HomeMy WebLinkAbout04-6025
LA W OFFICES OF PULEO & D'EMILlO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, P A 19422
(610) 941-3600
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.
I 7159 Corklan Drive
Jacksonville, Florida 32258
v.
NATHAN O. JACKSON, II
225 South York Street
Mechanicsburg, P A 17055
: No. 04 - 1cD2.5
ClL)'lL~~
CIVIL ACTION - MORTGAGE FORECLOSURE
COMPLAINT
NOTICE
You have been sued m court If you wIsh to detend agamst the claims
'L't t[mh In the followlIlg pages, you must take actIOn within twenty
(20) days atler this com pIa lilt and notice are served, by entenng a
\V'rillen appearance personally or by attorney and tiling in wnting with
the court vour defenses or objectIOns to the c1alms set forth agamst
you Yo~ are warned that If you fad to do so the case may proceed
without you and a Judgment may be entered against you by the court
IV' Ithout lurther notice for any money claimed m the complaint or for
any other c1alln or relief requested by the plaintltf You may lose
mDney or property or other nghts Important to you
YOU SHOULD lAKE THIS PAPER TO YOUR LAWYER AT
(lNCf': IF YOU DO NOT HA VE A LAWYER, GO TO OR
fELEPllONE THE OFFICE SET FORTH BELOW THIS OFFICE
CAN PRUVIDE YOU WITH INFORMATION ABOUT HIRING A
I A WYl,R
IF YOU CANNOT AFFORD TO HIRE A LA WYER, THIS OFFICE
MA Y BE ABLE TO PROVIDE YOU WITH INFORMATION
A130UT AGENCIES THAT MA Y OFFER LEGAL SERVICES TO
l.L1GIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle. PA 17013
(717) 249-3166
(800) 990-9108
II
A VISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea
defenderse de las demandas que se presentan mas adelante en las
slguientes pagmas, debe tomar accion dentro de los proxlmos vemte
(20) dias despues de la notificaclon de esta Demanda y A VISO
radicando personal mente 0 por medlo de un abogado una
comparecencia escrita y radlcando en la Corte por escrito sus defensas
de, y si usted faHa de tomar acci6n como se descnbe antenormente, el
caso puede proceder sin usted y un faHo por cualquier suma de dmero
reclamada en la demanda 0 cualquier otra reclamaci6n 0 remedlO
solicltado por el demand ante puede ser dictado en contra suya por la
Corte sm mas aviso adicional Usted puede perder dmero 0 propiedad
u otros derechos Importantes para usted.
USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO
INMEDIA T AMENTE. Sl USTED NO TIENE UN ABOGADO,
LLAME 0 V A Y A A LA SIGUIENTE OFICINA EST A OFICINA
PUEDE PROVEERLE INFORMACION A CERCA DE COMO
CONSEGUIR UN ABOGADO
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN
ABOGADO, ES POSIBLE QUE EST A OFIClNA LE PUEDA
PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN
SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A
PERSONAS QUE CUALIFICAN.
Curnberland County Bar Association
2 Liberty Avenue
Carlisle, PAl 70 13
(717) 249-3 166
(800) 990-9108
CIVIL ACTION - MORTGAGE FORECLOSURE
COMPLAINT
1. Plaintiff, ABN AMRO MORTGAGE GROUP, INC., is a corporation organized and existing
under laws of the State of Delaware with offices at 7159 Corklan Drive, Jacksonville, Florida.
2. Defendant, NATHAN 0, JACKSON, II, is the mortgagor and real owner of premises 225
South York Street, Borough of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter described,
whose last known address is as stated above.
3. On the 27th day of June, 2002, the above named mortgagor made, executed and delivered a
mortgage upon premises hereinafter described to ABN AMRO MORTGAGE GROUP, INC., the
plaintiff herein, which mortgage is recorded in the Office of the Recorder of Deeds for Cumberland
County in Record Book 1764 page 1138.
4. The premises subject to the said mortgage is described in Exhibit "A" attached hereto and
made a part hereof.
5. The mortgage secures defendant's certain Note dated the same as the mortgage in the amount
, of $94,250.00 payable in monthly installments with interest at the rate of 7% per annum. A copy of the
said Note is attached hereto, made a part hereof and marked Exhibit "B".
6. The said mortgage has not been assigned.
7. The mortgage is in default because the defendant has failed to make the payment of the monthly
installment of principal and interest in accordance with the terms of the mortgage for July 1, 2004, and
each month thereafter, up to and including the present time.
8, The following amounts are due on the mortgage:
-1-
II
II
II
i
I
Principal
Interest at 7% per annum from 6/1/04 thru
11/30/04 ($17,55 per diem)
Late charges accrued thru 11/30/04 ($32.01/month)
Escrow deficit (taxes and insurance) ($173.31/month)
Attorney's fee (5%)
Title information certificate
$ 91,510.37
3,211.65
160.05
866.55
4,575,52
325.00
Total
$100,649.14
9. The said mortgage is not a residential mortgage as defined by Pennsylvania Act NO.6 of 1974,
and hence, no notice of intention to foreclose is required by the said Act.
10. The aforesaid mortgage is insured under Title II of the National Housing Act, and therefore,
is not subject to the provisions of Pennsylvania Act No. 91 of 1983.
WHEREFORE, plaintiff demands judgment in the sum of $1 00,649.14 plus interest, late charges,
escrow advances and costs to the date of judgment and foreclosure of the said mortgage.
~fL
,,-THOMAS ~/PULEO
Attorney for Plaintiff
-2-
DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of
Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows,
to wit:
BEGINNING at a point marked by a nail in the Eastern side of South York Street, at the Northwest
comer of Lot now or formerly of A. B, Brubaker and known as 227 South York Street; thence
extending along the Eastern side of said South York Street, North 12 degrees 37 minutes 30 seconds
West, a distance of 31 feet to a point at Southwest corner of Premises No. 223 South York Street, now
or late of William S. Port and wife; thence extending along the line of said premises now or late of
William S. Port and wife, North 77 degrees 35 minutes 09 seconds East, a distance of 163.61 feet to
an iron pin in the Western line of a 20-foot wide public alley; thence extending along the Western line
of said public alley, South 13 degrees 15 minutes East, a distance of 10 feet to a point marked by an
iron pin at the Northeast comer of property now or late of A. N. Brubaker and known as 222 West
Keller Street; thence extending along the line of said land now or late of A. N. Brubaker and known
as 222 West Keller Street and also premises numbered 224 West Keller Street, the same being also the
Southern life of a 10-foot wide alley-way, South 77 degrees 25 minutes 00 seconds West, a distance
of 56.25 feet to a fence post at the Northwest comer of Premises No. 224 West Keller Street; thence
along the line of last mentioned property, South 07 degrees 23 minutes 10 seconds East, a distance of
22.50 feet to an iron pin in the Northeast comer of lot now or formerly of A. B, Brubaker and known
as 227 South York Street, aforementioned; thence along the line of said lot now or formerly of A. B.
Brubaker and known as 227 South York Street, South 78 degrees 26 minutes 40 seconds West, a
distance of 105.43 feet to a point marked by a nail in the Eastern side of South York Street,
aforementioned, at the point and place of beginning.
HA VING thereon erected a two and one-half story frame dwelling house known and numbered 225
South York Street, Mechanicsburg, Pennsylvania.
Tax Parcel #20-23-0567-142
l;~:
EXHIBIT A
.
i
NOTE
LOAN i: L4371
FHAC... No. C~
/4416939612-703 ,-,--. I
Multistate
.JUNE 27, 2002
[Date]
CAMP HILL,
[City]
225 S YORK ST, MBCHANICSBURG, PA 17055
[Property Address]
PENNSYLVANIA
[State]
1. PARTIES
"Bonower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means
ABN .AMRO MORTGAGE GROUP, INC., A DELAWARE CORPORATION
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of ............... * * *NINETY FOUR
THOUSAND TWO RUNDRED PIFTY AND NO/100************************************
Dollars (U.S. $94,250.00), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from
the date of disbursement of the loan proceeds by Lender, at the rate of SEVEY percent
( 7 . 000 % ) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Bonower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as
this Note and calIed the "Security Instrument." The Security Instrument protects the Lender from losses which might result if
Bonower defaults under this Note.
4. MANNEROFPAYMENT
(A) Time
Bonower shall make a payment of principal and interest to Lender on the 1ST day of each month beginning on
AUGUST 1, 2002. Any principal and interest remaining on the 1ST day of
JULY, 2032 will be due on that date, which is called the "Maturity Date."
(8) Place
Payment shall be made at
4242 N. HARLEM AVE.
HORRIDGE, IL 60706
ATTH: CASHIERING
or at such place as Lender may designate in writing by notice to Bonower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. $627.05. This amount will be
part ofa larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in
the order described in the Security Instrument.
(D) Allonge to this Note for payment adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge
shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note.
[Check applicable box) D Graduated Payment Allonge D Growing Equity Allonge
CJ Other (specify)
5. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day
of any month. Lender shall accept prepayment on other days provided that bonower pays interest on the amount prepaid for the
remainder of the month to the extent required by Lender and pennitted by regulations of the SecretaI)'. IfBonower makes a partial
prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to
those changes.
6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of Ibis
Note, by the end of 15 calendar days after the payment is due, Lender may collect a late charge in the amount of
FOUR percent ( 4.000% ) of the overdue amount of each payment.
(8) Default
IfBonower defaults by failing to pay in full any monthly payment. then Lender may, except as limited by regulations of the
Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued
interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent defanlt. In many
circumstances regulations issued by the Secretarv will limit Lender's rights to require immediate payment in full in the case of payment
.
FHA Multhtale Fin" Rot. Nato - 10195
EXHIBIT B
.
~OT 000 J
LOAN I: 624344371
defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note. "Secrelal'y" means
the Secretary of Housing and Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses
including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees
and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor.
"Presentment" means the right to require Lender to demand payment of amounts due. . 'Notice of dishonor" means the right to
require Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTlCES
Unless applicable law requires a different method, any notice that must be given 10 Borrower under this Note will be given by
delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has
given Lender a notice of Borrower 's different address.
Any notice that must be given to Lenderunder this Note will be given by first class mail to Lender at the address stated in Paragraph
4(B) or at a different address if Borrower is given a notice of that different address.
!
=
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this
Note, including the promise to pay the full amauntowed. Any person whois a guarantor, surety or endorser of this Note isaIsoobligated
to do these things. Any person who takes over these obligalions, including the obligations of a guarantor, surety or endorser of this
Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person
individually or against all signatones together. Anyone person signing this Note may be required to pay all of the amounts owed
under this Note.
I
BY SIGNING BELOW, Borrower accepts and agrees to the tenus and covenants contained in this Note.
I
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NATHAN . JACKSON II
0,
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(SBAL)
I
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FHA Mllltbtate Fixed Rate Note - 10/95
Page 2 of2
P8700NOT
VERIFICATION
Jimmie Edwards hereby states that he is Vice President of ABN AMRO Mortgage Group, Inc.,
the plaintiff, or servicing agent for plaintiff, in this matter; that he is authorized to take this Verification;
and that the statements made in the foregoing Complaint are true and correct to the best of his
knowledge, infonnation and belief. The undersigned understands that the statements made therein are
subject to the penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities.
DATE: / /~ ;} 1- dtkjLj
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Thomas 1. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, P A 19422
(610) 941-3600
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LA W
ABN AMRO MORTGAGE GROUP, INC.
v.
: No. 04-6025
NATHAN O. JACKSON, II
PETITION TO JOIN DEFENDANT
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
Plaintiff, ABN AMRO Mortgage Group, Inc., by its attorney, Thomas 1. Puleo, Esquire, petitions
this Court under Pa.R.C.P. 2232 to join Cheri A. Jackson as a defendant in this action, and in support
thereof avers the following:
1. On the June 27, 2002, the defendant, Nathan O. Jackson, made, executed and delivered a
mortgage upon premises 225 South York Street, Borough of Mechanicsburg, Cumberland County,
Pennsylvania, to plaintiff, ABN AMRO Mortgage Group, Inc., which mortgage is recorded in the Office
of the Recorder of Deeds for Cumberland County in Record Book 1764 page 1138. A copy of the said
mortgage is attached hereto as Exhibit "A".
2. The name of defendant, Nathan O. Jackson, appears on the face of the mortgage but is also
executed by Cheri A. Jackson, indicating that she is also a mortgagor.
3. Title to the said premises is also in the names of both the defendant, Nathan O. Jackson, II, and
Cheri A. Jackson, his wife, as tenants by the entirety, by deed dated the same as the mortgage and
-1-
recorded in the Office of the Recorder of Deeds for Cumberland County in Record Book 252 page 2723.
A copy ofthe said deed is attached hereto as Exhibit "B".
4. On December 1,2004, plaintiff filed a Complaint in Mortgage Foreclosure under the above
term and number naming as the only defendant, Nathan O. Jackson, II, as mortgagor since only his name
was appearing on the face of the mortgage instrument (and as the only name indicated in plaintiff's title
information certificate obtained in connection with this action).
5. Subsequent thereto, and after service of the Complaint was effected upon defendant, upon
further review of records of the Recorder of Deeds of Cumberland County, plaintiff discovered that title to
the premises was in the name of both defendant and his spouse, Cheri A. Jackson. This information
prompted a further review of the mortgage instrument indicating the signature of Cheri A. Jackson
thereon.
6. Since the said Cheri A. Jackson is also a mortgagor and real owner of the subject premises, it is
necessary that she be made a party to this action because of her interest in the real property.
7. Rule 1144( a) of the Pennsylvania Rules of Civil Procedure provides that in an action in
mortgage foreclosure, the plaintiff shall name as defendants both the mortgagors and real owners if the
mortgaged property.
8. Since Cheri A. Jackson is also a real owner and mortgagor of the property she must necessarily
be joined as a party in the instant mortgage foreclosure action.
9. Rule 2227 of the Pennsylvania Rules of Civil Procedure provides that persons having a joint
interest in the subject matter of an action must be joined on the same side as plaintiffs or defendants.
10. Since both the named defendant, Nathan O. Jackson, II, and his spouse, Cheri A. Jackson,
are the mortgagors and real owners of the said property and have a joint interest therein, plaintiff desires
-2-
I to amend its Complaint so as join the said Cheri A. Jackson as a party defendant in this action naming her
as such.
11. Rule 2232( c) of the Pennsylvania Rules of Civil Procedure provides that at any stage of an
action, the court may order the joinder of any additional person who could have been joined in the action
and may stay all proceedings until such person has been joined.
WHEREFORE, plaintiff prays this Court to grant its petition joining Cheri A. Jackson as a party
defendant herein, and allow plaintiff to amend its Complaint to reflect her interest in the subject property.
Respectfully submitted,
THOMAS I. PULEO
Attorney for Plaintiff
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:;: D:EDS
I~., ~ '.: I ~' C0U~HY - PA
· 02 JUL 5 AI'IlO 10
When recorded mail ~Ol
ABM AMRO MORTGAGE GROUP, IRC.
P.O. BOX 5064
TROl. MICBlGAB 48084
ATTJlI FIJlAL/TRAILIJlG 1>OCUMEIITS
Parcel Number:
~Ai~'1 624344371~
Commonwealtb of pennsyrv;;nia
[Span: Above Tbb Line For Recordlna Dalal
II'HA Case No.
MORTGAGE 4416939612-703
THIS MORTGAGE ("Security Instrument") is given on JUD2 27, 2002.
The Mortgagor is
NATHAN 0 JACKSON I I, A MARRIED MAN,
~-;:y
(' 'Borrower' '),
This Security Instrument is given to AS. AMRO MORTGAGE GROUP, IlIC., A DELAWARE
CORPORA~IOIl
which is organized and
existing under the laws of THE 5TA~E OF DELAKARE
and whose address is 2600 If. BIG BEAVER RD., TROY, MICBIGAH 48084
("Lender").
Borrower owes Lenderthe principal sum of **HUIETY POUR THOUSABD 'l'WO HUNDReD PIFTY AIiID
BO/l00*************************************************-***-******-*.*..-
Dollars
(U.S. $94,250.00 ). This debt is evidenced by Borrower's note dated the same date as this Security
Instrument ("Note"), which provides for monthly payments, with the full debt, ifnot paid earlier. due and payable
on JULY 1, 2032. This Security Instrument secures to Lender; (a) the repayment of the
debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the
payment of all other sums, with interest, advanced under paragraph 7 to protect the security olJ!1is .~ri~
Ini~ialsl ?~tf:t
FHA Penm)1Y11nJa Mortplt, 4/96 Page 1 of 9 PAVFHADE PAU'HADE 0101
BK 17 Oli;':; I
EXHIBIT A
LOAN " 624344371
Instrument; and (c) the perfonnance of Borrower' s covenants and agreements under this Security Instnnnent and
the Note. For this purpose, Borrower does hereby mortgage, grant and convey to the Lender the following described
property located in CUMBERLUD County, Pennsylvania:
SD LEGAL DESCRIPTIO. M'TACHED HERETO JUII) MADB A PAR!r HBRBOF.
which has the address of
225 S YORK 5T, MECHAHICSBURG
(Stree\. Cityl ,
Pennsylvania
11055
("Property Address");
(Zip Codel
TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements,
appurtenances and fixtures now or hereafter a part of the property. All replacements and additions shall also be
covered by this Security Instrwnent. All oftheforegoing is referred to in this Security Instrument as the " Property. "
BORROWER COVENANTS that Borrower is lawfully seized ofthe estate hereby conveyed and has the right
to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of
record. Borrowerwarrants and will defend generally the title to the Property against all claims and demands, subject
to any encumbrances of record.
THIS SECURITY INSTRUMENT combines unifonn covenants for national use and non-uniform covenants
with limited variations by jurisdiction to constitute a uniform security instrument covering real property.
Borrower and Lender covenant and agree as follows:
UNlFORM COVENANTS.
1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and
interest on, the debt evidenced by the Note and late charges due under the Note.
2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly
payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes
and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the
Property, and (c) premiums for insurance required under paragraph 4. In any year in which the Lender must pay
a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year
in which such premium would have been required if Lender still held the Security Instrument, each monthly
payment shall also include either: (i) a sum for the annual mortgage insurance premium to be pai~JaPde~
Initials I ?'~
FDA PeDIIOJ'!vanla Mort.".e - 4/!l6 Page 2 of 9 P ALFHAD
BK I 7 6 i-!- FG I t 3 9
LOAB " 624344371
the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium ifthis Security Instrument is held
by the Secretary, in a IeaSOnable amount to be determined by the Secretary. Eltcepl for the monthly charge by the
Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds."
Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the
maximum amount that may berequiredfor Borrower's escrow account under the Real EstateSett1ement Procedures
Act of 1974, 12 U.S,C. Section 2601 et seq. and implementing regulations, 24 CFR Part 3500, as they may be
amended from time to time ("RESP A"), except that the cushion or reserve permitted by RESP A for unanticipated
disbursements or disbursements before the Borrower's payments are available in the account may not be based on
amounts due for the mortgage insurance premium.
If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESP A, Lender
shall account to Borrower for the e.x<:e$S funds as required by RESPA. If the amounts of funds held by Lender at
any time is not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower
to make up the shortage as permitted by RESP A.
The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If
Borrower tenders to Lender the full payment of all such sums, Borrower's accountshall be credited with the balance
remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender
has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower.
Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be
credited with any balance remaining for all installments for items (a), (b), and (c).
3. Application of Payments. All payments under paragraphs I and 2 shall be applied by Lender as follows:
EiM, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by
the Secretary instead of the monthly mortgage insurance premium;
SmmlI. to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard
insurance premiums, as required;
:rIlillI, to interest due under the Note;
EolI!lh, to amortization of the principal of the Note; and
Eillh, to late charges due under the Note.
4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property,
whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including
fire, for which Lender requires insurance, 'This insurance shall be maintained in the amounts and for the periods
that Lender requires. Borrower shall also insure all improvements on the Property, whether now in e.xistence or
subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried
with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall
include loss payable clauses in favor of, and in a fonn acceptable to, Lender.
In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if
nol made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make
payment for such loss directly to Lender, insteadofloBorrower and to Lenderjointly. All or any partofthe insurance
proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and
this Security I nstrument, first to any delinquent amounts applied in the order in paragraph 3, and then to prepayment
of principal, or (b) to the restoration or repair of the damaged Property. Any application of the proceeds to the
principal shall not extend or postpone the due date of the monthly payments which are referred to in paragraph 2,
or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all
outstanding indebtedness under the Note and this Security Instrument shaJl be paid to the entity legally entitled
thereto.
In the event offoreclosure of this Security Instnunent or other transfer of title to the Property that extinguishes
the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the
purchaser. r::J
Initials$ ~ .
FHA P'1IDI)1..nJa MortPie - 41" Page J of 9 PALFHAD
8K \76l;f': 1\ 40
LOAR I. 624344371
S. Occupancy, Presen-atlon, Maintenanu and Protection of the Property; Borrower's LoaD
ApplltadoD; Leasehold.. Borrower shall occupy, establish, and use the Property as Borrower's principal
residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale or
transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least
one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for
Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notifY
Lender of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or subsl8ntially
change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect
the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action
to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during
the loan application process, gave materially false or inaccurate information or statements to Lender (or failed
to provide Lender with any material information) in connection with the loan evidenced by the Note, including,
but Dot limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If
this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower
acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger
in writing.
6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection
with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation,
are hereby assigned and shall be paid to Lender to the exlent of Ihe full amount of the indebtedness that remains
unpaid under the Note and this Security Instrument. Lender shall apply such proceeds 10 the reduction of the
indebtedness under the Nole and this Security Instrument, first to any delinquent amounts applied in lhe order
provided in paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall
not extend or postpone the due date nfthe IMnthly payments, which are referred to in paragraph 2, or change the
amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under
the Note and this Security Instrument shall be paid to the entity legally entitled thereto.
7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all
governmental ormunicipal charges, fines and impositions that are not included in paragraph 2. Borrower shall pay
these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect
Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts
evidencing these payments.
lfBorrower fails to make these payments or the payments required by paragraph 2, or fails to perfonn any other
covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may
significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to
enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property
and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in
paragraph 2.
Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower and be
secured by this Security Instrument. These amounts shall bear interest from the date of disbursement, atlhe Note
rate, and at the option of Lender, shall be immediately due and payable.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower:
(a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b)
contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the
Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an
agreement satisfactory to Lender subordinating the lien to this Security Instrument If Lender detennines that any
part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give
Borrower a notice identifying the lien. Borrower shall satisfY the lien or take one or more of the actions set forth
above within 10 days of the giving of no lice. /) -r
Initials. ~~
FIlA PtmdJo1>'llIIIa M"nCAa.. 4196 Page 4 of j) "PALFHADE
BK I 7 b i~~;; I I 4 I
LOAB .. 624344371
8, Fees. Lender may collect fees and charges authorized by the SecretaIy.
9. Grounds for Acceleration of Debt.
(a) Default. Lender may, except asfunited by regulations issued by the Secretary, in the case ofpayment
defaults, require immediate payment in full of all sums secured by this Security Instrument if;
(i) Borrower defaults by failing to pay in full any monthly payment required by this Security
Instrument prior to or on the due date of the next monthly payment, or
(Ii) Bonower defaults by failing. for a period of thirty days, to perfonn any other obligations
contained in this Security Instrument.
(b) Sale Witbout Credit Approval. Lender shall, if permitted by applicable law (including Section
341 (d) of the Gam-Sl Germain DepositoI)' Institutions Act ofl982, 12 U .S.C. 170Ij-3( d)) and with the
prior approval of the Secretary. require immediate payment in full of all sums secured by this Security
Instrument if:
(i) Allor part oftbe Property, or a beneficial interest in a trust owning all or part of the Property.
is sold or otherwise transferred (other than by devise or descent), and
(ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the
purchaser or grantee does so occupy the Property but his or her credit has not been approved in
accordance with the requirements of the Secretary.
(c) No Waiver. If circumstances occur that would permit Lender to require immediate payment in full,
but Lender does not require such payments, Lender does not waive its rights with respect to subsequent
events.
(d) RegulationsofBUD Secretary. In many circumstances regulations issued by the Secretary will limit
Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not
paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by
regulations of the Secretary.
(e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not
detennined to be eligible for insurance under the National Housing Act within 60 daysfrom the datehercof,
Lender may, at its option, require immediate payment in full of all sums secured by this Security
Instrument. A written statement of any authorized agent of the SecretaI)' dated subsequent to 60 days from
the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof
of such ineligibility. Notwithstanding the foregoing. this option may not be exercised by Lender when the
unavailability ofinsurance is solely due to Lender's failure to remit a mortgage insurance premium to the
Secretary.
10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full
because of Borrower's failure \0 pay an amount due under the Note or this Security InslrUment. This right applies
even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a
lump swn all amounts required \0 bring Borrower's account current including. \0 the extent they are obligations
of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and
expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security
Instrument and the obligations that it secures shall remain in effect as ifLender had not required immediate payment
in full.
However, Lender is not required to permit reinstatement if: (i) Lender has accepted reinstatement after the
commencement offoreclosure proceedings within two years immediately preceding the commencement ofa current
foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii)
reinstatement will adversely affect the priority of the lien created by this Security Instrument.
11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension ofthe time of payment or
modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor
in interest of Borrower shall not operate to release the liability of the original Borrower or Borrow~ ~ h_'
Initials. 7t:?'-o c;.it.;t
.'HA P.nnsylvlllllD Mort.a." . 4/96 Page 5 of 9 PALFHADE t!
BK I 7 6 L~ f'~ I'Ll 2
LOAN II 624344371
in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to
extend time for payment or otherwise modifY amortization of the sums secured by this Security Instrumentby reason
of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in
exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy.
12. Suecessors and Assigns Bouad; Joint and Several LiabUlty; Co-Signers. The covenants and
agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower,
subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any
Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security
Instrument only to mortgage, grant and convey tbat Borrower's interest in the Property under the tenDS of this
Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (e)
agrees that Lender and any other Borrower may agree to extend, modify,forbearor make any accommodations with
regard to the tenns of this Security Instrument or the Note without that Borrower's consent.
U. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it
or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed
to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall
be given by first class mail to Lender's address stated herein or any address Lender designates by notice to Borrower.
Any notice provided for in this Security Instrument shall bedeemed to have been given to Borroweror Lenderwhen
given as provided in this paragraph.
14. Governing Law; Severability. This Security Instrument shall be governed by Federal law and the law
of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security
Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security
Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of
this Security Instrument and the Note are declared to be severable.
15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security
Instrument.
16. Ilazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release
of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything
affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply
to the presence, use, or storage on tbe Property of small quantities of Hazardous Substances that are generally
recognized to be appropriate to normal residential uses and to maintenance of the Property.
Borrower shall promptly giveLender written notice of any investigation, claim, demand, lawsuit or other action
by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance
or Environmental Law of wbich Borrower has actual knowledge. If Borrower learns, or is notilled by any
governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances affecting
the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with
Environmental Law.
As used in this paragrapb 16, "Hazardous Substances" are those substances defined as toxic or hazardous
substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic
petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldebyde,
and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws and laws of
the jurisdiction where the Property is located that relate to health, safety or environmental protection.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agrce as follows:
17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues
of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs
each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to
Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, BOrrOW?~II~:1
Initials I ~ (~
FHA Pennsylvula MOrlgBgt - 4196 Page 6 of' PALFHADE
BK I 7 6 It ;;;; I I 4 3
Ii '
LOAD I. 624344371
and rcx:eive all rents and revenues of the Property as trustee forthe benefit ofLender and Borrower. This assignment
of rents constitutes an absolute assignment and not an assignment for additional security only.
IfLc.oder gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as
trustee for benefit ofLendcr only, to be applied to the sums secured by the Security Instrument; (b) Lender shall
be entitled to collect and receive all of the rents of the Property; and (c) each tenant ofthc Property shall pay all
rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant.
Borrower basool executedanypriorassignment of the rents andhas not and will not perfonn any act that would
prevent Lender from exercising its rights under this paragraph 17.
Lender shall not be required to enter upon, take control of or maintain the Property beforeor after giving notice
ofbreach to Borrower. However, Lellder or a judlclally appointed receiver may do so at any time there is a breach.
Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender.
This assignment of rents ofthc Property shall tenninate when the debt secured by the Security Instrument is paid
in full.
18. Foreclosure Procedure. If Lender requires Immediate payment In full under paragraph 9, Lender
may foreclose this Security IJutrument by judicial proceeding. Lender shall be entitled to collect all e1ptnSCll
incurred in pursuing the remedies provided in tbis paragraph 18, including, but not limited to, attorneys'
fees and costs of title evidence.
If the Lender's interest in this Security Instnunent is held by the Secretary and the Secretary requires
immediate paymmt in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale
provided in the Slagle Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.s.C, 3751 et seq. ) by
requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the
Property as provided in the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights
otherwise available to a Lender under this Paragraph 18 or applicable law.
19. Release. Upon payment of all sums secured by this Security Instrumenl, this Security Instrument and the
estate conveyed shall tenninate and become void. After such occurrence, Lender shall discharge and satisty this
Security Instrument without charge to Borrower. Borrower shall pay any recordation costs.
20. Waivers. Borrower, to the extent pennitted by applicable law, waives and releases any error or defects
in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws
providing for Slay of execution, extension of time, exemption from attachment, levy and sale, and homestead
exemption.
21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one hour
prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument.
22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower
to acquire title to the Property, this Security Instrument shall be a purchase money mortgage.
23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered
on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note.
24. Riden to this Security Instroment.lfoneor more riders are executed by Borrower and recorded together
with this Security Instrument, the covenants of each such rider shall be incorporated into and shall amend and
supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part oflhis Security
Instrument.
[Check applicable box(es}]
CJ Condominium Rider
CJ Graduated Payment Rider
CJ Growing Equity Rider
CJ Other(s) [specify]
c:::J PlaIUled Unit Development Rider
FHA Pelllllyl.anI. Morta:'" . 4196
Page 7 of9
Initials, ~ f"iM
~ PALFHADIl f
BK I 7 6 4 Ph I 4 4
( .
LOAR '1 62'3'4371
BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security Instnunent and
in any rider(s) executed by Borrower and recorded with it
~~~~ jL ~~/~-K
( I' /,/{/ HMIWt" JACKSOJI II ~
~/-
(Seal)
~~~6----
rr- . Cff
CertifICate of Residence
I,
do hereby cenify that the correct address of the within-named Lender is 2600 W. BIG BEAVER RD.,
TROY, MICHIGAB 48084
Witness my hand this
day of
Agent of Lender
FHA PennsyIv..... Morlgall" - 4/96
Page 8 of'
PALFHADE
BK I 7 6 4 Pf~ I I 4 5
LOAM .. 624344371
COMMONWEALTH OF PENNSYL V A,NIA, C v('IIber lull d County 55:
On this 2, day of J\.\t1--t 2G'O~ before me, the undersigned officer, personally
appeared RA'tHAII 0 JACKSOH II ~ (" Nln fl ~cl:;~,^
known to me (or satisfactorily proven) to be person
the within instrument and acknowledged that
herein contained.
whose name subscribed to
executed the same for the purposes
NoIarial Seal
MicI1Ilel J. ~. Nolary Pab1c
H/rnpden Twp., CUl11oe/fand Quly
My Cornrnssion EJ.,pres Mat. Zl. 2006
".... ~AIIOdIllan CXltllaltes
?4'~ /'--'
Ylo-lo"'( p/h~<..
TiU.ofOJlicer
./>?'
~........ .~ . ,
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"Jli~1 :' -.'t\~' ~ i t' ~
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~ >;. ";,;/ ~""""'''.~''"'OIH'''{~ ,I':'-It t .~
. ._' ~r ...> ...... L. ..."'"""...'"" ~ _
~ .. "~","" -,_ -....".J ..;
.~,.,~~,~::f;''' ...,
,,'r
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My Commission Expires:
FHA Pennsylvania MOrll"lle - 4196
Page 9 of9
tnitialsl ~ ~
PALFHADf
Recorder of Deeds
BK I 7 6 4 pr, I I 4 6
. .
,
. ATTACHED TO AND FORMING PART OF COMMITMENT NO. 688627
EXHmIT "A"
ALL THAT CERTAIN piece or parcel of land situate in the Borough of
Mechanicsburg, County of Cumberland and Commonwealth of Pennsylvania,
more particularly bounded and described as follows, to wit:
BEGINNING at a point marked by a nail in the eastern side of South York
Street, at the northwest corner of Lot now or formerly of A. B. Brubaker and
known as 227 South York Street; thence extending along the eastern side of said
South York Street, North 12 degrees 37 minutes 30 seconds West, a distance of31
feet to a point at southwest comer of premises No. 223 South York Street, now or
late of William S. Port and wife; thence extending along the line of said premises
now or late of William S. Port and wife, North 77 degrees 35 minutes 09 seconds
East, a distance of 163.61 feet to an iron pin in the western line of a 20-foot wide
public alley; thence extending along the western line of said public alley, South 13
degrees 15 minutes East, a distance of 10 feet to a point marked by an iron pin at
the northeast comer of property now or late of A. N. Brubaker and known as 222
West Keller Street; thence extending along the line of said land now or late of A.
N. Brubaker and known as 222 West Keller Street, and also premises numbered
224 West Keller Street, the same being also the southern line of a IO-foot wide
alley-way, South 77 degrees 25 minutes 00 seconds West, a distance of 56.25 feet
to a fence post at the northwest corner of premises No. 224 West Keller Street;
thence along the line of last mentioned property, South 07 degrees 23 minutes lO
seconds East, a distance of 22.50 feet to an iron pin in the northeast comer of lot
now or formerly of A. B. Brubaker and known as 227 South York Street,
aforementioned; thence along the line of said lot now or formerly of A. B.
Brubaker and known as 227 South York Street, South 78 degrees 26 minutes 40
seconds West, a distance of 105.43 feet to a points marked by a nail in the eastern
side of South York Street, aforementioned, at the point and place of
BEGINNING.
HA VING THEREON ERECTED a two and one-half story frame
dwelling house known and numbered 225 South York Street, Mechanicsburg,
Pennsylvania.
UNDER AND SUBJECT, HOWEVER, to the right to the free use of the
10 feet wide alleway adjoining lands now or fonnerly of Raymon and W. B.
Eberly on the South for ingress, egress and regress from the said 20 feet wide alley
into their said properties for the benefit of said Rayman and W. B. Eberly, their
heirs and assigns.
1t/30/2004 09:30 FAX 215 496 0904
ARACOR SEARCH&ABSTRACT
.-
MCini i-. Z!E:OL.KR
, ill:OOrl:":.r. i:; tJEEO&
Fill No. S'I'ULLEIl ~ I! !"~.EltL' ~:) OOUNTY. PA
'(Jbi~ ~e2b,....1hI ar _of ~.'t)tQ. '02JUL 5 M 10 O~
Between
DANA M. l!l'l'VLl.D.. SINGIB WOMAN BY BEll ATfOllNBY IN 'ACT JUCItUJ)
SCaTI' Btl'R1UIOL1Wl A.NP. S1JD1AU n, INC. BY 11IIDl ATl'OUlBY IN FACT
IUCBARD SCOTI' BURlmotDlR,
~ ceIJcd.. ~>t of !be CIIlC put, cd
NA'l"IIAN Q. SACKSON. m aQIICBEIJ It. 'ACB:8ON, IJtlSJWm AND '\\'l'B,
0-=1lIdla caIW /:bI Ora/Ilet). ot'the adIer pm.
Witnesseth 111M 11>>.11III 011IIOI Cor am CIClIIItdeaIIaD elf _ .. gf NINITY mE
tIIOUWm AN>> 001100 J)I)u.r\JIS (US,QIIOJJO) lotIJ ..-y of IIlIt UD11i1ld SIIIeI 0{ ~
. \IIlIO ... WlllIIId IrIJJ pt;d br GIll aJll a~. It at 1I:1bte tile __ .. ~ ..., iBIc
lalIIlpt.-.of II _by toct~. b. P*d. ~ aI 1OId, ... ad CIOIIfImJclI, lIIld
by W. ~ dotlllfllll. \lIUpiII ud un. ... a4 ~ II\ICIo ilia IIAd 0,.,... TI!IIIIII&t
by d11! ~, Clldr ..., b IlU'/Mlr oIlbm1l111d lhc .mar's p:nr:lQl14\N.. IIft10iWe IIId
...Ips u.etr I1I1t1 aa:1 wlJa;J.
AU. THAT CB1l.T.AI:N pi.;Illt or paocol or 1111II citul1ed ill tlul BorolIab of MecbGlkdmts.
CowIt)' of ~hlZld Atl CcmrDonwc:altb or'lIl/lSYlv_ more partiDalul)' boUndtcl .,.d
dOMi"olld II follow.. to wit:
nGINNJNG at . point maW by , nail ~ the eutan flde of SaUlb Yoric S\ro;t, lit DOIUlWecc
c:onIllI' Of lOt DIJW m fotmlliy Dt U, Brqbabt _ boW'lI 1& m Swdl 'YllIk St:el:f; thence
cm.:adins aIODf 1hc aataIl side of ,.us SoUlb Yd 81nl1t" Nmh 12 de..- 31 ~ 30
ICCClIIda WrtI Jl SMt 10. PC bit lit ~ ClCmII' ofpnlGd_ No. m ScidI YOlk Screet, QO'N
or _ ofWlJKw S. l'urt .,a'WiS\T, thalCC ClI1i:NUIlIIIoaa dMIlM of I8id ~ DII'fI or '-
af'W1J1lezQ S. Port 1114 Wi&. Nar1Il n dIpq~' IIIIJDda 0' ICCIlIIdI But. 143.81 '= fa IIIlne
pin in ~ wea:m 11M of . :10 !bot 9rlda pablJe &1Ioy; Ibtllleo ~111=a the ~ llua or
Mid public II">', SoDtlt U rJeareel t5 ~ Eul. 10 CUlt 10 . pofzIt I\UIlbd by I ireG pin at
. ~ ~ otprcpcrry 1lO'IIf or late or A.N.lS1'lIbakrs IaloII knovm u 111 Wcet KIller su..
thellC'e ~taDdiD8 aIoas the .lne of aid lIrId now or 1IlIO of AN. BrDbabr IIld bInm II m
WI:Irt ~er s~ a!II6l1to JII1IIId- numbnS 224 W_ Xener Slftec, tU IImObIiq 1110 tb
sol.llbcm lIn/! of a 10 1o?i ~4o 1111)'-"1)'. SoIIIt1 "'upII2.S mbm1al 0 tcaad. W. 56.25
bt ID a ftGee pout at 1he 1l0l1hwOlt cot!Iet otpnmllOl No. 224 West ~cr Stn:et; thllDOO 1II0l'\8
Cbo Uae ~ Jell mentiClZlld pt'Cpcny, Sauih 7 dt:pct 23 ~ 10 lIICODdIlur. 22.50 feet to III
iNGpill in a.1IOt1hW' CD1l:l' OflotDI7W Of b:mc1y of A.B. 9l\&b&kl!t and known.. 2.218011tk
YOlk 3lrtt:t.ltorcmantiON:ldt theIlcc atOllS rhc line fJt aa1d lot nQW Of bme:r11 or All, Etrublku
Ind ~ ;s ~1 Sau1!\ Yd, Streot, 18 dips 26lnismae 40 ICCOGdI Wat. I 05.4~ tCl:ll1o a.
polllt marblllry 111I.11 in the tuIIm lidt otSouth YON ~ atbremeatIonlll. It du: point &ad
lJlau ot'BBGlNNING. .
HAVING nmQON BUC1'ml a towo mid ~,.utf Itary .. dweltiq JxmSll known aid
IIlWbered .225 Sovtb YOlk Snot. Meolun:i.Ibutg, Pelllll)'ivmla.
tJNI)BR. AND SUBJECt, HI>WIVD, to 1be ript 10 Ulc = _ allhe tea &d wide allGfWl1
llljoiailli bmdI ~ or Rl>'m0:ll _ W.D. Jht1)' 1m dlo Sou1ll tI:lr iJWtA, ... IDd
~ M Iha aI4 20 .lilt 'Nido IItey imo Ihcir Mid ~. tbr tlIe Iacad1t af..w !tqrMD
DIId W A Bbcrly, thmbcln.~_....
B!ING THB SAMe PREMJ:1S8 wtdch :Dab1l1e K. BrebIQ, nIkfa Oebbi. ~ Halbrd md Baqy
t..1Iocbrd, bar ~ by tcalll*cS N~ber 22. 1993 I:IIlI ftlCotdod DeDn. 1. l$l~ 1ft
dall OlEce of.CII. aoc01'dl:r of_:>oGdI in lDllilt ~ Couqty, '__1".1.. m Deed Book
R. Vol1l1De 36, Pap 11. patd ad AC...IIo!t4 lIdO DllDak S1DUcr, tinp WOIUII, 0RAN10ll
hCftfft. 1'1sll1ldcl PUla M. EtDllar, Ilqle WOIDIIQ.. hereby ciwn.. ~ or AIIom~ ID
JUDha.nI Sc.oU ~oldc-, '" erldlDood: by Power or A\1ilrtq1l)' ~Cld OU _ . In
Soak ,PB,e__, ,
AIII'Ii" ~c^ .u...........,....,.,
..
.
EXHIBIT B
~002/005
12/30/2004 09:30 FAX 215 496 0904
ARACOR SEARCH&ABSTRACT
III 003/005
,
ALSO DBING 1JIB SaUlS PI!MISBS wlllcIll"- N. Sillier. .. WGIIUII by ltf8moraadum
or ~t of 511.1 10 .n ill SlItSU II. mo., dad . ..
~ ." .ID 11:. 0CIc0 or ~ lbGllI'da- of n.r. m UIll a:.. C\mJ1Ja1Incl ~.
PauuyIVlDla ill Boot.- _ _ . ... . . :Nn&Jo U, .. .. slWD chelr
PnfIt at AJtiJttIwf CD JUdu'd ScoII BllltMk, . B\iMM by PoMr of ^':1iItlWf reccriaI an
.mBDOk~. . PIp
mmucr MAl
. forM 252 ruE2724
1~/30/2004 09:30 FAX 215 496 0904
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Together wlCb all btlltqa,lar CIIc blllldlqa ~.'C~ . --. ~, ~..ua,., limen". 9U1e&U,
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twc~ IfPild ~ 1lCIoasIIlc, or .lII IrQ'Wi.1I ~, IDlI lilt rmntoa. 1IIlI1IlIII1Idet1. mlI!,
illVrJ. lIIId pmIII8 <<lemdi ullll !he .., d&Id. dO, iIIRi. pI'IlpIII1. ofaIm IDd d8mQ' ~'el ."
IIIe ui4lt11*Jr, . wcU "Ia'~ . izt cquJl)'. of. ill'" '" ee IIIII!.
To have and to hold 1he llIi1dl<< 01' pIKe of grOIDII dncdW ~"'-lJ. 1114 pr8Il)lNe
I1eftlly JraIIlIlll. or 1PlIIIOaDed &ad ~ed .11I be. wiG! die ~. lIIIIto lilt .. Gtutcce. 1bclr_1n
IIII1l11lpe, to tDCS tlr fU ClDIy ~ lI!e l!lilI WoofGtIlle said a~. Ibeir bdn... MIipJ, lo,moer,
And 1lIe Aid Onm&ur. be,' hein, ~ ad ~ do~. pl'llll!ile ., qrw. lID IIId 1ridI
lhc aU1 ann... IIU Wrt ... _.., ~ .. PftIm'I. _ die IIId Of.lMll' IIId bcf bei!8. dJ IIId
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~I \DItO ell. IIJd Orweet, tlItIr b5Jn atd "!P, IpJaat dae IIi4 ~ ..., lulr hdtI, and
apinst aD ~ eYC'lY pcsJllD Ill! petIC:III ~ l~llJ clIImIq Clr to claIrD die 11'IIIO or IfI1 part ~.
tJy, ttora or lII\dIr ar IIl'J af dll!lD,lIIIIlJ ad WiD
S'P!CJAILY wA.I.ItANT ID4 ~ .DIPINO.
In Witness Whereof, dJo JIIrt1 at tilt 11m put baeWllO ~ her!lllld ~ ettI. DlIlld ~ dlly
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'ACT JUCItUtO IIQ)1T ItIII.aOtu_ [..To 10 n ~llaf"''\~ pftMI) II lit till.... __ .-
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III 005/005
Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, P A 19422
(610) 941-3600
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LA W
ABN AMRO MORTGAGE GROUP, INC.
v.
: No. 04-6025
NATHAN O. JACKSON, II
PLAINTIFF'S MEMORANDUM OF LAW
IN SUPPORT OF PETITION TO JOIN DEFENDANT
The within mortgage foreclosure action was initiated by Complaint against the defendant, Nathan
O. Jackson, II, as the only apparent mortgagor of the subject premises. However, subsequent to the
commencement of this action, and upon further review of the mortgage instrument and deed to the
premises, it was discovered that the mortgage was also executed by Cheri A. Jackson as a party to the loan
transaction and also that her name appeared on the deed to the property. Since Cheri A. Jackson is both a
real owner and mortgagor of the property, she should be named as a party to this mortgage foreclosure
action.
Rule 1144(a) of the Pennsylvania Rules of Civil Procedure provides that in an action in mortgage
foreclosure, the plaintiff shall name as defendants both mortgagors and real owners of the subject
premises. Since Cheri A. Jackson is also a real owner and mortgagor, she must necessarily be joined in
the action. Furthermore, Rule 2227 of the Pennsylvania Rules of Civil Procedure provides that persons
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having a joint interest in the subject matter of an action must be joined on the same side as plaintiffs or
defendants. Finally, 2232( c) of the Pennsylvania Rules of Civil Procedure provides that at any stage of
II an action, the Court may order the joinder of any additional person who could have been joined in the
action and may stay all proceedings until such person has been joined. Thus, plaintiff seeks to amend its
I complaint in mortgage foreclosure to join Cheri A. Jackson as a party defendant in this action. This is the
I proper manner by which to add a party to the action. See 7 Goodrich-Amram 2d, Sec. 2232(c):1.3 (1976).
Therefore, in accordance with the Pennsylvania Rules of Civil Procedure, plaintiff seek leave of
II Court to amend its complaint so as to join Cheri A. Jackson as a party in this action alleging her interest in
the real estate along with that of defendant, Nathan O. Jackson, II.
Respectfully submitted,
OMAS I. ULEO
Attorney for Plaintiff
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VERIFICATION
Thomas I. Puleo, Esquire, on behalf of plaintiff/petitioner, being duly authorized to do so,
verifies that the statements contained in the foregoing Petition to for Joinder of Defendant are true and
correct to the best of his information, knowledge and belief and understands that false statements
herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn
falsification to authorities.
Dated: December 301 2004
;it rz
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Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LA W
ABN AMRO MORTGAGE GROUP, INC.
v.
: No. 04-6025
NATHAN O. JACKSON, II
CERTIFICATE OF SERVICE
I, Thomas I. Puleo, Esquire, do hereby certify that I have forwarded true and correct copies of the
within Petition for Joinder by first class mail to all interested parties listed below:
Mr. Nathan O. Jackson, II
225 South York Street
Mechanicsburg, P A 17055
Mr. Cheri A. Jackson
225 South York Street
Mechanicsburg, P A 17055
Date: December 30, 2004
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TN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, TNC.
v.
: No. 04-6025
NATHAN O. JACKSON, II
ORDER
AND NOW, this? day o.cl~, 2005, upon consideration of the Petition ofPlaintifffor
Joinder of Defendant, it is hereby ORDERE6. that the said Petition is granted and Plaintiff may join as a
defendant to this action Cheri A. Jackson.
It is further ORDERED that Plaintiff may amend its Complaint to allege the interest and title of
the said Cheri A. Jackson in the above entitled case.
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II LAW OFFICES OF PULEO & D'EMILIO, LLC
II By: Thomas 1. Puleo, Esquire
II Identification No. 27615
II
II 660 Sentry Parkway, Suite 210
Ii Blue Bell, PA 19422
II
Ii (610) 941-3600
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Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.
7159 Corklan Drive
Jacksonville, Florida 32258
v.
NATHAN O. JACKSON, II and
CHERI A. JACKSON, his wife
225 South York Street
Mechanicsburg, PA 17055
: No. 04-6025
CIVIL ACTION - MORTGAGE FORECLOSURE
AMENDED COMPLAINT
NOTICE
You have been sued in court. If you wish to defend against the claims
set forth in the foHawing 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 YOll 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 INFORMA nON ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE
MA Y BE ABLE TO PROVIDE YOU WITH INFORMA nON
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
AVISO
USTED HA 81DO DEMANDADOIA EN CORTE. 5i usted desea
defenderse de las demandas que se presentan mas adelante en las
siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte
(20) dias despues de la notificaci6n de esta Demanda y Aviso
radicando personalmente Q por media de un abogado una
comparecencia escrita y radlcando en la Corte par escrito sus defensas
de, y si usted falla de tomar acci6n como se describe anterionnente, el
caso puede proceder sin usted y un fallo por cualquier suma de dinero
reclamada en la demanda 0 cuaJquier oua reclamacion 0 remWl{}
solicitado par el demandante puede ser dictado en contra suya par la
Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad
U otros derechos importantes para usted.
USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO
INMEDlA TAMENTE SI USTED NO TlENE UN ABOGADO,
LLAME 0 VA Y A A LA SIGUIENTE OFlCINA ESTA OFICINA
PUEDE PROVEERLE INFORMACION A CERCA DE COMO
CONSEGUlR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN
ABOGADO. ES POSlBLE QUE EST A OFlCINA LE PUEDA
PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN
SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A
PERSONAS QUE CUALlFICAN
Cumberland C{lunty Bar Association
2 Liberty A venue
Carlisle, P A 170 I3
(717) 249-3166
(800) 990-9108
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II under laws of the State of Delaware with offices at 7159 Corklan Drive, Jacksonville, Florida.
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CIVIL ACTION - MORTGAGE FORECLOSURE
AMENDED COMPLAINT
1. Plaintiff, ABN AMRO MORTGAGE GROUP, INC., is a corporation organized and existing
2. Defendant, NATHAN O. JACKSON, II, is the mortgagor and real owner of premises 225
South York Street, Borough of Mechanics burg, Cumberland County, Pennsylvania, hereinafter described,
whose last known address is as stated above.
3. Defendant, CHERI A. JACKSON, is also a mortgagor and real owner of premises 225 South
York Street, Borough of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter described, whose
last known address is as stated above.
4. On the 27th day of June, 2002, the above named mortgagor made, executed and delivered a
mortgage upon premises hereinafter described to ABN AMRO MORTGAGE GROUP, INC., the
plaintiff herein, which mortgage is recorded in the Office ofthe Recorder of Deeds for Cumberland
County in Record Book 1764 page 1138.
5. The premises subject to the said mortgage is described in Exhibit "A" attached hereto and
made a part hereof.
6. The mortgage secures defendant's certain Note dated the same as the mortgage in the amount
of $94,250.00 payable in monthly installments with interest at the rate of 7% per annum. A copy of the
said Note is attached hereto, made a part hereof and marked Exhibit "B",
7. The said mortgage has not been assigned.
8. The mortgage is in default because the defendants have failed to make the payment of the
monthly installment of principal and interest in accordance with the terms of the mortgage for July I,
2004, and each month thereafter, up to and including the present time.
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il and hence, no notice of intention to foreclose is required by the said Act.
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9. The following amounts are due on the mortgage:
Principal
Interest at 7% per annum from 6/1/04 thru
11130/04 ($17.55 per diem)
Late charges accrued thru 11/30/04 ($32.0 IImonth)
Escrow deficit (taxes and insurance) ($1 73.3 l/month)
Attorney's fee (5%)
Title information certificate
$ 91,5/0.37
3,211.65
160.05
866.55
4,575.52
325.00
Total
$100,649.14
10. The said mortgage is not a residential mortgage as defined by Pennsylvania Act No.6 of 1974,
II. The aforesaid mortgage is insured under Title II of the National Housing Act, and therefore,
is not subject to the provisions of Pennsylvania Act No. 91 of 1983.
WHEREFORE, plaintiff demands judgment in the sum of $1 00,649.14 plus interest, late charges,
escrow advances and costs to the date of judgment and foreclosure of the said mortgage.
~
THOMAS . PULEO
Attorney for Plaintiff
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,..;,..~,'~~:i'.:::.J::~~;;;:2~;;.c.."c;~",~.,
DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of
Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows,
to wit:
BEGINNING at a point marked by a nail in the Eastern side of South York Street, at the Northwest
corner of Lot now or formerly of A. B. Brubaker and known as 227 South York Street; thence
extending along the Eastern side of said South York Street, North 12 degrees 37 minutes 30 seconds
West, a distance of 31 feet to a point at Southwest corner of Premises No. 223 South York Street, now
or late of William S. Port and wife; thence extending along the line of said premises now or late of
William S. Port and wife, North 77 degrees 35 minutes 09 seconds East, a distance of 163.61 feet to
an iron pin in the Western line of a 20-foot wide public alley; thence extending along the Western line
of said public alley, South 13 degrees 15 minutes East, a distance of 10 feet to a point marked by an
iron pin at the Northeast corner of property now or late of A. N. Brubaker and known as 222 West
Keller Street; thence extending along the line of said land now or late of A. N. Brubaker and known
as 222 West Keller Street and also premises numbered 224 West Keller Street, the same being also the
Southern life of a 100foot wide alley-way, South 77 degrees 25 minutes 00 seconds West, a distance
of 56.25 feet to a fence post at the Northwest comer of Premises No. 224 West Keller Street; thence
along the line of last mentioned property, South 07 degrees 23 minutes 10 seconds East, a distance of
22.50 feet to an iron pin in the Northeast comer of lot now or formerly of A. B. Brubaker and known
as 227 South York Street, aforementioned; thence along the line of said lot now or formerly of A. B.
Brubaker and known as 227 South York Street, South 78 degrees 26 minutes 40 seconds West, a
distance of 105.43 feet to a point marked by a nail in the Eastern side of South York Street,
aforementioned, at the point and place of beginning.
HAVING thereon erected a two and one-half story frame dwelling house known and numbered 225
South York Street, Mechanicsburg, Pennsylvania.
Tax Parcel #20-23-0567-142
EXHIBIT A
NOTE
LOU ..
Multistate
JUNS 27, 2002
[Date]
CAMP HILL,
[CitYI
PBHHSrLVAIlIA
[State]
225 S YORK ST. MIlCIIAlIICSSURG, PA 17055
[Property Addressl
1. PARTIES
"Bottawer" means each person signing at the end of this Note, and the person's s:uocessors and assigns_ "Lender" means
IoBII AMRO MOIl'rGAGB GROuP. IIlC.. A DSLAWARE CORPORAUOIt
lUld its successors and aSSigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In rewm for a loan received from Lender. Borrower promises to pay the principal sum of '" '" ** "'... *NINBTY FOUR
THOUSAND TWO HUNDRED FIFTY AND Ho/l00**.*.*****.***********..~"'**********
Dollars (U.S_ $94 ,250 . 00 ), plus interest, to the order of Lender. Interest win be charged on unpaid principal, from
the date of <liWursement oCtIle loan ploceeds by Lender, at me I1lte of SIVEN percent
( 7.000%) per year unli.l thefuU amount of principal has been paid.
J. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instruxnent that is dared the same date as
this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses whicb might result if
BolTower defaults under this Note.
.. MANNEROFPAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the 1ST day of each month beginning on
AUGUSi' 1, 20026 Any principal and interest remaining on the 1ST day of
JULY, 2032 will be due on that dale, whicb is called the . 'Maturity Date."
{B) Place
Payment shalt be made at
4242 N. HARLEM AVE.
MORRIDGB, IL 60706
A!lTll. CASUIIlRIIlG
or at such place as Lender may designate in writing by notice to BottQWer.
(C)Amoon'
Each monthly payment ofprincipa1and ioterest will be in the amount ofU,S, $621 6056 This amount will be
part ora larger monthly payment required by the Security Inslnunenlthat shall be applied tQ principal, interest and other items in
the order described {p the Security lnstrument
(0) AUooge to this Note (or paynsnt adjust1Dellts
If an allonge providing for payment adjustments is exearted by Borrower together with this Note, the covenants oftbe allonge
shall be incorporaled into and shal18111eOd. and supplement thewvenants of this Note as if the allonge were a part of this Note.
[ChecIc applicable bo.J 0 Graduated P_ Allonge D Growing Equily Allonge
o Other (specify)
5. BORROWER'S RIGHT TO PREPAY
BoJT<>W<lr has \he rigbt '" pay the debt evldeo<ed by this Note, io ,",ole or io part. wilbout charge or penally, on \he /irst day
of any month, Lendec shaJl accept prepayment on other days provided that borrower pays intel'l{S( on the amount prepaid for lbe
remainder of the month to the extent reqtdred by Lender and permitted by regulations of 1he Secretary. lfBonower makes a partial
prepayment. there will be no changes in the due date or in the amount ofUle momhly payment unless Lender agrees in writing to
- cl>anges.
6. BORROWER'S FAILURE TO PAY
(A) Late ChArge for Ovenhle paym.ents
If Lender has not received the fuU monthly payment required by the Security lnstrumenl, as described jn Paragraph 4(C) of this
Note, by the end of 15 calendar days after the payment is due. Lender may collect a late charge in the amount of
POUlt perwnt ( 4. ~ OOOt ) of the overdue amount of each payment.
(B) Defa.dt
If Borrower defaults by failing to pay in full an)' monthly payment. then Lender may, except as limited by regulations of the
Secretary in the case of payment defaults, reqllire immediate payment in full oftlJe principal balance remaining due and an accrued
interest. Lender may choose n{)l. to exerdse tl:Us option without waiving ils rigbts in the event of any subsequent dcfa....lt. In many
circumstances regulations issued by theSecretatYwiUlimit Lender' 5 rights to require immediatepaymenl infuJl in the caseofpayment
.
FHA Muki:!ll1le lih~ Rate No<<-" 10/95
EkJIBlt h
.
~OT 000 J
LOAN II 624344311
_nlls. This Noredoes notautlwrizeuccelerationwhen notpermiued by HUD regulations. As used in this Note. "Secn:wy" means
the Se<:retary ofHoosing and Il:ban Dewlopment or his or her desi&:=.
(C) P.y..... or C_ and E_...
JfLender has required i.mmediate payment in full, as described above, Lender may require Borrower t.o pay costs and expenses
including reasonable and customary attOlllCys' fees:for enforcing this Note: to the extent not prohibited by applicable law. Such fees
and CQSts shall bear interest tTom the date of disbursement at the same rate as the principal oElhi!; Note.
7. WAIVERS
BO['t'()\l/tt and any ot~ person who has obligations under this Note waive the rights ofpresentment and notice ofdishonoc.
"Presentment" means the right to require l..ePdet to demand payment of amounts due. . 'Notke of dishonor" means the right ta
require Lender to give notice ta ot~r persons that antOUJllS due have not been paid
8. GIVJNG OF NOTICES
Unless applicable law requires a different method, any notice lbat must be given ta Borrower under this Note will be given by
delivering it .or by mailing it by .first class mail to Borrower 41 the property address above or at a different address if Borrower has
given Lender a notice ofBorrowc::r's different address.
Any notitethat mustbe given ta LendetundertbisNote will be given by firstcJass mail to Lender at \headdress stated in Paragraph
4(13) or at a differertl address U"Bonower is given a notice .of that diH'erenl address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
Ifmore than one person signs this Note., each person is fully and personally obligated to keep all of the promises made in lhis
Note, including thepromisc lo pay the full amount owed. Any persan who is aguarantor, sun:tyor endorserofthis: Noteisalso obligated
to do tbese things. Any person who takes over these obIig;itions, including the obligations of a guarantor, surety or endorser of this
Note, is alw obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person
individually or against all signalories togetheL Anyone person signing this Note may be required to pay aU of the amounts owed
under this Note.
BY SIGNING BEWW, Borrower accepts and agrees to the terms and covenants conlained in this Note.
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NATHAN It JACKSON II
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(SBAL)
J1HA MuftbUlle "lId R..t., Note - 10/95
Page2of2
f8700NOT
Verification
hula Webb
hereby states that slhe is
Vice PresIdent
of ABN AMRO Mortgage Group, Inc., the plaintiff, or servicing agent for plaintiff, this matter,
that slhe is authorized to take this Verification, and that the statement made in the foregoing
Complaint are true and correct to the best of hislher knowledge, information and belief. The
undersigned understands that the statements made therein are subject to the penalties of 18 Pa.
C.S.A. Sec. 4904 relating to unsworn falsification to authorities.
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NamC1(~ ~i'ifi'?
Paula e
Title: Vice President
Date:
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SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06025 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ABN AMRO MORTGAGE GROUP INC
VS
JACKSON NATHAN 0 II
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to lawl
was served upon
says, the within COMPLAINT & NOTICE
JACKSON NATHAN 0 II
the
, at 1115:00 HOURS I on the 8th day of December, 2004
DEFENDANT
at 225 SOUTH YORK STREET
MECHANICSBURGI PA 17055
by handing to
NATHAN JACKSON II
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
7.40
.00
10.00
.00
35.40
Sworn and Subscribed to before
~
me this '1-' day of
c;L..u~fl .100j/ A. D.
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l-Nr~hon~~ ,wn
So Answers:
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R. Thomas Kline
12/09/2004
PULEOB:,DEMIL~
Deputy Sheriff
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-----,
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2004-06025 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ABN AMRO MORTGAGE GROUP INC
VS
JACKSON NATHAN 0 II
R. Thomas Kline
,Sheriff or Deputy Sheriffl who being
duly sworn according to lawl says, that he made a diligent search and
inquiry for the within named DEFENDANT
JACKSON NATHAN 0 II
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
, NOT FOUND , as to
the within named DEFENDANT
I JACKSON NATHAN 0 II
225 SOUTH YORK STREET
MECHANICSBURG, PA 17055
CHERI SAID THAT NATHAN LIVES IN NEW JERSEY. NO FORWARDING
ADDRESS ON FILE AT POST OFFICE.
Sheriff1s Costs:
Docketing
Service
Not Found
Surcharge
18.00
7.40
5.00
10.00
.00
40.40
So answer.. s~._.._.....~. ~ .~~-.. . ----'-"-"'::-,:>
./ ---.-....--..
R. Thomas Kline
Sheriff of Cumberland County
THOMAS PULEO
02/08/2005
Sworn and subscribed to before me
this
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day of }-i t.A..t<-.a...J
02 () c'/ A.D.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06025 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ABN AMRO MORTGAGE GROUP INC
VS
JACKSON NATHAN 0 II
RON KERR
I Sheriff or Deputy Sheriff of
Cumberland CountYlpennsylvanial who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
JACKSON CHERI A
the
DEFENDANT
, at 1455:00 HOURS, on the 3rd day of February, 2005
at 225 SOUTH YORK STREET
MECHANICSBURGI PA 17055
by handing to
CHERI A JACKSON
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff1s Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
r~~,~J
R. Thomas Kline
02/08/2005
THOMAS PULEO
Sworn and Subscribed to before
By:
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Deputy Sheriff
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day of
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Prothonotary
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THOMAS 1. PULEO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, P A 19422
(610) 941-3600
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL DIVISION - LAW
ABN AMRO MORTGAGE GROUP, INC.
v
: No. 04-6025
NATHAN O. JACKSON, II and
CHERI A. JACKSON, his wife
CERTIFICATE OF SERVICE
I, Thomas 1. Puleo, Esquire, do hereby certifY that I have forwarded true and correct
copies of the Amended Complaint in Mortgage Foreclosure by first class mail to all interested
parties listed below:
Mr. Nathan O. Jackson, II
225 South York Street
Mechanicsburg, P A 17055
Date: February 17,2005
-'
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II THOMAS 1. PULEO, LLC
II By: Thomas 1. Puleo, Esquire
11I1 Identification No. 27615
660 Sentry Parkway, Suite 210
'I Blue Bell, P A 19422
II (610) 941-3600
II
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Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LA W
ABN AMRO MORTGAGE GROUP, INC.
v.
: No. 04-6025
NATHAN O. JACKSON, II and
CHERI A. JACKSON, his wife
PRAECIPE FOR JUDGMENT
Enter judgment in favor of the Plaintiff and against the Defendant( s) for want of an answer and
assess damages as follows:
Principal
Interest from 6/1/04 thru 3/30/05
Late charges accrued thru 3/30105
Escrow deficit (taxes and insurance)
Attorney's fee (5%)
Title information certificate
$ 91,510.37
5,317.65
288.09
1,559.79
4,575.52
325.00
Total
$103,576.42
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED
AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM
CERTAIN FROM THE COMPLAINT.
I certifY that written notice of the intention to file this Praecipe was mailed or delivered to the party
against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and
at least ten days prior to the date of the filing of this praecipe. A copy ofth~no' is attached. Pa.R.C.P.
237.1 .
JCLN)
OMAS 1. P{j{EO, ESQUIRE
Attorney for Plaintiff
',-
AND NOW () ~Il ; ( "J , 2005, Judgment is entered in favor of plaintiff and against
defendants and damages assessed as per the above certification.
~ A/7-j~ ~ ~
Prothonotary
THOMAS l. PULEO, LLC
By: Thomas l. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, P A 19422
II (610) 941-3600
II
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Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.
: No, 04-6025
v.
NATHAN O. JACKSON, II and
CHERI A. JACKSON, his wife
To: Ms. Cheri A. Jackson
225 South York Street
Mechanicsburg, P A 17055
Date of Notice: March 14, 2005
NOTICE OF INTENTION TO FILE PRAECIPE FOR
ENTRY OF DEFAULT JUDGMENT UNDER Pa.R.C.P.237J
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRlTTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MA Y BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY
AND OTHER IMPORTANT RIGHTS.
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
(800) 990-9108
-
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A VISO IMPORT ANTE
A: Ms. Cheri A. Jackson
225 South York Street
Mechanicsburg, P A 17055
USTED EST A EN REBELDIA PORQUE HA F ALLADO DE REGISTRAR
COMP ARECENClA ESCRIT A POR SI MlSMO 0 A TRA VES DE UN ABOGADO Y SOMETER
CON LA CORTE SIJS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN
PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DlEZ DlAS DE
HABER RECIBIDO ESTE A VISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA
SIJY A SIN TENER DERECHOS A UNA VISTA Y US TED PUEDE PERDER SU PROPlEDAD U
OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIATEMENTE. Sl
USTED NO TlENE UN ABOGADO, LLAME 0 V A Y A A LA SIGUlENTE OFICINA. EST A OFICINA
PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUlR UN ABOGADO.
Sl USTED NO PUEDE PAGAR POR LOS SERVlCIOS DE UN ABOGADO, ES POSIBLE QUE
EST A OFlCINA LE PUEDA PROVEER INFORMACION SOBRE AGENClAS QUE OFREZCAN
SERVIClOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFlCAN.
Cumberland County Bar Association
2 Liberty A venue
Carlisle. PA 17013
(717) 249-3166
(800) 990-9108
THOMAS L PULEO, LLC
By: Thomas 1. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
BlueBell,PA 19422
(610) 941-3600
-
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Attorney for Plaintiff
fN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.
v.
: No. 04-6025
NATHAN O. JACKSON, II and
CHERI A. JACKSON, his wile
To: Mr. Nathan O. Jackson, II
225 South York Street
Mechanicsburg, P A 17055
Date of Notice: March 14,2005
NOTICE OF fNTENTION TO FILE PRAECIPE FOR
ENTRY OF DEFAULT JUDGMENT UNDER Pa.R.C.P.237.l
IMPORT ANT NOTICE
YOU ARE IN DEt' AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHfN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY
AND OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 MAYBE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
I
II
il
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
(800) 990-9108
-
AVISO lMPORTANTE
A: Mr. Nathan O. Jackson, II
225 South York Street
Mechanicsburg, P A 17055
FECfIA DEL A VISO:
USTED EST A EN REBELDlA PORQUE HA f ALLADO DE REGISTRAR
COMP AREC EN CIA ESCRlTA POR SI MlSMO 0 A TRA VES DE UN ABOGADO Y SOMETER
CON LA CORTE SUS DEFENSAS U OBJECClONES A LOS CARGOS QUE SE !-IAN
PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DlEZ DIAS DE
HABER REClBlDO ESTE A VlSO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA
SUY A SIN TENER DERECHOS A UNA VISTA Y OSTED PUEDE PERDER SU PROPlEDAD U
OTROS DEREC!-IOS IMPORT ANTES.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDlATEMENTE. Sl
USTED NO TlENE UN ABOGADO. LLAME 0 V A Y A A LA SIGUIENTE OFICINA. EST A OFICINA
PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
Sl USTED NO PUEDE P AGAR POR LOS SERVlCIOS DE UN ABOGADO, ES PO SIBLE QUE
EST A OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENClAS QUE OFREZCAN
SERVIClOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249.3166
(800) 990-9108
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I: THOMAS 1. PULEO, LLC
I: By: Thomas 1. Puleo, Esquire
III Identification No. 27615
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[I 660 Sentry Parkway, Suite 210
II Blue Bell, P A 19422
II
II (610) 941-3600
II
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Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.
No. 04-6025
v.
NATHAN O. JACKSON, II and
CHERI A JACKSON, his wife
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF MONTGOMERY
THOMAS 1. PULEO, being duly sworn according to law deposes and says that the defendant(s)
is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended;
I
I, That Nathan O. Jackson, 11 is over 21 years of age, resides at 225 South York Street,
II Mechanicsburg, Pennsylvania, and is employed by/as unknown.
II
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NOTARY PUBLIC
That Cheri A. Jackson is over 21 years of age, resides at 225 South York Street, Mechanicsburg,
Pennsylvania, and is employed by/as unknown.
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COMMONWEAL TH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ABN AMRO MORTGAGE GROUP,
INC.,
Plaintiff,
COURT OF COMMON PLEAS
NO. 04-6025
v.
NATHAN O. JACKSON, II AND
CHERl A. JACKSON, his wife,
Defendant( s).
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
AMOUNT DUE
INTEREST FROM
March 30, 2005
COSTS TO BE ADDED
$103,576.42
$
$171.90
.rz
T MAS 1. PUL , ESQUIRE
Attorney for Plaintiff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP, INC., Plaintiff (s)
From NATHAN O. JACKSON, II AND CHERI A. JACKSON, HIS WIFE
(I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
NO 04-6025 Clvll
CIVIL ACTION - LAW
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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (5) 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 himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $103,576.42
Interest FROM 3/30/05
L.L. $.50
Atty's Carom %
Atty Paid $173.80
Plaintiff Paid
Date: APRIL 4, 2005
Due Prothy $1.00
Other Costs $171.90
(Seal)
CURTIS R. LONG
Prothonotary Cyy
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Deputy
REQUESTING PARTY:
Name THOMAS I. PULEO, ESQUIRE
Address: 660 SENTRY PARKWAY, SUITE 210
BLUE BELL, PA 91422
Attorney for: PLAINTIFF
Telephone: 610-941-3600
Supreme Court ID No. 27615
.
.
.
THOMAS 1. PULEO, LLC
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615
Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.,
Plaintiff
NO. 04-6025
v.
NATHAN O. JACKSON, II AND
CHERI A. JACKSON, his wife,
Defendant
AFFIDAVIT UNDER PA. RCP RULE 3129
THOMAS 1. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure
action, sets forth as ofthe date the praecipe for the Writ of Execution was filed, the following
information concerning the real property located at 225 South York Street, Mechanicsburg,
Cumberland County, Pennsylvania, was true and correct to the best of its knowledge,
information and belief.
I. Name and address of each Owner and/or Reputed Owner:
Nathan O. Jackson, II
Cheri A. Jackson
225 South York Street
Mechanicsburg, P A 17055
2. Name and address of each Defendant named in the judgment:
Nathan O. Jackson, II
Cheri A. Jackson
225 South York Street
Mechanicsburg, P A 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
None.
.'
4. Name and address of the last recorded holder of every mortgage of record:
ABN AMRO Mortgage Group, Inc., Plaintiff
7159 Corklan Drive
Jacksonville, FL 32258
5. Name and address of every other person or entity which has any record lien on the
property:
None
6. Name and address of every other person or entity which has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 N. Hanover Street
Carlisle, P A 17013
Commonwealth of P A
Department of Public Welfare
P. O. Box 2675
Harrisburg, PA 17105
7. Name and address of every other person of whom the Plaintiff has knowledge who may
have an interest in the property which may be affected by the sale:
None
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
Date: March 29,2005
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THOMAS I. PULEO, LLC
660 Sentry Parkway. Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615
Attomey for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.,
Plaintiff
v.
NO. 04-6025
NATHAN O. JACKSON, II AND
CHERI A. JACKSON, his wife,
Defendant
NOTICE OF SHERIFFIS SALE OF REAL PROPERTY
TO: Nathan O. Jackson, II
Cheri A. Jackson
225 South York Street
Mechanicsburg, P A 17055
Your house at 225 South York Street, City of Mechanicsburg, Cumberland County, is
scheduled to be sold by the Cumberland County Sheriff's Department to enforce the Court
judgment of$103,576.42 obtained by Plaintiff ABN AMRO Mortgage Group, Inc. against you.
The Sheriff's Sale will be conducted on Wednesday, September 7, 2005, at 10:00 A.M.,
Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle,
Pennsylvania.
NOTICE OF OWNERS' RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. This sale will be canceled if you pay to ABN AMRO Mortgage Group, Inc. the
back payments, late charges, costs and reasonable attorneys I fees due. To find
out how much you must pay, you may call (610) 941-3600.
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 below 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 Sheriff's Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price bid by calling the Cumberland County
Sheriff's Department at (717) 240-6390.
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 bid in
the sale. To find out if this has happened, you may call the Cumberland County
Sheriff's Department at (717) 240-6390.
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 had 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
Cumberland County Sheriff on or about thirty (30) days from the date of Sheriff's
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 the distribution sheet is posted.
7. You may also have other rights and defenses, or ways of getting your house 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
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of
Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows,
to wit:
BEGINNING at a point marked by a nail in the Eastern side of South York Street, at the Northwest
corner of Lot now or formerly of A. B. Brubaker and known as 227 South York Street; thence
extending along the Eastern side of said South York Street, North 12 degrees 37 minutes 30 seconds
West, a distance of 31 feet to a point at Southwest corner of Premises No. 223 South York Street, now
or late of William S. Port and wife; thence extending along the line of said premises now or late of
William S. Port and wife, North 77 degrees 35 minutes 09 seconds East, a distance of 163.61 feet to
an iron pin in the Western line of a 20-foot wide public alley; thence extending along the Western line
of said public alley, South 13 degrees 15 minutes East, a distance of 10 feet to a point marked by an
iron pin at the Northeast corner of property now or late of A. N. Brubaker and known as 222 West
Keller Street; thence extending along the line of said land now or late of A. N. Brubaker and known
as 222 West Keller Street and also premises numbered 224 West Keller Street, the same being also the
Southern life of a IO-foot wide alley-way, South 77 degrees 25 minutes 00 seconds West, a distance
of 56.25 feet to a fence post at the Northwest corner of Premises No. 224 West Keller Street; thence
along the line of last mentioned property, South 07 degrees 23 minutes 10 seconds East, a distance of
22.50 feet to an iron pin in the Northeast corner of lot now or formerly of A. B. Brubaker and known
as 227 South York Street, aforementioned; thence along the line of said lot now or formerly of A. B.
Brubaker and known as 227 South York Street, South 78 degrees 26 minutes 40 seconds West, a
distance of 105.43 feet to a point marked by a nail in the Eastern side of South York Street,
aforementioned, at the point and place of beginning.
HAVING thereon erected a two and one-half story frame dwelling house known and numbered 225
South York Street, Mechanicsburg, Pennsylvania.
Tax Parcel #20-23-0567-142
THOMAS 1. PULEO, LLC
660 Sentry Parkway, Suite 210
Blue Bell, P A 19422
(610) 941-3600
By: Thomas 1. Puleo, Esquire
Identification No. 27615
Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.,
Plaintiff
v.
! NO. 04-6025
NATHAN o. JACKSON, II AND
CHERI A. JACKSON, his wife,
Defendant
AFFIDAVIT OF SERVICE
I, Lucy Fuentes, Legal Assistant to Thomas 1. Puleo, Esquire, attorney for plaintiff, being
duly sworn according to law, deposes and says that he mailed by ordil!-wY mail a Notice of Sale
pursuant to Pa.R.C.P 3129.2 upon the persons listed below on th'ed~~ay of JU).!:1 ,2005 as
evidenced by the U.S. Postal Service Certificate of Mailing (Fonn 3817), which is attached
hereto as Exhibit "A":
Cumberland County Domestic Relations
13 N. Hanover Street
Carlisle, P A 17013
Commonwealth of P A
Department of Public Welfare
P. O. Box 2675
Harrisburg, PA 17105
Borough of Mechanicsburg
West Strawberry and North Market Street
Mechanicsburg, PA 17055
a:
Lucy Fuen~; eg
Thomas 1. Puleo
SWORN TO AND SUBSCRIBED
BEFORE THISoI Gt~ro\Y
, ,2005.
.I{~
. ..-------.----.-....-
Nor~\F-~;,"~L S-E-AL'-"----
LISA A. I<~\NE, f,j0l8ry Public
Whitpam Twp, f/,::niqomery County
... My Com!"~",,;,, . ;\uq~s~1, 2005 _
,.
THOMAS I. PULEO, LLC
660 Sentry Parkway, Suite 2 I 0
Blue Bell, PAl 9422
(610) 941-3600
By: Thomas 1. Puleo, Esquire
Identification No. 27615
Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.,
Plaintiff
NO. 04-6025
v.
NATHAN O. JACKSON, II AND
CHERI A. JACKSON, his wife,
Defendant
AFFIDAVIT UNDER P A. RCP RULE 3129
THOMAS I. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure
action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following
information concerning the real property located at 225 South York Street, Mechanicsburg,
Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information
and belief.
1. Name and address of each Owner and/or Reputed Owner:
Nathan O. Jackson, II
Cheri A. Jackson
225 South York Street
Mechanicsburg, P A 17055
2. Name and address of each Defendant named in the judgment:
Nathan O. Jackson, II
Cheri A. Jackson
225 South York Street
Mechanicsburg, PA 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Borough of Mechanicsburg
West Strawberry and North Market Street
Mechanicsburg, PA 17055
4. Name and address of the last recorded holder of every mortgage of record:
ABN AMRO Mortgage Group, Inc., Plaintiff
7159 Corklan Drive
Jacksonville, FL 32258
5. Name and address of every other person or entity which has any record lien on the
property:
None
6. Name and address of every other person or entity which has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 N. Hanover Street
Carlisle, P A 17013
Commonwf:alth ofPA
Department of Public Welfare
P. O. Box 2675
Harrisburg, P A 17105
7. Name and address of every other person of whom the Plaintiff has knowledge who may
have an interest in the property which may be affected by the sale:
None
1 verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating nsworn fal . ca 'on to authorities.
Date: July 20, 2005
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THOMAS 1. PULEO, LLC
By: Thomas 1. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
Attorney for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
FIRST JUDICIAL DISTRICT OF PENNSYLVANIA
ABN AMRO MORTGAGE GROUP, INC.
v.
: No. 04-6025
NATHAN O. JACKSON, II and
CHERI A. JACKSON
PETITION TO POSTPONE SHERIFF'S SALE
_?
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
Plaintiff, ABN AMRO Mortgage Group, Inc., by its attorney, Thomas 1. Puleo, Esquire, petitions
this Court to postpone the Sheriffs Sale for the following reasons:
I. On December I, 2004, plaintiff filed a Complaint in Mortgage Foreclosure under the above
number.
2. On April 4, 2005, judgment was entered, a writ of execution issued and sheriffs sale of
the mortgaged premises scheduled for September 7, 2005.
3. On August 29,2005 plaintiff instructed the sheriff to postpone the sale to October 5,2005 to
allow the defendants to complete a sale of the property.
4. However a further postponement is necessary in order to complete the sale.
5. Pursuant to Pa.R.C.P. 3129.3 the plaintiff may postpone a Sheriffs Sale only once without the
necessity for new notices, unless authorized by the Court.
6. Plaintiff therefore requests this Court to further postpone the Sheriffs Sale until November 2,
2005, without the necessity of new notices or advertising ofthe sale.
WHEREFORE, plaintiff prays this Honorable Court enter an Order postponing the Sheriffs Sale
until November 2,2005.
Respectfully submitted,
-2-
THOMAS I. PULEO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
Attorney for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
FIRST JUDICIAL DISTRICT OF PENNSYLVANIA
ABN AMRO MORTGAGE GROUP, INC.
v.
: No. 04-6025
NATHAN O. JACKSON, II and
CHERI A. JACKSON
MEMORANDUM OF LAW IN SUPPORT OF
PETITION TO POSTPONE SHERIFF'S SALE
This action in mortgage foreclosure was commenced by Complaint on December 1, 2004. After
effecting service upon the defendants in this case. On April 4, 2005, judgment was entered, a writ of
execution issued and sheriffs sale of the mortgaged premises scheduled for September 7, 2005, which was
later postponed until October 5, 2005. Plaintiff requests that the sale be postponed until the November 2,
2005 sale date to allow time to complete a full payoff.
Pennsylvania Rule of Civil Procedure 3129.3 provides that the plaintiff can postpone a sheriff s sale
only once unless authorized by the Court. No parties will be prejudiced by the further postponement of the
sale. Plaintiff therefore requests that this Honorable Court order a further postponement of the sheriff s sale
so as to allow time to complete a full payoff.
VERIFICA nON
Thomas 1. Puleo, Esquire, on behalf of plaintiff/petitioner, being duly authorized to do so,
verifies that the statements contained in the foregoing Petition to Postpone Sheriffs Sale are true and
correct to the best of his information, knowledge and belief and understands that false statements
herein are made subject to the penalties of 18 Pa.C.S.A. ~4904, relating to unsworn falsification to
authorities.
Dated: September 20, 2005
T
ii-
THOMAS 1. PULEO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
Attorney for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
FIRST JUDICIAL DISTRICT OF PENNSYLVANIA
ABN AMRO MORTGAGE GROUP, INC.
v.
: No. 04-6025
NATHAN O. JACKSON, II and
CHERI A. JACKSON
CERTIFICATE OF SERVICE
I, Thomas 1. Puleo, Esquire, do hereby certify that I have forwarded true and correct copies of
Plaintiff's Petition to Postpone Sale by first class mail to all interested parties listed below:
Mr. Nathan O. Jackson, II AND
225 South York Street
Mechanicsburg, P A 17055
Date: September 20, 2005
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THOMAS I. PULEO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
RECEIVED SEP 2 0 ZG:j~
Attorney for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
FIRST JUDICIAL DISTRICT OF PENNSYLVANIA
ABN AMRO MORTGAGE GROUP, INC.
v.
: No. 04-6025
NATHAN O. JACKSON, II and
CHERI A. JACKSON
ORDER
AND NOW, this L\~ day of O~ , 2005, upon consideration of the petition of plaintiff, it is
hereby ORDERED that the Sheriffs Sale in this case scheduled for October 5, 2005(originally listed for
September 7, 2005) is postponed until the regularly scheduled sale to be held November 2, 2005. It is
further ORDERED that announcement of this postponement is to be given at the time and place next fixed
for Sheriff s Sale with no new notice required to parties already having been given notice of the sale.
J.
Z S :21 [J,d ll- 1JO son
;\8V.!.c;\Gi'":iC\::~j 3Hl jO
38i:l~(}{En1:J
ABN Amro Mortgage Group, Inc.
VS
Nathan O. Jackson, II and Cheri A.
Jackson
The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2004-6025 Civil Term
Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states
that on May 25, 2005 at 5:53 o'clock PM, he served a true copy of the within Real Estate
Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the
within named defendants, to wit: Nathan O. Jackson, II and Cheri A. Jackson, by making
known unto Pat Diberardine, adult in charge for Nathan O. Jackson, II and Cheri A.
Jackson, at 909 Greenbriar Drive, Mechanicsburg, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states
that on July 11,2005 at 3:46 o'clock P.M., he posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Nathan O. Jackson, II and Cheri A. Jackson, located at 225 South York Street,
Mechanicsburg, Carlisle, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendantd, to wit: Nathan O. Jackson and Cheri A. Jackson, by regular mail to their last
known address of 909 Greenbriar Drive, Mechanicsburg, P A 17055. This letter was
mailed under the date of July 01,2005 and never retumed to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly swom according to law, states this writ
is returned STAYED per instructions from Attorney Thomas Puleo.
Sheriffs Costs:
Docketing
Poundage
Advertising
Posting Handbills
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
30.00
2,025.87
15.00
15.00
.50
1.00
16.00
6.29
15.00
30.00
_~~7 ~
rJd;r~p J
R. Thomas Kline, Sheriff
BY Ij{)~ s,wiJ
Real Estat Sergeant
Share of Bills
Law Journal
Patriot News
Postpone Sale
18.20
485.00
376.49
20.00
$3,054.35
Sworn and subscribed to before me
2005, A.D.
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THOMAS 1. PULEO, LLC
660 Sentry Parkway, Suite 210
Blue Bell, P A 19422
(610) 941-3600
By: Thomas 1. Puleo, Esquire
Identification No. 27615
Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.,
Plaintiff
NO. 04-6025
v.
NATHAN O. JACKSON, II AND
CHERI A. JACKSON, his wife,
Dcfendant
AFFlDAVlTUNDERPA. RCP RULE 3129
THOMAS 1. PULEO, attomey for Plaintiff in the above captioned mortgage foreclosure
action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following
information concerning the real property located at 225 South York Street, Mechanicsburg,
Cumberland County, Pennsylvania, was true and correct to the best of its knowledge,
information and belief.
I. Name and address of each Owner and/or Reputed Owner:
Nathan O. Jackson, II
Cheri A. Jackson
225 South York Street
Mechanicsburg, P A 17055
2. Name and address of each Defendant named in the judgment:
Nathan O. Jackson, II
Cheri A. Jackson
225 South York Street
Mechanicsburg, PA 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Nonc.
I
.
4. Name and address of the last recorded holder of every mortgage of record:
ABN AMRO Mortgage Group, Inc., Plaintiff
7159 Corklan Drive
Jacksonville, FL 32258
5. Name and address of every other person or entity which has any record lien on the
property:
None
6. Name and address of every other person or entity which has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of P A
Department of Public Welfarc
P. O. Box 2675
Harrisburg, PA 17105
7. Name and address of every other person of whom the Plaintiff has knowledge who may
have an interest in the property which may be affected by the sale:
None
I verify that the statcments made in this Affidavit are truc and correct to the best of my
personal knowledge, information and belief. 1 understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
Date: March 29, 2005
,
THOMAS 1. PULEO, LLC
660 Sentry Parkway. Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas 1. Puleo, Esquire
Identification No. 27615
Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
ABN AMRO MORTGAGE GROUP, INC.,
Plaintiff
v.
NO. 04-6025
NATHAN O. JACKSON, II AND
CHERI A. JACKSON, his wife,
Defendant
NOTICE OF SHERlFFIS SALE OF REAL PROPERTY
TO: Nathan O. Jackson, II
Cheri A. Jackson
225 South York Street
Mechanicsburg, PA 17055
Your house at 225 South York Street, City of Mechanicsburg, Cumberland County, is
scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court
judgment of$103,576.42 obtained by Plaintiff ABN AMRO Mortgage Group, Inc. against you.
The Sheriffs Sale will be conducted on Wednesday, September 7, 2005, at 10:00 A.M.,
Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle,
Pennsylvania.
NOTICE OF OWNERSI RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF IS SALE
To prevent this Sheriffs Sale, you must take immediate action:
I. This sale will be canceled if you pay to ABN AMRO Mortgage Group, Inc. the
back payments, late charges, costs and reasonable attorneys' fees due. To find
out how much you must pay, you may call (610) 941-3600.
i
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 below 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.
] . If the Sheriff's Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price bid by calling the Cumberland County
Sheriff's Department at (717) 240-6390.
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 bid in
the sale. To find out if this has happened, you may call the Cumberland County
Sheriff's Department at (717) 240-6390.
4. Ifthe amount due from the buyer is not paid to the Sheriff, you will remain the
owner of the property as if the sale had 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
Cumberland County Sheriff on or about thirty (30) days from the date of Sheriff's
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 (l0) days
after the distribution sheet is posted.
7. You may also have otherrights and defenses, or ways of getting your house back,
if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, P A 17013
(717) 2;0-6200
.....
WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-6025 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP, INC., Plaintiff (s)
From NATHAN O. JACKSON, II AND CHERI A. JACKSON, HIS WIFE
(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 garnishee(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) Ifproperty 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 himlher that helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due $103,576.42
Interest FROM 3/30/05
L.L. $.50
Atty's Comm %
Arty Paid $173.80
Plaintiff Paid
Date: APRIL 4, 2005
Due Prothy $1.00
Other Costs $171.90
CURTIS R. LONG
(Seal)
Prothonot~
'---..!ly: ktd a--, 0
r;).~m-Jcr
Deputy
REQUESTING PARTY:
Name THOMAS I. PULEO, ESQillRE
Address: 660 SENTRY PARKWAY, SUITE 210
BLUE BELL, PA 91422
Attorney for: PLAINTIFF
Telephone. 610-941-3600
Snpreme Court ID No. 27615
Real Estate Sale #35
On May 11, 2005 the Sheriff levied upon the
defendant's interest in the real property situated in
Mechanicsburg Borough, Cumberland County, PA
Known and numbered as 225 South York Street,
Mechanicsburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: May 11,2005
By: ,JadL[S~~
Real Estate Deputy
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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
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a cOlporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established
March 4th. 1854, and September 18th, 1949, 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! Metro editions which appeared on the 19th and 26th day(s) of July and the 2nd
day(s) of August 2005. That neither he nor said Company is interested in the subject matter of said printed notice or
advertising, and that all of the allegations of this statement as to the time, place and character of publication are true;
and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution 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 in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14. Page317.
PUBLICATION
COpy
S ALE #35
1
Sworn to and subscri
eh)16thdaYOf
NOTA Y PUBLIC
My commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO.
For publishing the notice or publication attached
hereto on the above stated dates
376.49
REAL ESTATE SALE No. 3li
WrllNo.~5
ClvtlTenn
ABN Amro~
GrouP. Inc.
Vo. '
_on O. Jsckson, II _ ChsrI A.
_\111
Atty.:~ Puleo
...
DESCRIPTION
ALL TIIAT CERtAIN piece or parcel of land
.iluare in \be Borough of MeclJaoicsburg, Counly
of Cumberland and Commonwealth of
Pennsylvania, more particularly bounded and
described as follows, to wit
BEGlNNING at a point marked by a nail in the
Eastern side of South York Street. at the Northwest
comer"of LJt noW or formerly of A.B. Brubaker
and' known as 227 South York Street; thence
exlending along \be E''''4" ,ide 01 said Sooth
YOIt S-. North 12 degrees 31 minutes JO
seconds West. a distance of 31 feet ro a point at
Sou~ comer of Premises No. 223 South York
Street. now or lateofWIlliar8 S. Port and wife;
thence......m.a along \be line of said premises
now or late of William S. Port and wife, North 77
=r- 119_....._01
161' ".............ota
2Qfoo!Lwide public ~y; thence ..--"'ft.
1he W..... line of said pabIio alley, SOoII .
........15minuleslZt,.dislanc:eofHl."'.
poiolmarted~anifonpinal1he~
CCDIlIr of property now or late ofA.N. BtlfllIIiIr
lid known as 222 West KeUer Street; thence
exlendingalong1helineolsaidlaodllOWorlateol
A.N. Brubaker and known as -222 West Keller
Street and also premises mbered 224 West
Kelko: S-. \he same beinralso \be Soothem life
of a 10 foot wide alley-way, South 77 degrees 25
minutes 00 seconds West, a distance of 56.25 feet
to a fence post at the Northwest corner of
Premises No, 224 West Keller Street; lbence along
the1ineoflastrnentionedproperty,SouthrJJ
degrees 23 mil1ute& 10 seconds East, a distance of
22.50 feet to an iron pin in the Nortbeast comer of
lot now or formerly of A.B. Brubaker and known
as 2lJ South York Sttet:t, aforementioned; thence
along the line of said lot now or formerly of A.B.
Brubaker and known as 227 Sooth York Street,
South 78 degrees 26 minute.& 40 seconds West, a
distance of 105.43 feet to a pcjnt: marked by a nail
in. the Eastern side of South York Street,
aforementioned, at the point and place of
~
HAVlNG thereon erected a two and ooe-half
story frame dwelling house known and numbered
225 South York Street, Mechanicsburg,
Penmylvania.
Tax Parcel # 20-23-0567-142
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, Esqnire, Editor of the Cumberland Law Joumal, 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:
July 15,22,29,2005
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.
SWO TO AND SUBSCRIBED before me this
29 day of Julv. 2005
NOT AR Al SEAL
LOIS E. SNYDER, Notary Public
Carlisle 8010, Cumberland County
Mv Commission Expires Marcl\ 5. 2009
REAL ESTATE SALE NO. 35
Writ No. 2004-6025 Civil
ABN AMRO Mortgage Group, Inc.
vs.
Nathan O. Jackson, n and
Cheri A. Jackson
Atty.: Thomas Puleo
DESCRIPTION
ALL THAT CERTAIN piece or
parcel of land situate in the Bor-
ough of Mechanicsburg. County of
Cumberland and Commonwealth of
Pennsylvania, more particularly
bounded and described as follows.
to wit:
BEGINNING at a point marked
by a nail in the Eastern side of
South York Street, at the Northwest
comer of Lot now or formerly of A.
B. Brubaker and known as 227 South
York Street: thence extending along
the Eastern side of said South York
Street, North 12 degrees 37 min-
utes 30 seconds West, a distance
of 31 feet to a point at Southwest
comer of Premises No. 223 South
York Street, now or late of William
S. Port and wife; thence extending
along the line of said premises now
or late of WUliam S. Port and wife,
North 77 degrees 35 minutes 09
seconds East, a distance of 163.61
feet to an iron pin in the Western
line of a 20-foot wide public alley;
thence extending along the Western
line of said public alley, South 13
degrees 15 minutes East, a distance
of 10 feet to a point marked by an
iron pin at the Northeast comer of
property now or late of A. N.
Brubaker and known as 222 West
Keller Street; thence extending along
the line of said land now or late of
A. N. Brubaker and known as 222
West Keller Street and also premises
numbered 224 West Keller Street,
the same being also the Southern
life of a 10-foot wide al1ey~way.
South 77 degrees 25 minutes 00
seconds West, a distance of 56.25
feet to a fence post at the North-
west corner of Premises No. 224
West Keller Street: thence along the
line of last mentioned property,
South 07 degrees 23 minutes 10
seconds East, a distance of 22.50
feet to an iron pin in the Northeast
comer of lot now or formerly of A.
B. Brubaker and known as 227
South York Street, aforementioned;
thence along the line of said lot now
or formerly of A. B. Brubaker and
known as 227 South York Street,
South 78 degrees 26 minutes 40
seconds West, a distance of 105.43
feet to a point marked by a nail in
the Eastern side of South York
Street, aforementioned, at the point
and place of begirming.
HAVING thereon erected a two
and one-half story frame dwelling
house known and numbered 225
South York Street, Mechanicsburg,
Pennsylvania.
Tax Parcel #20-23-0567-142.