIGHTS. Under the Act you em entitled to a temporary stay of forec=losure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeling with this lender or with a consumer credit work out repayment plan, or to othe~se settle your delinquency. THIS MEETING MUST ................... ~OCC.UR W~..,T__HLN' .THE. N .,E~.. ~_HIR_.T~_ .,(3_.0, ),,D. ~_Y_S.:. ..................... If you. attend a face-to-face meeting with this lender or with a consumer credit counseling agency Identified in this notice, no further proceedings in mortgage foreciosum may take place for thirty (30) days after the date of this meeting. The names, addresses and p~tone numbera of our representative are; REBECCA BEACOM IDC 23-571 '150 ALLEGHENY CENTER MALL PITTSBURGH, PA 15212 1-800-745-1787 The hemes, addresses and phone numbers of designated consumer credit counser~ng agencies are: ACTION HOUSING, INC. TWO GATEWAY CENTER prr'rsl~URGH, PA 1~;~)~ 412-281-2102 CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYt. VANIA, INC. 309 SMITHFIELD sr. P,O. BOX 278 surrE 500 500.02 THIRD AVE. PITTSBURGH, PA 15222 DUNCANS'VILLE, PA 16635 412-47'1-7584 814-696..3546 662 NORTH MAIN ST. 125 NORTH JEFFERSON ST. GREENSBUR(~, PA 15601 NE'W CASTLE, PA 16101 412-838-1290 412-652-8074 HOUSING ACTION COALITION. INC. WESTMORLAND COUNTY ONLY 714 PHILADELPHIA ~T. INDIANA, PA 15701 HOUSING OPPORTUNmE$, INC, 823 VERSAILLES AVE. MCKEESPORT, PA 15134 MON-VAI. LEY UNEMPLOYED COMMI'rTEE 60O WALNUT ST. MCKEESPORT, PA 15134 URBAN LEAGUE OF PITTSBURGH, INC. URBAN LEAGUE OF HARRISBURG, INC. ALLEGHENY COUNTY ONLY 28 NORTH SECOND STREET BUILDING FOR EQUAL OPPORTUNITY HARRISBURG, PA 17101 ....... 200.ROS.,~ STREET ., 717-234-5925 ....... PITT,~BURGH, PA 15219 412-261-I 130 CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY t211 CHESTNUT STREET SUITE 411 PHILADELPHblk, PA 19'i07 215-5635665 CONSUMER CREDIT COUNSEMNG SERVICE OF LEHIGH VALLEY' 1031 MNDE. N STREET ALLENTOWN, PA 18102 It is extremely important that you file your application promptly. If you do not do so or if you do not follow the other time periods set forth In this letter, foreclosure may proceed eligibility for assistance. Available funds for emergency assistance are very limited. They will be disbursed by the Agency under the eligibility e, riteda established by the Act. It is extremely important that your applicatio~ is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision a~ter it receives your application. During that additional time, no forecJosure proceedings will be pursued against you if you have met the time requirements set foAfl above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029 in 'Harrisburg, Pennsylvania 1'7105. Their telephone number is 717-780-3800 or, you may call toll free at 1-800-342-2397. In addition, you may receNe another notice from this lender underact 6 of 1974. This notice is called a 'Notice of Intention to Foreclose Mortgage'. You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose Upon you dudng that time. Also, E you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. Very [ruly yours,, / t E~een Gonzales Collections Manager 0~, :~dOq~N3 ~0 dod, .iV U3~;)U.~ ;lO~rt4 ; t~v,k~Odl~l :. IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983. PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARDS YOUR MORTGAGE PAYMENTS. RE: 6019590148708 April 2, 1999 Jeannetta Rudy 515 Herman Avenue Lemoyne, PA 17043 FROM: Altagra Credit Company IDC 06-571 150 Allegheny Center Mall Pittsburgh, PA 15212 YOUR MORTGAGE IS IN SERIOUS DEFAULT because you have tailed to pay promptly Installments of prfncipal and interest as required, for a period of at least sixty (60) days, The total amount of delinquency is $1,659.20. This sum includes the following: Four (4) payments at $442.67 each plus late charges of $88.52. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE THAT WILL PREVENT FORECLOSURE ON YOUR MORTGAGE, if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the 'Act'). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control and if you meet the eligibi/k'y requirements of the Act as determined by the Pennsylvania Housing Finance Agency. PLEASE READ ALL OF THIS NOTICE. IT CONTAINS AN EXPLANATION OF YOUR RIGHTS. Under the Act you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a face-to.face meeting with this lender or with a consumer credit work out repayment plan, or to otherwise settle your delinquency. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. If you attend a face-to-face meeting with this lender or with a consumer credit counseling agency Identified in this notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The names, addresses and phone numbers of our representative are: REBECCA BEACOM IDC 23-671 150 ALLEGHENY CENTER MALL PITTSBURGH. PA 15212 1-800-745-1787 The names, addressee and phone numbers of designated consumer credit c~unseling agen~es are: ACTION HOUSING, INC. TWO GATEWAY CENTER PrTT$$URGH, PA 412-281-2102 CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYLVANIA, INC. 309 SMITHFIELD ST. P.O. BOX 278 SUITE 500 500-02 THIRD AVE. PITTSBURGH, PA 15222 DUNCANS~ILLE, PA 16635 412471-7584 814-6ge-3546 ~ NORTH telA/N ST. 125 NORTH JEFFERSON ST. GREEN~URG, PA 15604 NEW CASTLE, PA le10t 412-838-1290 412-852-8074 HOUSING ACTION COALITION, INC. WESTMORLAND COUNTY ONLY 7'14 PHILADELPHIA ST. )NDIANA, PA 15'70t HOUSING OPPORTUNITIES, INC. 623 VERSA/I_LES AVE. MCKEESPORT, PA 15134 MON-VALLEY UNEMPLOYED COMMITI-EE 600 WALNUT bT. MCKEESPORT, PA 15134 URBAN LEAGUE OF PITTSBURGH, INC. URBAN LEAGUE OF HARRISBURG. INC. ALLEGHENY COUNTY ONLY 28 NORTH SECOND STREET BUILDING FOR EQUAL OPPORTUNITY HARRISBURG, PA 17101 -200 .RQS$$TREE'J' ................................... 717-234-5925 ....................... PrlI"r~BURGH, PA 15219 412-261-1130 CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1211 CHEb"TNUT STREET SUITE 411 PHILADELPHIA, PA 19107 215-~63-8~e5 CONSUMER CREDIT COUNb'EUNG SERVICE OF LEHIGH VALLEY 1031 LINDEN STREET ALLENTOWN, PA 18102 It is extremely important that you file your application promptly. If you do not do so or if you do not follow the other time periods set forth in this letter, foreclosure may procccd eligibility for assistance. Available funds for emergency assistance am very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. it is extremely important that your application is accurate and complete in every._r~pect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision' after it receives your application. During that additional time, no foreclosure p~ings will be pumued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your applicatiOn. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029 in Harrisburg, Pennsylvania.17'105. Their telephone number is 717-780-3800 or, you may cell toll free at 1-800-342-2397. In addition, you may receive another notice from this lender under Act 6 of 1974. This notice is called a 'Notice of Intention to Foreclose Modgage'. You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you am receiving that assistance. Collections Manager SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-01489 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALTEGP~A CREDIT COMPANY VS RUDY JEANETTA R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: RUDY JEANNETTA but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT - MORT FORE/NOT On April 10th 2001 , this office was in receipt of the attached return from PERRY Docketing 18.00 Out of County 9.00 R'~h~~T omas K~ Surcharge 10.00 . ine DEP. PERRY CO 40.08 Sheriff of Cumberland County .00 77.08 04/10/200i STERN & STERCHO Sworn and subscribed to before me this 7/~ day of A.D. f ! Prothonot ar~ In The Court of Common Pleas of Cumberland County, ?ennsy vania A]tegra Credit Company Jeanetta Rudy No. 01-1489 Civil NOW, 4 / 2 / 01 ,20 O ~, I, SHERIFF OF CUM-BERLAND cOLrNT¥, PA, do hereby deputize the Sheriff of Perry COllrtty to execute dais Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland Count'y, PA Affidavit of Service }XlOW, April 6, ,20 01, at 9:40 o'clock A M. servedthe within Complaint in Mortgage Forclosure upon Jeanetta Rudy at 13 B Pfautz Rd. Duncannon, Penn Township, PA. 17020 %y handing to Jean~-tta Rudy a True & Attested copy of the ori~nal Comp. Mtg. Forc and made tmown to he,* the contents thereof. So answers, Deput ' Perry County, PA COSTS Sworn and subset/bed before SERVICE 1 8.0 o med-Js ~'~ dayof phlOr~l ;20~1 MILEAGE ~? aa .~FFIDAVIT ?. 00 - N0t~b%S[N- $ 40.08 ~ COMMISSION BllqRES fEB. 16. PRAECIPE FOR WRIT OF EX~-CL'rlO,N- (MONEY JUDGME.NTS) P~. R.C.P. 3101 to 3149 Altegra Credit Company . ............................................................. : ............. In the Cour Common Pleas of ....................... . .................. : .................. -.. ..................... County, Pennsylvania. ' ~ ~ No ...... .o.!.-.L~.~. ........................ Jeannetta Rudy PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDG~IENT) To the prothono~ry: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the $~erif~ of ....... Qi~[~-l-?---riel ................. County, Pennz.; (2) against ............................................................... r ................................................................................................ Jeannetta Rudv Defendant (s); ( 3y}X~[ya~y~[~4~ ............................................................................................................................ GXt~J~); (4). ah'd index th~s .writ -. (a) a~'ainst ................................................................................................................................................... .............................. .J.9~[~..~ ....................................................... Defendant (s) and ( ~Cv.%~e~ .............................................................. : ........................... ::. ............ :-..--' .................................... as a lls pendens against the real property of the defendants is) (Specifically describe proper~y per attached property description): 515 Herman Ave., Lemoyne, PA SEE ]%TTACHED LEGAL DESCRIPTION (5) A~nount due $. ,.~1 ~.~Q~., .~.....' Interest frornthe date judgment is entered ......................... at the per diem rate of $10.14. Total ........................, . Plus costs. n~ted . . ~~-~ : ................................... RICHARD F, STERN, At. to,~,.~ for -. NOTE Under para,D-=oh ~11 ~-hen the ~'i: is directed ~o th~ sheriff nf another county :~ authom=~ hy Rule ::I03~hl, the county ~houid he indic=:ed. ~'nder Rule 3103(c) a wv~t issued on · transferred judg-men~ ma:: be directed only to the sheriff o£ the coun:y which isaued. Parag-~'aph (3) above should be completed only if · named garnishee isto be included m the writ. Paragraph (41 (al should be completed only if indexing of :he esecution in the county of issuance, is desired as authorized by Ru · 3104¢a). When the ~-rit issues to another count? indexing is required as of course in that county by the prothonotary. See Rule 3104(b). Paragr=ph ¢41 Cb) should be completed only if real property L'. :he name of = ~arnishee is at:ached and indexind' as · lis pendens is des[re~. See Rule 3104{c). in the Court of Cammon Picas of :c~.~ Count~, Pennsylvania. A]t~g~ credit C~mp~ny ................... Jeannetta Rud¥ PRAECIPE FOR V~RFf OF E~CECUTtO~ (kioney Jud~men*-) P:u F~CP. R101 to 3149 etc. Premises: 515 Herman Ave., Lem~yne, PA oo LEGAL DESCRIPTION Ai.L THAT CERTAIN piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland and State of Penn.~ylvania, more particularly bounded and described as follows, to wit: BEING western section of Lot No. 41, Section 'D' in a Plan of Lots known as Plan No. i Riverton, Pennsylvania~ said plan being recorded in the Recorder's Office in ~na for Cumberland County, Pennsylvania.~ at Carlisle, Pcun.~ylvania, in Deed Book '$', Volumn 4, Page 40. The said western section of lot starting at a point on the northern line of Herman Avenue in the center of Lot No. 41 and thence through the center walls or partitions of double house known as 513-515 Herman Avenue on a parallel. line with Fifth Street, formerly known as Clinton Street, one hundred fifty (150) feet to the southern line' of Peach Alley; thence westwardly seventeen feet six inches (17'6"), thence southwardly one hu~red fif~ (150) feet to northern line of Her~n Avenue; thence eastwardly seventeen feet and six inches (17'6") to point of BEGINNING. ERECTED TI4R, REON dwelling house No. 515 Herman Avenue. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 ALTEGRA CREDIT COMPANY VS. NO. 01-1489 CIVIL JEANNETTA RUDY AFFIDAVIT PURSUANT TO RULE 3129.1 RICHARD F. STERN, attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 515 HERMAN AVE., LEMOYNE, PA 17043. 1. Name and address of Owner(s) or Reputed Owner(s): Jeannetta Rudy 13 B Pfautz Road Duncannon, PA 17020 2. Name and address of Defendant(s) in the judgment: Jeannetta Rudy 13 B Pfautz Road Duncannon, PA 17020 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: N/A 4. Name and address of the last recorded holder of every mortgage of record: Farmers Trust Co. P.O. Box 220 Carlisle, PA 17013 AVCO Financial Services, CDC 3542 Gettysburg Pk. Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: N/A 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: N/A 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Commonwealth of Pa. Inheritance Tax Division 1400 Spring Garden Street Phila., PA Internal Revenue Service Federated Investors Tower 13th Fl., Ste. 1300 1001 Liberty Ave. Pittsburgh, PA 15222 Tax Claim Bureau Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Occupant 515 Herman Ave. Lemoyne, PA 17043 I verify that the statements made in this affidavit are tree and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, Date: 5/30/01 STERN AND STERCHO Attorney for Plaintiff LEGAL DESCRIIrflON A ¥ ~l~ THAT CEP. TAIN piece or parcel of land siamte in the Borough of Lemoyn~, County of Cumberland znd State of Pe~n.~ylvania, more particularly bounded and described as follows, to wit: BEING western section of Lot No. 41, Section "D" in a Plan of Lots known as Plan No. 1 Rivcrton, Pe,~-sylv~ said plan being recorded in the Record~r's Office in and for Cumberland County, Penmylvania~.al C~rlisle, Pennsylvania, in Deed Book "J", Volumn 4, Page 40. Th~ said western section of lot starting at a point on the nerdaera line of Herman Avenue in the center of Lot No. 41 and thence through the center walls or partitions of double house known as $13-$15 Herman Avenue on a parallel. line with Fifth Street, formerly known as Climon Street, one hundred fiity (150) feet to the southern line' of Peach Alley; thence westwardly seventeen feet six inches (17'6 "), thence southwardly one hundred fifty (150) feet to northern line of Herman Avenue; thence eastwardly seventeen feet and six inches (17'6") to point of BEGINNING. ERECTED THEREON dwelling house No. $15 Herman Avenue. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 ALTEGRA CREDIT COMPANY VS. NO. 01-1489 CIVIL JEANNETTA RUDY CERTIFICATION UNDER RULE 237.1 I, the undersigned, attorney on the writ and attorney for plaintiff, hereby certify that a ten day notice of intention to enter judgment by default was sent to defendant in accordance with Pa. R.C.P. 237.1. A true and correct copy of said notice is attached hereto. STERN AND STERCHO C~H~A~RD F. STERN, Attorney for Plaintiff IN THE COURT oF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW RICHARD F. STERN, ESQUIRE STERN and STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. g03315 ALTEGRA CREDIT COMPANY : VS. :NO. 01-1489 CIVIL TERM JEANNETTA RUDY : NOTICE OF INTENTION TO ENTER DEFAULT JUDGMENT TO: JEANNETTA RUDY, 515 HERMAN AVENUE, LEMOYNE, PA 17043 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 1-800-990-9108 STERN AND STERCHO DATE: 4/27/01 BY: ///'/'/-'~ . RICHARD F. STERN, Attorney for Plaintiff \~erver~office do~um~Anne Mari¢~Ten Day~RUDY.CUMBERLAND 10 DAY.wpd COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 ALTEGRA CREDIT COMPANY : VS. NO. 01-1489 CIVIL JEANNETTA RUDY AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF MONTGOMERY : RICHARD F. STERN, being duly sworn according to law, deposes and says, to the best of her knowledge, information and belief, defendant's: 1. Last-known address is: 515 Herman Ave., Lemoyne PA 17043 2. Is over the age of twenty-one. 3. Is not now nor have been within the last six (6) months in the Armed Services of the United States as defined in the Soldiers' Civil Relief Act of 1940, as amended. STERN AND STERCHO BY: RICHARD F. STERN, worn oth .~f~amis~d Attorney for Plaintiff be force, ne o'~-~ ~'/~ ,2001. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 ALTEGRA CREDIT COMPANY : VS. : NO. 01-1489 CIVIL JEANNETTA RUDY : CERTIFICATE UNDER ACT 91 OF 1983 It is hereby certified that the Sheriff's Sale scheduled in the above-captioned matter is not protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688, No. 621 because notice, as required, was sent to defendant and no timely response was made. STERN AND STERCHO Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 ALTEGRA CREDIT COMPANY VS. NO. 01-1489 CIVIL JEANNETTA RUDY CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: Altegra Credit Company 116 Allegheny Center Pittsburgh, PA 15212 Jeannetta Rudy 13 B Pfautz Road Duncannon, PA 17020 STERN AND STERCHO RICHARD F. STERN, Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. # 03315 ALTEGRA CREDIT COMPANY : VS. : NO. 01-1489CIVIL JEANNETTA RUDY : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JEANNETTA RUDY 13 B PFAUTZ ROAD DUNCANNON, PA 17020 Your real estate at 515 HERMAN AVE., LEMOYNE, PA 17043 is scheduled to be sold at Sheriff's Sale on DECEMBER 5, 2001 at 10:00 A.M., in the Cumberland County Courthouse, Carlisle, PA, to enforce the court judgment of $51,505.43 obtained by Altegra Credit Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFFIS SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to Stem and Stercho the back payments, late charges, costs and reasonable attorney's fees due. To fine out how much you must pay, you may call Stem and Stercho, telephone (215) 572-8111. 2. You may be able to stop the sale by filing a petition asking thc 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 on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Stem and Stercho, telephone (215) 572-8111. 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 fred out if this has happened you may call Stern and Stercho, telephone (215) 572~8111. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the properly until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date. 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 date of filing of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house 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. LAWYER REFERENCE SERVICE COURT ADMINISTRATION CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 LEGAL DESCRIPTION ~i'.L THAT CEI~.TAIN piece or parcel of~.-d situale in the Borough of Lemoyne, County of Cumberland and Stat~ of Pennsylvania, more particularly bounded snd described az follows, to wit: BEING we. stem section of Lot No. 41, Section "D" in a Plan of Lots known as Plan No. i Rivcr~on, Pennsylva~ia~ said plan being recorded in the Recorder's Office in and for Ctunberland Count, Penn~ylvani~, a'; C:u'lizle, Pennsylvania, in Deed Book "~I", Volumu 4, Page 40. The said westrm section of lot starting at a point on the northern line of Herman Avenue in the center of Lot No. 41 and thence through the center walls or partitions of double house known as $13-515 Herman Aventte on a parallel .. line with Fifth Street, formerly known as Climon Street, one hundred fife/(150) feet to the southern line of Peach Alley; thence westwardly seventeen feet six inches (17'6 "), thence sou~hwardly one hundred fifty (l!f0) feet to northern line of Hermsn Avenue; thence eastwardly seven~,.'en feet and six inches (17'6") to point of BEGINNING. ERECTED THEREON dwelling house No. ifl$ Herman Avenue. RICHARD F. STERN, ESQUIRE STERN and STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. #03315 ALTEGRA CREDIT COMPANY :IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY VS. NO. 01-1489 CIVIL JEANNETTA RUDY CERTIFICATE OF SERVICE I, RICHARD F. STERN, ESQ., attorney for the within Plaintiff, hereby certify that notice of the Sheriff's Sale was mailed to the Defendant by regular and certified mail, return receipt requested on October 30, 2001. I further certify that notice of the Sheriff's Sale was mailed to each lienholder by regular, first-class, postage pr~aid mail on October 30, 2001 as evidenced by copy of certificates of mailing attached. STERN AND STERCHO RICHARD F. STERN Attorney for Plaintiff 10/30/2001 pmimlsrly Imnded and dm~bed m follow~ to BEJNG wmt~ s~ ef L~ No. 41. Section "fY' ~n a I~m of Lnm known m I~n No. I ~ of dmIMe' bmJle ImowB m $13-511 ~A~