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Home My WebLink About02-0150MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Charter One Credit Corporation : COURT OF COMMON PLEAS 2812 Emerywood Parkway Richmond, VA 23294 Plaintiff Vo Melissa Greene Thomas Beers 515 Third Street West Fairview, PA 17025 Defendant(s) ATTORNEY FOR PLAINTIFF i CIVIL DIVISION : · Cumberland County COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your 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 YO'ua 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas si~uientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un ahogado y entre~ar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UNABOGADO I~M~DIATA~ENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PAPA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill~ NJ 08034 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: N/A Assignments of Record to: N/A Recording Date: N/A Book: N/A Page: N/A 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 515-517 Third Street MUNICIPALITY/TOWNSHIP/BOROUGH: Township of East Pennsboro f/k/a Borough of West Fairview COUNTY: Cumberland DATE EXECUTED: 10/14/99 DATE RECORDED: 11/1/99 BOOK: 1579 PAGE: 986 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of November 12, 2001: Principal of debt due and unpaid Interest at 9.99% from 6/19/01 to 11/12/01 (the per diem interest accruing on this debt is $14.74 and that sum should be added each day after 11/12/01) $53,841.85 2,166.78 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $0.00 and that sum should be added on the first of each month after 11/12/01) 1,397.89 Late Charges (monthly late charge of $23.67 should, be added on the fifteenth of each month after 11/12/01) I65.69 Attorneys Fees (anticipated and actual to 5% of principal) TOTAL $60,794.30 7. The attorney's fee 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 the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A"~ and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $60,794.30 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 o~ ~? ~umbErl~ud Co~flt¥. pennsylvania. ,note ' h~r~ t~rty-fiv~ (135) ~t ~[~m~wardly fr~ ~he No~as~ ~t al~g l~ o~ la.~ ~ m~ n~r~ u 527 ~rd Sbreet. li~ ota t~t~-~t ~id. alloy: ~h~ Smtth 35 d~c~ 45 ' ~nuL~ ~t at~ ~ ti~t~ (~S) to m point; th~co 5~th 56 ~t~*et ~ beyS. ~e I~c~ thirteen a~ foct~-L~o B~{IWNII~ a~ a point XSO ~m~[ north ut k-~_~st Street el~ the c~ter of lot No. 41,, ~ mt~ly t~ t~ c~er nC lot, AX2 t~, ~ or l~, to ~ ilJ~; ~ ~out~rdly' I~ s~d allly, 15 fNt to.lot ~ oc late ot oliver B~ ~ a~ecn blf ~ ~t No~ 41 u 8~ m the Plmt and the lender intends · ~fthe ~ ~ttach~ - .. " - · , %r~m~"w} may ue aole to help Save y({ur hom'~. '.' This Notice contains ...... - important legal inform!tion. If¥o~ hire any q~stions, rePr~e~tatires i~ tha Consumer Credil Cotmselint · .. Agency aa¥ be a~.le to halp e.xp. lain il. ¥o~ ~a¥ also wahl to ¢oota¢~ a~ attorney in your area. The lo~al bar a.sso¢lalion .. ' ' to help you fad ~i lawyer, . · .' ,.; : ..... · .. . . . . . . . ' .; .'... '. .. . .. ARR/BA. PU~DES st~K ELEOIBLE PARA UN PRESTAlVIO POR. EL PROORAMA LL.~WA.DO "HOMEOWN~F,S EMEKOENCY MORTOAOE ASSISTANCE PROORAM" EL CUAL PUEDE-SALVAk · SU CASA DE LA PERDIDA DEL DERECHO A RP. nlMIP. SU HIPO'I~CA IS' SERIOUSLY IN DEFAULT because: the abovc lender on your property located at. ' ' ' ' - - - ' ~I¥ Y. O .U .DO ?.eT CUI.~E...TI~...D.EF. AULT.- .If. yo..u do not sure the dc,~ult within THII~Ty 00) DAYS of the' date 0r this Notice; t~ ~_n_a_,e~r_~_n_~n~ a_s ,t0 ex_e~c_~e' ,.~ r~gnts to uc. cete.r?e .me mo. rtgage..debt..This m. e~ns that .thc eat= outstanding bahncu of this debt will .cv .~tucrcu uuc lmmcuia~ciy anu you may teac mc chance to pay mc mortgage m monthly installments..If full payment of the total enlo · [:' ' yourPaSt dUCmortf~alediS not made.property.Within TI-~,TY (30) DAYS, the lender also intends to instruct its attomcys to start legal action to foreclose upon · ' J IF THE MORTGAGE IS FORECLOSED UPON'- ~'hc'mortgagcd property'will bc s~ld by thc Shcriffto pay off.the mort~,asc dcb~. ·. thc l.cnder rcfcrs your case to its aitomcys, but you sur~ th~'dclinqucncy before thc lender begins legal recccdin s ' rcqulredtopaythcreasonablcattomcy'sfcasthatwcreactuallvinc~rred u,~t,~:fn,~,~ ,-:' ... p . g..a~a,nstyou, you. wil ' - --, r ..... vv.. rmwcvcr, Illegal procceamss arc started again f~ ~y?.c~..ed br the ~..der cron. ir thc~ exceed ~o.oo. ,~ ~omcy's u~,,,, u,, ~,,~ ~,vu vwv m~ ~cuucr, wnxcu may also mciuoc omcr reasonable costs. If you cure the default wlthln th'e /. (30) DAY uertod~ you will not be requlred to pay attorney's f'e-~ . . .. .. ......... ~ ' OTHER LENDER REMEDIES - Thc !coder maY:also sue you pcrseaally for the unpaid principal halenco end all other sums due unit the me.ese. ' . .. .. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S S~, I .~.. - If you have not cured the default withtn'th~ THIRTY (30) D~ -. period end foreclosure proceedings have begun, you still have the right to cure the def's-~ end vrevent thc sale e~ =n~ ~ .... ,~ ,~.. ~^. before the Sheriff's Sale. You may do so by payinl thc total amount then hast due- nlus ~,~v ~,~. .... u ....... -'~'~ --:" '~ .... ~. ~"" allomcy s fccs and -_-_._-._- ,.v,,..~_._:_~ w~lh the ,v,~osure sale and any or_her co_,~ ~o,,,?_¢t _,yl with the Shell,Ts Sale as specified in · thc louder'and by [:i¢if~.,i.'ql~ on)' Ol,',~- [~iii~,,,ents endclt the m~rt~e Curing the defaull in the'manner ael forth In this notice reatore your mortgage to the same posiflou as ifyon hsd never d~faulted .... . . · 'EARLIE,~ POSSl]ILE SHER~'~"S SALE DAntE' .- It IS estimated '~t ~he carilest 4~t~ ~h,t such'a'Sberiff's Salc:'oftho . morl~agedpropcr~.coi,ldt~beldwouldbeapprnxlmately · [~ months fromtheduteorthisNollce. Auntice 0ftbe . . actual skl~ dalc of thc Shcriff's'Salc will be sent to you before lhc sale. Of course,, the amount ~ceded lo' cure.tho dcl, aul~ will increase It :: ........ loogeryouwok. Youmay~ndou~a~enythnccxac~ywha~ther~quIredpaymea~.orac~innw~bebycuntactingtho~eadec. HOW TO CONTACT T~: LENDER: . · . · · E, F. FECT OF S,HE..l.:~.llq~'s SALE - .Y. ou sho. uld realize th_al a Sheriff's Saio wiil ead your owncrship of thc mortgaged propcrly en~ yoc · . ,right to occupy it. If you continue to live in Ibc propcrty.al~cr thc Sheriff'S Sale, ii lawsuit to remove you end Your furnishings end other ociongln~s could bc .s~artcd by thc.lender at any time · · ' . ~- ._. CHARTER ONE MORTGAGE 561 P02 NOV 14 '01 11:24 ACT 9,1 NOTICE D~t¢: November 14, 20(~1 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mo~t~e_ae on your t~..~..r~ Lq in d~f~ult, and the l~ntter ;_n_?.~ds to foreclose. Soecific information about the nature of the de~.lt i~ provided in the attached _lra~es. · ~ HOMEOWN~ER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to helo save your home. This notice e~c~l,~in~ how the Pro_~ram works. To see ifHEMAP can heM. you must MB2¥ WITIt A CON'SUMER CR.BDIT COUNSELING AGHNCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE.' Take this Notice with you when you.meet with the Counselln~, Aecncv. Th .. . [.a _~. ....... ~..~ ,~£c',~n~---- Credit Co. nceline Aeencics servine your County ~re !!smd at the e, nd of ~ Notice. If you have any °ucstions. you may call the Pe-,,.vlvsnla I-l~.cm~ Finance A_~encv toll free at _1-800-342-2397, (Pen t with intoaired hearine can call (7171780-18691, This Notice contains important le2al information, If you have my quealions, representatives at the Consumer Credit Coumeling Agency may be able to help explain it. You may also want to contact an attorney in your area, The local bar association may be able to help you find a law,jer, LA NQT~-iCA¢ION BN ADIUNTO ES DB SUMA INt'ORTANCIA. PUBS AFBCTA SU DERBCHO A COBITINUAR VIVIBNDO BN SU CASA. SI NO COMPRENDB EL CONTBNIDO DB ESTA NOTIFICACION OBTBNGA UNA TRADUCCION IlCMBDITAM~NTE LLAMANDO BSTA A(jlINCIA ~Elq~$YLVANIA HOUSING FINANCE Ao_,_R~ICY] SIN CARGOS AL NUMttRO MBHCIONADO AKI~ mA. PUBDBS SER ELBGIBLE PARA UN PI~.$TAMO PeR BL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUBDE SAL gAR SU CASA DB LA PERDIDA DEL DBRBCHO A REDIMIR SU I-ilPOTECA. CHARTER ONE MORTGAGE 561 P03 NOV 14 '01 11:24 HOMEOWNER'S NAME(S): Thonlas Been PROPERTY ADDRESS: $1~; 3N St.. Wc~t Falrvfew. PA ! 702S LOAN ACC'T. NO.: ?385339 ' ORIGINAL LENDER: Charter One Credit Coro.. · CURRENT LENDER/SERVICER: Charter One Mort~aee HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU'MAY BE KLIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT~), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: · IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCESBEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPKCT OF BEING ABLE TO PAY YOUR MORTGAGE pAYMENTS, AND · IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY, T~MPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a amporary stay of foreclosure on your mortgage for thirty (30) days from the dale of this Notice. During that time you must arrange and attend a "face-to-f~ce" meeting with one of the consumer credit counseling agencies listed et the end of dais Notice, THIS MEETING MUST OCCUR WITHIN THE NEXT ~30) DAYS. IF yOU DO ~Q,T APPLY FOR EMERGENCY MORTGAGE ASS[STANCF.~ YOU MUST BRING YOUR MORTGAGE UP TO DATE. PART OF THIS NOTICE CAY.!.I~.B "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMI~R Ci~EI~IT COUN~I~LING AGENCIES- If you mcca with one of the consumer credit coun~,.ling agoncic~ listed al tho cad of this Nodce, the lender may NOT t~ke ~ction a~in..~ you for thirly (~0) days after the date of this m~ting, The names, addresses and tel-'ohone ntia~a of ,4,~hmst,~l ~.c,~.,~.iar credit co-~se!in~ a~enci~s for the cotmtv in which the ~ro~a'~ is l~¢a!_~d_ are set forth at the end of this Notice, It is only ne~_~'y to sch~ule one face-to-face m~tln~, Advise your I~ader immediately of your intention, ApP~.~i(~ATION FOR MORTGAGE ASSISTANCE - Your mortgag~ i~ in default for thc roa.son~ sca fo~h lam' in this Notice (s~e followin~ pag~ for sp~ific information about the nature of your default), Ify~u have tried and sr~ unable to reaolve this problem ~th the lender, you have the right to ~ply for financial assistance fi'om the Homeowner's Fanorgcncy Assistance Prelim. To do so, you must fill ou~, sign end file a completed Homeowner's Emergency AssisUmce program Application with one of thc dosisnated consumer credit counselins agencies listed the end of this Notice. Only consumer credit counseling agencies have application for the pro$~ram and they will assis~ you in suhmlrgng a complete application ro the Pennsylvaoia Housing Fin~cc Agency. Your application MUST be filed or postmarked within thirty (30) days of your f~co-to-faca YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FIAL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. ~- Available funds for cmc~ency mortgage assistance sro very limiled, They will b~ disbors~d by lite Agency under eli~'biliiy criteria established by the Act. The Pennsylvania Housin~ Finsaco Agency has sixty (60) days to make e decision after it receives your applimion. During that time, no foro~:iosurc proceedings will be pursued agalmt you if you have m~ the time requirements set forth above, You will bc notifiM dir~cdy by thc Pennsylvania Housing Finance Agency ofits decision pn your application, NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THli FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (IF YOU HAVE FILED BANKRUPTCY YOU CAN STILL APPLY FOR EMERGENCY MORTGAGE A~SISTANCE.) HOW TO CUI~E yOUR MORTGAGE DEFAULT (Briar It u~ to date~. NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lende~ on your property located a~: ~ ~JFd St- West Fal~iew. PA I?02S , IS SERIOUSLY IN DEFAULT ~c~us~: CHARTER ONE MORTGAGE 561 P04 NOU 14 '01 11:25 A. YOU HAVE NOT MADE MONTHLY MORTGAOE PAYMENTS for thc foUowln$ mouths end the followin$ amounts are now past due: Other char~as (explain/itemize): - 22 's TOTAL AMOUNT PAST DUE: $1.871,14 B. YOU HAVE FAILED TO TAKE THE FOLLOW'INn ACTION tDo not use ifnnt a~li~able~: HOW TO ,CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS oft. he date of this notice BY PAYING THE TOTAL AMOUNT pAST DUE TO THE LENDER, WHICH IS $1480.37, PLUS ANY MORTGAGE PAYMENTS AND LATE CIIARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pa_vment~ mus~ be made cithet by cash. ,.l~M~,'s check. ~rtlfled check or motley order mede ~avab!e and sent to: ~'harter One Mo~e~e 2SI2 Emervwood pI~WY Richmond. VA 23294 YOU can curt any other default by taking the following action within THIRTY (30) DAYS of the d,to of this letmer (Do not use ii'not '- annltcable% _XF YOU DO NOT CURE THE DEFAULT - If you do not cu~ the default within THIRTY (30) DAYS of the date of this Notice, th~ lender Intends to axe~.'lse ita riches to -_~,4,,-nle the mortmtfe debt. This romans that the entire outstanding halan~ of this debt will be considered due immediately and you n~y Icao the chance to pay ~o rnv,?.~age in monthly installments. If full payment ct'the to,al amount past due is not made within THIRTY (30) DAYS, thc lendet also intends to instruct i~s a~tomeys to start legal action to ~ your mortgaged uronertv. IF THg. MORTGAGE IS FO~nRCLOSED UPON - The mortgaged prop~'ty will be sold by the Sheriff to ~ off the mortgage deb~. the lender refen your case to its auomeys, but YOu sure the delinquency before the lender basins legal proceedings against you, you required zo pay the r~asonabtc attorney's l'~.s that wcro actually incurred, up to $$0.00. However, if la,al proc~,.-.dinga a~e started against you, you will have to pay all reasonable attorney's ~c~ actually inoun'ed by the lend~ even ifth~y exceed $~0.00. A~y ~ttom~-y's fe~s will be added to tho amount you owe the lender, which may also include other reasonable costs. [if you cure the default within the THIRTY (~}~ DAY neriod, you will not be reuuired to ney affornev's fens. OTmC. lt LENDER REMEDIES - The lender may also sue you pc~sonnlly for the unpaid principal balance and all o~et sums due under the murtga~e. RIGHT TO CUItE THE DEFAULT pRIOR TO SI-~gRIFF'S SALE - If you have not cured the d~fault within the THIRTY (30) DAY paflod and f,~t~,;Iosure pr~,~_-._ed~mgs have k-e~m, you still have the r{uht to cu~ the ,4,,¢~,,It end nrevent ~e sale at any time un to on_e hot,, bee re iff's S You so ' I o u an ate et es th ~e .... · me 'si~ 'dec nece ' tho I sure and co withth e' ' edin " the !~,~d~' aud bv ue~orrnina any othet rsoulrements under tho mestoate. Cae'lng tho default in the manner set forth in thl~ notice will r-store your mortgage to tho same position as if you had never defaulted. EARLIEST POSSIBLE .~g~.RI~F'S SALE DATE - It is ,~stimated thai thc earliest date that such a Sheriff's Sale of the mon'g~ed property coutdbe held would be approximately 10 months f~om the date of thh Notice. A notice of the actual sale daze of the Shoriff's Sale will be sent to you befor~ the sale. Of course, tho nmouu~ needed to cu~ tho default will increase the longer you wait. You may find out at any time egacdy wist the required payment or notion will be by contacting the lend~. HOW TO CONTACT THE LENDF,~ Name of L~nderz Contact person: Linde M~6h EFFECT OF SHERIFF'S SALE- yo~ should Fcalizo that a Sheriff's Sale will end your ownership of the mortgaged proper~ nd you right to occupy it, Il'you continue to live in the proper~ after the Sheriff's Sale, a lawsuit to remove you and your fin'nishings and other b~lunsings could be started by the lender a~ any tiao CHARTER ONE MORTGAGE 561 P05 NOU 14 '01 11:~5 ma not (CHBC~ ONE) iel| or I~'nnsfer yoUr home to a buyer or TGAGK- You '. m~y or'~ ¥. rn's fees nnd costs nra I~id ~SSUMPTI. ON ,O..F MOR ..... -.... ~.L. -mvided that ~11 the outstanding payments, cha~ges and atto ey t~s~e~e~who Writ ~Le~UI11e ~le mo~&~ ~ r . p~'tor to or at the sale nad that the other tequkementS of the mortgage are mlsfied. ~OU MAY ALSO 12.AY~ TYfK RIGHT; · TO SELL THE pROPERTY T° OBTAIN MONEY TO PAY OFF THi~ MORTGAOE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO-PAY OFF THIS DEBT, TO HAVE THIS DEFAULT CUR.ED BY ANY THIRD pARTY AL'TING ON YOUR BEHALF. · TO HAVE Tile MORTGAGE R.ESTOP. ED TO TEE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CL1T~ THE DEFAULT, (HOWEVER, YOU DO NOT HAVE T[.{IS RJOHT TO CURE YOUR DEFAULT MORE TI-IAN THR~E TIMED IN ANY CALENDAR YEAR.) FO CLOSL11LE pROCEEDING OR ANY OTHER LAWSUIT · TO ASSERT THE NONEXIISTENCE OF A DEFAULT IN ANY RE INSTITUTED UNDER THE MORTGAGE DOCUMENTS. HAVE TO SUCH ACTION BY TH~ LENDER. , TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY · TO SEEK PROTECTION UNDER THE FEDERAL BANICRUSTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (SEE APPENDIX C ON THE I~OLLO~qENO PAGES) VERIFICATION reports of Plaintiff's agents. this statement herein is made Pa.C.S. Section 4904 relating authorities. Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and The undersigned understands that subject to the penalties of 18 to unsworn falsification to Mar~E MARK J. UDREN & ASSOCIATES - REGULAR CASE NO: 2002-00150 SHERIFF'S RETURN P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHARTER ONE CREDIT CORPORATION VS GREENE MELISSA ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GREENE MELISSA the DEFENDANT , at 2030:00 HOURS, at 515 THIRD STREET WEST FAIRVIEW, PA 17025 MELISSA GREENE a true and attested copy of COMPLAINT - on the 14th day of January , 2002 by handing to MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this 2V~ day of ~O~.L A.D. ~Pz~ot honor ary So Answers: R. Thomas Kline 01/18/2002 MARK UDREN By: Deputy Sheriff SHERIFF'S RETURN CASE NO: 2002-00150 P COMMONWEALTH OF PENNSYLVANIA: COLrNTY OF CUMBERLAND CHARTER ONE CREDIT CORPORATION VS GREENE MELISSA ET AL - REGULAR BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GREENE MELISSA the DEFENDANT , at 2030:00 HOURS, on the 14th day of January , 2002 at 515/517 THIRD STREET WEST FAIRVIEW, PA 17025 MELISSA GREENE a true and attested copy of by handing to COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~,q ~ day of C~ ~- A.D. /' I Pr-~thon0t~y ' , t SO Answers: R. Thomas Kline 01/18/2002 MARK UDREN By: Deputy Sheriff- SHERIFF'S RETURN - REGULAR CASE NO: 2002-00150 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHARTER ONE CREDIT CORPORATION VS GREENE MELISSA ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BEERS THOMAS the DEFENDANT , at 2030:00 HOURS, on the 14th day of January , 2002 at 515/517 THIRD STREET WEST FAIRVIEW, PA 17025 MELISSA GREENE a true and attested copy of COMPLAINT by handing to - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 2V~ day of ~ot ho~n0t ary So Answers: R. Thomas Kline 01/18/2002 MARK UDREN By: Deputy Sheriff REOULAR SHERIFF'S RETURN - CASE NO: 2002-00150 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CI/MBERLAND CHARTER ONE CREDIT CORPORATION VS GREENE MELISSA ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BEERS THOMAS the DEFENDANT , at 2030:00 HOURS, at 515 THIRD STREET WEST FAIRVIEW, PA 17025 on the 14th day of January , 2002 by handing to MELISSA GREENE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~¥ -- day of ~r6~hon6tary ' ~ So Answers: R. Thomas Kline 01/18/2002 MARK UDREN By: eputy Sheri fY MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Charter One Credit Corporation 2812 Emerywood Parkway Richmond, VA 23294 Plaintiff Vo Metissa Greene Thomas Beers 515 Third Street West Fairview, PA 17025 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-150 Civil Term PP. AECIPE TO DISCONTINu~ WITHOUT PRE~uuICE TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: Mark J. Udren, Esquire Mark J. Udren & Associates Attorney for Plaintiff