HomeMy WebLinkAbout04-4749UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
National City Mortgage Co.
3232 Newmark Drive
Miamisburg, OH 54342
Plaintiff
ATTOP, NEY FOR PLAINTIFF
: COURT OF COMMON PLEAS
:CIVIL DIVISION
Cumberland County
Vo
Roxann N. Macavoy
413 Spring Run Drive
Mechanicsburg, PA 17055
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any
money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF
YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
AVISO
Le hah demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UNABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify
us in writing of a dispute within the 30 day period, we will obtain verification of the debt or
a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not
an admission of liability on your part. Also, upon your written request within the 30 day
period, we will provide you with the name and address of the original creditor if different from
the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. If Plaintiff is an assignee then it
is such by virtue of the following recorded assignments:
Assignor: ~/A
Assignments of Record tc,: N/A
Recording Date: ~/A
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 413 Spring Run Drive
MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Upper Allen
COUNTY: Cumberland
DATE EXECUTED: 09/23/99
DATE RECORDED: 09/24/99 BOOK: 1572 PAGE: 361
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
(b)
09/13/04:
below;
by failing or refusing to pay other charges, if any,
indicated below.
The following amounts are due on the said Mortgage as of
Principal of debt due $113,691.57
Unpaid ~nt~rest at 8.375%
from 05/01/04
to 09/13/04
(the per diem interest accruing on
this debt is $26.45 and that sum
should be added each day after
09/13/04) 3,597.20
Title Report 250.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $247.01 and that sum should
be added on the first of each
month after 09/13/04) 872.89
Late Charqes
(monthly late charge of $45.15
should be added in accordance
with the terms of the note
each month after 09/13/04) 135.45
Attorneys Fees (anticipated and actual
to 5% o~ principal) 5,684.58
TOTAL $124,511.69
7. The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be collected
in the event of a third party purchaser at Sheriff's Sale. If the
mortgage is reinstated prior to the sale, reasonable attorney's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A", and made part
hereof, and defendant(s) have failed to proceed within the time
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $124,511.69 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
Mark J. Udr IRE
UDREN LAW O~FICES, P.C.
Attorney for Plaintiff
Attorney I.D. No. 04302
ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF UPPER ALLEN, COUNTY OF
CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED /tND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT A POINT IN THE EASTEP, N LINE OF SPRING R~N DRIVE (65 FEET WIDE) WHICH
SAID POINT IS IN THE DIVISION LINE BETWEEN LOTS NOS. 39 AND 40, ON THE HEREINAFTER
MENTIONED PLAN OF LOTS; THENCE ALONG THE EASTERN LINE OF SPRING RUN DRIVE BY THE
ARC OF A CIRCLE CURVING TO THE RIGHT, IN A NORTHWARDLY DIRECTION, SAID CIRCLE
HAVING A EADIUS OF 1467.50 FEET, THE ARC DISTANCE OF 90.07 FEET TO A POINT IN THE
DIVISION LINE BETWEEN LOTS NOS. 40 AND 41 ON SAID PLAN; THENCE ALONG THE DIVISION
LINE BETWEEN LOTS NOS. 40 ARD 41, SOUTH 71 DEGREES 07 MINUTES HAST, 165.73 FEET TO
A POINT IN THE LINE OF LANDS NOW OR LATE OF MT. ALLEN HEIGHTS; THENCE SOUTH 12
DEGREES 34 MI~u~ES NEST, 79.94 FEET TO A POINT IN THE DIVISION LINE BETWEEN LOTS
NOS. 39 AND 40, AFOREMENTIONED; THENCE ALONG THE DIVISION LINE BETWEEN LOTS NOS. 39
AND 40, NORTH 74 DEGREES 38 MINUTES WEST, 172.09 FEET TO A POINT IN THE EASTERN
LINE OF SPRING RUN DRIVE, AFOREMENTIONED, AT THE POINT AND PLACE OF BEGINNING.
BEING LOT NO. 40 IN THE PLAN OF SPRING RUN ACRES, SECTION 3, WHICH SAID PLAN IS
RECORDED IN THE CUMBERLAND COUNTY RECOHDER'S OFFICE IN PLA~ BOOK 19, AT PAGE 29.
HAVING THEREON ERECTED A SINGLE BRICK AND ALUMINUM DWELLING HOUSE.
Mortgage
August 04, 2004
National City Mortgage Co,
A Subsidiary of National City Bank of Indiana
3232 Newmark Drive · Miamisburg, Ohio 45342
Telephone: (937) 910-1200
Mailing Address:
F'.O. Box 1829
Day,on, Ohio 45401 ~1820
Roxann N Macavoy
413 Spring Run Dr
Mechanicsburg PA 17055
Loan No. 961197-7
Current Servicer: National City Mortgage
HOW TO CUP~E YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT-- The MORTGAGE debt held by the above lender on
your property located at:
413 Spring Run Dr
Mechanicsburg PA 17055
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s)
6/1/2004 8/1/2004
and the following amount(s) are now past due:
Monthly Payments
Late Charges
Other Fees
Less Suspense Balance
Total Due 3,544.12
3,449.94
85.43
8.75
.00-
YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION
(Do not use if not applicable):
HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days
HOW TO CURE THE DEFAULT
of the date of this notice BY PAYING THE TOTAL AMOUI~T PAST DUE TO THE
LENDER, WHICH IS $ 3,544.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cashier's check, certified check, cash
or money order made payable and sent to:
National City Mortgage
Attn: Customer Counseling Department
3232 Newmark Dr.
Miamisburg, OH 45342
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)
DR672 JCS Page 1 - ACT 91 NOTICE
EXHIBIT A
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the
lender intends to Foreclose. Specific information about the nature of the default is
provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP~ may be able
to hah3 save your home. This Notice exDialns how the proQram works.
To see if HEMAP can helD, you must MEal' WITH A CONSUMER CREDIT COUN-
SELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. TaKe this_
Notice with you when you meet with the Counselin~ Aclencv.
The name. address and phone number of Consumer Credit Ccunseiino Agencies
servinq your Countv are included with this Notice; if you have any ClUestions, you
may call the Pennsylvania Houslno Finance. Aaencv toll free at 1-800-342-2397.
(Persons with iml3aired hearing can c~ll ¢717)780-1869~.
This Notice contains important.legal information. If you have any questions, repre-
sentatives 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.
I..A NOTIFICAClON EN ADJUNTO ES DE SUMA IMPOR'rANClZk, PLIES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION ,c
INMEDITAMENTE LLAMANDO 'ESTA AGENCIA (PENNSYLVANIA HOUSING FI-
NANCE AGENCY) SIN CARGOS AL NUMERO MENClONADO ARRIBA. PUEDES
SER ELEGIBLE PARA UN PRESTAMO POREL 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 EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE.
YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS,
OCt !7.2002 10:25A~ NATIONAL 8[TY ~u. ~ r, o
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
· - IF YOUR DEFAULT HAS BEEN CAUSED B~ CIRCUMSTANCES BEYOND YOUR
CONTROL..
· IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND.
. IFYOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED
BY THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a tempo-
rary 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 (30) DAYS. IF YOU DO NOT APPLY FOR EMER-
GENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO
DATE. THE PART OF THIS NOTICE CALLED 'cHOW TO CURE YOUR MORTGAGE
DEFAULT", ExpLAINS HOW TO BRING YOUR= MORTGAGE UP TO DA'FE.
CONSUMER CRED1T COUNSELING AGENCIES - If you meat with one of the con-
sumer credit counseling agencies listed at the end of this notice the lender may NOT take
action against you for thirty.(30) days a~ter the date Of-this meeting. The ~arrtes,-~dd~esses
and telephone· numbers of desic!nated consumer credit counseling aaencies for the county
in which the oroperW is located 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 (see following pages'for specific information about the
nature of your default), If you have tried and are unable to resolve this problem with the
lendeq you have the right to apply for financial assistance from the Homeowneffs Emer-
gency Mortga. ge Assistance Program. To do so, you must fill out, sign and file a compteted
Homeowner's Emergency Assistance Program Appiica, tion with one of the designated
consumer credit counseling agencies listed atthe end of this Notice. Oniy.~ .~nsumer credit
counseling agencies have applications for the program and they will assist you in submi~-
ting a comptete application tothe Pannsyivariia Housing Finance Agency, Your application.
MUST be filed or postmarked within thirty (30) days of your face'to-face meeting,
YOU ~MUST FILE YOUR APPLICATION PROMPTLY. IFYOU FAIL TO DO SO OR IF
YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LE'CFER,
FORECLOSURE MAY PROCEED AGAINST yOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds For emergency mortgage assistance are very limited.
They will be disbursed by the Agency under the eligibility criteria established by the Act.
2082 10:35AM NATIONAL
'Fha ~ennsylvania Housing Finance Agency has sixty (60} days to make a cJecision after it
receives your applica~on. During that time, no loreclosure proceedings will be pursued
against you if you have met the time requirements set forth above. You will be notified
directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY- THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN A'i-I'EMPT TO
COLLECT THE DEBT,
(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.)
IF YOU DO NOT CURE rrHE DEFAULT(see paae 1) - If you do not cure the default
within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its
right, to accelerate the mortgaoe debt. This means that the entire outstanding balance
of this fdebt will be considered due immediately and you may lose the chance to pay the
mortgage in monthly installments, if full payment of the total amount past due is not made
within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start teg~l
action to foreclose umon v_our mortgacle property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by
the Sheriff to pay off the mortgage debt If the lender refers your case to its attorneys, but
you cure the delinquency before the lender begins legal proceedings against you, you will
still be required to pay the reasonable attorney's fees that were actually incurred, up to
$50.00. However, if legal proceedings are staffed against you, you will have to pay all
reasonable attorneys' fees actually incurred by the lender even if they exceeCt $50.00,
Any attorney's fees will be added to the amount you owe the lender, which may also
include other reasonable costs. If you cure the default within'the THIRTY'(30) DAY period,
you will not be required to may attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid
principal balance and all other sums due unoer the mortgage.
RIGHT TO CURE THE DEFAULT'PRIOR TOSHERIFF'S SALE - If you have not cured
the default within the THIRTY (30) DAY period and foreclosure proceedings have begun,
you still have the dolt to cure the default an'd prevent'th6 sale at any time ul~ to on,hour;
before the Sheriff's Sale. YOu may do so by baying the total amount then Bast due. plus a.n~
late or other charoes then due. reasonable attome'Cs fees and costs connG;:;ked with the
foreclosL~re sale and any other costs connected with the Sheriff's Sale as sl~ecifie, d in
wdtin9 by the lender and bv pei'formincl any other requirements under the mortclac~e. 'Cur-
ing 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 SHER1FF;S SALE DATE - it is estimated that the earliest date
that such a Shedff's Sale of the mortgaged property cou{d be held would be approxi-
mately FOUR(A) months from,the date of this NOtice, A notice of the actual date of the
Sheriff's Sale wilt be sent to you before the SaJe. Of course, the amount needed to cure the
default will increase the longer you wait. You may find out at any time e×actly what the
required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER: Name of Lender: National City IVio~gage
Address: 3232. Newmark Dr, Miamiaburg OH 4-~34.2
Phone Number: 1-800-523.8654 Fax Number: (937) 910-4058
Contact Person: COLLECTIONS DEPT.
EFFECT OF SHERIFF'S SALE - You shauld realize that a Sheriff's Sale witl 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 furnishing and other
beLongings.could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -You · may ormay not be able to 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. For additional informa-
tion please contact the Collection Dept.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BE-
HALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DE-
FAULT HAD OCCURRED, IF YOU CURETHE DEFAULT, (HOWEVER, YOU DO NOT
HAVETHIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF DEFAULT IN ANY FORECLOSURE .PRO-
CEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
APPENDIX C
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
- CONSUMER CREDIT COUNSELING AGENCIES
(717) 637-3768
FAX (~17)
(717) ~4'~ -175'7
(717) 762-3285
(412) ~7~02
FAX {724 46,5-S 18
(724)
{724) 72S-75 !
(412)
FAX (432)
BEDFORD ~UN~
(81 ¢) .6~.g129
(Bt4) ~4-8100
(814)
FAX (61~)
~ch~it Co~y
F~ 81~) ~-71S7
K~sto~ ~omlc Development Co~
(El4) ~4-81Q0 or (~14) 9~.~47
Weaibe6zatlon
C~S o( No,he.tam P~nns~vania
1~ ~n
FAX (~0) S~.9134/~135
(~0) 42~8960 or BO~S~.g537
F~ (a~4)
(~O) 2~S-3~B
FAX (~0~
P,0. E~x 21
t=Ax ~57a) g3~-~144
(570) 836.6840
(Rev,
{~?0) 7fi4-S2E2
FAX (~70)
[570/ ~941
F~ ~570) ~3~817
(~5) 765. I~1
FAX [2~5~ 7~1427
F~ (215 32~753
(~15~ 7S0~310
F~ (215) 75~318
CCC~ of Demwa~e
p~iade~h~ PA 19140
(~15) 426-~0Z5
FAX (215~ 426-~1~
QCC~ ol Delaware V~[ley
(2~5)
pni~de~p~a,
(215) 7~-2990
FAX [215) 7~-2012
OCCS ol Lehigh
W~e~[. PA 1~52
FAX (GLO)
1 ~ E beka[b
King o~ P~is PA 19~06
610-g71-221~
~AX (6~0)
755 Y~ Rd, S~fa 103
Warmi~ter PA 15974
(215) ~4-9429
FAX (215)
F~ (412) 3g
OCC~ of Wes:em PA
FAX (~1
Mous~ng ~po~unhi~s inc.
F~ (412) 6CA,BT3
FAX (412)
CAMBRfA COM~
(814) 623-g129
FAX ~814) 6~-7187
Pmgmm
X (412) 465-5118
(614~
{814) ~5-~28
No,hem Tier Comm~ni~ Action
135 W~I4~
~orium, PA 158~
{Bl4} 4B~1
FAX (a14) 486-O8~5
2~7 E. P~nk
', (814) 944-81~
',FA~ (al4)
'~AR~ON C~UN~
'EOC o{ ~:huy~i~ Coun~
~57o) ~-1995
3671 Cmsent Cou~
FAX (814)
F~ (El4) ~4-574'7
A~l~n (STEP
(~0) ~587
FAX (570) ~-2197
;AX (B14] ~38-366S
· .CCC5 O( No~e~tem PA
(~) 32B-~87
FA~ (~70) 322-2
(215) 765,1~1
FAX'(215~ 7~-1427
{215) 324-7~ ·
FAX ~15}
(2~ 5)
FAX (215) 563-7020
HACE
1~7 W. Allegheny AW, 2nd FI.
Phlt~cielp~ia, PA 19140
[21~) 4~.B025
FAX {215)
{61~) ~.3682
FAX (610) ~4-824~
~17) 3a7-5182
FAX ~17)
(215) 563-S6~
(810)
F~ (slo)
~:AX ($14)
CCCS of Wa,.~tern PA
{B1'~) 539-6335
~]I~ON CouN~
(~0) ~26~05E7
FAX (~70) 3~-2197
(B~4)
FAX (~14)
FAX (570) 323-662~
~_~fA CQU~
P.Q. BOX 11~7
(570) 821,0a37 OR 1
(~0) 587-91~ or S0~B~.O~7
F~ (~0) 5~7-91~35
1 ~3 ~r
FAKING
(~O) 455~9~ H~ELT~
FAX (~70} 455-5~l~ALL ~EFOR~
{~o) ~3s~090 ~UNKHANNOCK
8ooKer T. Wa~9~on
~720 Ho~and
(B14) 45~45B1
FAX (B14}
John F. Kenne~ Center, Inc~
(814) SgB~40~
F~X [S14) BgB-1~43
Shenang= Valley Uman League,
[412) 98%5310
cu~
FAX (717)
WAX ~17) ~.34-g45a"
FAX ~77
FAX ~7) ~-~7
(315) 3~{-7SO0
(alo) 5~846
(~14) 445-962~
FAX {~14) 443.38g0
FAX (71T)
~17) 637~768
F~ .~17) 537~294
Cemm~{~ ~{on Comm~ion
C~ Region
FAX ~ ~-~7
~37)
~17) 541,17~
FAX (717)
~LTO~ C0U~
.. 0C%:17, O0 xlO:37A
HuntSmen, PA 16652
14~
~ (~0) 5~7-g134/9135
P.O,
(717) & {814 ONLy
(717) ~6-4176
~17) 397-51~ OR
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FAX (~0)
43~ E.
FAX ~I~) ~g~127
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FAX (570) 672.-0~2S
F~ (STO) B21-17~
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FAX (~70)
F~ {570) 82~-1785
F~ (STO) ~87-9134~135
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(8t4) ~3,~43
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9 Sout~ ~h
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(~0) B~6~510 O~ 1-600-B22-0~59
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{215) '5~-5865 ·
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1515 Mamet Street, SuJt~ 1~25
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~17) 762,3255
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Event. PA 15537
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Germ~ S,eeL P.O, Box 389
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(~14) ~4.81 B0
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[~0) 821-08~ or 800~-9537
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(~0) 32B-~27
~==te~ E~e Community Ac o
FAX (a 14) d56-0161
FAX (514) 89B-12
WARREN COUNTY
FAX (8~4) 4~6.~161
~ Gamen Center Drlv~
(412)
FAX (4~2) ~73
FAX (4~2} 336-9963
(57a) 5~7-g~3 OR
(~70} 821.0837 or
FAX ~S70) ~1-17~
9 South 7th
(570) 420~80 or 80~g~-g~7
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bIATIONAL CITY
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FAX (570) 724-~a3
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FAX (~0)
FAX {~0) ~IeSS
FAX (41~) ~512
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(~O) ~1~7 et ~0~-9537
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(S7o) ~7.~1 ol
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103 Wa~ ~msL P.D, ~x 709
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Hat.burg. PA 17~02
91~ Sou~ Goose Stme[
York, PA 17~03
A~ Coun~ Ho~ing
Ge~ PA 17325
~17) 3~.151E
VERIFICATION
Mark J. Udren, Esquire, hereby states that he is the attorney
for the Plaintiff, a corporation unless designated otherwise; that
he is authorized to take this Verification and does so because of
the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he has
personal knowledge of some of the facts averred in the foregoing
pleading; and that the statements made in the foregoing pleading
are true and correct to the best of his knowledge, information and
belief and the source
reports of Plaintiff's
this statement herein
PaIC.S. Section 4904
authorities.
of his information is public records and
agents. The undersigned understands that
is made subject to the penalties of 18
relating to unsworn falsification to
UDREN LAW OFFICES, P.C.
SHERIFF' S RETURN - REGULAR
CASE NO: 2004-04749 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONAL CITY MORTGAGE CO
VS
MACAVOY ROXANN N
RONALD HOOVER ,
Cumberland County,Pennsylvania,
says, the within COMPLAINT - MORT FORE
MACAVOY ROXANN N
DEFENDANT at 2049:00 HOURS,
at 413 SPRING RUN DRIVE
MECH3LNICSBURG, PA 17055
ERIC DICK, ~LDULT lin CHARGE
a true and attested copy of COMPLAINT -
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 23rd day of September, __
by handing to
together with
MORT FORE
2004
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.88
Affidavit .00
Surcharge 10.00
.00
36.88
Sworn and Subscribed to before
me this ~'~ day of
A.D.
/ P~othonotary '
So Answers:
R. Thomas Kline
09/24/2004
UDREN LAW OFFICES
By:
Deputy Sheriff
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
National City Mortgage Co.
3232 Newmark Drive
Miamisburg, OH 54342
Plaintiff
Vo
Roxann N. Macavoy
413 Spring Run Drive
Mechanicsburg, PA 17055
Defendant (s)
ATTORNEY FOR PLAINTIFF
: COURT OF COMMON PLEAS
. CIVIL DIVISION
· Cumberland County
NO. 04-4749
Civil Term
PRAECIPE TO MARK SETTLED, DISCONTINUED AND ENDED
TO THE PROTHONOTARY:
Please mark the above captioned matter SETTLED, DISCONTINUED
and ENDED, upon payment of your costs only.
Mark J. Udren, Esquire
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
Dated: October 27, 2004