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Home My WebLink About01-3290FEDERMAN 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 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150, HORSHAM, PA 19044 TERM Plaintiff NO. CUMBERLAND COUNTY JEFFREY I. PAUL 1906 LOGAN STREET, CAMP HILL, PA 17011 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR A'FFEMPTING 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 AND 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 THIS 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 Lonn #: 306586431 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 1~ U.S.C. § 1692 et seq. (197'0, 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. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVEI~ IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (TItROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. 1. Plaintiff is: GMAC MORTGAGE CORPOP~A. TION SOO ENTERPRISE ROAD SUYFE 150, HORSHAM, PA 19044 2. The name(s) and last known address(es) of the Defendant(s) are: JEFFREY 1. PAUL 1906 LOGAN STREET, CAMP HILL, PA 17011 who is/are the mongagnr(s) and real owner(s) of the property hereinafter described. 3. On 1 I/13/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinai~er described m ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office ofthe Recorder of CUMBERLAND County, in Mortgage Book No. 1497, Page 972. By Assignment of Mortgage Recorded 7/28/99 the mortgage was assigned to PLAIN'I'll· which Assignment is recorded in Assignment of Mortgage Book No. 620, Page 393. 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 mortgage due 2/1/01 and each month thereai~er are due and unpaid, and by the terms of said mortgage, 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 $101,381.68 Interest 2,352.24 1/1/01 through 5/1/01 (Per Diem $19.441 Attorney's Fees 4,000.00 Cumulative Late Charges 138.92 11/13/98 to 5/1/01 Cost of Suit and Title Search 550.00 Subtotal $108,422.84 Escrow Credit 394.06 Deficit 0.00 Subtotal f$ 394.061 TOTAL $108,028.78 7. The attorney's fees set forth above are in conformily with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs 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 terminated 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 ofwhich 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 $108,028.78, together with interest from 5/I/01 at the rate of $19.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. Attorney for Plaintiff RrM Mortgage Lo~ ~e~t~g .................................. PO Box 85071 San DiegoCA 92186-5071 GMACMortgage 3451 Hammond Ave PO Box 780 Waterloo IA 50704-0780 Date: April 11, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Tbis is an official ooticc thai the mortgage.on ypnr .hqm. e is_ip_defa.ult, and the lender kiteo_d s !_o..fprccloso. Speci_~g hifpr_matlon about the nature of the _dgfault is provided iu the attached i)age~. The .I-IO_M.~:O~'NER'S MOI~TG_A_(;_F.. A~SIS'rANCE PRO(;R,~M {!1E.M_A.P) may be able to help to save your home. This Notice explains how the Drogram works. To see if HEMAP can he[p_,yon mast MEET WH'D A CONSUMER CREDIT (~.O__U_NS_'E_I._IN(; _A. GE~CY WITIIIN 30 DAYS OF THE DATE OF Tills NOTICE. Take this Notlee _wit. h you .w__h_en yon mee.t wi_t_h th.__e Counselin~ Anencv. The name, address and phone number of Consumgr_C__re_d_i_t__Cou_n_sc_l_i_ng _Agencies sorvlng your Countva~e listed at the end of thiLNotlce, l_fyou have a__ny qnc~b'o_P_% y_og_ma__y.c_al_[~tke Pen~!y_l_van_ia_ llousln g _Fiaa. a.ee ~011 free _at_L-S0__0:_34_2_-2_3_9'/. (persons _w_ith tm. paired hganng can call This Notlee eontalus important leRal iufonnatlon. If you have any questions, represontatlves at the Consumer Credit Counselluz Ageu~' may be able to help explain il. You may also want to contact an attorney ia )'our area. The local bar association may be able to help you find a lawyer. I,A NOTIFICACION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AI.'ECfA SU DERECIlO A CONTINUAR VIVIENI}O EN SU CASA. SI NO COMPRENDE El, CONTENII)O DE ESTA NOTII.'ICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE I,I,AMANDO ESTA ACENCIA (PENNSYI,YANIA llOUSING FINANCE AGENCY) SIN CARGOS Al, NUMERO MENCIONAI}O ARRIBA. PUEDES SER I{I,EGIBI,E PARA UN PRF. STAMO POR El, PROGRAMA I.I,AMADO "HOMEOWNER'S EMER(;ENCY MORT(;A(;E ASSISTANCE PRO(;R.~M" El. CUAI, PUEI)I.'. SAI,VAR SU CASA DE I,A PERI}IDA DEL DERECIIO A REI)IMIR SU IlII'OTECA IIOMEOWNER'S NANIE(S}: JEFFREY I. PAUL 1906 LOGAN fit PROPERTY AI)I)RI,'.SS: CAMP Ribs., PA 17011 I.OAN ACCT. NO.: 306586431 ORIGINAl, I,ENDER: N/A CURRENTI,ENI)ER/SERVICER: GMAC Mortgage Corporation IIOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAy_ BE EI,IG. IBIoE FOR FINA_NCIAI, ASSIST_AN_CE. WHI_CI_I__CAN SAVE YOUR IIOME FROM FORECI,OSURE AND IIEI,P Y_QU_ .b_IAK.I..;...I,_'._U_TURE MO_R~.'(.~AGE.PAYb_!ENTS IF YOU COMPI,Y WITII TilE PROVISIONS OF TIlE llOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (Tlli.~ "ACT"), YOU MAY lie Ei,IGIBI,E I.OR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR I)EFAUI,T llAS BEEN CAUSED BY CIRCUMSTANCES YOUR CONTROl°, IF YOU RAVE A REASONABI,E PROSPECT OF BEING ABI.E TO PAY YOUR MORTt'7'AT; E PAYMENTS, AND IF YOU MEET OTHER EI,IGIBIIoITY REQUIREMENTS ES'I'ABI,ISH El) BY TilE PENNSYI,VANIA IIOUSING I.'INANCE AGENCY. TEMPORARY STAY OF FORECI,OSURE .. [!nder thc Act. you are entitled to a temporary stay of foreclosnre on yoor mortgaga for thirty (30) days from the date of this Notice. During that time you mum arrange and attend a "face-m-face" meeting with one of the consumer credit coun.~ling agencies listed at the end of this Notice. Tills MI.:ETING MUST OCCUR WITlilN Tile NEXT (38) I}AY$._II_" ~.O.~,~ !X) NQT APPI,Y FOR EMF. RGENCY MORT(;AGE ASSIS'I3NC]';. YQU.~I_~IST BRLN.(.i ~' _O.~.} R M OR~I_'(_;AG E UP '_I'_O_ l)..t~'l'E: ~1'11~ 1'6R_T OF Tills NOTICE (:AI.I,ED "IIOW 1'O CU.R_E y_QI!.R ~,~OR_'I'GAGE D]~..FAU~.~TI'~ EXPI.LS, JNS. HOW TO J~RIN¢; Y_O.~JR MORTGAGE UP TO DATE. CONSUMER CREI)IT COU_N.~EI,I~.G .A.G ENCIES -- If you meet with one of the conaimer c.r~dit counseling agencies limed at the end of this notice, the lender may NO']' take action againm you for thirty (30) days after the date of this meeting. The names, addres.~s an_d_tel _ep_h~_n;. mm}h~rs of de sign_at.e._d.con.s~_m~r c~:dit co~mseling age_~gies for the county i.n. ~_v. hi.c.h_.thc pr0pc0.y i~ lo_9_a~e_d Ore .~_.t t~mh at thc end of~his Nc~tice. It is only necessary to schedule one face-to.face meeting. Advi~ your lender immediately, ofym~r intentions. · APPI,ICATION FOR MORTGA(;E ASSISTANCE -- Your mortgaga is in default for the reasons ~t fotlh later in this Notice (see following pages tbr specific information about the nature of your default.) If yon have tried and are unable to ~.,olve this p~hlem with the lender, yon have the right to apply for financial assistance from the Ilomeowncffs Emergency Mortgage Assistance P~t~gram. To do ~, ym~ mum fill out. sign and file a completed ] lomeowner~s Eme~gancy Assistance Program Application with one of the desi~ated consumer credil counseling agencies lisled at the end of this Notice. Only consumer credi! coonseling agencies have applications for the program and they will assist you in .~thmitting a complele application to the Pennsylvania Honsing Finance Agency. Your application Ml~S'l' be filed or postma~ed within Ihirly (30) days of ym~ face-to-face meeting. YOU MUST FII,I.'. YOUR APPI.ICATION PROMPTI,Y. II.' YOU FAll, TO DO SO OR IF YOU I)O NOT Fei,LOW TIlE OTllER TIME PERIODS SET FORTll IN Tills I,E'I'I'ER, FORI.'.CI,OSURI.; MAY PROCEED AGAINST YOUR IlOMI.: IMMI.',I}IATEI,Y AND YOUR APPI,ICATION FOR MORTGAGE ASSISTANCE WII.I. BI,', I}ENIED. AGENCY ACTIO.N.' .- Available fimds Ibr emc~ency merlin, age assistance are ve~. limiled. They will he disbnrsed by the Agency under the eligibility criteria established by the Acl. The I'ennsylvania Ilousing Finance Agency has sixty (60) days to make a decisinn after il receives your applicatim~. During that time, no foreclos-ure proceedings will he pursued against ycm ifyou have mci thc time requi~'mcnls set forth above. You will bc notified directly by the Pennsylvania llousing Finance Agency of its decision on your application. " NOTE: IF YOU ARE CURRENTI,Y PROTECI'I.:I) BY TIlE FII,IN(; OF A PETITION IN BANKRUPTCY, TIlE FOI,I,OWING PART OF 'I'.ilIS NOTICE IS FOR INFORMATION PURPOSES ONI,Y AND SIIOUI,D NOT BE CONSIDERED AS AN ATTEM}~[' TO COLLECT ']['RE !)EB'I'. (If you have filed bankruptcy you can stnl apply for Emergency MortF, age Asssatnnce ) HOW TO CURE YOUR MORTGAGE I)EFAUI.T (B_Fin[Lii__np t~ date.). NATURE OF TIlE I}EFAUI.T -- The MORTGAGF. debt held by the above lender is on your property located at: 1906 Loqan St Camp Hill, PA 17011 IS SERIOUSLY IN DEFAULT because: YOU HAVI': NOT MAI)}'. MONTH] .Y MOI;,'I'(;A(;E ]L:%YM ENTS IhT thc following months and the following amounts are now past due: February 1, 2001 throuqh April l, 2001. See attached Exhibit for payment breaRdown. Monthly PaymenW'- 2,846.73 I ate (~bargcs 6 9.4 6 NSF 0.00 Inspections 7.25 Other Suspense 0.0 0 TOTAl, AMOUNT PAST DUE: 2,923.44 B. YOV I IAVI{ FAll .El) TO 'I'AKI{ Till.. 1;O1 .I .OWING A('TION (Do not use if not appJj_cah!e.): ROW TO CURE TIlE I}EI.'AUIoT .. You may cur~ the default within TIIIRTY (30) DAYS of the date of this notice BY PAYING ]'HE TOTAl, AMOUNT PAST DUE TO THE LENDER, W]IICII IS $ 2,923.44 , PI.US ANY MORTGAGE PAYMENTS ANI) I.ATF. CIIARGES WIIICII BF. COME DUF. I)URING TIIF. '1'111R'I%' (30) DAY PERIOD. Payrnents mnst be made either by cash~cashiefs check, certified check or money onler made payable and sent to: Palnnen ~ Processin~ GMAC Mortqage Corporation PO Box 780 Waterloo, IA 50704-0780 You can cnm any otber del.~nlt by taking the fbllowint~, action within TI IIRTY (30) DAYS of the dale ofthis letter: f-~-JLgt P'-~ if-rig! -apl}lJg{d)le") Not Applicable IF YOU DO NOT CURE TIlE DEFAUI.T -- Ifyou do nnt cure thc default within TIIlR]3' (30) DAYS of the date of this Notice, the lender intends to exerelse i~s rights to aeeelerute the mort g,a_Re debt. This means that the entire outraanding balance of this debt will be considered due immediately and you rna~-Fo~-~"~'cbance to pay the mortgage in monthly inaalhnents, lffidl payment of the total arnrnmt past due is not made within TIIIRTY (30) DAYS, the lender also intends to h~nrnci its attorneys tn start legal action to foreclose npo_n..~,:.o.9_r, ra_o~Ra_l!e.d_ property. IF Tile ~(_}RT_Gc~G ~; IS I:OR_.EC. l.OSl'~]l u~O.N -- Tbe mortgaged property will be ~ld by the Sheriff'to pay off the mortgage debt. If the lender refers your ca.~ to its attorneys, but you cure the delinquency befere the lender begins legal proceedings agaio~ you. you will still be required to pay the reasonable attorney's fees that were actually incurred, ep to $50.00. llow,;ver, illegal proceedings are started again.q against yrn, yo~ wi have to pay a rea.tunable attorney's fees actually inctrn'ed by the lender even ii'they exceed $50.00. Any attorney's fees will be added to the amoent you owe the lender, which may aim include other reasonable costs. I f you_e_u_r_e_th_e de-fault within the _T_I_I_I_R.'~' (30) DAYS period, you will not.~e.re,qu~red to. pgy attorney's fees. OTilER LENDER REMEI)IES -- Thc lender may also sue yml personally for the unpaid principal balance and all other s~lms dxle tinder the mmlgage. RIGIIT TO CURE Tile DEFAUI,T PRIOR TO SllERIFF'S SAI,E -- If you have not cured the default within the TIIIRTY (30) DAY period and foreclosur~ proceedings have hegun, voo still hevc the right to cure thc default and nrevent the sale at any time up to one hour before the_S.heri~s Sale. You_n!a.. y. doE_by paying the total amount then past due, phis any late or other charges then due,_~.a, sonablc attorney's fees and costs connected with the foreclosure sale nnd any=_o.t.h_.er._co~.s~_nn=e..ct_cd with the ~.he_r~f~_S_a_lc as _spacificd in writing by the lender and by ~e .rf. orminp, any other requirements tinder the mortga~.,e. CuH. n.g your default in the manner set forth in this notice will restor~:yo~-~ ~-n~r-~'~-f-~e-~aine posttma as sfyou hsd saver defaulted. EARl.lEST POSSIBI.E Sll ERII,'I,"S.' SA=ii =Y_. ])A_'~'E -- It is estimated that the earliest date that .,,'itch a Sheriff's Sale of the moflgagcd propasty could he held would he ,approximately six (6) months from the dale of this Notice, A notice ofthe actoal date of the Sheriff's Sale will be ~nt to you before the sale. Of court, thc amount needed to care the defatllt will increaas.thc longer you wait. You may find out at any time exactly what the required payment or action will be by contacting thc lender. HOW TO CONTACT TIlE i.ENI)ER: lqame o/~ ~.ender: Gt,~AC t, lorccjaqe CorporacJ. on Address: 403. t,S~.3.e o~ Cars Way Na~.J. ona] C5.1~¥, CA 93.950 Phone Number: {800) 8~0-4622 Fax Number: {63.9) 4'/0-5'~'/9 Coat. act. Person: Co3.lect'.J. on Depa~'r. taen~. EFFECT OF SHERIFE'S SAI,E -- You should realize that a Sheriff's Snlc will cad your ownership of thc mortgaged property and your right to occopy it. If you continue to live in thc property after thc Sheriff's Sale, a lawsuit to remove yoo and your furnishings and other helonginpos could be started by thc lender at any time. ASSUMPTION OF MORTGAGE .. You may or may not sell or transfer ymtr home to a boyer or transferee who will assume thc mortgage debt, provided that all the outstandinp., payments, cheFges and attorney's fees and costs are paid prior to or at the sale and that thc other requirements of the mortgage are Mtisfied. YOU MAY Al.SO _I~ _AVE '~.~!I_E.=RI(_; _H'_I~: TO SF.I .I. TI1F. PROI'F. RTY .10 OII'I'AIN MONI'iY '10 PAY OF]; TIlE MOR'I~iAG]~. I)I~IYI' OR TO BORROW MONEY FROM ANO.171]'~R ] .]'~N])]NG INSTITUTION '10 ]'AY OFF .1'Ills DEBT. TO IIAVE Tills DI:J:AUI.T CURF. I) llY ANY TII]RD PARTY ACTING ON YOUR BF.I IAI.F. TO I IAVE '1'111~ MOIt'I'GAG]~ R]'.S']'ORE])TO T! I1~ SAME POSITION ..\S Il" NO I)EFAI ;1 .T OCCURRE]), I}" YOU CURI'~ Till'. I)I!];AI~] .T. 01OWI'.VI'~R, YOU 1)O NOT HAVE TillS RI¢iIIT CURE YOUR I)]~::\UI .T MORF. TI lAN '1'11RI,:I'.' '1'1MI'~S IN :\NY CAI .ENDAR YI'~AR.) TO ASSI~.RT'I'II]'~ NONI'~XIS'I']:.NCI~ OF ..1 I)I';I"AUI.T IN ANY FOR]:.C].OSt IRI: PROCI~I~I)ING OR ANY O.1'IIER I.AWSUI.1' INS.1'I.1'I "D~]) UNDER 'I~IE MORTGAGI'~ IX)Ct !MENTS, TO ASSERT ANY OTIIER I)]!]:I'~NSI'. YOU ItEl .]EVE YOU MAY J I,.\VE 'IX.) SI !CJI ACTION BY ']'lll~ I.]:.N])ER. '1%.) SF. EK PRO'IT:CT]ON UND]~R 'l'llE ];]'.'])ERAI. ]l..\NKRUPTCY ] .AW. CONSUMER CREDIT COUNSEl.IN(; AGENCIES SERVING ~/QUR COUNTY IS ENCI.OSED PENNSYLVANIA HOUSING FINANCE AGENCY ROMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/O0) ~I~{TON COUNTY Lycaming-Clinmn CouoUas Commisiun for CCCS of No,hemtem PA Community Ac,ion (STEP) 1631 South Ath~.on SC, Sui~ 100 2138 Lincoln Su'~:t P.O. [~x 1328 StucCo{lcd. PA 1680l WHlian,.sport. PA 17703 1814) 238-3668 FAX 1814) 238-3669 (570) 326-0587 FAX (570) 322-21~'/ CCCS of Northeastern PA 201 Basin Strict Will|amspo~ PA 17703 (570) 323-6627 FAX (570) 323-6626 COLUMBIA COUNTY 31 W. Market Su'~¢t 1,800 Abingmn £xecutl,,'c Park FOB 1127 Sui~ I Wilin:s-Bun'c. PA 18702 Clarks Summit. PA 1841 (570) 821.0837 or (800) 922-92;37 (570) 587-9163 or (800) 922-9:{37 FAX (:{70) 821-1785 FAX 1570) 587.0134.013:{ Commission un £counmias Opportunity or' Luzm'nc County {63 Amber Lane Wilk~-Barrc. PA 18702 (570) 826-05 l0 or (800) 822-03:{9 FAX (570) 829-166:{~(Call Before Fuing) (:{70) 455-4994 Hazcltown FAX (570) 4:{5-563 I---(Csll Beforu Fmxing) (570) 836-{090 Tunk~anunck CRAWFORD COUNTY Bmmk~ T. Washington Canto' Oranm' £ri~ CommumUy Action Committ~ 1720 Holland Center {8 Wast 9'~ Sm:ct ,c-tie. PA 16503 Erie, PA 1814)4:83-5744 FAX (814) :{749 1814)459-{:881 FAX(SI4)456-0161 John F. K~unedy Center. Inc. $hanmgo Valley Urban i.~ngue, Inc. 2021 East 20a Su-~t 601 Indiana Avanuc {:ne, PA 16510 Fun~ll, PA 1612i 1814) 898°0400 1412) nglo5310 FAX 1814) 898-1243 CUMBS'RLAND CCCS ofWastem Pcun$¥1vania, Inc. Fiunncisl Counseling $~r,,'icar o{'Franldin 2000 Linglastown Road 31 Wast 3'~ St,~-et Harrishorg. PA 17102 W&~.~sboro, PA 17268 ~,717) :841-1757 1717) Urban Lesgu~ o f [Vietmpolitun Hamsburg YWCA of Carlisle N. 6~' St~t 301 "O" Su~t {'~misburg PA 17[01 C~lisle, PA 17013 1717)234-5925 FAX(717) ~4.-9~:89 1717)243-3818 FAX {717) 731.0589 Community Action Corem of the C~pim{ I~giun Adsms County Homing Authority 1514 D~y Succt 139-143 Carlisle St. Hamsburg. PA 17104 C~ysburg PA 1717) 232-9757 FAX (71T) 234..2227 1717)334.-1518 FAX334-8326 PENNSYLVA~NIA BULLETIN, VOL. 29, NO. 23. JUNE S. 1999 deerees 2~ m~nu~es (Ilo. Is) £ee~ ~o a y---,,- -- ---Z.~ f- ._ --- arc curving ~o ~he lef~ (x.0?) £ee~ ~e a point; ~hence Pa~e ~9. he. se kn~ as and a,,--~ered unFo~--cF~ed w$~, L. ~unke~beF~e=, hSs w~e, G~O~ heFeSn. ..,n AnD SUB~EC~, nevertheless. ~o eaa--en~s, record oF vLeSb~e upon inspection o£ TC~U~q wi~h &iX and Sln~ulaF, ~he ~enemen~s, assigns. ~o and ~o~ ~he on~ p=ope~ use and behoof of she saSd G~EE, h~s/hec ~eA=s and assigns, ~oFeveF. execu~oFs, and a~nSs~=a~o=s, do by ~hese peasantS, ass$~ns. ~ha~ ~he sa~d G~O~. ~he~F hoses and assigns, a~ and un~o ~he said G~. ~is/her he,rs and assA~ns, a~aAns~ ~o~ an~ ~heA= heirs and assigns agains~ aXl and eve~ o~her of ~hem. shall and will bF ~hese pcesen~s SPECX~= ~.~ VEI~FICATION SHIRLEY J. EADS hereby states that she is FORECLOSURE SPECIALIST of GMAC MORTGAGE CORPORATION moiXgagc sen, icing agent for Plaintiff in this matter, that she is authorized to take this Verification. and that thc statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct tx) the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. / FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 GMAC MORTGAGE CORPORATION : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. JEFFREY I. PAUL : Cumberland County Defendants :No.01-3290 PI~AECIPE TO ~m?~TATE CIVIL ACTION/MORTgAgE FOI~ECLOSUR~ TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. Attorney for Plaintiff Date: June 20, 2001 SHERIFF'S RETURN - REGULAR CASE NO: 2001-03290 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS PAUL JEFFREY I DAWN KELLL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PAUL JEFFREY I the DEFENDANT , at 1904:00 HOURS, on the 22nd day of June , 2001 at 1906 LOGAN ST CAMP HILL, PA 17011 by handing to JEFFREY I PAD-L 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 9.30 ~'~~..~ Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 37.30 06/25/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: % ~,p% .~~_~~[~ me this ~ ~ (~ day of Deputy Sheriff SHERIFF'S RETURN - NOT SERVED CASE NO: 2001-03290 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS PAUL JEFFREY I R. Thomas Kline , DeDuty Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: PAUL JEFFREY I but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE REINSTATED NOT SERVED , as to the within named DEFENDANT , PAUL JEFFREY I SINCE DEFT WAS SERVED IN CUMBERLAND COUNTY DO NOT DEPUTIZE DAUPHIN COUNTY PER JASON Sheriff's Costs: ~~ Docketing 18.00 Not Found 5.00 Out of County 9.00 ~~AS KLINE Surcharge 10.00'-~SHE/~FF OF CUMBERLA~-D COUNTY .00 42.00 FEDERFL~N~-~HELAN 06/25/2001 Sworn and subscribed to before me this I~ day of FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIF, E IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 " (2151 563-7000 COURT OF COMMON PLE,,~. CIVIL DIVISION ' ''?' : GMAC MORTGAGE CORPORATION .:.'. 500 ENTERPRISE ROAD SUITE 150, : HOP, SHAM, PA 19044 TERM " '::. ~=. CUMBERLAND COUNTY SEFFREY L PAUL 1906 LOGAN STREET, C OMPLAII~T IN I~IORTGAGE F ORECLOSURI~ NOTICE **THIS FIRbI IS A DEBT COLLECTOR ATTEMPTING 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 R~AFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A'FTEbIPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. lfyou 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 right~ important to you. 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 OFF[CE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ., CUMBERL a rD COUNT ASSOCIATION 2 LIBERTY AVENUE We h. ereby oertify tho (717) 249-3166 within to be atrue and original filed o{ record TRUE COPY FROM FEDERMAN AND PHELAN k~ T&Ui~',uit~ed, I ~,'e unto ~m'.,' Loan ~: ]06586,13 [ · · FEDEKMAN A.ND PH. ELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 161'/JOHN F. KENNEDY BOULEVARD SUI'I ~, 1400 PHILADELPHIA, PA 19103-1814 (215) 563-'/000 COURT OF COMMON PLEAS CIVIL DIVISION GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150, HORSHAM, PA 19044 TERM Plaintiff v. NO. CUMBERLAND COUNTY JEFFREY I. PAUL 1906 LOGAN STREET, CAMP HILL, PA 1'/01 Defendant(s) .CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE, PREVIOUSLY RiCEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE 1S NOT AND SHOULD NOT BE CONSTRUED TO BE AN AI'i'EMPT 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 sev,'ed, by entering a wriRen appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 We hereby certify the 2 LIBERTY AVENUE within to bo atrue and CARLISLE. PA 17013 correct copy of the (717) 249-3166 original filed of record p'EDERMAN AND PHELAN ~ COPY FROM RECORD al~ I~e Selg t~ :~ :'.-.,u;~ .... ;',~:~, Pa. Loan ,~: IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION pRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE TI-IX 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 pLAIlVHFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH ~RITTEN 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 .~,.BOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A j'-CDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. 1. Plaintiffis: GMAC MORTGAGE COKPORATION $00 ENTERPRISE ROAD SUITE 150, HORSHAM, PA 19044 2. The nall;IgiZ) and last known address(es) of the Defendant(s) are: JEFFREY I. PAUL 1906 LOGAN STREET, CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 11/13/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1497, Page 972. By Assignment of Mortgage Recorded 7/28/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 620, Page 393. 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 mortgage due 2/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, 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 $101,381.68 Interest 2,352.24 l/1/01 through 5/1/01 (Per Diem $19.44) Attorney's Fees 4,000.00 Cumulative Late Charges 138.92 11/13/98 to 5/1/01 Cost of Suit and Title Search 550.00 Subtotal $108,422.84 Escrow Credit 394.06 Deficit 0.00 Subtotal ($ 394.06) TOTAL $108,028.78 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 Sheriffs 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." I 0. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's wriuen 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, PLAII~TIFF demands an in rem Judgment against the Defendant(s) in the sum of $108,028.78, together with interest from 5/1/01 at the rate of $19.44 per diem to the date of Judgment, and other costs 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 First Mortgage Loan ~rvioing PO Box 85071 Sari Diogo CA 92186-5071 GMAC Mortgage 3451 Hammond Ave PO Box 780 Watedoo IA 50704-0780 Date: April 11, 9001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE , riffle;al nnllee that the mort~ue ou your home is iai default, and the lender hlteods to foreclose. Thlsisal ......... : ....... . ...................... ; - · . . - ...... Specifi~ ~[o~atmn ~gut the oature of the ~e.fault ,s provided m the attached pages. The IlOMEOWNE~'S,~Q~'(;~(~; A~IS'I'~NCE PRD(;.~A~i ~1') may be able to help to ~ve your home. This Notice explains how the program works. To ge if llEMAP can hele~yon must MEET WITll A CONSUMER CREDIT COU~[I,~N~;a~(;.~CY WITilIN 30 DAYS OF THE DATE OF Tills NOTICE. Take this Notice with yop w~n yo~ ~qe~ wi~ the Counsdln A enc '. The name, address and phone number of Consumer Credit Couu~l~g ~ZcP~ ~inz ~~ !~e~ at the end of thls No6ce. If~u havc~ly que~G~.~_%ygp ~ay~ Pem~y~ ~n~i. a31~g Aeency toll free &LI~80J:342-23p7 (~er~lll ~th ~pa~ bganp~ can call (717) This Notice cootalus importaut lezal informatlou. If you have any questlo~s, rep~sentafives at the Consumer Credit CouuselJ.g Ageocy may be able to help explal, it. You ma~ also wuut to coutact an atloruey ia your area. The local bar association may be able to help you fiod a lawyer. I,A NOTII.'ICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECI'A SU DER~CliO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPR~LNi)E El, CONTENil)O ])E ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMED1ATAMENTE I,I,AMANDO ESTA AG~NCIA (PENNSYLVANIA IIOUSIN(; FINANCE AGENCY) SIN CARGOS Al, NUMERO MENCIONADO ARRIBA. PUl:DES S];R 1.',I,EGIBI ~ PAR ~ UN PR1. N'I AMO POR El. PRO(;RAMA I.I..~MAI)O "IIOMEOWNER'S EMERGENCY MORT(;AGE ASSIN'I'ANC~ PROGR.~M" El, CUA1. PUEI)E SAI.VAR SU CASA DE I,A PERI)IDA i)EI. I)ERECHO A REDIMIR $U IIIPOTECA IlOMEOWNER'S NA.ME(S): JEFFREY ! · PAUL 1906 LOGAN $'J' PROPER'IY AI)I)RF. SS: CAMP HILL, PA 17011 I,OAN ACCT. NO.: 3C~6596431 ORIGINAl. l.ENDER: N/A CURRENT I.ENI)E~SERVICER: GY~C Mortgage Corporacxon I IBIT A IIOMEOWNER'S EMER(;ENCY MORT(;A(;E ASSISTANCE PROGRAM YOU MAY BE FJ,I(;_IBI,E FOR_._F]~,_~'~CIAI. ASS.I ST,_~NC__E. WIIIC.!I--C~N SAVE yOUR IlOME FROM lzORECI,OSURE AND llgl.P YOU MAKE FIJTURE MOR'I'(;AG_E PAYME~'i',~ lb' YOU COMPI.Y WI'I'll 'i'llE PROVISIONS OE Tile IIOMI,:OWNER'S I,:.MER(; ENCY .MORTGAGE ASSISTANCE ACT OF 1983 ('l'll E "ACT"), YOU MAY lie EIol(;IBI.E EOR EMERGENCY MOR'I'(;A(;E A$SIS'I'ANCE: IF YOUR I)EItAUI.T }lAS BEEN CAUSED BY CIRCUMSTANCES YOUR CONTROl., IF YOU_II.~VE A REASONABI.E PROSPECT OF BEING ABIoE TO PAY YOUR MOR'i'(;';~';I'; pAYMENTS, AND IF YOU .~IEET O']'IIER I,:I.I(;IBII.I'IY REQUIREMENTS ESTAIII.ISIIEI) BY THE PENNSYI.VANIA llOUSIN(; FINANCE AGENCY. TEMPORARY SI'AY OF EORECI.OSURE -- ldndcr thc Act, yon are entitled to a temlmrary stay of foreclosure ~on your mortgage for th ~,y (30) days from the date ofthis Notice. During that time you must arrange and attend a face.to.faceN meeting with one of the consumer credit conn~ling agencies listed at the end of this Notice. Tills MEI,:'I'IN(; MUST OCC .U_~.R .~,_'l_TllI.N_'.'l!l l"..~.E._.X'I' (~0) ])AYS.',II: ~_'.O;I.; ],;~). N_OT :.XI'I'I.y FOR F~MI:.RGENCY MOR'I'GA(iF. ASSI,qTt__ANCF., YOU MUS'I ItRI~G_.¥Q!.JR MOR'I'(,A(,E IJl' TO I)ATI:. '_1:1 !Ii P$_R_'Ii OF TI_IllS NOTICE (:Al J .E.D 'I IOW '!_iQ .(_.'U R E .Y_O__t LR..~.I..O_R_ TC., :.X G E 151.iFA! ;I .TL F..X!O .,_XlNS_}LOW...TQ._B.R!,'.'G .y_o._u R MORTGAGE lip TO DAlli. aCgOe ~cel~lEo fUEl)IT COIIN-IiEI,ING A_(~ENCIES -- If you meet with o. ne of the con?umer credit cotmmling ~c~e~s'ii'~;~ ~t';l~'~-e'~'t~[i~"-~oii~e-, t-fie lender may NOT take action against you for thmy (301 days after the date of this meeting.The nantes, addresses a_:Ld._te_l..ep .hgn~: ra mhers of des_ign_ate__d conbx_mer c~dit co~Lnseling agencies for thc county in which the pr0I~Oy i~ I.o..c_ate_d .a_re set iB~h at titc ~nd o.f3bis ..No. tice. It i.~ only neces~' to schedule one face-to-face meeting. Advi.~ your lender immediately of your intentions. APPI.ICATION FOR MOR'I'GA(;E ASSISTANCE -- Your mortgage is in default for thc reamns mt forth later in th s Notice (~ee following pages for specific infomration about thc nature of your default.) If you have tried and are unable to n~mlve this prnblem with the lender, you have the right to apply for financial assistance front the ! Iomeownefs Emergency Mortgage Assistance Program. To do m, you must fill out, sign and file a completed !lomeowner~s Emergency :\ssit~tal, tce ProEm il A ~ tlication, with one of the designated consumer credit coun.~ling a~encle~ li~ted at the end'ofth ~ Notice Only const leer cred counseling agencies have applications for the program and they will assi~ you iii nlbmitting a complete application to the Pennsylvania 1 lousing Fhrance Agency. Your application .MUST be ~led or postmarked within thin}' (30) days of you face-to.face meeting. YOU MUST FII.E YOUR API'I.ICA'I'ION PRO.MP'I'I.Y, II,' YOU FAll. TO I)O SO OR Il; YOU I)O NO'I' FOl.].OW THE O'I'IIER 'I'I~,IE PERIODS SET f'OR'l'l! IN 'fills I.ETI'ER, I;ORECI.()SURE MAY PROCEEI) AGAINST YOUR llO3,1E I.~I.XlEI)IA'I'EI.Y AND YOUR APPI.ICA'I'ION EOR .~IOR'i'(;A(;E ASSISTANCE WIl.I. lie I)ENIEI). AGENCY ACTION -. Available lhnd.~ Iht emergency mortgage assistance are very. limited. They will be disbursed by lhe Agency trader the ehgibilit.v criteria established by thc Act The Pennsylvania IIousing Finance Agency has s~xty (60) days to make a decision slier it receix ca your apl}hcatlon. During that time, no foreclosure ])n~cecding.~ will hc pursued again.~t you ifyou ha~,e met t]te time requirement.~ set £onh aho',c. You ,,,,'ill bc not~fied directly by the Pennsylvania I Iousing Finance Agency of its decision on your application. [--- ]~O'I'E: IF YOU ARE CURRENTI.Y PROTECI'EI) BY Tile I.'%I.ING OF A PETITION.. IN BANKRUPTCY, ~ TIlE I.'OIoI.OWING PART OF 'I'?IIS NOTICE IS FOR INFORMATION PU,.R. POSES ONI.Y AND ] $IlOUI,D NOT BE CONSIDERED AS AN ATi'EMPT TO COLI.EC !' THE !)EB'I'. (If you have filed bankruptcy you can still apply for Emergeucy Mortgage Assistance.) HOW TO CURE YOUR MORT_GAGE DEFAUI.T (B_~__~g it u_p to date). NATURE OF TII.___.~E .I}EI,'__AUI ;I' -- 'l'be MOR'I'(iAGE debt held by thc above lender is on your pmpe~.y located at: 1906 Logan St Camp Hill, PA 17011 IS SERIOUSI~Y IN DEFAUI~q' because: x.,'. · A~ xx.,~ .ctv~' \t apl; MONT}II Y MO t' 'C AC ]' 'AYM ~N'I'S tbr thc following months and the foli~'~i~'~''~m~'n't'~"~'&'no'w pa'st' due: February 10 2001 throuqh April 1, 2001. See attached Exhibit for pa~qnent breakdown. Monthly Paymen~~'m' 2,846.73 69.46 l-re Charges 0.00 NSI: 7.25 Inspections Other 0.00 SusI~n~ TOTAI. AMOUNT PAST DUE: 2,923.44 IL YOl' I1..\VI~ ]:Ali .l~D TO TAKI'. 'l'lll; FOI .I .OWING A(TI'ION (Do not usc 'not applic__ahlc_): lIOW TO CURE Tile I}EFAUI.T -- Yon may cure th-' default within TIIIK.]~ (30) DAYS ofthe date of this notice BY PAYING THE TOTAl, AMOUNT PAST DUETO ]'HE I,ENDER, WIllCll IS $ 2,923.44 , PI.US ANY MORTGAGI~ PAYMF. NTS AND I.ATF. CtlARGES WIIICH BF. COME DUE DURING TIll~ TIIIRTY (30) DAY PERIOI). Payments must be made either .b.v c_a.'4_%.ca~ie?s check certified check or ntone¥ order made lm__yable and sent to: Pa~qnen ~ Procea~inq GMAC Mortqaqe Corporation PO Bo;( 780 Waterloo, IA 50704-0780 Ynu can cure aoy other dethult By takinE thc ~blk)wioE action x~ithin TIIIRTY (30) DAYS of thc date o£this ]etter: (D° °°t t sc-f-~9-t aPPIjca-b[~') Not Applicable 11.' YOU DO NOT CURE 'I'JJE DI'2_J",~_UI_._T" If you do oct cure the de fauh within TIIIRTY (30) DAYS oftbe date ofthis Notice, the kadet intends to exerelse its rights to aeeelerate the mort~ll, debt. This means ti? the entire outstanding belance of this debt will be considered due immediately and you may lose the chance to pay me mortgage in monthly installments Iffidl payment oftbe total amount past due is not made within TIIIRTY (30) DAYS. thc lender aiso intends to insm ct ts attorneys to start legal action to foreclose up.o__n..ygu__r m. o~ga ge_d_ property,. Il,' TIlE .%_IQR_]'.G~.%(.; E I..%.FORECI.OSED UPON .- ']'he mortgaged property will be ~ld by the Sheriff'to pay off thc mnn~agc debt. Il'the Icnde{ ~f~n, your case to ~t.,, attorneys, but you cure the delinqaency before the lender ben. in.~ cpa proceedings ap. ernst yot, yo A ,,,.'All stall be req ired to pay the rea.~nab e attoroey s fees that ,,,ere ac~mlly i~currcd, up to $:,{~. .00. IIov,.ever, if legs proceedings are .~tarted age nst age nsf you,. you wil have to pay. all rea~oabl¢ attorney's fees actually incum:d ~' the lender even if they exceed $50.00. Any attonrey's fees will he added to thc amount yot owe the lender, which may al~o include other reasonable costs. if you care the defauR withi!t th_c ]~I_i_I_RTY (30) D:\YS period, you will not be_rg_qah'ed to pa.,,' atto.rt!.e.v'%fees. OTll F.R I,F, NDF, R RKMEDIKS. -- Thc lender roay also me you pe~onally for thc unpaid principal halance and all other roms dne under the mortgat~c. RIGIIT TO CURE TIlE DEI:AUIoq' PRIOR TO SiiERIFI:'$ SAI,I,: -- If you have not cured thc default within tho TIIIRTY (30) DAY period and fo~clostu-e proceedings ]~v-~'hegtro, you ~till have the rinht to cure the default nreve , at one hour he,ore th he. ffs d.o _by then mst dna. olus mv late or other charaas then due. ~a. so~aole attoma!r s lees ar~ cobs collna~r,u f(~reclosnre sale and any other costs connected with t~c__S_~_!i_ff..s Sale as _spc_c~ifind.'_m.~_.~_~.R-~~/ parforofine, any other ~quirerocnts!mdcr _th_e_ monga~..e... Curl. e, [~ )'our default in ~e roanner sot forth in this nogce will restore your roort§aile Ia the same posttmn as ~fyou had never defaulted. KARl.lEST POSSIBI,E SIIERII,'I"'S SAI.E I)ATE -- It i,~ cstiroatcd that thc earliest date that ~lch a Shariff.~ Sale ofthc montaged propcny could be }laid wou[d be approslroately six (6) roonths froro thc date of this Nollce. A notice ofthe actual date ofthc Sheriffs Sa[e will bc ~nt to you heforc thc sale. Ofcoursa, thc amount nccdcd to cure thc default will increa~,~he longer you wait You may find out at any tiroe exactly what thc required payment or action will bc by contactinB the lender· llOW TO CONTACT TIlE I,KNDER: Name of Lender: GMAC MorCqafle Corporation Address: 401 Mile ol Cars Way National City, CA 91950 Phone Number= (800) 8b0-4622 Fax Number: (619) 470'r~579 Contac~ Person: Collection Department. K~'~'~"r n~ sst~,'m~,'t:'.S SAI E .- You should realize that a Sheriffs Sale will end yin= ownership of the, moll§ngcd prepafty and yo~ r n§ht to occupy t. If you continue to hvc m the property alter th, c Sheriff's, Sale, lawsuit to remove you and your furoi~in~s and other bclongh~p.,s could bc started by thc lenoer at any tm~c. · N : .MORTGAGE -- You tony or roay not soil or transfer your hemc to a buyer or tmnsfcrec who ,Oo ,age debt. pro ,ded that a' ,he payment.,, cha e., an,' atto ey's fee, and co.,,, are paid prior to or at thc sale and that thc other requiremem.~ of thc mon§a§e are satisfied. YOU .MAY A! .SO IIAVF. ?H E_R_I(_; !1'.1.': TO SEI .I. 'rllF. PROI'I",R.I'Y 'lO OBTAIN MONEY .l'O PAY OFF 'l'liE MORT(iA(;E DF. It'I' OR TO BORROW MONEY FRO.M ANO'I']II,,R I.ENDIN(; INSq']'I'UTION '1'O PAY OF]: 'lllIS DEll.l'. TO IIAVE Tills DI!]:AI 'I .'1' CURED BY ANY T}IIRD PARTY ACI'ING ON YOUR BF.]IAI .F, 'I'() IIAX,'l~ '1'} IE MOR'I<;A(i}~ RI..S'I'OR]']) 'lO 'l']ll.. SAME ]'OS]'I'ION AS Il: NO ])I~I:AI'I.'I' IIAD OCCURRI~.D, IF YOU CURl: .l Ilk I)I:FAI '1.'1'. 0 IOWI,.VI'.R, YOU l)(.) NOT llAVh Tills RI(;II'I '1'O ('URE YOUR DI']:AI.'] 3' .MORF 'I'II:\N q'lIRl,I.. 'I'IM1..S IN ANY ('Al .ENDAR YI..AR.) '1'O ASSERT '1'11E NONhX] S'l'hNt'k ()F :\ DI..I, :\l '] ,'l' IN ANY I:ORE('] .OS!.'R]'. PKO( ']..]d}lN(; OR ANY O'I'IIER l.Awsvrr INS.l'rl'( "I'ED I 'NDI.]{ Till- XI()I{T(iAGE DO('I'.MI'~N'['S. TO :\SSFR'I' ANY OTllliR I)]d:l,.NSl' YOI.' Itl.il .ll,.VI.. YOU MAY lb\V},..l'O SI 'CII :\CHON ]IY 'l'lll,. I.ENDI:.R. .l'() SEEK ],RO'I'I:C'I'IO.N' l.'.N.l)l{l{ 'I'll\ Fhl)I,.RAI. II:\NKRI'P'I'('Y I.:\W. CONSUq,.i.I'~_R _C_REI~I'I' COUNSEl.IN(; AGENCIES SERVING yOUR COUNTY IS ENCI.OSED PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY A.~i~TANCE PROGRAM CONSUMER C~D~ CO~SELING AGENCIES (~v. L~ing~linmn Corem C~isim ~r CCCS of No~ PA Co~uni~ ~n (S~P) 1631 ~ ~n 21~[ Lincoln S~t P.O. Box 1~28 S~ Col~ PA (5~0) ]26-0~[7 F~ {570) 322-~197 CCCS of N~ PA 201 Brain S~ Willi~ PA 1400 Abm~n Exc:utlve P~k 3l W M~et S~ Sui~ I Wi~-B~, PA Co~i~ ~ Eco~mi~ Op~ni~ of L~e Co~ I~ ~b~ ~c Wilkm-B~. PA 1870~ F~ (570) ~9-t665~C~1 Be~m F~xin~ (~;0) ~36~ T~ C~WFORD B~ T. W~hin~n Crater I ~ W~t 9n S~.t I~0 Holl~d Center ~e. PA 16503 ~e. PA 16~01 (gl4) 453-5~ F~X (gl4) 5~49 {~14) 459458l F~ {814) 4~6~161 John F. Kgnncdv Center. Inc. S~e~go V~ley Urb~ Le~e. ~c. ' 601 ~di~a Avenue 2021 E~t 20n S~gt F~II, PA 16121 Er~c, PA 16~10 (~ 14) 898~00 (4 [~) 981-5310 Fin~ci~ C~nsehn~ Sg~ic~ CCCS ofWes~ pgn~lv~i~ Inc. 2~0 Linglest~n Ro~ ~ I W~t 3~ S~ct H~sbur~ PA t7102 War--bom. PA 17~68 (717) 541 - 1757 (717) 762-3285 U~ Le~ oF M~lim ~b~ ~CA of C~isle N. 6~ S~eet 301 'G~ S~t H~bu~ PA 17t0t C~i~e. PA 17013 ~ Coun~ Eousing Au~ori~' Co~i~ ~tton Co~ of~ C~ Region 13~143 C~lislo 1~14 De~' S~et H~bu~ PA tTl~ ~sb~ PA (71~ 232-97~7 F~ (717) 23d-2227 (71~ 334-1518 F.~ p£.NNSYLV.-~NL-~ BULL£TL~¢. VOL. 29, NO. 23. J~'NK 5. 1999 ~ed F~F ~&S0) fee~ e distance of Six~y--zigh~ and ~un~ed~hs (68~38) ~ee~ ~o ~he ~in~ of BEGZNNING =~co=ded in ~he c~eFla~ Cou=~ ~eco=d~='s Office ~n plan Book 8, Page 10. ~u~ - ........ ~-----~. 4~ Dee~ ~ook J, Volume 33, =eco=d or visible upou inspection of pr~mises. here~A~=~s and appu=~enances ~o ~he .~ belonging o= . -- ~- - assigns, ~o and fo= ~he only p=ope= use an~ behoo~ of ~he said sin~la= ~he heFedi~amen~s and pFemiSeS he=eAnabove described and ~erson o= perseus vhomsocv~=, lawfully cl~!mi~ o= ~o claim VERIFICATION SHIRLEY I. EADS hereby states that she is FORECLOSURE SPECIALIST of GMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification. and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that flus statement is made subject [o r, he penalties of 18 Pa. C.S. Sec. 4904 relating to uns'.vom falsification to authorities. FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff GMAC MORTGAGE : CUMBERLAND COUNTY CORPORATION : 500 ENTERPRISE ROAD SUITE : COURT OF COMMON PLEAS 150 : HORSHAM, PA 19044 : CIVIL DIVISION Plaintiff : : NO. 01-3290 CML VS. : : J~FFREY I. PAUL : 1906 LOGAN STREET : CAMP HILL, PA 17011 : : Defendant PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rera, in favor of the Plaintiff and against JEFFREY I. PAUL, Defendant, for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $108,028.78 Interest 511101 TO 7/24101 $1~652.40 TOTAL $109,681.18 I hereby certify that (I) the addresses of the Plaintiff and Defendant are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQ~rIRE Attorney for Plaintiff DAMAGES ARE H~:REBY ASSESSED AS INDICATED._ _ /Q DATE: ~~"~'Y~ PRO PRO~AtY **THIS ~ IS A DI~BT COLLECTOR AI'rEMPTING TO COLLI~CT A DI~BT AND ANy INFORMATION OBTAINI~D WILL BI~ USI~D FOR TliAT PURI~E. IF YOU IIAV~ PREVIOUSLY RF, C~'IVED A DISCHARGE IN BANI~UPTCY AND TI~ DI~BT WAS NOT I~,~I~IRI~I~ TIlls CORR~FONng. aNC~ IS NOT AND SHOULD NOT BI~ CONS'rRU~n TO BI~ AN ATI~MPT TO COLLICCT A DEBT, BUT ONLY ENFORC'EbI~NT OF A LI~N AGAINST PROPI~RTY. ** SHERIFF'S RETURN - REGULAR · ~AS~ NO: 2001-03290 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAOE CORPORATION VS PAUL JEFFREY I DAWN KELLL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PAUL JEFFREY I the DEFENDANT , at 1904:00 HOURS, on the 22nd day of June , 2001 at 1906 LOGAN ST CAMP HILL, PA 17011 by handing to JEFFREY I PAUL 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 9.30 R~Th~~ Affidavit .00 Surcharge 10.00 . line .00 37.30 06/25/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: me this day of Deputy Sheriff A.D. Prothonotary FEDERMANAND 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 : COURT OF COMMON PLEAS GMAC MORTGAGE CORPORATION : CIVIL DIVISION Plaintiff : CUMBERLAND COUNTY VS. : NO. 01-3290 JEFFREY I. PAUL Defendant (s) TO ~ JEFFREY I. PAUL CANP HILL,PA 17011 DATE OF NOTICEs ~ THIS FI~LM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN ANATTEMPT 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 ENFORCENUENT OF LIEN AGAINST PROPERTY. I I 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 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PI]ELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attomey for Plaintiff GM_AC MORTGAGE CORPORATION : CUMBERLAND COUNTY : Plaintiff : Court of Common Pleas : vs. : CML DIVISION : JEFFREY I. PAUL : NO. 01-3290 CML : Defendant : : VERIFICATION OF NON-Mll.ITARY SERVICI~. FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin 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 Sailors' Civil Relief Act of Congress of 1940, as amended Co) that defendant JEFFREY 1. PAUL is over i 8 years of age and res/des at 1906 LOGAN STREET, CAMP HILL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN Attorney for Plaintiff (Rule of Civil Procedure No. 236 - Revised) GMAC MORTGAGE CORPORATION : CUMBERLAND COUNTY : Plaintiff : Court of Common Pleas : vs. : CML DIVISION : JEFFREY I. PAUL : NO. 01-3290 CIVIL : Defendant : : : Notice is given that a Judgment in the above captioned matter has been entered against you on ~DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215} 563-7000 **THIS FIRM IS A DEBT COLLECTOR A i-r~:MPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WH.L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REA~YmMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A.I-i'KMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA NO.: 01-3290 CIVIL VS. JEFFREY I. PAUL 1906 LOGAN STREET CAMP HILL, PA 17011 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY Kindly mark the judgment that was entered in the above captioned matter on 07/25/01 vacated upon payment of your costs only, Frank Federman, Esquire Attorney for Plaintiff August 23, 2001