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Home My WebLink About01-2994FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION STANDARD FEDERAL BANK 4242 NORTH HARLEM AVENUE NORRIDOE, IL 60634-1283 TERM Plaintiff NO. (~)1 CUMBERLAND COUNTY ROBERT THRUSH 1009 ROCKLEDGE DRIVE CARLISLE, PA. 17013 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR A'I'rEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT ANI) SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. 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 TFI-~S PAPER TO YOUR 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 L.o~n #: 0608915881 I. Plaintiffis STANDARD FEDERAL BANK 4242 NORTH HARLEM AVENUE NORRIDGE, IL 60634-1283 2. The name(s) and last known address(es) of the Defendant(s) are: ROBERT THRUSH 1009 ROCKLEDGE DRIVE CARLISLE, PA. 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/2/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafu.~r described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1.548, Page 676 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mongaga due 1/1/01 and each month thereafter are due and unpaid, and by the terms of said mongaga, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $123,807.36 Intarest 3,351.60 12/1/00 through 5/1/01 (Per Diem $22.05) Attorney's Fees 4,000.00 Cumulative Late Charges 229.12 6/2/99 to 5/1/01 Cost of Suit and Title Search 550.00 Subtotal $131,938.08 Escrow Credit 685.03 Deficit 0.00 Subtotal ($ 685.03} TOTAL $131,253.05 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. §1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has tarminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $131,253.05, together with interest from 5/1/01 at the rate of $22.05 per diem to the date of Judgment, and other cnsl~ and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~ben recorded m~J..I.t, os STABDRDD IPBDnAL BMIE 2600 N. BTO B~AV~p. RD. TROrv J(:IC~'rG]uI 48084 LOAIr #s 608910881 MORTGAGE TH[$ MORTGAGE ("Security lnstmment") i$ si~n on o~.~B 2~ 1999, ROBERT 'fHRDSH, AB uIr~q]LRRZRD ~ Themorisagor~S This Security lnsm~ment is giveu to S'ZABDABO i~OERAL BA]IK, A F~DERAL SAVXiI~ BANK ("Borrower"). ~e~tin8 undo..the laws of WI~ UlIZ~BD ~'~ATr~ Of which is or~niznd sad whe~eaddrcssis 2600 w. B'rO BBA.~R RD., TA~RO~'~H?,~H.r(aAii ,8084 gorrowcr owcs Lender tile principa! sum of' ~ HUml)RED THZ ........ ("Lender"). (US ******* Dolhra · .- . $13A,000.00 )'Thi~debtisevid~ncedby~r~w~r.Sn~Mda(ndthes~me`~*~sthisSec~rity~ns~mm~t(.*N~te~)~ · · · . --~". ........ ~ ~. cvmcncca ny the No~ with imercs~, and nil ra:lew~s~ extcnsmns and mocliflC~ons of the No~, (b) thc paym~m of all other sums. with interesr~ ndv~ncnd ..fl~: paragraph 7 to pro~t the sccuri~y of Ms -_q,~_.rity lnstrun~nt; and (c) the perfonnanc~ of ~rower's covenants Xnstn~mmt and the Nots. For this purpose, Borrower do~s h~J~y moz~fe. Brant and con'nd a~mments under Ms Security property located in emm~RLABD ~ounty. Pennsylvan~:Lender the followir~ d~scrib~ "See [.egal R~tFtEO TO BE k TRUE AND CORRECT which hes the nddress of 10o9 ROC~LI~DG~ Pmnsyfvam 17013 ("Property Adt:b~s"); Isa-fei, CJty[. [z~p Codel PENIqSYLyANIA* Shll° FendY 'MqM'~i'HLMC UN IFORM INSTRUMKh'T Zn:tt::Lala s ~.,~."~ Fonu.ra.ls ~J'J0Amedd MI PaBe ! of TOGE'rH~. WI'fH all tl~ imp~.nis now or ~ ~ on ~[ ~ ~ e 608glS88Z ~ ~~ ~im u~ ~ ~r u~l ...... ' - ~ ~ ~n~ ~ wi~ ~ 1. Paint ~ Pff~ipal nd h~sq P~payment and h~ Chn~. flo~ ~I1 · . Fu~s m an a~m ~ to o~ ~ ~xm.m ~m a J~r ~ a g~lly ~ m~ hn ~y ~ui~ ~ t~ ~ ~n~ in ~ ~ tho ~iMm~u ~a~li~ble ~. If ~ ~m of ~ ~ ~M ~ ~ at a~ ~ ~ ~ ~ient to ~y ~e b Items wh~ d~, ~ ~ M ~ Bo~ tn ~dnA ~, in ~ ~ ~ shll ~y ~en~ at ~r's ~ d~tion. ~r~rshll ~mWydt~a~oa~h~whtch h~prtonty~ ~ [~l~u~r: (a) a~in ~tin8 S. ilazardorPruperh, lnmrnnce. Borro___L ........ LOAI J8 60891S88]. · .. -~,, Mm. ~ ~nc ~mprovemenu now exi~ing o~ hemf~r nmal on the Pmpmy mrdred against loss by fire, h~,o.ds included within the term "extended covcrag(' and any other he~,ls, including floods or flooding. J'or which Lender requires insurancc. This insuranc~ slmll be maimined in the amounts attd for the proofs that t.~ _-_,' requires. Thc inm~nce carrier providing thc insuranc~ shall be clmsen by Borrower subject to ~ p-,M,._.'s a~roval which shall not be unrfm..,,_.ubly Mthhe. M if*Borrower fails to maintain cov~rag~ described abort, Lender nmy, at Lemlcr's option, obtain covera~ to protect I.~nder's fights in I1~ Property in accordanc~ v,4th parngraph 7. pmulumsandrenewsIwif,~ fn,k...-.e.;ff__ ~,_ .~ .. . ----""~"vu'~uJ~lssvelOL,~lGerallreC~l~sof~dtM ma~makcprooror]ms~'n~nuid~pmmpllybyBorrow~. 8 pro pt md~emsurm~G~mndLender, g.~4,? *'~" ,em,~m;ml~iyxmmmeal~L.e~Cl. ssecunty~snotlessmed. Ifthe~----~onorrepairisnM wl~elner or not then flue, with anyexcess ~M 1o Bo..,.._. Tru ........ -7~'' ,,- .uu,a ....~a u7 U~is Mthm 30 days a flmice from Lender that the insurance canicr has off, red to settle a ~ ~ ~ ~ ~1~ ~ ~ proceeck. L~der ma), use the pro,'~_- to rcpair or r'=~4ore the Property or to pay sums secured by this Security inmument, whether or not then due. The 30-day period will begin when the notice is given. Unlcss L.end~ and Borrower otherwise afrec in writing, any application of proceeds to principal shall not extend or Imstpone the due dat," of the mommy payments refefl~d to in paragraphs I and 2 or change the amount ofthe paymems, if under paraSraph 21 the Property is acquired by Lender, Bonov~r's right to an)'insurance policies and proceeds ruulting from dama~c to the Properly · --~' ;, · · Man AppncaUon, Leaseholdt Borrower shah occupy, embhsh, and use the Property as Borrower's principal ruid~nc~ within sixty da~s afler the exec~on of this Security Instrument and shall continuc to o~'upy ~h~ Prope~ as Borrower's principal residence for at least one year al~er the da~ ~. occupancy, unless Lender oth~nme agrees in writing, which consmt shall not ~ unr~t--sonably withheld, or unless extenuating c~rcummnces exist which are beyond aorrow~'s conuoi. Borrower shall not d~troy, damage or impair th~ Propmy, allow d~ · '-"~-' "~'~-,' 'sm.qsalmjungn~ntc~nlMresultil~lO ' . the hen creat,~d by this Securi.,, v..+ ...... · ....... FAttu~of~l~ Propeflyor o~mvise nmtn~llyim~ir muarafmnh la h,.,~,,~.,...s,..~, ............. ty · Horrower may cur~ s~ch o d,-~_ult and reumnt~ as nrm,ld,.a or macc'"'a~ m;ormatm o.mem.na to j. end..(or t~a,ed to .rovide, ._,.o......_. _n~_M. i.. _ ~ ~e.utemUyfMs. ]°an evidaK:ed bY the Note. in,'*luding, but no~ limitM i~o, r "~'"~' ~'u' ~"Y ma~"naf mtormauon) in c~nnection with Ihe repruemtiom conceminf lk~'mw.,'s occupancy of the Propmy u a pnnclpal [uidmce ifth~s Security lnsln~mentls on a i~, _hold. ikh. Tower shah comply wltball theprovisions ofthe lease, if,~ acquires fee tifr~ to the Property. th," IcasehoM and the fee *itle shall not mer~ unless Lender a~-ees to the mcr r an wn 7. Protection of lender's RIsMs in Ihe Pro,,e~-. Ir'Bo ............ ge ' 'fln~ e. .- "uwr'a- mm to peri'onn tl~e covenanL$ and asreements contained in this m nccess~t~ lo pt..ecl (he value of'the Pro~r~ and Leflder's rJshls in th~ Properly. L,cnd~"s actions may inc]ud~ paying any sums ~'ured I~ a lien which has priori~ over this Secur~W Inslmmenl, appearing in coufl, peying r~somibl," ilorne~s' f'eu and enMrjnS °n I~ Pr°Pcr~ M nud[c repots. Although Lender ma~ lake 8ction under this ]xira~aph ?, ~ ~ ~ h~ M ~ M. Any amounlf ~ur~d by I.endu. under this para~nph 7 shall become addJbo~l debt or BoFrow~r s~u~d I~ this Sccu~y Inslnn~cnt. Unlcss Borrower and Lender aS~e ~o oth~. ~.ms of ~yrn~, tl~c amoun[s shah ~ Jnwul F~om the dale of disbursement ,,! Ih,' No~e ml~ 8od shah be payable, with inleresl, upon nMice fi'om Lender to Borrower requeslin~ paym~d InSurdnce cov~mSe required by LendcF laM or ccase~ to ~ in.effecl, ~ shall p~y th~ premiums requital Io dXaJn co~qe subsL~ntially Huiul."nl [o ~he mor~ insurance pl~"viously in ," f~-'~ a~ 8 cosl subslanfially equi~de~ Io Ihe cost ~o Bonuwer of the mortgage insurance previously in efl'ect, from an alternate mortgage insurer approv~ by Lender. If substantially cquivalmlt mortgage instwance coverage is not availabl,", Borrower shall pay to Lender each month a sum equal to one-twc]f~h of tim yearly approved bY Lender agnin becomes n. ailable o ............. '~ ~m ~or me perma trmt i.endcr rcqmres) provided by an imur~. and is obtaincd. Borrower shall pay the premiums required to maintain mort~ag~ PKNNSYLVANL~ Singb Family "~rMAA~HLMC UNIltORM INSTitUMgNT Tw~.f.~.13. l i ~ lrn 3o3~ 9~o Ameuded SOl Page 3 of 6 PALDEED insunrooa in effect, ortoprevideahiseruerve untiithe--uire ....... . LOM[ #~ 608915881 asreemnot be~on i~'mwer and t~nder or applicable law. gege m LL':~_ _-hnce ruth any wrote· ,.~., .w uK~ mor poor to an inspection specifying reasonable cause for ri~ inspection. ' "~""' 10. Condemnation..The proceeds of any award or clairo for dam··u, direct or consequential in court.iOn with any ~con~id ~.other taking of any pan of the Properly. or for conveyance in lieu of condemnation, aro hmsby ·ssi·nod and shall In the event of a total taking of the Property, the proceeds shall he allied to the sums secured by this Security tnsmm~nt, wheri~. or nnt then dno' Mth any excus Issid to Bonower. tn the ovent of· partial takin8 of the Proporty in which the Mr mrokct value of -----, ~,mw~ qfl~ mwn. ng, tn~ sums secured by this Secu. liy Insmnnem .shall he red,, _,.~_ by thc amoun/of Ihe proceeds roullipliM by Ihe followina fraclkm: (it) the loud amount of the sums secured IromMtetelybefore Ihe ~iJn& divMed b~. (b) ti? fmr roarhet value of tho Prolm~ tmmMtetcly boforc the Iddnf. Any balanc~ slu]l be paid. to B. orrowe~. In the cvenl of· part,~l ~kro~ of the Property in which thc hit roarhet vslue of the Pro~rty iromcdialely !he t~k, .ro8 te less Ihen the amount of'thc sums secured iromedlately before th,. taking, unless Borrower and Lender olherwisu agree tn wmrog or unless applicabla law otherwise provides, the proceeds slmll he applied to th~ sum~ s~'~ fed by fills Secority las~ument whcther or not the snms are thru dno. to collect and apply the proceeds, at its option, either to ..... , ....~ *..~.~_u.,a~..a~. cf..me (me me nm?~ ts gn~.n, tender isauthorisud tnsmnnont, whetter or not then dno. .,-,,,..,.,,., u. ~-palr mine t'ropet~ or to me sums ~ by this Security Ual,ss tender and Borrower roherwisu airne in writing, any application of proceeds to principnl shall not extend or postpone the duc date of the monthly payments referred to in paragrltphe I and 2 or chan~ the amount of coch payments ! !. Bor'~wer Not Rdex."ed; Forbearance By Lender Not · Waiver. Extenoion of the tin~ for payment (;r modification of amortintion of the sums secun:d by this Security [extru~ent ~'anted by Lender to any sucoexsor in interest of BQm~ shall not l-n°Pe~x:~litn°re]case thellability°fth~orinionlBorrm~r orBetrowe~'ssuccpssu~3inintores~ v --..L-- ........ by this .Secu~ty Imtmmonl by reason of' any dcm·nd . . "----~ -.--,-'.mmmmcsumsrocurod made by Ihe on_mn-! Borrower or Borrower's succassu~ in interest. Any fotheannc~ by lender in excrcisinf any right or ~msdy shell not he a wuivor of or preclud~ dm ex~ci . 12. Sueceuors and Asdges Bonnd; joiot ande .... , ........ .- . _ as of any risht or reroedy. Inslnnneot shell bind and benefit the ,n .-~-.,,,....d ._, ......... . .co~umm and spume·ts of this Secro~ Bonuwer s covenante and naraempnte th. II J.. ;..; .... .~ ....... . s~ thp. provrstoex of [~ro.uh !? execntc the Nnte-,-,-' ........ -"--'-~.' _ ...... ' q'; .~'s~nm~ rots ~econty inst~msnt only to mro~age, pant and,..,,._, that fl.___._' ........ i~!a~ ul~ ~rms of this Security lexlreroont; Co)is not porsunolly obit·ted to nnv *J,. ~. ',~' '.;,..~" .".~ 13, Loan Charges. - · , . . If the k~n secored by this Secomy Insmro~nt ts subject to a law which sets manirouro loan chrgu, and thet law is finally inte~-tM so Ilut Ihe inter,',=st or other loan cherge, collected or to he collected in connection with Ihe loan eAc~d the p~mitted limits, then: (a) any such loan cherge shell he red,,~__ by the amount necassmy to reduc~ the charge to the permittnd limit; and Co) any sums already collectnd from Borrower which excec~ permitted limits will he refunded to Borrowcr Lexdcr may eheo.~ to make this refund by fencing the pnnc~pal owed under b'~ Nalc or by linking a direct payment to Borrower. Ifa re. Amd redL,~ principal, the reduction will he irc·ted as a partial prepayment witlmut any prepayment charge under thc Note. 14. NoticeL Any noli~ to Borrower provid _p~_ for in this Secm'ity hmrom~,t sludl he given by de, lJv~ing it or by rustling it by first class mail unless applicable law requires uss of soot her method. The nolico shall be directed to the Property Address or any other clanned to heve heno given to Borrower or T ..,~_ _,.~ _: - - -" -' ,',~'.'~ "."""u Pmvmc~ xor ro tats :security ]nstnuncot shell he IS. Governing Lawl Severobility. This Secority Instmmeot.~utll he ~overned by fnd~rol law and the ]aw of the jurisdiction in which the Property is Iooated. in theevent that any provision or claore of this Secority ~slmronot or th~ Nnt~ conflicts wi~h applicobl,, law, such cooflict shell .... . conflicting provision. To·ct affect othor provisions of th~s Sec·lily Instrument or the Not- which can he given ~ect wlihant the 16. Borrower's Cop ry.hi'S end the provisione of'this Security Instrument and the No~ are d~lored to he sever·bls. Borrower shall he Siven one conformed copy of the No~ and of'II'is -q~cority lmtmment. ! ?o Transfer of Ihe Property or · Beneficial Interest in Borrowcr. Xf'sll or any part of the Property or any interest in it is sold or h'nosferred (or if · beneficial interut in Dorrowor is sold or tronsfrored and BroTm~t is no~ · nomrei person) without Lmdcr's prror wmtno consent, Lender may, nt tis optlno, reqroro Immedi,,t,- payment ro ~li of all sums secured by this Security lastmro~t. · · · . LO]d It 608915883, t~ ~U ~ FMm t~ ~M ~ ~ ~ ~iw.~ ~_..~ ..~.~' _~.-;-~ ...... ~ . c all ~ ...... z~ aM (d) ~b~ ~ ~n n ~ . -, .~-.~,~u~ m m imm ~ lO gsloflrN~ ...... ~ -- ---- ~a~lnl~of~]~on~r~h 17. ~ t~ c~n~ m ~ m~ ~ 14 ~ aM a~l~ law. ~ ~ w~l m t~ ~ aM ~ of t~ law. of[ . ~.. ~,~ "~ [~ ~ am~ m~s S~nn~ ~ En~ ~ w~Bo~~ k~ lfB~h~l~ or ~a~~t~n~fi~, or mh~ ~ ~a~ ~n~ S~ ~i~ t~ P~ is n~, ~ ~11 ~m~y ~ ~ in a~ wi~ En~ml ~w. · . . '~. . .?~,~ ~ m~mmmme or t~ ~lum p~, 20, "En~mn~l ~w*' mu~ f~ml lam and h~ oF t~ j~icdon w~ ~e P~ ~ I~ ~t ~late or en~Mn~ntal p~i~. NON-~I~ ~A~S. ~,~r a~ L~ ~u~her ~nl aM as~. fol~: 21. ~e~rath; ~d~ ~r ~ p~ ri.ice to B6;~ 5der p~r to a~leration r~l~laI Bo~r'l b~ ~y c~enanf or aR~ment Jo this SRuHiy [flat.merit (but nM p~or fo Reelection under pn~Rraph 17 un~u nppli~b~ law p~d~ othe~n~ ~d~ ~h~ Miry Bo~r ~, tmon8.~ thJnp: (a) the default; (b) t~ ~th ~qul~ M cuu the dda~t; (c) whm the ~nlt mu~ ~ cu~d; and (d) that f~lu~ M cum t~ ~adt u~ifl~ may ~lt ~ the mini ~ by ~ls ~urfty iuMmmenf, fo~uu~ ~ judld~ p~ing nd hie ~ tb Pupe~. ~er shall fuflher hro~ brewer ~e ~t M ~in~ a~r R~eH~ nd tb ~t M ~ in t~ ro~ p~in8 fu~er Wnd and may fo~ tbil ~ ln~Nnenl b~ jud~ p~O]n} ~r ~tll be ulitld ~S. ~ U~n ~l ~al] s~ ~ ~ this S~fity Inseam, ~is ~W lnstm~nt a~ t~ ~ll lermt~ ~ ~ ~ld. ~er such ~ L~r s~ll d~r~ a~ ~tis~ this S~ l~m~t ~t~t c~ to Bo~. ~r ~Jl ~ ~ ~t~n ~ ~fi~, ~[~ ~m att~mem, J~ a~ ~, and ~m~ ~mption. ~MM ~i Pa~ S ~6 p~ ~a2nn~em~ ~24. Refnpfe*-,,~_t Period. lkmower's lime to reias~l~ provided ia -'-----h 1- '" LOAll # t 608915881 °f.b. idd~n8 at a she~rs sale or o(her salc .,,.mmnt ._ .~:_ ~_ .P'm~aP.. s sn~ exlend to nac hnar prior to lac asemoneyMort,n~ If---,-,.,----,-- ~'-':_ ~,--soccuntymsmtment. r ~qzu3Y, UIIS C -~"--'rlt~ ~S~i shill k... =._L_ __ -" *'~"' '~ Jimuun~.'Ill IS I~llt IO JJorrower to j~auin. Nd. ,.~ ,L~ ,,,~ e Vu.~n~c Inalley illO~ -~. 26. Interest Rate Aftu'Judgment. Zk)rrowor a-tees that And .......... ns~:mcn ot each s~cn rider shall be in~nr~rsted ~ ..... ,~,L ..... ~'"s~ .~'T wzm una Sa:ority [Check a~)l'..t~, box(es)] " ....... '~ u Inc rmerts} w~o a part of ~hjs Security instmznut. ,-- ~ Adjustable Rate ~ [~ Condominium Rider ~ I OrndwtedPaymcntRJdcr ~ plnanedUnitD~RMer [~ l-4FamilyRida. · s Balloon RJder ~ Rate Improvuzent Riaor Biweekly Payment RM~r ~ V.A. ~ L.z~] Omcr(s) [specie,! legal Certificate of Residonce Z. oftl~ within-named A'IOFI~ is do busby ccrl~ that lite correct addnna 2600 #. BXG B~A. VBR RD., ~RD,, NxcIfTGAii 48084 Minus my lund this 2uc1 ay o~ June, 2999 COMMONWEALTH OF PENNSYLVANIA. County s~: On this, tbe 2r~ day ut' June, ].999 RI3~EIq~ THRUSH before me. ~ undel~jned ofF]cur, pel3onaJJy IIp~ .known to me (or smisfactorily Moron) to be Ibe persm Instnunent and acknowledf~d thru he whos~ name La sul~cribed to the I / / ~ MY Colrd~m jq/ml Mly ~0. ~O(~ Paje6 of'6 DATE: ~a~h2,2~l ACT 91 NOTICE TAKF ACTION TO SAVE YOUR HOME FROM FOI F, CLOSURE* This is an official notice that the mort~a~_o on your home is in defn_~!t~ and the ;~-=~:-:- int.--,:~ i.. fo~ciose. Specific information about the nnt,~e of the dt~fnnl~ is provided in the ~::~.-:._.M pno,~ .The HOMEOWNER'S MORTGAGE ASISTANCE PROGRAM (HEMAP) may be able t help to save your home. This Notice explains how the orogram work~ To see if HEMAP can hzlp~ you must MEET WITH A CONSUMF..I~ CREDIT COUNSFJ.INC AGENCY WITHIN 30 DAYS OF THIS NOTICE. Take this Notice with you when you i~-~t witl, the Counseling Agency. The name. address and telephone number of Consn__m_er Credit Cmmse!ing Agencies serving County are listed at the end of this Notice. If you have any a_-~_t_!_nns, you may call :_~- Pennsylvania HonMno_ Flnnnee Agency tall free at 1-800-342-2397. ( P~r-~ons with imp~e ' heading call (717) 780-1869. This Notice contains important legal information, if you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO ENSU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Robert Thrush PROPERTY ADDRESS: 1009 Rockledge Dr Carlisle PA 17013 LOAN ACCT. NO.: 060891~;881 GINAL LENDER: Standard Federal Mortgage Group CURBENT LENDE~SERVICER: ABN AMRO Mortpge Group EY,,HIB T A HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCAL 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 ASSISTANC~ IF YOUR DEFAULT HAS BEEN CAUSFA) BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSEURE---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 one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 130) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF TH~S NOTICE CALLED" HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCI~If you meet with one of the consumer credit counseling a~ency listed at the end of this notice, the lender may NOT take action against you for (30) days after the date of this meeting. The names, addresses nnd te]eohone numbers ofdesianated consumer credit counselina anencies for the county in which the nronertv is [ocated are set forth at the end of this Notice. It is only necessary to schedule one face-to.face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE~Your mortgage is in default for the reasons set forth later in this Notice (sec following pages for specific intbrmation about the nature of your default.) If you have tried and arc unable to resolve this problem with the lender, 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 MORTGAGE 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. Your application MUST be filed or postmarked within thirty (30) days of your face-to.face meeting. YOU MUST FILE YOUR APPLACATION PROMPLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHE TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE .WILL BE DENIED. AGENCY ACTlONMAvailable funds for emergency mortgage assistanee are very limited, They will be disbursed by the Aaenev under the elinibilitv criteria established bv the Act. The Pennsylvania Housinn Finance Anencv has sixty ¢60) days to nmke a dncision after it receives your auulication. Durinn that time. no foreclasure nroeeedinns will be oursued anainst you if you have met the time rnouirements set forth abeve. You will be notified directly by the Pennsylvania Hoasinn Finance Anencv of its decision on your aunlleution. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. ( If you filed for bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFALT (Bring It Up To Date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 1009 Rockledge Dr Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for thc following months and the following amounts are now past due: January, February, March Other Charges Late Charge $114.$6 TOTAL AMOUNT PAST $4,2SS.61 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not anolicable~: HOW TO CURE THE DI~FAULT--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 $4,255.61 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check, certified check or money order made oavable and sent to: ABN AMRO Mot~aee Gmun 4242 N. Harlem Ave.. Norridne. IL 607{}6 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) 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 mortoaee d,~ht: This means that the entire outstanding balance of this debt will he considered due immediately and you may lose your chance to pay the mortgage in monthly installments. If full payment of the total amount is not made within THIRTY (30) DAYS. the lender also intends to instruct its attorneys to start legal action to foreclose uoon your mort a ed ro rt . IF THE MORTGAGE IS FORECLOSED UPON-. The mortgage property will he 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 he required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However. if legal proceedings are started against you, you will have to pay -all reasonable attorney's fees actually incurred by the lender even if the exceed $50.00. Any attorney's fees will he added to the amount you owe the lender, which may also include other reasonable costs. If you cure the will not be reauired to nay attorney's fees. OTHER LENDER REMEDIES~The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE DEFAULT PRIOR TO SHERIFF'S ~;ALE.--If you have not cured the default within the THIRTY (30) DAYS period and foreclosure proceedings have begun, you still have the right tO cure the default and nmvent the sale at any time un to one hour before the Sheriff's Sale. You may do so by oavin~, th~ tarsi amount then hast due. nlus any late or other chert, es then due. renn,nnable attosnev's fees and costs conn~'Ct~vl with the foreclosure sale and any other costs connected with the Sheriff's Sale as snecified in writing, by ti'a lender and by oerformin~ any other reouirements under the mortoaoe Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHIERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six ¢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 coursa, 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: ABN AMRO MORTGAGE GROUP~ INC 4242 N. HARLEM AVEN~£ 1-800-544-8012 OR 1-708-4S2-1330 Fax Number: 708-456-8S.9~ 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 he started by the lender at any time. ASSUMPTION OF MORTGAGF,--You may or may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR 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 CALENDER YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWsurr INSTrFUTED 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 CQUNTY (See Attached) PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES o (REv. L3~oming-Clinmn Counties Commisioo ~ CCC$ of NonJwastem PA Community Action (STEP) 1631 Sou~t Alhmon St., Suite 2138 Lincoln Sucar P O. Box 1328 Ste= Colln~e, PA 16801 Williamspo~.. PA 17703 (814) 238-3668 FAX (814) 238-3669 (570) 326-0587 FAX (570) 322-2197 CCCS of Nonhenstern PA 201 Besin Struet Williaorspo~ PA 17703 (570) 323.0627 FAX (570) 323-6626 31 W Market Street 1400 Abington Executive Park POB ] 127 Suite I Wilkes-Bane. PA 18702 Clark SummiL PA 18411 (570) 821-0837 or (800) 922-9~37 (570) 587-9163 or (800) 922-9537 FAX (570) 821-1785 FAX 1570) 587.0134-91.15 Commission on Economics Opportanity of Lu~earue County 16.t .am~bet Lane Wilkes-Bane. PA 18702 (570) 826.0510 or (800) 822.0359 FAX (570) 829-166~--(Ca~! Before Faxing) (570) 455-4994 Hazeltovm FAX (570) 455-563 I---(Ca~l Befo~ Faxing) (570) 8.16.4090 Tunkhanoo~k Booker T. Weshingmn Center Greaart Erie Community Action Commktee 1720 I-fo[land Center 18 West 9a Slrear Erin, PA 1650.1 Erin, PA 16501 (814) 453-5744 FAX (814) 5749 (814) 459-4581 FA.,~C (814) 456-0161 John F. Kennedy Center. Inc. $henango Valley Urban League. Inc. 2021 East 20a Slreet 601 Indiana Avenue Ena, PA 16510 Farrell. PA 16121 (814) 898-0400 (412) 981-5.110 FAX (814) 898-1243 ND CCCS of Western Pennsylvania, Inc. Financial Counseling Services 2000 Linglestovm Read 31 West 3'~ Slreet Han~sburg. PA 17102 W&ynesboro, PA 17268 (717) 541-1757 (717) 762-3285 Urban League or' Melropolilan I'~1~sburg YWCA ot'Ceslisle N. 6a Suuet 301 "Oq $~ruet Hamsburg, PA 17~01 Cadlslo, PA 1701.1 · (717)234-5925 FAX(717)2.14-9450 (7(7)243-.1818 FAX(717)731.0589 Community Action Corem of the Capitol Region Adanu Coooty Housin8 Authority 1514 De~y Street 1.19-143 Carlisle St. Ha~sborg PA 17104 Gettysburg PA 17325 (717)2.12-9757 FAX(717)234-2227 (717)334-1518 FAX334-8326 PENNSYLVANIA BULLETIN, VOL. 29, NO. 23, JUNE S, 1999 F_.XHU3 T A Count,, P~n:~ania, mar. psrCioularly bounded and described as follows, ~ha.back road to Mt. Nelly, whlGh point is No=Ch 17 degrees 20 ~e road known aa ~ha 'back road to KC. Nolle' and ~he Nor=hem ·ne o~ a propomed S0 £oot street, which poin~ ia also the 40 minutes 250 feaC ~o a SU~JBCT =o res~riotions and covenants oon~ained in prior instruments' of record. of Deed~ of Cumberland County, ~ennsylvania, ~n Dead Book PB~ISES ON= ~009 R0~.~T~E 9HI~E PATRICIA SRAGA hereby statestl---~ ~is VICE PRESIDENT of ABN-AMRO MORTGAGE GROUP, INC. mortgage set~'icing ,,gent for Pl,,infiff in this matter, that he is ,mthorized m take this Verification, and that the statements made in the foregoing Civil .action in Mortgage -- Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this s~atement is made subject to the penalties of 18 Pa. C.5. Sec. 4904 relating to unswom falsification to authorities. SHERIFF'S RETURN - REGULAR CASE NO: 2001-02994 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STANDARD FEDERAL BANK VS THRUSH ROBERT DEP DAVE MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon THRUSH ROBERT the DEFENDANT , at 1701:00 HOURS, on the 31st day of May , 2001 at 1007 ROCKLEDGE DRIVE CARLISLE, PA 17013 by handing to ROBERT THRUSH a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 3.10 _~~~~ Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 31.10 06/01/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: i~ i/~/-~/ __~ me this ~- ~ day of Deputy She2.iff SHERIFF'S RETURN OF SERVICE Plaintiff(s) CIVIL ACTION NUMBER STANDARD FEDERAL BANK SHERrFF*S NUMBER Defendant(s) ROBERT THRUSH COST MILEAGE DISTRICT Serve At 1009 ROCKLEDGE DRIVE __ Summons xx Complaint CARLISLE, PA. 17013 __ Other Special Instructions TYPE OF ACTION Mortgage Foreclosure TO BE COMPLETED BY SHERIFF Served and made known to ., Defendant, on the __ day of , 19 , at __ o'clock, _.m., at ., County of , Commonwealth of Pennsylvania, in the manner described below: Defendant(s) personally served. Adult family member with whom said Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. and officer of said Defendant company. Other: SHERIFF By: ~ Deputy Sheriff On the day of ,19 j at o'clock, _.m., Defendant not found because: Moved _ Unknown _ No Answer _Vacant_Other SHERIFF By: , Deputy Sheriff DEPUTIZED SERVICE Now, this day of .19 , I, Sheriffof County, Pennsylvania do hereby deputize the Sheriff of County to serve this Complaint and make return thereof and according to law. SHERIFF By:. ., Deputy Sheriff A'I'IORNEY FOR PLAIN~FF: TO BE COMPLETED BY ROTHONOTARY Name Frnnk ~od~nnn. l:~.-ire A'I-FEST Id. No. ~ Pro Prothy Adckess C~ne Penn C'~nter nt ~l]h~trhnn ~tntiqn 1617 Jnhn F Kennedy Rnl~l~vn~-I: .qtfim 1400 Date Ph/lnd,,.l?hin: Pa 1 q I By:. FRANK FEDERMAN Identification No. 12248 One Penn Center at Submban Smiio~ Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff STANDARD FEDERAL BANK : CUMBERLAND COUNTY 4242 NORTH HA~I.~M AVENUE : NORRIDGE, IL 60634-1283 : COURT OF COMMON PLEAS Plaintiff : : CML DMSION VS. : NO. 01-2994 CML TERM ROBERT THRUSH : 1009 ROCKLEDGE DRIVE : CARLISLE, PA 17013 : : Defendant : : PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO ~ ?RO~-~ONOTAR¥: g~dly enter judament, in rcm, in favor of the Plaintiff and against ROBERT THRUSH, Defendant, for failure to file an Answer to ?laintiffs Complaint w~rhl. 20 da~s from service thereof and for foreclosure and sale of thc mortgaged prcrr~cs, and assess ?la~ltiffs damages as follows: As'set for~ in Complaint $131,2S3.0S lntc~st S/l/01 TO 7/3/01 $1~411.20 TOTAL S132,664.2S I hereby ¢~ify that (I) the addresses of the ?laintiffand Defendant arc as shown above, arid (2) no~ce has been ~ven in accorchncc w~th Rule 237.1, copy attache. FRANK FF_.DERMAN, ESQUIRE Attomqr for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~'~.~ b .~0-O! PRO SHERIFF'S RETURN - REGULAR CASE NO: 2001-02994 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STANDARD FEDERAL BANK VS THRUSH ROBERT DEP DAVE MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon THRUSH ROBERT the DEFENDANT , at 1701:00 HOURS, on the 31st day of May , 2001 at 1007 ROCKLEDGE DRIVE CARLISLE, PA 17013 by handing to ROBERT THRUSH a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 31.10 06/01/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By:~ me this day of ueputy Sheriff A.D. Prothonotary FEDERMAN AND PHELAN, L.L.P. -Frank Federman, Esquire Identification No. 12248 ATTORNEY FOR PLAINTIFF One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 STANDARD FEDERAL BANK : COURT OF COMMON PLEAS : CIVIL DIVISION vs. : CUMBERLAND COUNTY ROBERT THRUSH Defendant(s) : NO. 01-2994 CIVIL TO~ ROBERT THRUSH oo, FILE COPY CARLISLE, PA 17013 DATE OF NOTICEs ~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. You are in default because you have failed 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: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 L~ERTY AVENUE CARLISLE, PA 17013 (717) 249~ 166 ~rank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Perm Center at Suburban Station Suite 1400 Philad~lph~, PA 19~03-1814 (21 S) 563-7000 Attorney for Plaintiff STANDARD FEDERAL BANK : CUMBERLAND COUNTY : Plaintiff : Conrt of Common Pleas ; v~. : CIVIL DMSION : ROBERT THRUSH : NO. 01-2994 CML TERM : Defendaat : ; VERIFICATION OF NON-MIl.WARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailor' Civil Relief Act of Congress of 1940, as amended Co) that defendant ROBERT THRUSH is over 18 years of age and resides at 1009 ROCKLEDGE DRIVE, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FI~AN~ FEDERlV~AN - Attorney for Plaintiff (Rule of Civil Procedure No. 236- Revised) STANDARD FEDERAL BANK : CUMBERLAND COUNTY : Plaintiff : Court of Common Pleas : vs. : CIVIL DIVISION : ROBERT THRUSH : NO. 01-2994 CML TERM : Defendant : : : Notice is given that a Judgment in the above captioned matter has been entered against you on JULY ¢ ~ 2000. If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Hling Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1514 (215) 563-7000 **THIS FIRM IS A DEBT COI.I'.I~CTOR A-FI'Ii;MPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED Wn.[. BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND 'l'mS DEBT WAS NOT REA. e'~'mMED, THIS IS NOT AND SHOULD NOT BE CONS'i'RUED TO BE AN A'i-i'scAfl)T TO CO'i'.! .izCT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 STANDARD FEDERAL BANK : CUMBERLAND COUNTY Plaintiff, : v. : No. 01-2994 CIVIL TERM : ROBERT THRUSH : : Defendant(s). : TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $132,664.25 Interest from 7/3/01 to 12/5/01 $3,380.55 and Costs (per diem - $21.81) TOTAL $136,044.80 SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property. No. ALL THAT CERTAIN lot of ground with improvements thereon erected situated in the Township of South Middleton, Cumberland County, Pennsylvania, more particularly bounded and described ~ follows, to wit: BEGINNING at a point in the center of the road leading from the Walnut Bottom Road to Nit. Holly Springs, locally known as 'the back road to Mt. Holly", which point is North 17 degrees minutes East 440 feet from the intersection of the said center road known as the "hack road to Mt. Holly ' and the Northern line of a proposed 50 foot street, which point is also the Northern line of property now or formerly of Theodore S. Grissinger and Rena V. Grissinger, his wife; thence along the center line of the said road North 17 degrees 20 minutes East 180 feet to the Southern line of land of Earl B. Swarner and wife: thence along the line of the latter South 72 degrees 40 minutes ......- East 250 feet to a point; thence South 17 degrees 20 minutes West 180 feet to a point on the Northern llne of land now or formerly of Theodore S. Grissinger and wife aforesaid; thence along the line of the latter North 72 degrees 40 minutes West 250 feet to a point, the place of BEGINNING. TAX PARCEL #40-23-0602-032 TITLE TO SAiD PREMISES IS VESTED IN Robert L. Thrust by Deed from Richard M. Brown and Linda 1. Brown, formerly Linda J. Ryan, Husband and Wife dated 7/2/1997, recorded .~ 7/21/1997, in Record Book 161, Page 351. FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12240 ATTORNEY FOR PLAINTIFF Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 STANDARD FEDERAL BANK : : CUMBERLAND COUNTY Plaintiff, : COURT OF COMMON PLEAS : CIVIL DIVISION ROBERT THRUSH : : NO. 01-2994 CIVIL TERM Defendant(s). : CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. NK FEDE~rsAN, ESQUIRE Attorney for Plaintiff STANDARD FEDERAL BANK : CUMBERLAND COUNTY Plaintiff, : : No. 01-2994 CIVIL TERM ROBERT THRUSH : : Defendant(s). : August 7, 2001 TO: ROBERT THRUSH 1009 ROCKLEDGE DRIVE CALISLE, PA 17013 **THIS FIRM IS A DEBT COLLECTOR ATl~EMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIR-MED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 1009 ROCKLEDGE DRIVECALISLE, PA 17013is scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by STANDARD FEDERAL BANK (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the MARCH 6, 2001 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: ~ 2. 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 ttae 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.) ~~~A~.L.E__TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DO~ I. If the Sheriff's Sale is not stopped, your properly will be sold to the highest bidder. You may find out the price bid by calling (21 $~ $63-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff.the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. · 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner o£the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriffgives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a shale 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 Sheriffwithin 30 days of 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 (I0) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act irrwaediately aRer the sale. ~, ~;U TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9! 08 STANDARD FEDERAL BANK : : CUMBERLAND COUNTY Plaintiff, : : COURT OF COMMON PLEAS ROBERT THRUSH : CIVIL DIVISION : Defendant(s). : NO. 01-2994 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (.Affidavit No. 1) STANDARD FEDERAL BANK, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praccipe for the Writ of Execution was filed the following information concerning the real property located at 1009 ROCKLEDGE DRIVEC?,! JISLE~ PA 17013 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ROBERT THRUSH 1009 ROCKLEDGE DRIVE CALISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whoso judgment is a record lien on the real property to be sold: NAME. LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please 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 LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiffhas knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 1009 ROCKLEDGE DRIVE CALISLE, PA 17013 Domestic Relations of Cumberland 13 North Hanover Street County Carlisle, PA 17013 Commonwealth of Pennsylvania PO Box 2675 Department of Welfare Harrisburg, PA 17105 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. Sec. 4904 relating to unsworn falsificatioR t_o au~ August 7, 2001 F~~ FEDE~AN DATE , ESQUIRE A'ttomey for Plaintiff AFFIDAVIT OF SERVICE PLAINTIFF STANDARD FEDERAL BANK CUMBERLAND COUNTY No.01-2994 CIVIL TERM DEFENDANT(S) ROBERT THRUSH Type of Action SERVE ROBERT THRUSH AT - Notice of Sheriff's Sale 1009 ROCKLEDGE DRIVE CALISLE. PA 17013 Sale Date: DECEMBER $, 2001 SERVED Served and made known to ~XC)~)',~f,.~'- "~Xt','''/'3~'x .Defendant. onCe ]~ ~ dayof ~,200~, of Pennsylvania. in the ~er described below: ~ De~ndam pe~omlly se~ed. ~ Adult fan~ly member with whom Defendants) reside(s). Relationship Adult in charge of Defendant(s)'s residence who reused to give name or relationship. Mac,er/Clerk of place of lodging in which Defendant(s) ~side(s). Agen~or person in charge of Defendant(s)'s office or us~l place of busi~ss. an officer of said Defendant(s)'s company. Other: Descrip,ion: Age ff~ Height~ Weight~5~ Race ~ Sex ~ Other I ~a~e~ ~, ¢~7 ~co~etent adult, beMg duly sworn accoMing to law. d~ose ~d state t~t I pe~o~lly ~nded ~'~e and co.et copy of~e Notice of ShefiWs Sale in ~ ~er as set b~h ~reM, issued in the captioned e~e on &e date and at the address indicated a~ve. I ~dal ot'~. 2001. , / On the ' day of ,2~ , at o clock .m., Defen&nt NOT FOUND because: ~.ioved ~. U~own~ No Answer ~ Vacant O~hzr. Sworn ~o and sub :"~ ibed retire me thi~ Nozaz5: Attorney for Plaintiff Frank F~erman, Esquire - iD. No. 12148 One Penn Center Suburban Slafion, Suite 1400 Philadelphi~ PA 1910] (215) ~-7000 Standard F~eral Bank In The Court of Common Pleas of VS Cumberland County, Pennsylvania Robert Thrush Writ No. 2001-2994 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is return~ STAYED pursuant to instructions from Attorney Frank Federman. Shoriff's Costs: Docketing 30.00 Surcharge 20.00 Posting Handbills 15.00 Law Library .50 Prothonotary 2.50 Shar~ of Bills 25.66 Mileage 6.50 Levy 15.00 Advertising 15.00 Certified Mail 1.11 Poundage 2747.15 Postpone Sale Law Journal 265.40 Patriot News 206.94 $3350.76 paid by attorney This ]~ ~ day of~ R. Thomas Kline, Sheriff Prothonotary Real Estate Deputy STANDARD FEDERAL BANK : : CUMBERLAND COUNTY Plaintiff, : v. : COURT OF COMMON PLEAS : ROBERT THRUSH : CIVIL DIVISION : Defendant(s). : NO. 01-2994 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) STANDARD FEDERAL BANK,. Plaintiffin the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1009 ROCKLEDGE DRIVECALISLE~ PA 17013 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ROBERT THRUSH 1009 ROCKLEDGE DRIVE CALISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME. LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None REAL ESTATE SALE'No. v,, Sept:. XO, ~OOX thesMrifllsvieduloontl~edmefl~nu, intlrelt in the real property situated in .~,~.~h Middleton..Township Oumbllrllfld County, Pa., kno.,, qnd nunlboIld~: ~oo9 c~is~e and more fLJl' ,~cri~ on this walt dad by this ~erence THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1~29 Commonwealth of Pennsylvania. County of Dauphin) ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounte 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 P-.~zLg..t:[~ and The Sunday Patriot. New~ 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. respective,y, and all have been continuous,y published ever since; That the printed notice or publication which is securely attached hereto Is exact,y 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 unanimous,y passed and adopted severa,ly 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 Dauphines4 .Mlscellaneous Book "M", Volume 14, Page 317. PUBLICATION ~ COPY s~ .......................... ~ ........................................................ o~ to and ~"b~k, ...... :L:c~gth d~f N~mber 2001 A.D. ' ho ^R¥ PUBLIC 7 · w My commission expires June 8, 2002 Aat':. Fr~ W ~ CUMBERLAND COUNTY SHERIFFS OFFICE ~ ~ Ca~t t~ ?..;,L=l,. '~ CUMaF_RI.N~D(Z)UNTY COURTHOUSE s~,,,~=,o~_,~'~ Statement of Advertising Costs .~ea~j~440~em~.~m=~','"'- hereto on the above stated dates ~/~,~,~'~.~f~ Prebating same Nota~ Fee(s) $ 1.50 ~ r~ o~ ~ ~' ~ $' Total $ ~08.g4 ..~?.~,_,.~.s.~,~,~s=~ Publisher's Receipt for Advertising Coat C..iI~"~ ~t~ a,a~ckn12ow~ed~0;'Pr:cblel~phterofO:h~and~~ .' ,newspapers of genera, been duly paid. noace ano pure,cation costs and certifies that the same have 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 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, 19S2, 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 .lournal 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. 2001-2994 Civil Standard Federal Bank vs. RoJ~er M. Morgenthal, Editor Rober~ Thrush Atty.: Frank Federman SWORN TO AND SUBSCRIBED before me this ALL THAT CERTAIN lot of ground with Improvements thereon erected 26 day situated in the Township of South Mlddleton, Cumberland County, Pennsylvania, more particularly ~ L .~ ~..~ bounded and described as follows, .~ j . ~' / tO wit: l~].t d B ..,.Oat a.oint ] ter of the road leading from the LOIS ~.~}~¥;.-~, ;:?~':t;'! Walnut Bottom Road to Mt. Holly Cgff~sb.',~ O.~.e; · Sprin~.s. locally known as 'the back · ' ...... road to Mt, Holly," which point is f North 17 deg~es 20 minutes East 440 feet from the intersection of the said center road known as the 'back mad to Mt, Holly' and the Northern line of a proposed 50 foot street. FEDERMAN AND PHELAN By: FRANK FEDERMAN~ ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION ATTORNEY FOR PLAINTIFF PHILADELPHIA, PA 19103 ~215~ 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION STANDARD FEDERAL BANK 4242 NORTH HARLEM AVENUE NORRIDGE, IL 60634-1283 v. NO. 01-2994 CIVIL TERM ROBERT THRUSH CUMBERLAND COUNTy PRAECIPE TO MARK JUDGMENT SATISF~Er TO THE PROTHONOTARy: Kindly mark judgment in the above captioned matter~a.i~fi~d~ your costs only December 3, 2001 FRANK FEDE~IAN~ ESQU~