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F`ENI~SY~.VANIA
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: M~4RK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID#45362
LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576
SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675
SALVATORE CAROLLO, ESQUIRE - ID#311050
PAIGE M. BELLING, ESQUIRE - ID#309091
HARRY B. REESE, ESQUIRE - ID#310501
KASSIA FIALKOFF, ESQUIRE - II}#310530
ELIZABETH L. WASSALL, ESQUIRE - ID#77788
AGNES MOMBRUN, ESQUIRE - ID#309356
ELANA B. FLEHINGER, ESQUIRE - ID#209197
KATHERINE E. KNOWLTON, ESQUIRE - ID#311713
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadingsC~udren.com
PNC Bank, National Association COURT OF COMMON PLEAS
C/O PNC Bank, N.A. CIVIL DIVISION
3232 Newmark Drive !CUMBERLAND County
Miamisburg, OH 45342 ~
Plaintiff n ~ ~ l
v. NO. ' p[, S'S~0
DANIEL L. CORRIGAN
623 3RD STREET A/K/A 623 THIRD STREET
hiEW CUMBERLAND, PA 17070
LESLIE A. CORRIGAN A/K/A LESLIE R. CORRIGAN
623 3RD STREET A/K/A 623 THIRD STREET
NEW CUMBERLAND, PA 17070
Defendant(s)
COMFLAINT 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
G s 103.7Spd a N~
~x-r~ 3 sya ~
' 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 PROVH)E 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
(800) 990-9108
AVISO
Le han 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 provisioner de esta demanda. Usted
puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O 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
(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 PNC Bank, National Association .Plaintiff is the legal. holder of the
Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of
record, is the legal holder of the Mortgage by virtue of being successor in interest to
the current mortgagee of record, or is the legal holder of the Mortgage by virtue of
Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of
Assignment of Mortgage, it is by the following Assignments of Mortgage, all of
which have either been recorded or Plaintiff is in the process of formalizing the actual
Assignment of Mortgage in Plaintiff s favor:
Assignor: N/A
Assignee: N/A
Date of Assignment: N/A
Recorded Date: N/A
Book/Instrument N/A
Page: N/A
2. Upon information and belief Defendant(s) and/or their predecessor:
Daniel L. Corrigan and Leslie A. Corrigan a/k/a Leslie R. Corrigan
(hereinafter "Defendants"), are the owners of property located at 623 3rd Street a/k/a
623 Third Street, New Cumberland, PA 17070 , by virtue of Deed dated 04/12/2006
and recorded 04/19/2006 in Official Records Book 274 at Page 471 of the Public
Records of Cumberland County, Pennsylvania (hereinafter the "Property").
3. On 04/12/2006 ,Defendant(s) and/or their predecessor:
DANIEL L. CORRIGAN AND LESLIE A. CORRIGAN A/K/A LESLIE R.
CORRIGAN
promised to pay to the order of National City Mortgage a division of National
City Bank of Indiana ,the principal sum of $ 238,000.00 payable with interest
thereon provided in the Note.
4. By Mortgage dated 04/12/2006 ,Defendant(s) and/or their predecessor:
DANIEL L. CORRIGAN AND LESLIE A. CORRIGAN A/K/A LESLIE R.
CORRIGAN
to secure the Note, mortgaged to National City Mortgage a division of National
City Bank of Indiana , the Property which is the subject of this action. The
Mortgage was recorded on 04/19/2006 in Official Records Book 1947 at Page 1967
. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P
1019(g). A legal description of the mortgage premises is attached hereto and made
a part hereof.
5. Said mortgage is in default in that the payment due 04/01/2012, and all subsequent
payments have not been made, and by its terms, upon breach and failure to cure said
breach after notice, all sums secured by said Mortgage, together with the other charges
authorized by said Mortgage and itemized below, shall be immediately due.
6. After demand, the Defendant(s) continues to fail or refused 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 below;
(b) By failing or refusing to pay other charges, if any, indicated below.
The following amounts are due on the said Mortgage or modification agreement as of the
date stated below
Unpaid Principal Balance $279,099.79
Accumulated Interest $6,156.54
Accumulated Late Charges $63.95
Escrow Deficit/(Reserve) $2,401.56
Recoverable Balance $490.00
Grand Total $288,211.84
The above figures are calculated to 08/23/2012:
The interest rate is subject to adjustment if more fully described as such in the note and
mortgage. The interest rate on the subject note is at 4.62500 The per diem interest accruing
on this debt is $35.37 and that sum should be added to the above date and each day after the
above date.
The late charge is subject to adjustment if more fully described as such in the note and
mortgage. The late charge rate on the subject note should be added in accordance to the terms of
the note and mortgage charged monthly at $63.95.
7. Breach letters have been sent to Defendant(s) in accordance with the requirements of
the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of
Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached
hereto as Exhibit "A"
WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the
sum of $288,211.84 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged
premises.
UDRE CES, P.C.
BY:
Sherri Braunstein, Esquire
PA ID 90675
VERIFICATION
I, Bn~ceTrowman , as an Authorized SigRar of the Plaintiff, PNC
Bank, National Association do hereby verify that I am authorized to and do make this
verification on behalf of the Plaintiff and that the facts set forth in the foregoing Complaint are
true and correct to the best of my information and belief. I understand that false statements
therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: ~S ~`30 O 1'~ ~l~t c.[1-~--
Name:
Title: Authorized Signer Bruce T?owrnan
Company:- PNC Bank, National Association
1vIJU 12070145 CASE 12070145-1
ALL THOSE CERTAIN LOTS OR TRACTS OF LAND SITUATE IN THE BOROUGH
OF NEW CUMBERLAND, COUNTY OF CUMBERLAND AND STATE OF
PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS
FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE NORTHEASTERN CORNER OF THIRD STREET
AND ROSEMONT AVENUE AND EXTENDING NORTHWARDLY ALONG THE LINE
OF THE SAID ROSEMONT AVENUE A DISTANCE OF 140 FEET TO A TWENTY-
FOOT WIDE PUBLIC ALLEY; THENCE EASTERLY ALONG THE LINE OF THE
SAID ALLEY 100 FEET TO THE DIVIDING LINE BETWEEN LOTS NOS. 8 AND 9;
THENCE SOUTHWARDLY ALONG THE LINE OF THE SAID LAST MENTIONED
LOTS, A DISTANCE OF 140 FEET TO THE NORTHERLY SIDE OF THIRD STREET;
THENCE WESTWARDLY ALONG THE NORTHERLY LINE OF THIRD STREET A
DISTANCE OF 100 FEET TO THE NORTHEASTERN CORNER OF THIRD STREET
AND ROSEMONT AVENUE, THE POINT AND PLACE OF BEGINNING.
BEING LOTS N. 9, 10, 11 AND 112 IN BLOCK `B" IN THE GENERAL PLAN OF
GEORGE W. BUTTORFF'S ADDITION TO THE BOROUGH OF NEW
CUMBERLAND, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS
IN BOOK `B", VOLUME 5, PAGE 498.
HAVING THEREON ERECTED A BRICK DWELLING HOUSE KNOWN AND
NUMBERED AS 623 THIRD STREET.
UNDER AND SUBJECT TO ACTS OF ASSEMBLY, COUNTY AND TOWNSHIP
ORDINANCES, RIGHTS OF PUBLIC UTILITY AND PUBLIC SERVICE
COMPANIES, EXISTING RESTRICTIONS AND EASEMENTS, VLSIBLE OR OF
RECORD, TO THE EXTENT THAT ANY PERSONS OR ENTITIES HAVE ACQUIRED
LEGAL RIGHTS THERETO.
AS DESCRIBED IN DEED BOOK 274 PAGE 471
REPRESENTATION OF PRINTED DOCUMENT
Attention: Collection Department
(B6-YM07-01-5)
'R`T~'iAGE~' 3pGiam sbu 9
OH 45342
7107 8381 6590 2133 9350
5749-75505.0000014-001-01-006-000-000-000
LESLIE A CORRIGAN
623 3RD ST
NEW CUMBERLAND PA 17070
Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Exhibit A
t~4
)~ERNET REPRINT
_ REPRESENTATION OF PRINTED DOCUMENT
May 30,.2012
Re: Loan No. 0004627751
NOTICE OFINTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by PNC Mortgage a division of PNC Bank, National Association (hereinafter we, us or
ours) on your property located at 623 Third St New Cumberland PA 17070,15 IN SERIOUS DEFAULT because
you have not made the monthly payments of $3,395.68 for the months of April 1, 2012 and May 1, 2012. Late
charges and other charges have also accrued to this date in the amount of $499.00. The total amount now required
to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $3,894,68.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of
$3,894.68, plus any additional monthly payments and late charge which may fall due during this period. Such
payment must be made either by cash, cashier's check, certified check or money order, and made at PNC
Mortgage/Collections Center, Mail Code B6-YM09-O1-01, 3232 Newmark Drive, Miamisburg, OH 45342.
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the
mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment
of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a
lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by
the Sher•~to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they
begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to
$ 50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees
even if they are over $ 50.00. Any attorney's fees will be added to whatever you owe us, which may also include our
reasonable costs. If
you cure the default within the thirty day period, you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you
have not cured the default within the thirty day period and foreclosure proceedings have begun, you still hm~e the
right to cure the default and prevent the sale at arty time up to one hour before the Sherds foreclosure sale. You
may do so by paying the total amount of the unpaid monthly payments plus arty late or other charges then due, as
well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other
requirements under the mortgageJ. It is estimated that the earliest date that such a Sheriffs sale could be held would
be approximately nine -ten months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of
course, the amount needed to cure the default will increase the longer you wait. You may find out at any time
exactly what the required payment will be by calling us at the following number: 1-800-523-8654. This payment
must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriff s sale will end your ownership of the mortgaged property and your right to remain
in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you.
You have additional rights to help protect your interest in the property. YOU 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. [YOU MAY HAVE THE RIGHT TO SELL
OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO
DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
If
you cure the default, the mortgage will be restored to the same position as if no default had occurred However,
you are not entitled to this right to cure your default more than three times in any calendar year.
We do encourage you to contact aHUD-approved counseling agency for financial counseling. To locate an agency
near you, please visit www.hud.gov or call 1-800-569-4287.
This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have
received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan
was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only
exercise its rights against the property itself, and is not attempting to collect the discharged debt from you
ppersonally.
INTERNET REPRINT
REPRESENTATION OF PRINTED DOCUMENT
Attention: Collection Department
(B6-YM07-01-5)
_ ~ID~?~iE54 Miam sbu g,
OHD45342
7107 8381 5590 ?_133 9393
9-749-75505-0000013-001-01-000-000-000-000
DANIEL L CORRIGAN
623 3RD ST
NEW CUMBERLAND PA 17070
Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE
PA003
INTERNET REPRINT
REPRESENTATION OF PRINTED DOCUMENT
May 30, 2012
Re: Loan No. 0004627751
NOTICE OFINTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by PNC Mortgage a division of PNC Bank, National Association (hereinafter we, us or
ours) on your property located at 623 Third St New Cumberland PA 1.7070, IS IN SERIOUS DEFAULT because
you have not made the monthly payments of $3,395.68 for the months of April 1, 2012 and May 1, 2012. Late
charges and other charges have also accrued to this date in the amount of $499.00. The total amount now required
to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $3,894.68.
You may cure this default within THIRTY (30) D,4YS of the date of this letter, by paying to us the above amount of
$3,894.68, plus any additional monthly payments and late charge ia~hich may,fall due during this period. Such
payment must be made either by cash, cashier's check, certified check or money order, and made at PNC
Mortgage/Collections Center, Mail Code B6-YM09-O1-01, 3232 Newmark Drive, Miamisburg, OH 45342.
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the
mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment
of the amount of default is not made within THIRTY (30) DAYS, we also intend to Instruct our attorneys to start a
laH~suit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by
the Sher~to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they
begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to
$ 50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees
even if they are over $ 50.00. Any attorney's fees will be added to whatever you owe us, which may also include our
reasonable costs. if
you cure the default within the thirty day period, you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you
have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sherds foreclosure sale. You
may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as
well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform arty other
requirements under the mortgageJ. It is estimated that the earliest date that such a Sheriffs sale could be held would
be approximately nine -ten months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of
course, the amount needed to cure the default will increase the longer you wait. You may find out at any time
exactly what the required payment will be by calling us at the following number: 1-800-523-8654. This payment
must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain
in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you.
You have additional rights to help protect your interest in the property. YOU 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. [YOU MAY HAVE THE RIGHT TO SELL
OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO
DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOiJR BEHALF.
If
you cure the default, the mortgage will be restar•ed to the same position as if no default had occurred. However,
you are not entitled to this right to cure your default more than three times in any calendar year.
We do encourage you to contact aHUD-approved counseling agency for financial counseling. To locate an agency
near you, please visit www.hud.gov or call 1-800-569-4287.
This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have
received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan
was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only
exercise its rights against the property itself, and is not attempting to collect the discharged debt from you
personalty.
INTERNET REPRINT
' FORM 1
IN THE COURT OF COMMON PLEAS OF G~ ,
r~:
~~f~1 ~~jy~? CUMBERLAND COUNTY. PENNSYLy'ANI~~~ -.~:-Y;
~'~P ainfftt(s~'"~/C'J'~: r~n~-=~ ~ ' ,.r'-,j
~
Defendant(s) ~oc SSZQ b Civil ~G ~tr`'
~ ~ r'`''
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to Pose your home.
If you own and live in the residential property which is the subject of this foreclosure action. you may
be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your
lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal
Services at (717) 243-9400 extension ] 0 or (800) 822-5288 extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative, you must
promptly meet with that legal representative within twenty (2U) days of the appointment date. During that
meeting you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
worksheet in the format attached hereto, the legs] representative will prepare and file a Request for Conciliation
Conference with the Court. which must be filed with the Court within sixty (60) days of the sen~ice upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
If you are. represented b}~ a la~cyer, you and your lawyer must take the following steps to he
e[ig'eble for a conciliation con€erence. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However, you must provide your lawyer with all requested financial
information so that a Loan resolution proposal can be prepared on your behalf, if you and your lawver complete
a financial worksheet in the format attached hereto, your lawyer will prepare and. file a Request for Conciliation
Conference with the Court, which must be fled with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. ]f you do so and a conciliation conference is scheduled, you «~ill have an
opportunit<~ to meet with a representative. of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forwarii.
IF YUU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REt1'UIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Re ~tted:
Date jSignature of Counsel for Plaintiff)
Sherri J. Braunstein, Esquire
PA ID 90675
• FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROV4jER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please pro~~ide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? ~'es ? No ? Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied'? Yes ? No ?
Maiiin~ Address (if different):
Cite: ~ State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How Lang?
Mailing Address:
City: ~ State: Zip;
Phone Numbers: Home: Office:
Cell: Other:
Email:
of people in household: How long?
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage. PaS~nents Amount: $ Included Tapes 8~. Insurance: _
Date of Last Payment:
Priman• Reason far Default:
Is the loan in Banl~ruptcy? Yes ? No ?
_ _ _
.
_
i
' if yes, pro~2de names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $ i
Retirement Funds: $ $
Lnvestments: $ $
Checking*: $ $
Sa~ings:^ $ $ i.
Other: $ $ ~
i
,Automobile #l: A-lodel: Fear:
Amount owed: Value:
Automobile #2: Model: Year:
Amount owed: Value:
Other transportation (automobiles. boats. motorcvcles~: Model:
Year: Amount owed: Value
'i Monthly Income
Name of Employers:
1.
I
I
Additional Income Description (not ~~~ages):
I . monthly amount:
~ monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
MortsaQe Food
2"° Mort aye Utilities
Car Payment(s) Condo/Nei h. Fees
i
Auto Insurance Med. (not covered)
Auto fuel/re airs Chher ro ayment
~ Install. Loan Payment Cable TV 1
~ Child Su ort'Alim. S endin Mone~~ ~
~ Day/Child CarelTuit. j ~ Otlier Expenses
.Amount Available for ivlonthly Mortgage Payments Based on Income & Expenses:
Have you been ~~-orking with a Housing Counseling Agency?
Yes U No ?
If yes, please pro~~ide the following information:
Counseling .Agency:
Counselor;
Phone (Officej: Fay:: _
I
• Email:
Have you made application .for Homeowners lmergency Mortgage flssistance Program
(HEMAP) assistance?
Yes No ?
If ves, please indicate the status of the application:
Have ~~ou had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ? No ?
If ves. please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or Lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact' Phone:
h~We• ,authorize the above
named to use/refer this information to my lender,~servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. UWe
understand that I/we am;are under no obligation to use the services provided by the above
named
Borro~~~er Signature Date
Co-Borrower Signature Date
Please forward this document. along with the•following information to lender and
lender's counsel:
Proof of income
i
1~ Past 2 bank statements
V Proof of any expected income for the last 45 days
1~ Copy of a current utiiih~ bill
Letter expiainiag reason far delinquencti~ and any supporting documentation
J (hardship letter)
~V Listiag agreement (if property is currentl~• on the market)
J
_
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ~;`~QT~I~~~~~.~t'+'
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID#45362 ~ ~ ~ ~ ~ $
LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 ~~.U'~~EI.AND CQUNTY
SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 ~~NSYL.~Atdi~
SALVATORE CAROLLO, ESQUIRE - ID#311050
PAIGE M. BELLING, ESQUIRE - ID#309091
HARRY B. REESE, ESQUIRE - ID#310501
KASSIA FIALKOFF, ESQUIRE - ID#310530
ELIZABETH L. WASSALL, ESQUIRE - ID#77788
AGNES MOMBRUN, ESQUIRE - ID#309356
ELANA B. FLEHINGER, ESQUIRE - ID#209197
KATHERINE E. KNOWLTON, ESQUIRE - ID#311713
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadin~s(a~udren.com
PNC Bank, National Association COURT OF COMMON
3232 Newmark Drive, Miamisburg, OH 45342 PLEAS
Plaintiff 'CIVIL DIVISION
CUMBERLAND County
DANIEL L. CORRIGAN
623 3RD STREET A/K/A 623 TIHRD STREET
NEW CUMBERLAND, PA 17070 NO. - ~S(~ ~ ~c'U( ~
LESLIE A. CORRIGAN A/K/A LESLIE R. CORRIGAN
623 3RD STREET A/K/A 623 THIItD STREET
NEW CUMBERLAND, PA 17070
Defendant(s)
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire;
Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Sherri J. Braunstein, Esquire; Paige M.
Bellino, Esquire; Harry B. Reese, Esquire; Kassia Fialkoff, Esquire; Salvatore Carollo,
Esquire; Elizabeth L. Wassall, Esquire; Agnes Mombrun, Esquire; Elana B. Flehinger,
Esquire; Katherine E. Knowlton, Esquire; on behalf of the Plaintiff, in the above-
captioned matter.
UDRE FICES, P.C.
BY:
Sherri J. Braunstein, Esquire
PA ID 90675
SHERIFF'S OFFICE OF CUMBERLAND COUNTY C
Ronny R Anderson MF
Sheriff x�6 r— V rri
at Climb,
Jody S Smith co C
Chief Deputy , -r
Richard W Stewart - - a
Solicitor OFFJCE OFTME SRERIFF �+ �
PNC Bank Case Number
vs.
Daniel L. Corrigan let al.) 2012-5568
SHERIFF'S RETURN OF SERVICE
01/03/2013 11:29 AM-Deputy Dennis Fry, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 623 3rd Street a/k/a 623 Third Street, New Cumberland,
PA 17070, Cumberland County.
03/04/2013 As directed by Mark Udren,Attorney for the Plaintiff, Sheriffs Sale Continued to 5/1/2013
04/30/2013 As directed by Mark Udren,Attorney for the Plaintiff, Sheriffs Sale Continued to 7/10/2013
07/03/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $1,223.81 SO ANSWERS,
July 03, 2013 RbNtV R ANDERSON, SHERIFF
Lo L
5',
{c}Coun±ySuite Sher-iff,7eleosoft,Inc.
WRIT OF EXECUTION and/or ATTACHMENT
66MMOf4WEALTH OF PENNSYLVANIA) NO. 12-5568 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PNC BANK,NATIONAL ASSOCIATION Plaintiff(s)
From DANIEL L. CORRIGAN,LESLIE A.CORRIGAN A/K/A LESLIE R. CORRIGAN
(1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEE(S)as follows:
and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the gamishee(s) is enjoined from
paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant
(s)or otherwise disposing thereof,
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $291,834.58 L.L.: .50
Interest FROM 11/29/2012 TO DATE OF SALE MARCH 6,2013-Ongoing Per Diem of$35.37 to
actual date of sale including if sale is held at a later date -43146..1.6
Atty's Comm: Due Prothy:$2.25
Atty Paid: $212.25 Other Costs:
Plaintiff Paid:
Date: 12/3/12
David D. Bu 11,Prothonot
(Seal) BY.
Deputy
REQUESTING PARTY:
Name: KATHERINE E. KNOWLTON,ESQUIRE
Address: UDREN LAW OFFICES,P.C.
WOODCREST ROAD,SUITE 200
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
Attorney for: PLAINTIFF
TRUE COPY FF2C.lEId RECORD
Telephone: 856-669-5400 In Testimonywhere;of, i e.re unto set my hand
Supreme Court ID No.311713
and the s a!of s�,i�!C r at.dar4t§Ie,Paff
This day of�,20/�
t onotary
On December 11, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
New Cumberland Borough, Cumberland County, PA,
Known and numbered as, 623 3rd Street, a/k/a 623 Third
Street, New Cumberland, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: December 11, 2012
By:
Real Estate Coordinator
CUMBERLAND LAW JOURNAL
Writ No. 2012-5568 Civil BEING KNOWN AS:623 3rd Street
a/k/a 623 Third Street, New Cum-
PNC Bank berland,PA 17070.
VS. PROPERTY NO.:25-25-0006-115.
Daniel L. Corrigan, TITLE TO SAID PREMISES is
Leslie A. Corrigan vested in Daniel L. Corrigan and
At .: Mark Udren Leslie R.Corrigan,husband and wife
�' by Deed from Bride C. Speck,unre-
ALL THOSE certain lots or tracts married widow dated 04/12/2006
of land situate in the Borough of New recorded 04/19/2006 in Deed Book
Cumberland,County of Cumberland 274 Page 471
and State of Pennsylvania,more par-
ticularly bounded and described as
follows,to wit:
BEGINNING at a point on the
northeastern corner of Third Street
and Rosemont Avenue and extend-
ing northwardly along the line of the
said Rosemont Avenue a distance
of 140 feet to a twenty. foot wide
public alley; thence easterly along
the line of the said alley 100 feet to
the dividing line between Lots Nos.
8 and 9; thence southwardly along
the line of the said last mentioned
lots, a distance of 140 feet to the
northerly side of Third Street;thence
westwardly along the northerly line
of Third Street a distance of 100 feet
to the northeastern corner of Third
Street and Rosemont Avenue, the
point and place of BEGINNING.
BEING Lots N. 9, 10, 11 and 112
in Block "B" in the general plan of
George W. Buttorff's addition to the
Borough of New Cumberland,as re-
corded in the Office of the Recorder
of Deeds in Book "B", Volume 5,
Page 498.
HAVING THEREON ERECTED
a brick dwelling house known and
numbered as 623 Third Street.
UNDER AND SUBJECT to acts of
assembly, county and township or-
dinances,rights of public utility and
public service companies, existing
restrictions and easements,visible or
of record,to the extent that anyper-
sons or entities have acquired legal
rights thereto.
As described in Deed Book 274
Page 471.
36
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 25, February 1, and February 8, 2013
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time,place and character of publication are true.
L"Xisa Marie Coy e, Editor
SWORN TO AND SUBSCRIBED before me this
da of Februar 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
. The'Patriot-News Co.
2020 Technology Pkwy Q a rio ews
Suite 300
Mechanicsburg, PA 17050 NOW you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013 r
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Marianne Miller, being duly sworn according to law, deposes and says:-
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania,with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot-Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below: That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board_ of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
2012.5568 Civil shin in Miscellaneous Book"M", Volume 14, Page 317.
PNC Bank
Vs
Daniel L.Corrig This ad ran on the date(s)shown below:
Leslie A.Corrig n _
Atty. Mark Udr a 01/22/13
ALL THOSE CERTAIN LOTS OR¢ f 01/29/13
TRACTS OF LAND SITUATE IN THE 02/05/13
BOROUGH OF NEW CUMBERLAND, a
COUNTY OF CUMBERLAND AND
STATE OF PENNSYLVANIA, MORE 6,
PARTICULARLY BOUNDED AND w . . . . . . . . . .
DESCRIBED AS FOLLOWS,TO WIT. r
i BEGINNING AT A POINT ON THE
a
NORTHEASTERN CORNER OFTHIRD Sworn to and subscribed before me this 14 day of February, 2013 A.D.
i STREET AND ROSEMONT AVENUE I
I AND EXTENDING NORTHWARDLY i.
j ALONG THE LINE OF THE SAID ;
"s ROSEMONT AVENUE A DISTANCE
i OF 140 FEET TO A TWENTY. FOOT IIC
WIDE PUBLIC ALLEY; THENCE
EASTERLY ALONG THE LINE OF
THE SAID ALLEY 100 FEET TO
i THE DIVIDING LINE BETWEEN COMMON LTH OF PENNSYLVANIA
I LOTS NOS. 8 AND 9; THENCE Notarial Seal
SORTHWARDLY ALONG THE LINE Holly Lynn Warfel,Notary Public
OF THE SAID LAST MENTIONED ry
LOTS,A DISTANCE OF 140 FEET TO i washington Twp.,Dauphin County
THE NORTHERLY�„1�THIRD lE Commission Expires Dec.12,2016
STREET; THENCE WESTWARDLY { MEMBER PENNSYLVANIA ASSOCIATION OF NOTARIES
ALONG THE NORTHERLY LINE OF
THIRD STREET A DISTANCE OF
100 FEET TO THE NORTHEASTERN
CORNER OF THIRD STREET AND
Pr1CRMr1MT AVPMT TP TUP Pr)rMT
z
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD; SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
pleadings(i7udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
Daniel L. Corrigan
Leslie A.Corrigan a/k/a Leslie R. Corrigan MORTGAGE FORECLOSURE
Defendant(s)
NO. 12-5568-CIVIL
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RULE 76
PNC Bank,National Association ,Plaintiff in the above action,by its undersigned attorney,upon information
and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed,
the following information concerning the real property located at:
623 3rd Street a/k/a 623 Third Street,New Cumberland,PA 17070
1.Name and address of Owner(s) or reputed Owner(s):
Daniel L.Corrigan x
623 3rd Street a/k/a 623 Third Street
New Cumberland, PA 17070
Leslie A. Corrigan a/k/a Leslie R. Corrigan
623 3rd Street a/k/a 623 Third Street
New Cumberland, PA 17070
2. Name and address of Defendant(s) in the judgment:
Daniel L. Corrigan
623 3rd Street a/k/a 623 Third Street
New Cumberland, PA 17070
Leslie A. Corrigan a/k/a Leslie R. Corrigan
623 3rd Street a/k/a 623 Third Street
New Cumberland, PA 17070
3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Jr Lien Holders -None
4.Name and address of the last recorded holder of every mortgage of record:
PNC Bank,National Association
3232 Newmark Drive
Miamisburg, OH 45342
Sr Mortgage Holders -None -
Jr Mortgage Holders None
5. Name and address of every other person who has any record lien on the property:
Sr lien Holders -None
6. Name and address of every other person who has any record interest in the property and whose interest may
be affected by the sale:
Cumberland County Domestic Relations Section
1.3 North Hanover Street
Carlisle,-PA`47013
Commonwealth of PA,Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg, PA 17128-1230
Cumberland County Real Estate Tax Department
1 Courthouse Square
Carlisle,PA 17013
Tenants/Occupants
623 3rd Street a/k/a 623 Third Street
New Cumberland,PA 17070
7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the
property which may be affected by the sale:
Federal Tax Lien Holders -None
Condo/Homeowners Association-None
I verify that the statements made in this affidavit are true and correct to the best of my information and
belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904
relating to unsworn falsification to authorities.
DATED: UDREN LAW OFFICES, P.C.
BY: i�-�'�
Attorney for Plaintiff
Katherine E. Knowlton, Esq
- PA IQ 311713
MJU#: 12070145 CASE#: 12070145-1
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
leadinas udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
DANIEL L. CORRIGAN,LESLIE A. MORTGAGE FORECLOSURE
CORRIGAN A/K/A LESLIE R.
CORRIGAN
Defendant(s) NO. 12-5568-CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Leslie A. Corrigan a/k/a Leslie R. Corrigan
623 3rd Street a/k/a 623 Third Street
New Cumberland, PA 17070
Your house (real estate) at 623 3rd Street a/k/a 623 Third Street,New Cumberland, PA
17070 is scheduled to be sold at the Sheriffs Sale on March 6, 2013 at 10:00am at the
Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor,.Carlisle, PA
17013, to enforce the court judgment of$291,834.58, obtained by Plaintiff above (the
mortgagee) against you. If the sale is postponed, the property will be relisted for the Next
Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff s Sale,you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee.the back payment,late charges,costs and reasonable
attorney's fees. To find out how much you must pay,you may call:(856)669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the
judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
Af r
f ] `
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff s Sale is not stopped,your property will be sold to the highest bidder. You may fmd
out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd
out if this has happened,you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your House. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule
will state who will be receiving that money. The money will be paid out in accordance with this schedule unless
exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses,or ways of getting your home back,if you act
immediately after the sale.
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 LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
c
N.� n
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
leadin s udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
DANIEL L. CORRIGAN,LESLIE A. MORTGAGE FORECLOSURE
CORRIGAN A/K/A LESLIE R.
CORRIGAN
Defendant(s) NO. 12-5568-CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Daniel L. Corrigan
"623 3rd Street a/k/a 623 Third Street
New Cumberland, PA 17070
Your house (real estate) at 623 3rd Street a/k/a 623 Third Street,New Cumberland, PA
17070 is scheduled to be sold at the Sheriffs Sale on March 6, 2013 at 10:00am at the
Cumberland County Courthouse,Commissioners Hearing Room, 2nd Floor, Carlisle, PA
17013, to enforce the court judgment of$291,834.58, obtained by Plaintiff above(the
mortgagee) against you. If the sale is postponed, the property will be relisted for the Next
Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale,you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable
attorney's fees. To find out how much you must pay,you may call: (856)669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the
judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
L If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find
out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened,you may call 856-669-5400.
4. '- -- If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule
will state who will be receiving that money. The money will be paid out in accordance with this schedule unless
exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses,or ways of getting your home back,if you act
immediately after the sale,
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 LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
ALL THOSE CERTAIN LOTS OR TRACTS OF LAND SITUATE IN THE-BOROUGH
OF NEW CUMBERLAND, COUNTY .,OF CUMBERLAND AND STATE OF,
PENNSYLVANIA, MORE PARTICULARLY . BOUNDED AND DESCRIBED AS
FOLLOWS,TO WIT:
BEGINNING AT A POINT ONTHE NORTHEASTERN CORNER OF THIRD STREET
AND ROSEMONT AVENUE AND EXTENDING NORTHWARDLY ALONG THE LINE
OF THE SAID ROSEMONT AVENUE A DISTANCE OF 140 FEET TO A: TWENTY.
FOOT WIDE PUBLIC ALLEY; THENCE EASTERLY ALONG THE LINE OF THE
SAID ALLEY 100 FEET TO THE DIVIDING LINE BETWEEN LOTS NOS. 8 AND'9;
THENCE SOUTHWARDLY ALONG THE LINE OF THE SAID LAST MENTIONED
LOTS, A DISTANCE OF 140 FEET TO THE NORTHERLY SIDE OF THIRD STREET;
THENCE WESTWARDLY ALONG zTHE NORTHERLY LINE OF THIRD STREET A
DISTANCE OF 100 FEET TO THE NORTHEASTERN CORNER OF THIRD STREET
AND ROSEMONT AVENUE,THE POINT AND PLACE OF BEGINNING.
BEING LOTS N. 9, -10, 11 AND 112 IN BLOCK 'W' IN THE GENERAL PLAN OF
.,GEORGE - W. BUTTORFF'S ADDITION TO THE BOROUGH " OF NEW
CUMBERLAND, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS
IN BOOK "B", VOLUME 5,PAGE 498.
HAVING THEREON ERECTED A, BRICK DWELLING HOUSE KNOWN AND
NUMBERED AS 623 THIRD STREET.
UNDER AND SUBJECT TO ACTS OF ASSEMBLY, COUNTY AND. TOWNSHIP.
ORDINANCES, RIGHTS OF PUBLIC UTILITY AND PUBLIC SERVICE
COMPANIES, EXISTING RESTRICTIONS AND "EASEMENTS, VISIBLE OR OF
RECORD, TO THE EXTENT THAT ANY PERSONS OR ENTITIES HAVE ACQUIRED
LEGAL RIGHTS THERETO.
AS,DESCRIBED IN DEED BOOK 274 PAGE 471
BEING KNOWN AS: 623 3RD STREET A/KJA 623 THIRD STREET,
NEW CUMBERLAND, PA 17070
PROPERTY ID NO.:25-25-0006-115
TITLE TO SAID PREMISES IS VESTED IN DANIEL L. CORRIGAN AND LESLIE R.
CORRIGAN,HUSBAND AND WIFE BY DEED FROM BRIDE C. SPECIC,
'UNREMARRIED WIDOW DATED 04/12/2006 RECORDED 04/19/2006 IN DEED BOOK
274 PAGE.471.