HomeMy WebLinkAbout04-4750UDREN 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, Ohio 45342
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
Patrick T. Sullivan, III
330 South 31st Street
Camp Hill, PA 1'7011
Defendant(s)
i 0'.,' -- z/?,¢'0
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 ¥ 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 DEF~ANDA A UN ABOC~DO IMMEDIATAMENTE, SI NO TIENE ABOGADO
0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVlCIO, VAYA EN
PERSONA O LLAME POR TELEFONO A LA OFICINA CD-MA DIRECCION SE
ENCUENTRA ESCRITA AEAJO PAPA 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, wc 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
Ill 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: N/A
Assignments of Record to: N/A
Recording Date: N/A
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff} loaned
to the Defendant(s} the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness~. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 330 South 31st Street
MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Camp Hill
COUNTY: Cumberland
DATE EXECUTED: 12/8/97
DATE RECORDED: 12/16/97 BOOK: 1421 PAGE: 1047
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)
9/20/04:
below;
by failin9 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 $80,159.17
Unpaid.Igterest at 6.5%
from 5/1/04
to 9/20/04
(the per diem interest accruing on
this debt is $14.47 and that sum
should be added each day after
9/20/04) 2,007.44
Title Report 250.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $390.96 and that sum should
be added on the first of each
month after 9/20/04) 167.01
Late Charges
(monthly Iate charge of $27.70
should be added in accordance
with the terms of the note
each month after 9/20/04) 83.10
Other Fees Due 17.50
Attorneys Fees (anticipated and actual
to 5% of principal) 4,007.96
TOTAL $86,972.18
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
~ppearin9 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.
WMEREFORE, the Plaintiff demands judgwnent, in rem, a~ainst
the Defendant(s) herein in the sum of $86,972.18 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. Udre~,\
E~Q~RE
UDREN LAW oFFICES, P.C.
Attorney for Plaintiff
Attorney I.D. No. 04302
ALL T~AT CERTAIN piece or parcel ef land situated in the Borough
cf Camp ~111, County of Cumberland and Commonwealth of
Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a point at the southeast corner of the street lines
of DickinSon Avenue and South Thirty-first Street (formerly
called Girard Avenue), being also the northeast corner of Lot
No. 143 as shown On the hereinafter mentioned Plan of Lots;
thence along the eastern side of Dickinson Avenue in a
southwardly direction along the eastern sides ef Lots No. 143,
742, ~4~ and 140, as shown oh said Plan of Lots, a distance
of 1~0 2est to a point on the same at the dividing line be=ween'
Lots Nos. ]40 and 139, as shown on said Plan of Lots; thence
along sa.id dividing' line between Lots Nos. 140 and 139, as shown
on said Plan of LOts, in a westwardly direction, a distance
of 120 fest~ to a point on the eastern side of a 10-foot-wide
alley; thence along the eastern side of said TO-foot~wide alley
in a northwardly direction, along the western sides of Lots
Nos. 140, 141, 142 and 143, as shown on said Plan of Lets to
a point on the southern side of South Thirty-first Street
(formerly Girard Avenue); ~hence along said ~outhern side of
South Thirty-first Street in an eastwardly direction, along
the nc=them side of Lot NO. ~43, as shown on sai~ ~lan of Lots
a distance of 12~ feet to a point on the sam~ at the point of
intersection with the western side of Dickinson Avenue, the
place Of
S~NG ALL OF ~ot~ NOS. ~40, ~4~, ~42 an~ ~43, as Shown on a
certal~ suO-division Plan of Lots called "South Earlington",
a~ recorded in the Office of the Recorder ef Deeds in and for
Cumberland County, Pen~sylvaaia~ in Plan Book
HAVING erected thereon a dwelling house with attached garage,
known and numbere~ as 330 South Thirty-first Street, Camp Bill,
Pennsylvani~.
Nat m C y,
Mor'igage
National City Mortgage Co.
A Subsidiary of National City Bank of Indiana
3232 Newmark Drive · Miamisburg, Ohio 453,~
Telephone: (937) 910-1200
Mailing Address:
P.O. Box 1829
Dayton, Ohio 45401-1820
August 04, 2004
Patrick T Sullivan III
330 S 31st Street
Camp Hill PA 17011
Loan No. 859708-8
Current Servicer: National City Mortgage
HOW TO ~3RE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATO-RE OF ~ DEFAULT-- The MORTGAGE debt held by the above lender on
your property located at:
330 S 31st Street
Camp Hill PA 17011
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the
6/1/2004 8/1/2004
and the following amount(s) are now past due:
following month(s)
Monthly Payments
Late Charges
Other Fees
Less Suspense Balance
Total Due 2,899.06
2,834.91
55.40
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 ~OUNT PAST DUE TO THE
LENDER, WHICH IS $ 2,899.06, PLUS ~ MORTGAGE PAYMENTS AND LATE C~ARGES
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 held save your home. This Notice explains how the proaram works.
To s~ if HEMAP can helD, you must MEET WITH A CONSUMER CREDIT COUN-
SELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this_
Notioe with you when you meet with the CounselLng Agency.
The name. address and phone number of Consumer Credit Counselin~l Aaenc/es
servinq your Countv are included with this Notice; if you have any questions, you
may call the Pennsylvania Housincl Finanee-Aaenov toll free at 1-800-342-2397.
(Persons with impaired hearincl can c~ll (717) 780-1869).
This Notice contains important4egal 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.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANClA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRAi)UCCION ,~
INMEDITAMENTE LLAMANDO ESTA AGENClA (PENNSYLVANIA HOUSING FI-
NANCE AGENCY) SIN CARGOS AL NUMERO MENClONADO 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 EMERGENCY MORTGAGE A'SSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE.
YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS,
IF'YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
· EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HA~ BEEN CAUSED B~ CIRCUMSTANCES BEYOND YOUR
CONTROL. ...
· IF YOU HAVE A REASONABLE PROSPECT OF~B'EING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
· IF. YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED
BY THE PENNSYLVANIA HOUSING FINANCE AGENCY,
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a tempo-
raw stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice.
During that tfme 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, ,TH_IS 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 "HOW TO CLARE YOUR MORTGAGE
DEFAULT", ExpLAINS HOW TO BRING YOUR' MORTGAGE UP TO DATE.
CONSUMER CRED1T'COUNSEUNG AGENCIES - If you meet with one of the con-
sumer credit counseling agencies listed at the end of this notice, the tender may NOT take
action against you f0¢ thirty.(30)days a~ter the date of-t,~$ .meeting. The narr, es;3ddTesses
and telephone numbers of desiclnated consumer credit counselino agencies for the countv
in which the DroperW is located are set forth at the end of this Notice, It is only necessary to
schedule one face-m-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 f~llowing pages'for specific information about the
nature of your default). If you have tried and are unable to resolve this problem with the
lender, you have the right to apply for financial assistance from the Homeowner's Emer-
gency Mortgage Assistance Program. To do so, you mu~t fill out, sign and file a completed
Homeowner's Emergency Assistance Program Application with one of the designated
consumer credit: counseling agencies listed at the end of this Notice, Only,~=nsumer credit
counseling agencies have applications for the pr°gram and they will assist you in submit-
ting a complete application Lethe Pennsylvania Housing Finance Agency. Your application..
MUST be filed or postmarked within thirty (30) days of your face-to-face meeting,
YOU M. UST FILE YOUR APPLICATION PROMPTLY. IF'YOU 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 criteda estaJ~lished by the Act.
The P'ennsylvania Housing Finance Agency has sixty (60) days to make a decision after it
receives your applica~on. During that time, no foreclosure 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 QF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN A'I-I'EMPT TO
COLEECT THE DEBT..
(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.)
IF YOU DO NOT CURE TIlE DEFAULTCsee paae 1) - If you do not cure the default
within THIR'FY (30) DAYS of the date of this Notice, the lender intends to exercise its
r_iqhts_to accelerate the )'nortqacle debt. This means that the entire outstanding balance
of this "debt 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 star legal
action to foreclose uoon your mortgage orot~erty,
IF THE MORTGAGE I~ FORECLOSED UPON - The mortgaged property will be sold by
the Sheriff to pay offthe mortgage debt. If the lender refers your case to its attorneys, but
you cure the delinquency before the lender beg[ns legal proceedings against you, you will
still be required to pay the reasonable attorney's fees that were actually incurred, up to
$S0.00. However, if legal proceedings are staff[ed against you, you will have to pay all
reasonable attorneys' fees actually incurred b~; the iender even if they exceed $50.00.
Any attorney's fees will be added tO.the amoun~ you. owe the lender, which may also
include other reasonable costs. If you cure the'default wtthin:the-rHIRTY'(30) DAY ~eriod.
YOu Will not be reouired to Day attornev'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'THE DEFAULT:PRiOR TO'SHERIFF'S SALE - If you have not cured
the de~ault within the THIRTY (30) DAY period and foreclosure proceedings have begun,
you still have the rioht to cure the default and prev~nt'th~ sale at any time UD to one hour
before the Sheriffs Sale. You may do so by' paving' the total amount then Da_st due. plus a.n_y
late or other charges then due; reasonable attorney'S fees and costs connE~ked with the
foreclosure sale and any other costs connected with the Sheriff's Sale as specified in
wdting by the lender and by pefforminc~ any other recluirements under the mortaac~e. CUr-
ing your default in the manner set forth in this notice will restore your mortgage to
the same positi°n as if you hsd never defaulted,
EARLIEST POSSIBLE SHER'IFF;S SALE DATE - it is estimated that the earliest date
that'such a Sheriff's Sate of the mortgaged property could beheld would be approxi-
mately FOUR(4) 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 oourse, the amount needed to cure the
default v411 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.
¢?" !O 36A~ NATIONAL
0~... :?. 2002 :
,HOW TO CONTACT THE LENDER: Name of Lender: National City Mo~gage
A~ddress: 3232 Newmark Dr. Miamisburg OH 45342
Phone Number: 1-800-523-8654 Fax Number: (937) 910-4058
Contact Person: COLLEC'[IONS DEPT.
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 furnishing ~nd other
belongin.gs, 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 pdor 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 DEB'T.
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 CURE THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
TO ASSERTTHE NONEXISTENCE OF DEFAULT IN ANY FORECLOSUIRE.PRO-
CEE[DING 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 PROTECTIOh UNDER THE FEDERAL BANKRUPTCY LAW.
2002
NATIONAL CITY
APPENDIX C
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
- CONSUMER CREDIT COUNSELING AGENCIES
(717) 637.3768
FAX ('717) 637-3294
CCCS ot Western PA
2000 Llngle~[own Road
(717) 762-328.5
FAX {7'[7) 334-8326
(Marcia
[724) 852.-2883
(412~ 227-a8~
', (412) 482-99{52
~724) 485-2657
FAX ('724} 465-$118
~12) 3,gl-~ass
(724) 774-07186
(~4) 726-751
(~t 1.2) 4~2-8962
(412} 462-9~64
HOUSing ~ponun[l~as Inc,
HT2) 338-9854 o~ 1'(a~) 737-~
FAX (412) ~8-9~63
F~X (814)
(81~) ~4-8100
F~ (814) 443-3690
(814) ~3-~3
CCCS of Lehigh
Whilehall PA 18052
(610) 821-4011 or 800-22.0-2.7'33
FAX (610) 8Z1.883~
(717}
FAX {717)
(§ 10)
FAX {610) 444.8243
(814} b'23-8129
FAX (814) 623-7187
Keyslone Economic Deveiapmeflt Corp
(814)
F~ {81~4)
GOC$ o~ Westm'n Peil~,sylvanla. inc.
(814) 944-8100 Or (814) 944.57/~7
917 Mifflin Stme[
(814) 843-2343
CCC$ ol Nmrt~eastem
1400 Ablr~on Exect.a~ Pa~% Sui[e I
[570) 587-8163 OR I-800-922-8537
FAX (E/0} ~;87-8134/9135
[570) 821-06;37 or 600-922--9537
FAX (570) 821-171~ "·
$1mud.~Ln~ PA 18360
(0-70) 420.8980 or 800-9~2.-8537
FAX (570) 420-8581
(814-) 2,38-3668
FAX (814) 23~t366~
FA~ [~70) 278-1688
P,0. Bo~ 21s
(ET0~ 2~7-210~'
(Rev,
33 9Vainut Stree[
Welt~bom, PA 16901
(STO)
FAX (670) 724-~a~
931 Main Stme{
Ho~es~le PA 18431
~0)
F~ (5701 ~3~517
~UCK~ COU~
F~ (2~5) 76~14~
(21~ ~4.7500
F~ (215) 32~7~
(21~ 75~310
P~la~e~ni~ PA 18140
(215) 426-8025
FAX (215) 42~81~
CCCS oJ De~m Vall~
P~el~a, PA 19124
(215) 7~-2980
F~ (215) 7A4.201~
CCC5 of L~ig~ V~ley
W~e~[. PA
FAX (~10)
(~Sa) 212-6~41
1~ E De~alb Pi~e
~ of Pm~ia PA
61~97t-~I0
FAX (610~ 265~8t
(215) ~-9429
FAX (215)
F~ (412)
CCCS of W~tem PA
(726) 2~-7~2
{412)
FAX {4~2) 6~873 , '
Hmuslng Oppoffunl~ inc.
(814) 623.g129
F~ ~814) 6~7187
(412)
(814) ~-6556
(s~4)
~REON COUN~
3671 Cresenl Caurl'Eaat
FAX ~I0) 821-0137
FAX I570) 567-9134/9135
FAX (570) S1~-1785
FAX (ET0} 420-8981
{814) 238.3688
FAX (814) 238-3s69
,C. EFT~E¢ OUHTY
FAX (a14) 944-$747
(570) 3.2~0587
(1~14) 236.-36B8
FAX (814) 238.3669
(570) 32B-0587
Fp, X ($70) 322-2197
(215) 765,1221
(2~ 5) 324-7500 '
FAX (~15) 324.t~7~
(21 s)
HAZE
167 W,
Phllaaeiphia, PA lg140
f~ {21S)
(61 ~} 444-3682
FAX [610)
FAX ~17) 399~1~
(610)
FAX (610) 2~ala
1954 ~ Gra:~
FAX (814} S~-lSS8
AX (B14)
1631 $ AIherton $[,, Suiie 100
FA)~ (814) 238-366g
(B14) 539.6335
FAX (570)
(B14)
FAX (570) 323-6626
~_~ou~
P.O. Box 11~7
FAX (~0) B21.17~
~a~ 5um~lk PA 1~11
F~ (~0) 867-91~135
(~0) 825-0510 OR 1
FAX {~0) ~g-l~A~ BEFORE
FAXING
(~0) 455~994 H~ELTON
F~ (570) 455*5~l~ALL BEFORE
(57~) 836~0~ TUNK~ANNOCK
Erie PA le~3
(814}
(814)
FAX (8~4} 45~161
(814) a98~4~
F~ (814) ~9B.1~43
Shensng~ Valley Uman League,
(432~ 981-5310
(717) 5~I-17~
FAX (717) 541 ~670
FAX (717) '~34-g4.,~-'
(-7 ~ 7~ 243-3818
FAX ~7) ~-~7
FAX ffl~ ~4~4670
~7) ~-~
P~ (717) 2~-~7
F~ ~15} 765-1427
FAX (~15)
[215) 42~8025
(SI0) 565~846
PAX (610)
~15)~67-7803
FAX (2~
4~0 G~om Street
Phaa~e~i~, PA 19124
.~(~Q} 674-1484
(215)
(610) g71-~10
FAX (610)
(6t~) 97~-~I 0
Jo~n F, Ken~ ~nler, Inc.
2021 ~ 2~ Skree~
{814) 89B~00 .
F~ (814) 896-1243
(614) ~6.1161
F~'(814) 48~S25
(8~4) .453.57~4
FAX (~4)
Gm~ter Ede ~Un~ At,on
~ommiffee
(B14)
F~ (814)
~1 ~t 20th
E~. PA 16S10
F~ (414) ~8-1243
(4~2} ~1.1956 ot {412) 281-~10~
FAX (41~) ~91~12
CCC$ o~ Western Pen~,
~24) 437-6~50 OR 1~0~27-1NF0
FAX (413) 437--~41e
FAX (814)
CCCS OF W~iern PA
UnJonto~ PA 154~1
(~4} 43~39
(412)
O~po~nity Co.oil
~7~
FAX .~17) 637~294
CommunRy ~lion Ca~ion
C~ti~ Region
F~ (7~7) 3~-~26
FAX [81~) ~-7.187
~17} 7~2.~B5
~17)
PIRsDu~n. pA 15219
(412) 391-1~56 ot (412~
FAX (412) 39t-4512
FAX (412) 4~-~64
~2~)
FAX (412} 6~7-~13
(814~ ~-9129
FAX (814) 623-71~7
FAX [al~)
~4) 83~12g0
I~a~ ~. Comm~ ~n P~
~4 ) 46~2~
FAX (412)
FAX (814)
~s~ cou~
Jo~n F. ~anne~y O~nleh Inc.
~4) Bg~-~oo
FAX (814)
Prog~
PAX (~IZ) 4~5-5~
OCT., 1% 2002x}O:37^M
(814) 944-8100
FAX ($1~)
(717) & (8~4) ONLY
FAX (215)
~17) 397-5~ OR 1-80~7a8-50~2
~Z4) 652-a074
~Z4)
~4] 72B-~02
F~ (412) 728-7202
(570) S~2-
CCC$
(610) B~I.,4011 OR 1-60~27~3
[57~ & (814) ONLY
Co
570) 8~1-oe37 OR
FAX (570} ~ -17~
(57o) ~7-81 ~ or ~0-9~-8537
FAX (~0)
~mm.
(~O) 826-0~10 OR
FAX (570) 8~l~A~
F~ING
(~0) 455~994 H~TON
FAX (~0) 45~5~1~A~ BEFORE
FAXING
(570) S3~0 TUNKHA~OCK
EOC o~ S~uyAill
~t~a; PA 17901
FAX (S70) 6~4~
31 W.
O.O. BOX ~1~
Wllgee-~a~, PA 18702
{~0) 821.0~7 OR .1-8~-g22~7
FAX (570) 821-1785
(~0) 587-91S3 or.~9~-9637
F~ (STO) S87.9134~1~
~1~ PA 1~
F~ (570) 323-6626
~po~ PA 17?03
FAX (~0) 3~-2~g7 '
M~N COU~
{814) 898~00
FAX (834) a98-12~
P.D. Box 389
814) 486-~ 16~
FAX {81A ~6~825
33~ North Wa~hb3Oion SIree!
{7~4) 282-78'12
MI~LIN COU~
217 E-
[814) g~-8100
FAX (814) 944-5747
(814)
(814) ~6-~668
CCCS Of No~oastem
(S70) 587-g1~
FAX (~0)
9 Saut~ 7~ Street
S roddaburg PA 18360
(570} 42~980 or 800~22-g~7
F~ (~ 420-89B1
~kes-Ba~, PA
F~ 1570~ 829-16S~aLL BEFORE
F~iNG
· (~0) 455~g94 H~ELTON
FAX (570) 455-5~1~ BEFORE
(~0} 836~090 ~NKHANNOCK
P~a~AIA, PA 1
(215)
F~ (215) 765-1427
Nod~we~l ~aeiiqg
(215) 324-7~0
FAX (2f5) 324-8T~
{610)
F~ (630) 2~-2123
CCCS o~ Delaware Vattey
(215) 563-5665
FAX (21~) ~4-~243
(570) e~.1-0837 OR
FAX (570) 821-17~
F~ {ST0) 5S7-91~35
U17) & (814) ONLY
FAX (~10)
NOR~UM~ ER~
F~ (570) 621,1785
FAX ~0)
FAX (ST0) 6~2.~29
EEn~y CO~
FAX (717) 5~q-4~70
~ 17) 762-~B5
~17) 2~,5925
{8~} 64.3-2348
(71 ?) ~2-~
FAX (215)
FAX (~l)
~215)
F~ {215) 7~-7614
NATI UNAi, bi
FAX .~,570)
7400 ~ton ~e~t~ Pa~. ~e 1
Cla~ S~ PA 1~11
FAX (~0) 587~1~1~
Stmu~ ~A 18300
~ (570} 42~981
(g14) 48~1
~AX (814)
~HUYLK~LL
Reaa~, PA 1~01
(610) 37~-7866
FAX (610) 3Z~7830
E~n ~ ~inet al S~u~la Co
Po~Ula. PA 17901
Com~s~ on E~n ~DIu~ily
BEFORE
F~ (~0) 4SS-5~I~C~L BEFORE
(~0) ~011
SN~E~ COU~
He~sDu~, PA 171~
~ ~-17S7
F~ ~17) ~1~670
21~7 N, 6~
~7) ~-1757
FAX (7~
Comm~JW ~Oon
Regio~
FAX ¢I~ 23~7
EYe,CJI, PA 15537
(~4) s2~912g
F~ (814) 6~-7187
{724)
Jen~slown PA 15904
-Tableland Serv~cm; Inc.
{B14} ~9628 - 1.80~52~148
FAX (8~4)
~IJLLIVAN COU~
~G~ OI N~he~m Penn~W~ia
(~0) ~?-91~ OR
(5~) 821~7 or 8~2~-9~37
FAX (~0) a21-17~
(~0) 297-210~
FAX (~)
(~0)
F~ (S~ 928.81
(~oJ 72~2
103 We~ ~[, P.O. Box 709
~0) a~6840
(~01 278.~6
F~ (570) ~78-
~~cou~
GC~ ~ No~e~tem Pmn~lwania
14~ ~tn~on
(~0) 587~1~ OR 1~g~-9537
31 .W. Marc[
(570) ~?~8~ or' 8~-g~-9537
~ T~ ~er
(~0 92~966B
F~ (570
(570) 724-5252
(~0) 253-89+1
F~ (~0) 83~32
FAX (D0) 926-8144
FAX (~0) 724,~3
(~o)
F~ (570)
(~0)
Gr~mt ~de Communily Action
WARREN COUNTY
F_tie, PA ~ ~03
~po~nlty
Coun~
Pl~, PA 15219
(41~) ~I-19~ ~r (412)
COCS of We~em Pann~vahi~. lnc,
I No~ ~at~ ~quare
~4)
M=~espon, PA 15132
{432) ~1~0
FAX (4~2) 6~873
F~ (412) 462-g96
(432) ~8-S~S4 or I(B00) 737-2933
FAX (412) 338-9963
1~ ~n ~ Pa~, ~le 1
(570) ~7-91~3 OR
FAX (570~ 587-9134~1~
(ST0} 821-0837 or 600~22-g~7
FAX (570)
tST0) 4~o~ao or
FAX ~70) 420-608~
FAX (~0}
NATIONAL
FAX (570) 297-279g
FAX [570) ~2~8144
(S~o)
FAX (570)
F~ (570
(~0) 8~e4o
FAX {4t~) ~1~512
W~u~, PA 15370
FAX (412)a~0a~
(~12) 4e2.g962
F~ (412)
~24)
FAX (724) ~-51 iB
(814)
(81 ~)
FAX (834)'~3-3SS0
FAX H12) 338-9~
3~m'OMfNG CO_U~rrY
(~O) ~51D OR ~-B0~-0359
F~ING
F~ ~0~ 455,S~l~ALL ~ORE
(~0) ~6~0 TUNK~NNOC~
(~) 5~-DI~ OR 1~0~2~537
F~ (~) ~I-1735
F~ ~) ~7-2799
(~0) 62~966e
FAX (S70) 724-~83
FAX {~)
F~ ~1~ ~4~7934
~17)
FAX ~1~ ~-8326
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 of his information is public records and
reports of Plaintiff's agents. The undersigned understands that
this statement herein is made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
Mark J. Ud
UDREN LAW
SHERIFF'S
CASE NO: 2004-04750 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONAL CITY MORTGAGE CO
VS
SULLIVAN PATRICK T III
RETURN - REGULAR
RONALD HOOVER
Cumberland County,Pennsylvania, who being duly
says, the within COMPLAINT - MORT FORE was
SULLIVAN PATRICK T III
DEFENDANT , at 1900:00
at 330 SOUTH 31ST STREET
CAMP HILL, PA 17011
PATRICK SULLIVAN III
a true and attested copy of
HOURS,
, Sheriff or Deputy Sheriff of
sworn according to law,
served upon
the
on the 23rd day of September, 2004
by handing to
COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18
Service 11
Affidavit
Surcharge 10
39
00
10
00
00
00
10
Sworn and Subscribed to before
me this ~ day of
O~ ~L~3~ A.D.
otary
So Answers:
R, Thomas Kline
09/24/2004
UDR N LAW OFF C
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.
Plaintiff
Vo
Patrick T. Sullivan, III
Defendant
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
: CIVIL DIVISION
. Cumberland County
-NO. 04-4750
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly mark the above DISCONTINL~ED WITHOUT PREJUDICE,
upon payment of your costs only.
Mark J. Udren, Esquire
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
DATED:October 27, 2004