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COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff is MANUFACTURERS AND TRADERS TRUST COMPANY SB/M KEYSTONE
FINANCIAL BANK NA SB/M FARMERS TRUST COMPANY, PO Box 840, Buffalo, NY 14240-
0840.
2. The name(s) and address(es) of the Defendant(s) is/are ALMEDA M. RUDA, 65 Derbyshire Drive,
Carlisle, PA 17013 and JOSEPH S. RUDA, 65 Derbyshire Drive, Carlisle, PA 17013, who is/are the
mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described.
On July 08, 1999 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter
described to MANUFACTURERS AND TRADERS TRUST COMPANY SB/M KEYSTONE
FINANCIAL BANK NA SB/M FARMERS TRUST COMPANY, which mortgage is recorded in the
Office of the Recorder of Deeds of Cumberland County as Book 1222 Page 539. These documents are
matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule
of Civil Procedure 1019(g).
3. The premises subject to said mortgage is described as attached.
4. The mortgage is in default because monthly payment of principal and interest upon said mortgage due
July 08, 2004, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon
default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith.
5. The following amounts are due on the mortgage:
Principal Balance $103,396.37
Interest from 06/08/2004 $2,321.43
through 11/30/2004 at 4.6590%
Per Diem interest rate at $13.20
Attorney's Fee at 5.0% of Principal Balance $5,169.82
Late Charges from 07/08/2004 to 11/30/2004 $308.30
Monthly late charge amount at $52.98
Costs of suit and Title Search $900.00
$112,095.92
Escrow +$1,610.73
$113,706.65
6. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania
law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is
reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually
performed.
7. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face-to-face meeting
within the required time and Plaintiff has no knowledge of any such meeting being requested by the
Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate
Consumer Credit Counseling Agency.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure in the sum of $113,706.65,
together with interest at the rate of $13.20, per day and other expenses incurred by the Plaintiff which are
properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the
mortgaged premises.
By: _ „'_
Q4LDBCK McCAFFERTY & McKEE
BY: JOSEPH A. GOLDBECK, JR., ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
I, Diana M. Robinson, as the representative of the Plaintiff corporation within named do
hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff
corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my
knowledge, information and belief. I understand that false statements therein are made subject to the
penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities.
Date: I -,' 7 --f) y
Diana M. o inson
M&T MORTGAGE COMPANY
EXHIBIT A
LDan,Na.. ce?? caw al ?ltxourd ifhxr fn?t ?
Prlnci?st "' ' ,Loa J'Svaturlty.
"a ?:r 'f???7-02Di4? .. .......?;,:; '?? ;+F1a;!?''•
9$130M.
Refsrenas hn 0a shaded area are for L.endw% use o* and do not IinM the appttgWtly, of ft documall to any par8cula Ian ar item
Borrower: Joseph & Rude Lender: Farmers Trust company
948 Doubling Gap Road Main office
Newvllle, PA 17241 One West High Street
Carlisle, PA 17013
This EWt4t A Is attached to and by this reference Is made a part of each Deed of Trust or Mortgage, dated July s, 1994, and executed M
connection with a loan or other financial accommodations between Farmers Trust Company and Joseph S. Ruda.
ALL THAT CERTAIN lot or parcel of land situate in South Middleton Township, Cumberland
County, Pennsylvania, BEING Lot No. 66 on the Plan of Lots known as "Final Plan for
Mayapple Village, Derbyshire Lots 40-73," prepared by Statler-Brehm, Engineering and
Planning Consultants, dated January 26, 1989, and recorded in the Office of the Recorder
of Deeds of Cumberland County, Pennsylvania, in Plan Book 58 page 68.
AND BEING more fully described in Deed from Craig E. Dallmeyer to Joseph S. Ruda and
Almeda M. Ruda dated May 13, 1994 and recorded in the Office aforesaid in Deed Book 105
page 496.
of Pennsylvania
-Inty of Cumberland SS
°'rzt?d in the office for the recording of Dwds
m and f?y beriand Cou
{,
15'0 handa va-- Pag
Carlisle, PA th?l1 ?„ of
? A
R eco?dor
THIS EXHIBIT A IS EXECUT DON JULY 8, 19
X, ? u,
LENDER:
Farmers Tru c0 ?jy?
By: 74 ' 1--1 ?
Authorized Officer
e6% 1222 PAcf 5,5
LASER PRO, Req. U.S, Pal, 6 T.M. off, Ver. 3.17(c) 1994 CFI ProServicee, Inc. Allrights reaerveo. IPA-GW RUOAJS,LM R22.OVLI
M&T Mortgage corp.
P.O. ® ?
- P.O. Box 1288
Buffalo, NY 14240-1288 ww.u.rawra,rx
09/13/2004
Joseph S Ruda
65 Derbyshire Dr Carlis
Carlisle, PA 17013
HOMEOYNERS NAME(S): Joseph S Ruch
PROPERTY ADDRESS: 05 Derbyshire Or Carlis
Carlisle. PA 17013
LOMi ACCT NO: 0009799090
CURRENT LENDER/SERVICER: M&T Nortyaas Corporation
Certified No.: 71826389306004487815
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
a YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
,L
Hi 3 1 Ec*?sel YOU CMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
OF 1983 (THE "ACT's YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
'sT
ANc,
STAN
CE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES
BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY
YOUR MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS
ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a
"face-to-fae"meeting with one ofthe consumer credit counseling agencies listed at the and ofthis Notice. THIS
MEETING MUST OCCUR WITHIN THE NEXT (301 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS
NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT". VXPLAINS FLOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling
agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date
of this meeting. The names, addresses and tyleDhone numbers of dcsianated consumer credit counselins agencies for
the county in which the DroDerty is located are set forth at the end of this Notice. It is only necessary to schedule one
face-to-face meeting. Advise your tender immediately of your intentions.
1 800 724 1633 Correspondence - P.O. Box 840, Buffalo, NY 14240-0640 Payments - P.O. Box 1364, Buffalo, NY 14240-1364
Aorgage account information, just a dick away. www.ma"rnortgage.com
M&T Mortgage Corp. ®?.
P.O. Box 1288
Buffalo,NY 14240-1288 Aaar.rotersw
09/13/2004
Joseph S Ruda
Po Box 866
Carlisle, PA 17013
FINE011NERS NAME(S): Joseph S Rude
PROPERTY ADDRESS: QS Derbyshire Or Carlis
Carlisle, PA 17013
LOAN ACCT NO: 0009789090
CURRENT LENDER/SERVICER: 1167 Mortgage Corporation
Certified No.: 71826389306004487808
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR ROME FROM
FORECLOSURE AND HELP YOU MAKE FUT[IRE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACP'), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES
BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY
YOUR MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS
ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a
"face-to-fag"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS
MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS
NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - Ifyou meet with one ofthe consumer credit counseling
agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date
of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for
the county in which the DrooertV is located are set forth at the end of this Notice. It is only necessary to schedule one
face-to-face meeting. Advise your lender immediately of your intentions.
1 800 724 1633 Correspondence - P.O. Box 640, Buffalo, NY 14240-0840 Payments - P.O. Box 1364. Buffalo. NY 14240-1364
Mortgage account in/orrnatkm, just a dick away. www.mandtmortgage.com
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the Lessons set forth huta
in this Notice (see following pages for specific information about the nature of your default) Ifyou have tried and
are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the
Homeowner'sEmergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed
Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.
Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed
by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has
sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings
will be pursued against you if you have met the time requirements set forth above. You will be notified directly by
the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES
ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(if you have tiled bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date).
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at:
66 Derbyshire Or Car11s
Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MORTGAGE PAYMENTS for the following months and the following amounts are
now past due:
Regular paysLents of $1089.62 for the months of 07/08/2004
through today's date: $ 3186.84
Other charges: Accrued Late Charges: $ 349.24
Accrued Other Charges $ 9.00
TOTAL AMOUNT PAST DUE: $ 3848.18
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS ofthe date of this
notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3545.18, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash. cashier's check, certified check or money order made Davable and
sent to,
M&T Mortgage Corporation
One Fountain Plaza 17th Floor
Attn: Payment Processing
Buffalo, NY 14203
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter.
IF YOU DO NOT CURE THE DEFAULT-Ifyou do not cure the default within THIRTY (30) DAYS ofthe date
of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire
outstanding balance of this debt will he considered due immediately and you may lose the chance to pay the
mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged
property.
1 600 724 1633 Correspondence - P.O. Box 840, Buffalo, NY 14240-0844 Payments - P.O. Box 1364, Buffalo, NY 14240-1364
Mortgage account information, just a dick away. www.mandimortgage.com
IF THE MORTGAGE IS FORECLOSED UPOri - The mortgaged property will be sold by the Sheriff to pay off
the mortgage debt. If the lender refers your case to its attorneys, but you true the delinquency before the lender
begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were
actually incurred, up to 550.00. However, if legal proceedings are stetted against you, you will have to pay all
reasonable attorney'sfees actually incurred by the lender even if they exceed 550.00. Any attorney sfees will be
added to the amount you owe the lender, which may also include other reasonable costs. Ifyou cure the default
within the THIRTY (30) DAY period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all
other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within
the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default
and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount
then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the
foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by
performmg any other requirements under the mortgage. Curing your default in the manner set forth In this
notice will restore your mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale
of the mortgaged property could be held would be approximately 10 months from the date of this Notice. A
notice ofthe actual date of the Sheriff sSale will be sent to you before the sale. Of course, the amount needed to
cure the default will increase the longer you wait. You may find out at any time exactly what the required payment
or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: M&T Mortgage Corporation
Address: P.O. Box 840
Buffalo, NY 14240
Phone Numbyr: (800) 724-1633
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff sSaic will end your ownership of the
mortgaged property and your right to occupy it. Ifyou continue to live in the property after the Sheriffs Sale, a
lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You _ may or X may not sell or transfer your home to a buyer or
transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's
fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Sincerely,
Russell M. Alessi Jr.
Collections Manager
Enc: Act 91 Notice
Consumer Credit Counseling Agencies Serving Your County
1 800 724 1633 Correspondence - P.O. Box 840, Buffalo, NY 14240-0840 Payments - P.O. Box 1364, Buffalo, NY 142441364
Mortgage account information,lust a dick away. www.mand0rodange.com
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an officisi notice that the mortesee on your home is in default, and the lender intends to foreclose.
Specific Information about the nature of the default is provided in the attached pages,
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save
Your home. This Notice explains how the program works.
To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGI-NCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with von when You mad with
the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving Your County are
listed at the end of this Notice. If You have any questions, you may Fall the Pennsylvania Housing Finance
Aeencv toll free at 1-800-342-2397.(Persons with Impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact as
attorney In your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
1 600 T24 1633 Conaspondence - P.O. Box 840, Buffalo, NY 14240-0840 Payments . P.O. Box 1364, Buffalo, NY 14240-1364
Mortgage account information just a click away, www.mandtmortgage.com
Homeowners' Emergency Assistance Program
CUMBERLAND COUNTY
CCCS of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
Community Action Comm of the Capital Region Adams County Housing Authority
1514 Derry Street 139-143 Carlisle St
Harrisburg, PA 17104 Gettysburg, PA 17325
(717) 232-9757 (717) 334-1518
FAX (717) 234-2227 FAX (717) 334-8326
NOV. 3.2004 8:41AM
19 ZVIf Mom Corpora#ion
A5ub8ldiery0lM9Beek
November 03, 2004
Almeda M, Ruda.
PO Box 866
Carlisle, PA 17013
RE: Homeowner's Name(s): Joseph S Ruda
Property Address: 65 Derbyshire Dr Carlis
Carlisle PA 17013
Loan Acct.No.: 0009789090
Curent Lender/ Servicer: M&T Mortgage Corporation
NO.9283 P. 9/14
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBILE
FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND
YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS,AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled
to a temporary stay of foreclosure on your mortgage for thirty (30)
days form the date of this Notice. During this time you must arrange
and attend a "face-to-face" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING
MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU nO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO
DATE, THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the
consumer credit counseling agenices listed at the end of this notice,
the lender may NOT take action against you for thirty (.30)-days
after the date of this meeting. The names, addresses and telephone
numbers of designated consumer credit counseling agencies for the
country in which the property is located are set forth at the and
of this Notice, it is only necessary to schedule one face-to--face
meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default
for the reasons set forth later in this Notice (see following pages
for specific information about the nature of your default.) If you
have tried and are unable to resolve this problem with the lender,
1 800 724 1633 • Correspondenoo - P.O. Box 844, buffalo, NY 14240-0840 • Payments - P.O. Box 1364, Buffalo, NY 14240-1364
MorCgaw account Information, just a ollok away. www.mandtmortgage.com
NOV. 3.2004 8:39AM
1' M P=tiM
A&A*0kWydM1kT6E"k
November 03, 2004
Almeda M. Ruda
65 Derbyshire Dr, C
Carlisle, PA 17013
RE: Homeowner's Name(s): Joseph S Ruda
Property Address: 65 Derbyshire Dr Carlis
Carlisle PA 17013
Loan Acct.No.: 0009789090
Curent Lender/ Servicer: M&T Mortgage Corporation
NO.9283 P. 3/14
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORT-GAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBILE
FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND
YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS,AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled
to a temporary stay of foreclosure on your mortgage for thirty (30)
days form the date of this Notice. During this time you must arrange
and attend a "face-to-face" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING
MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO
DATE. THE PART OF-THIS NOTICE-CALLED "-IOW TO CURE YOUR MORTGAGE
DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the
consumer credit counseling agencces listed at the end of this notice,
the lender may NOT take action against you for thirty (30) days
after the date of this meeting. The names, addresses and telephone
numbers of designated consumer credit counseling agencies for the
country in, which the property is located are set forth at the end
of this Notice. it is only necessary to schedule one face-to-face
meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default
for the reasons set forth later in this Notice (see following pages
for specific information about the nature of your default.) If you
have tried and are unable to resolve this problem with the lender,
1 800 724 1533 • Correspondence - P_0. Box 840, Buffalo, NY 14240.0940 ¦ payments-P,0, pox 1364, Buffalo, NY 14240-1364
Modgago amount infnrmagon,11ist a crick away. www.mandimortgage.com
NOV. 3.2004 8:39AM
130Mb "e Capmt on
A $UWd-Wy t Mdr Bank
%9283 P. 4/14
you have the right to apply for financial, assistance from the
Homeowner's Emergency Mortgage Assistance Program. To do so,
you must fill-out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer
credit counseling agencies listed at the end of this Notice.
Only consumer credit counseling agencies have applications for
the program and they will assist you in submitting a complete
application to the Pennsylvania Housing Finance Agency. Your
application MUST be filed or postmarked within thirty (30) days
of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION POMPTLY. IF YOU FAIL TO DO SO OR
IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION -- Available funds for emergency mortgage assistance
are very limited. They will be disbursed by the Agency under the
eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has (60) days to make a decision after it
receives your application:. During that time, no foreclosure
proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by
the Pennsylvania Housing Finance Agency of its decision on your
application.
NdTE: IF Y017 ARE CURRENTLY PROTECTED BY THE FILING-OF A PETITION
IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY ANT) SHOULD NOT EE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency
Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT--- The MORTGAGE debt held by the above lender on
your property located at: 65 Derbyshire Dr Carlis
Carlisle IAA 17013
is SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following
months and the following amounts are now past due:
Regular monthly payments of $ 1059.62 for the months of
07-08-04 through today's date.
Other charges: Accrued late charges:$ 348,12
Accrued other fees: $ 18.00
TOTAL AMOUNT PAST DUE: $ 4616.72
CL 954
1 800 724 1633 - Correspondeme - P.O. Box 840, Buffalo, NY 14240-0840 • Payments- P_Q_ Box 1364, Buffalo, W 14240-1364
Mortgage account inforrmatron, just a dick away, www.mandtmortgage_com
NOV. 3.2004 8:40AM NO.9283 P. 5/14
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HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY
(30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT
PAST DUE TO THE LENDER, WHICH IS $ 4616.72, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE
THIRTY (30) DAY PERIOD. Payments must be made by cash, cashier's
check, certified check or money order made payable and sera to:
M&T Mortgage Corporation
One Fountain Plaza/ 7th Floor
Attn: Payment Processing
Buffalo, NY 14203
You can cure any other default by taking the following action
within THIRTY (30) Days of the date of this letter:
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default
within THIRTY (30) DAYS of the date of this Notice, the lender
intends to exercise its rights to accelerate the mortgage debt.
considered due immediately and you may lose the chance to pay the
mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action
to foreclosure upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will
be sold by the Sheriff to pay off the mortgage debt. If the
lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against
you, you will still, be required to pay the reasonable attorne 's
fees that were actually incurred, up to $50,00. However, if Yegal
proceedings are started against you, you will have to pay all
reasonable attorney's fees actually incurred by the lender even
if they exceed $50.00. Any attorney's fees will be added to the
amount you owe the lender, which may also include other reasonable
costs. If you cure the default within the THIRTY (30) DAY period,
you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES -- The lender may also sue your personally
for the unpaid principal balance and all other sums due under
the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have
not cured the default within the THIRTY (30) DAY period and
foreclosure proceedings have begun, you still have the right to
cure the default and prevent the sale at any time up to one hour
before the Sheriff's Sale. You may do so by paying the total
amount then past due, plus any late or other charges then due,
reasonable attorney's fees and costs connected with the foreclosure
sale and other costs connected with the Sheriff's Sale as specified
in writing by the leader and by performing any other requirements
under the mortgage. Curing your default in the manner set forth in
this notice will restore your mortgage to the same position as if
you had never defaulted.
1 800 724 1633 • Corrospondance - P.O. Bpx 840, Buffalo, NY 14240-0840 • Payments- P.O. Box 1364, Buffalo, NY 14240-1364
Mortgage account information, just a click away. www.mandtmortgage.com
NOV. 12004 8:40AM NO. 9283 P. 6114
Mortgage Corpmation
A SjWdiW a M9 EWA
EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the
earliest date that such a Sheriff's Sale of the mortgaged property
could be held would be approximately 10 months from the date of
this Notice. A notice of the actual date of,the Sheriff's Sale
will he sent to you before the sale. Of course, the amount
needed to cure the default will increase the longer you wait. You
may find out at any time exactly what the required payment or
action *ill be contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: M&T Mortgage Corporation
Address: P.O. Box 840
Buffalo, NY 14240
Phone Number: 800-724-1633
EFFECT OF SHERIFF'S SALE You should realize that a Sheiff's Sale
will end your ownership of the mortgaged property and your right
to occupy it. If you continue to live in the property after the
Sheriff's Sale, a lawsuit to remove you and your :furnishings and
other belongings could be started by the lender at any time,
ASSUMPTION OF MORTGAGE -- You may or XX may not
sell or transfer your home to a--Buyer or transferee who will assume
the mortgage debt, provided that all the outstanding payments,
charges and attorney's fees and costs are paid prior to or at the
sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO SORROW MONEY FROM ANOTHER LENDING INSTITUTION TO
PAY OFF THIS DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES
IN ANY CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Sincerely,
CL 955
Carol Schmidt
Enc : 43.
1 800 7241633 • Correspondance - P.O. Box 840, Buffalo, NY U240-0840 • Payments- P.O. Box 1364, Buffalo, NY 14240.1364
Moroage account infbimatim, just a ollak away, www.mandtmortgage.com
NOV. 3.2004 8: 41 AM NO. 9283 P. 7114
a[?
CUMBERLAND COUNTY
HEMAP Counseling Agency List as of 412812003
Adams County Housing Authority
139-143 Carlisle St.
Gettysburg, PA 17325
(717) 3344518
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
(717) 232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
(717) 762-3285
PHFA
2101 North Front Street
Harrisburg, PA 17110
800.342-2397
Urban League of Metropolitan Hbg
2107 N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
NOV. 3, 2004 8:41AM NO. 92$3 P. 8/14
Date:
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE,
This is an official notice that the mortgage on your home is in default, and the ]ender
intends to foreclose. Specific information about the nature of the default is provided i_n
the attached nags.,
The HONI7,OWNER'S MORTGAGE ASSISTANCE PROGRAIYI (.PIEMAP) may.be_.
Able to help to save your home. This Notice explains how the program works.
To see if IM; MAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITPIIN 30 DA'Y OF TI-IE_DATE OF THIS NOTICE.
Take this Notice with you when you meet with the Counseling Agency.
'The name, address. and-phone number of Consumer Credit Counseline A;encies
.serving your County are listed at the end of this Notice. If You have any guestions, you
may call the Pennsylv4nia Housine Finance Agency toll free at 1-8.00-342-2397.(Persorns
with impaired hearing can call (717) '78.0-18691.
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain
it. You may also want to contact an attorney in your area. The local bar association
may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUIVIA 1WORTANCIA, PUSS AFECTA
SU DERECRO A CONTZNUA.R VIVIENDO EN SU CASA. SI NO CONIPRENDE EL
CONTENID0 DE ESTA NOTIFICACION OBTENGA DNA TRA)DUCCION
INNMDITANMINTE LLA.M.ANDO ESTA AGENCIA (PENNS'YLVANIA, I-101iSING
FINANCE AGENCY) SIN CARGOS AL NUMERO 1y1ENCI0NADO AP.RJBA.
PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA,
LLANUDO "HOZYMOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM" EL CCJAL PUEDE SA.LVAR S.U CASA DE LA PERDIDA DEL
DERECHO A REI)IMIR SU HIPOTECA..
NOV. 3, 2004 8:39AM
NO, 9283 P, 2/14
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CASE NO: 2004-06126 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUS
VS
RUDA ALMEDA ET AL
RON KERR
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
RUDA ALMEDA M
the
DEFENDANT , at 1833:00 HOURS, on the 10th day of December-, 2004
at 65 DERBYSHIRE DRIVE
CARLISLE, PA 17013
by handing to
PAPER WAS PLACED ON PORCH PER JEFFERY BLACK, ADULT IN CHARGE
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
SHERIFF'S RETURN - REGULAR
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
3 .70 .00
y%r ..
10.00 R. Thomas Kline
.00
31.70 12/13/2004
GOLD13ECK MCCAFFERTY MCKEEVER
Sworn and Subscribed to before By
me this jp µJ day of
A. D.
rothonotary"
Z -,_ /?-
Deputy Sheriff
CASE NO: 2004-06126 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUS
VS
RUDA ALMEDA ET AL
RON KERR
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
RUDA JOSEPH S
was served upon
the
DEFENDANT , at 1833:00 HOURS, on the 10th day of December-, 2004
at 65 DERBYSHIRE DRIVE
CARLISLE, PA 17013
by handing to
PAPER WAS PLACED ON PORCH PER JEFFERY BLACK, ADULT IN CHARGE
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this 1,6 day of
?? wi?..e ?ZOD r A.D.
So Answers:
ww a: -?
R. Thomas Kline
12/13/2004
GOLDBECK MCCAFFERTY KCKEEVER
By: eputy Sheriff
?n ,per?`
P othonotary
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6321
Attorney for Plaintiff
MANUFACTURERS AND TRADERS TRUST
COMPANY S/B/M KEYSTONE FINANCIAL
BANK NA SB/M FARMERS TRUST
COMPANY
PO Box 840
Buffalo, NY 14240-0840
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
of Cumberland County
No. 04-6126
ALMEDA M. RUDA
JOSEPH S. RUDA
Mortgagors and Record owners
65 Derbyshire Drive
Carlisle, PA 17013
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended without prejudice upon payment of
your costs only.
JOSEPH A. GOLDBECK, JR., ESQUIRE
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