HomeMy WebLinkAbout05-1831
JANET L. GOLD, ESQUIRE (Equity One, Inc.)
Attorney J.D. #38100
EISENBERG, GOLD & CETTEI, P.c.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
EQUITY ONE, INC, D/B/A POPULAR! NO. 05' - IfJI C;u,LT8LYYl
FINANCIAL SERVICES, LLC !
301 Lippincott Drive, Suite 100 ! CIVIL ACTION - LAW
Marlton, New Jersey 08053
Plaintiff,
NOTICE TO DEFEND
vs.
VICTORB. STEZIN
98 CENTER ROAD
NEWVILLE, P A 17241
SUZANNE M. STEZIN
807 SOUTH MARKET
MECHANICSBURG, PA 17055
Defendant.
NOTICE
You have been sued in Court. If you
wish to defend against the claims set
forth in the following pages, you must
take action within twenty (20) days
after this Complaint and Notice are
served by entering a written
appearance personally, or by attorney,
and filing, in writing, with the court
your defenses or objections to the
claims set forth against you. You are
warned that if you fail to do so, the
case may proceed without you and a
Judgment may be entered against you by
the Court without further notice for
any money claimed in the Complaint or
for any other claim or relief
requested by the Plaintiff. You may
lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, P A 17013
(7 I 7) 240-6200
Lawyer Referral Service
4th Floor,
Cumberland County Courthouse
Carlisle, P A 17013
(717) 240-6200
JANET L. GOLD, ESQUIRE (Equity One, Inc.)
Attorney LD. #38100
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
EQUITY ONE, INC. D/B/A POPULAR: NO. 0 S' - / P 3{
FINANCIAL SERVICES, LLC !
30 I Lippincott Drive, Suite 100 : CIVIL ACTION - LAW
MarIton, New Jersey 08053 !
: COMPLAINT
ClUl ~~
Plaintiff,
vs.
VICTOR B. STEZIN
98 CENTER ROAD
NEWVILLE, PAl 7241
SUZANNE M. STEZIN
807 SOUTH MARKET
MECHANICSBURG, PA 17055
Defendant.
1. The Plaintiffis Equity One, Inc., a duly organized and subsisting corporation existing
under the laws of the State of Delaware, Mortgagee and which corporation maintains a principal
office at 400 Lippincott Drive, Marlton, NJ 08053.
2. The Defendant (s) Victor B. Stezin, Mortgagor and real owner of the premises
hereinafter described, whose address is 98 Center Road, Newville, PA 17241 and Suzanne M.
Stezin, Mortgage and real owner of the premises hereinafter described whose address is 807 South
Market, Mechanicsburg, PA 17055.
3. On the 22nd day of February, 2002, the Defendant made, executed and delivered a
Mortgage upon the premises hereinafter described to Equity One, Inc., Plaintiff which mortgage is
recorded on February 26, 2002 in the office for the Recording of Deeds of Cumberland County in
Mortgage Book 1750 Page 56 & c.
4. The premises subject to the said mortgage is fully described in Exhibit A which is
attached hereto, incorporated herein and made a part hereof. A copy of the Note and Mortgage are
attached hereto as Exhibit Band C.
5. On or about February 20, 2004, Plaintiff properly prepared a Notice ofIntention to
Take Action under Section 403 of Act #6 of 1974 (4 I Purden's Statutes, Section 403) and thereafter
on February 20, 2004 mailed the same to the Defendant(s) herein by Certified Mail, return receipt
requested in the Postal System of the United States. A true and correct copy of the aforesaid Notice
is attached hereto, made a part hereof and marked Exhibit D, said Exhibit representing compliance
with Pennsylvania Rule of Civil Procedure 1147 as to a cause of action in Mortgage Foreclosure.
6. The within Cause of Action in Mortgage Foreclosure was instituted more than thirty
(30) days following the forwarding to Defendant of Plaintiffs Notice ofIntention to Take Action
under Section 403 of Act #6 of] 974, supra, and in compliance with the requirements of said Section
of Act #6 of 1974.
7. On or about February 20, 2004, Notice under the Homeowners' Emergency Mortgage
Assistance Act, Act 91 of 1983 was given to Defendant herein by first class mail, postage prepaid,
together with a 3817 Certificate of Mailing. A true and correct copies of the Notice is made a part
hereof as Exhibit E.
8. The said mortgage is in default because all interest and principal became due on
August 22, 2003 and was not paid and the entire principal and all interest due thereon is collectible
forthwith.
9. The following amounts are due on the mortgage:
(a)
Principal
$256.591.50
(b)
Interest from 03/23/04 to 03/21/05
$ 20.236.49
(c)
Attorney's Commission
$ 3,500.00
(d)
Late charges
$ L296.56
(e)
Extension Fees
$ 2.717.50
TOTAL
$ 284.342.05
WHEREFORE, the Plaintiff demands Judgment against the Defendants for foreclosure and
sale of the mortgaged premises in the amounts due as set forth in paragraph 9, namely
$284.342.05 plus the following amounts accruing after 03/21/05 to the date of judgment:
(a) Interest of $60.58 per day;
(b) Late Charges of$90.87 per month;
(c) Tax and Insurance Advances plus interest at the legal rate allowed on
judgments after the date of judgment, additional attorneys fees (if any) hereafter incurred and costs
of suit.
EISENBERG, GOLD & CETTEI, P.C.
Attorneys for:
Equity One Inc., d/b/a
Popular Financial Services
BY9z'~
ET GOL, ESQUIRE
Dated: April 4, 2005
JANET L. GOLD, ESQUmE (Equity One, Inc.)
Attomey J.D. #38100
EISENBERG, GOLD & CETTEI, P.c.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
EQUITY ONE, INC. D/B/A POPULAR FINANCIAL! NO,
SERVICES, LLC
30 I Lippincott Drive, Suite 100 CTVTL ACTION - LAW
Marlton, New Jersey 08053
AFFIDAVIT
Plaintiff,
vs.
VICTOR B. STEZIN
98 CENTER ROAD
NEWVILLE, PA 17241
SUZANNE M. STEZIN
807 SOUTH MARKET
MECHANICSBURG, PA 17055
Defendant.
STATE OF NEW JERSEY
ss.
COUNTY OF BURLINGTON
\, '"",0",,,",'1 \ r<-'--i ,of full age, being duly sworn according
to law, upon his/her oath, deposes and says that:
I am the \ c, ,,<.., \\,',..\.\ ($'.\-' GY'\ \\\:.....f\G.."2 ( of Equity One, Inc., Plaintiff in the
foregoing, and I am authorized by said Corporation to make this Affidavit on its behalf, and state that
the facts set forth in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best
of my knowledge, information and belief.
/
--
SWORN TO AND SUBSCRIBED
B~RE ME THIS \ >t DAY ESMERALDA VIJIiJMEl
\..~/~ ~ aoTARYMUCCfBJIII5EY
U.;;.\. .' ,2005 CoIllmWonExplrlll1J.U8P
NOTARY )b~
"LEGAL DESCRIPTION"
ALL THAT CERTAIN tract of land situated in Upper Allen Township,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a point located on the eastern right of way line of South
Market street (50 foot right of way) at a common point with lands now
or formerly of Mechanicsburg Area Joint School System, thence from
said point, along said right of way, North 49 degrees 55 minutes 42
seconds West a distance of 8.28 feet to a point; thence along the
same, along a curve, curving to the right with a radius of 1121.18
feet, an arc distance of 160.00 feet to a point; thence along lands
now or formerly of Larry M. and Jean A. Roth, North 72 degrees 15
minutes 00 seconds East a distance of 201.84 feet to an iron pin;
thence along lands now or formerly of Mechanicsburg Area Joint School
System, South 16 degrees 46 minutes 00 seconds East a distance of
150.50 feet to a point; thence along the same, South 73 degrees 26
minutes 00 seconds West a distance of 119.59 feet to the point of
beginning.
Said area described containing 0.558 acres,
HAVING THEREON erected a two story frame dwelling and other invrovements.
\
BEING THE SAME PREMISES which Charlotte E. Hertzler, widow, by deed
dated October 27, 1994 and recorded October 31, 1994 in the Cumberland
County office of the Recorder of Deeds in Deed Book 114, Page 98
granted and conveyed to Victor B. Stezin and Suzanne M. Stezin,
husband and wife.
Amount: $271.750.00
Dated: F e b r u a r y 2 2. 2 0 0 2
Interest Only
Non-Revolving Construction Mortgage Note
ORIGINAL
This Non-Revolving Construction Mortgage Note (the "Note" ) is made between
M. STEZlN
VICTOR B. STEZJN and SUZANNE
(the" Borrower ") with an address of 8 0 7 SOU T H MAR K E T S T R E E T . M E C H A N I C S BUR G. P A 1 7 0 ~fid
Equity One. Jnc.. dba Popular Financial Services
(the" T,ender ") with an office located at 4 0 0 Lip pin cot t D r i v e. Mar 1 ton. N J 0 8 0 5 3
The word "Lender" means the original Lender and anyone else who takes this Note by transfer.
1. BORROWER'S PROMISE TO PAY PRINCIPAL AND INTERESf
1.1 In return for a loan that the Borrower received, the Borrower promises to pay the order of the Lender the sum of
Two Hundred Seventy One Thousand Seven Hundred Fifty Dollars
( $ 2 7 1 . 7 5 0 . 0 0 ) or if less, the total amount the Lender advances in accordance with the construction Loan
Agreement which the parties are signing even date herewith (the amount actually advanced hereinafter referred to as (the"
Principal ") together with Interest computed at tile fixed rate of E i 9 h tan dOn e I Hal f
( 8. 5 0 0 ) per annum, which Interest will be charged on that part of the
Principal which has not been paid from the date of this Note until all Principal has been paid computed on the basis of
actual days elapsed in a year of three hundred sixty (360) days uuless prohibited by law (the" Tnterest ").
1.2 Notwithstanding any provisions to the contrary contained herein, the Lender does not intend to charge, and the
Borrower shall not be required to pay any Interest or other fees or charges in excess of maximum pennitted by applicable
law. Any payments in excess of such maximum, at the election of the Lender, be refunded to the Borrower or credited
against Principal.
.
2. PAYMENT OF PRINCTPAL AND INTEREST
2.1 PAYMENTS
The Borrower shall pay all Interest which has accumulated and the Principal as follows:
2.1.1 Interest shall be paid by the Borrwer to the Lender monthly, the first monthly interest only payment
becoming due on Mar c h 2 2. 2 0 0 2 , and on the same day of each consecutive month
thereafter;
2.1.2 The unpaid balance of Principal and any Interest remaining upaid, together with all other sums due to
the Lender shall become due and payable on F e b r u a r y 2 2. 2 D D 3 .
2.2 The Borrower acknowledges that this Note is a Balloon Note, the Lender being under no duty or obligation to
renew or extend the maturity date of the Note.
.,
3. LATE CHARGE FOR OVERDUE PAYMENTS
3.1 In the event that any payment shall not be receivcd by the Lender within 1 5 days of the due date,
Borrower shall, to the extent pennitted by law, pay Lender a late charge of 5 . 0000 %
of the overdue payment (but in no event to be less than $25.00 nor more than $2,500.00). Any such late charge assessed is
immediately due and payable.
4. FULLPREPAYMENT
4.1 The Borrower may prepay the unpaid Principal at any time before it is due. This is known as full prepayment. No
penalties shall be charged. Interest shall be charged only to the date of the full prepayment.
5. PARTIAL PREPAYMENT \
5.1 The Borrower may prepay any part of the unpaid Principal before it is due. This is known as partial prepayment.
It may be made at any time. The Lender shall utilize the partial prepayment to reduce the Principal. Interest on the partial
prepayment shall be charged only to the date it is paid. No penalties shall be charged. A partial prepayment shall not
change the due dates of the payments.
6. PLACE OF PA YMENT
6.1 The Borrower shall make the, {lay,!,e~ts to. the order of the Lender at 400 Lipponeott Drive, MarIton, NJ 08053 or
8, ADDITIONAL SECURITY
8.1. As additional security, the Borrower has:
8. I. I. Execnted and delivered to the Lender: a Consluction Loan Agreement; Hazardous Substances
Certificate and Indemnity Agreement; Assignment of Permits and Approvals; Assignment of Architect's Plans and
Specifications: Assignment of Engineer's Plans and Specifications and Assignment of Agreement with Contractors':
(collectively the "Loan Documents" ); and
8.2. All of the tenns, covenants, provisions, conditions, stipulations and agreements contained in the aforesaid Loan
Documents and Guaranty are made a part hereof to the same extent and with the same force and effect as if they were fun
set forth herein.
9, DEFAULT - LENDER'S RIGTIT OF ACCELERATION
9.1. The Lender may declare the unpaid Principal and Interest hereunder due itnmediately upon the occurrence of
anyone or more of the following events of default (the "Events of Default"). They are:
9.1. I. The failure of the Borrower to make any payment of Principal and/or Interest under this Note or any
payment due under by other Loan Documents, within ten (10) days after its due date: or
9.1.2 Default by the Borrower in the performance of any of the other teOlls, conditions, promises and/or
covenants hereof, the Mortgage, Loan Documents, or any other security document executed in connection herewith; or
9.1.3. The insolvency of, appointmeot of an assignee for the benefit of creditors or receiver for, commission of
any act of bankruptcy hy, or the entry of a judgement against the Borrower, or a levy under a warrant of attachment,
execution or otherwise upon the credit, property or collateral held by the Lender, or in case any petition in backruptcy
shall be filed by or against the Borrower or any proceedings in bankruptcy or under acts of Congress or other
governmental authority relative to the relief of debtors should be commenced for the relief or re'adjustment of any
indebtedness of the Borrower or through reorganization, composition, extension or otherwise. The Borrower shall
not be deemed in default nor shall the Lender be entitled to acceleration in the event involuntary insolvency
proceedings are filed against the Borrower and said proceedings are dismissed within sixty (60) days of the date of
filing; or
9.1.4. ]f any certification, consent, v;tatement, warranty or representation made or hereafter made by the
Borrower to the Lender shall prove to be materially false; or
9. 1.5. The taking of possession of a substantial part of the Real Property at the instance of any office, agency,
department or other anthority of the federal or any state government; or
9.1.6. Default by Borrower in the performance of any term, covenant or promise in any agreement, note,
mortgage or loan document between Borrower and Lender not cured within any applicable cure period; or
9.2. In the occurrence of an Event 9f Default as specified in Section 9 of this Note, the Borrower must immediately
pay the full amount of any unpaid Principal and Interest, other amounts due on the Mortgage, this Note and the Loan
Documents, the Lender's costs of collection and reasonable attorney's fees.
9.3. Upon nonpayment of the Principal as its satcd or accelerated maturity, the Interest rate from the date of such
nonpayment shall be five perceut (5 %) per annnm above the Interest Rate as defined in Paragraph 1.1 of this Note.
9.4. The Lender's failure to accelerate for any cause shall not prevent the Lender from doing so for a later cause.
10. REMEDIES CUMULATIVE
10. I. The remedies hereunder and under the Mortgage, the Loan Documents and any and all other security
documents executed in connection with this loan providing for the enforcement of the payment of the Principal and Interest
set forth herein and for the performance ,of the covenants, conditions and agreements contained berein and all remedies
provided by law are cumulative and concurrent and may be pursued singly or successively or together at the sole discetioIJ
of the Lender and may be exercised as often as occasion therefore may occur.
11. WATVER OF FORMAL ACTS
ILL The Lender is not required to do any of the following before enforcing the Lender's rights hereunder:
11.1.1. Demand payment of amounts due known as "presentment":
11.1.2. Give notice that amounts due have not been paid known as "notice of dishonor"; and/or
11.1.3. Obtain an official certified statement showing non-payment known as a 'protest".
12, NO ORAL CHANGES
12.1. This Note can only be changed by an agreement in writing signed by both the Borrower and Lender.
13, W ATVER OF JURY TRIAL
13.1. Borrower and Lender, upon advice from their respective counsel, hereby intentionally, knowingly, voluntarily,
expressly and mutually waive the right to trial by jury of any claim, demand, action or canse of action (1) arising under this
Note or (2) in any way connected with or related or incidental to the dealings of the parties hereto or any of them with
respect to the Note or the loan transaction related hereto in each case whether now existing or hereafter arising and
whether in contract or tort or otherwise, flOd each party hereby agrees and consents that any such cJaim, demand, action or
cause of action shall be decided by court trial without a jury and that any party to the Note may file this original Note or a
copy thereof with any court as written evidence to the consent of the parties hereto to the waiver of their right to a trial by
iury.
with copies to:
If to the Lender:
with copies to:
Materials, information and correspondence other than notices required to be given by the Borrower or Lender may also be
sent by United States first class mail, postage prepaid, addressed as set forth above, and shall be deemed givcn on date
deposited in the United States Mail.
15. COMMITMENT
15.1 The terms and conditions of the Commitment Letter from the Lender to the Borrower dated
(the "Commitment Letter" ) are hereby incorporated by reference. The failure to comply with any of the terms and
conditions contained in said Commitment Letter shall constitute a default hereunder, and the entire unpaid Principal
indebtedness and all additions hereto and the Interest thereon at the option of the Lender shall become immediately due
and payable thereafter.
16. GOVERNING LAW
16.1 This Note and the rights and obligations of all parties hereto shall be subject to and governed by the laws of
New J e r 5 e y , without resort to issues concerning conflicts of law.
18, SIGNATURE
18.1 The Borrower agrees to the terms hereof by affixing his hand and seal hereto the day and year first above written.
WITNESS:
L-,
#";02- L.S.
Date
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;21f).~<<A-'s,
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L.S.
Dale
L.S.
Dale
CEllTiFfEDTO E3r,:'; .,~l!.e[ ,r,,~':f)
COPY OFTi'I!:: OFliGii'H,L.
CGR~H~
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1{A.)l ~~ li-'2.-1.5'-Db30- 02.3
.111is instrument was prepared by: MORTGAGE
Veronlca Kornsey
LN# 00295696
ORIGINAL
THIS MORTGAGE ("Securi!y Instrument") iSJ\iven on
VICTOR B. STEZIN and SULANNE M. STELIN
February 22, 2002
. The mortgagor is
("Borrower"). This Security Instrument is given 10 Equity One. Inc.. dba Popul ar Fi nancia 1 Services.
a Corporation
which is organized and existing under the laws of Pennsyl vani a
principal office and mailing address is 400 Li ppi ncott Dri ve. Ma r lton. NJ 08053
, and whose
("Lender"). Borrower owes Lender the principal sum of
Two Hundred Seventy One Thousand Seven Hundred Fifty and no/100
Dollars (U.S. $ 271.750.00 ).
This debt is evidenced by Borrower's note dated the same date ;IS this Security Instrument ("Nole"), which provides for
monthly payments, with the full debt, if nol paid earlier, due and payable on February 22. 2003 .
This Security Inslrument secures to Lender: (a) the repayment of the debt evidenced by lhe Nole, 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 of dlis Security Instrument; and (c) the performance of Borrower's covenants and agreements under this
Security Instrument and the Note, 111is Security Instrument and the Note secured hereby are subject to modification (including
changes in the interest rate, the due date, and other terms and conditions), as defined in New Jersey Laws 1985, ch. 353,
Section I el seq.. and upon such modification, shall have the benefit of the lien priority provisions of that law. The maximum
principal amount secured by lhis Security Instrument is $ 271.750.00 . For these purposes, Borrower does hereby
mortgage, grant and convey to Lender the following described property localed in
Cumber 1 and Counly, New Jersey:
SEE ATTACHED LEGAL DESCRIPTION
which has the address of 807 SOUTH MARKET STREET. MECHANICSBURG
New Jersey 17055 [ZipCodeI ("Property Address");
NEW JERSEY -Single Femily-FNMAlfHlMC
UNIFORM INSTRUMENT fo,m 3 1 9/90
G ~6RINJI196oBL02 Amen a/sa
P\\9" {!> 01 6 MW 0&'96.Q2 Inllllll,: "
VMf' MORTGAGE FORMS -18001521-7291\
lStreet. City],
11111111111111111111111111111111111
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 Secnrity
Instrument. All of the foregoing is referred to in this Security Instrument as the "Property."
BORROWER COVENANTS tbat Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage,
grant and convey the Property and that the Property is nnencumbered, except for encumbrances of rccord. Borrower warrants
and will defend generally the title to the Property against all claims and demands, subject to any encnmbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants witl, limited
variations by jurisdiction to constitute Il unifornl secnrity instrument covering real property.
UNIFORM COVENANTS. Borrower and Lender covenantllnd agree as follows:
1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shllll promptly pay when due the
principal of and interest on the debt evidenced hy the Note and any prepayment and late charges due nnder the Note.
2. I'unds for Taxes and Insurance, Subject to applicable law or to a written waiver by Lender, Borrower shall pay to
Lender on the day monthly payments are due under the Note, until the Note is paid in full, a sum ("Funds") for: (a) yearly taxes
. and assessments which may attain priority over this Security Instrument as a lien on the Property; (h) yearly leasehold payments
or ground rents on the Property, if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums,
if any; (e) yearly mortgage insurance premiums, if any; and (I) llDY sums payable by Borrower to Lender, in accordance with
the provisions of paragraph 8, in lieu of the payment of mortgage insurance premiums. These items are called "Escrow Items."
Lender may, at any time, collect and hold Funds in an amount not to exceed the maximnm amount a lender for a federally
related mortgage loan may require for Borrower's escrow account under the federal Real Estate Settlement Procedures Act of
]974 as amended from time to lime, ]2 U.S.C. Section 2601 el seq. ("RESPA"), unless another law that applies to the F\1llds
sets a lesser amount. If so, Lender may, at any time, collect and bold Fnnds in an amount not to exceed the lesser amonnt.
Lender may estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of fulure
Escrow Items or otherwise in accordance with applicable law.
The Funds shall he held in an institution whose deposits are insured hy a federal agency, instrumentality, or entity
(including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the
Escrow Items. Lender may not charge Borrower for holding and applying the Funds, arulUally analyzing the escrow account, or
verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make such
a charge. However, Lender may require Borrowcr to pay a one-time charge for an independent real estate tax reporting service
used by Lender in connection with this loan, unless applicable law provides otllerwise. Unless an agreement is made or
applicable law requires iuterest to be paid, Lender sh,ll not be required to pay Borrower any interest or eamings on the Funds.
Borrower and Lender may agree in writing, however, that interest shall be paid on !lIe Funds. Lender shall give to Borrower,
without charge, an annual accounting' of the Funds, showing credits and debits to the Funds and the purpose for which each
debit to the Funds was made. The Funds are pledged as additional security for all sums secured by this Security Instrument.
If the Funds held by Lender exceed lhe amounts penrutted to he held by applicable law, Lender shall acconnt to Borrower
for the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Lender at any
time is not sufficient to pay the Escrow Items when due, Lender may so notify Borrower in writing, arid, in such case Borrower
shall pay to Lender the amount necessary to make up the deficiency. Borrower shall make up the deficiency in no more than
twelve monthly payments, at Lender's sole discretion.
Upon payment in full of all sums secured hy this SecJ1fity Instrument, Lender shall promptly refund to Borrower any.
Funds held by Lender. If, under paragraph 21, Lender shall acquire or sell the Property, Lender, prior to the acquisition or sale
of the Property, shall apply any Funds held by Lender at the time of acquisition or sale as a credit against tile sums secured by
this Security Instrument.
3. Application of Payments, Unless applicable law provides otherwise, all payments received by Lender under paragraphs
I and 2 shall be applied: first, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2;
third, to interest due; fourth, to principal due; and last, to any late charges due under the Note.
4, Charges; Liens, Borrower shall pay all taxes, assessments, charges, fines and impositions attributable to the Property
wl,ich may attain priority over this Security Instrument, and leasehold payments or ground rents, if any. Borrower shall pay
these ohligations in the manner provided in paragraph 2. or if not paid in that manner, Borrower shall pay them on time directly
to the person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid uuder this paragraph.
If Borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts evidencing tile payments.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in
writing 10 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 Properly is subject to a lien which may attain priority over
this Security Instrument, Lender may give Borrower a notice identifying tile lien. Borrower shall satisfy the lien or take one or
more of Ihe actions set fOl1h ahove within 10 days of the giving of notice. ~
Initials;
tQ ~6RINJJ (96081.02 P9\}6 2 of 6 Form 3031 9/90
...
5. Hazard or Property Insurance. Borrower,shall keep the improvements now existing or hereafter erected on lhe
Property insured against loss by flre, hazards included within the term "extended coverage" and any other hazards, including
floods or flooding, for which Lender requires insurance. This insurance shall be maintained in lhe amounts and {or the periods
that Lender reqnires. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's approval
which shall not be unreasonably withheld. Jf Borrower fails to maintaio coverage described above, Lender may, at Lender's
option, obtain coverage to protect Lender's rights in the Property iu accordance with paragraph 7.
All illsurance policies and renewals shall be acceplable to Lender and sl,a11 include a standard mortgage clause. Lender
shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts of
paid premiums and renewal notices. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender.
Lender may make proof of loss if not made promptly by Borrower.
Unless Lender and Borrower othelWise agree in writing, insnrance proceeds shall be applied to restoration or repair of the
Property damaged, if the restoration or repair is economically feasible and Lender's security is not lessened. If thc restoration or
repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums
secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. If Borrower abandons the
Property, or does not answer within 30 days a notice from Lender tbat the insurance carrier has offered to settle a claim, then
Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums
secured by this Security Instrument, whether or not then due. The 3D-day period will begin when the notice is giveu.
Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or
postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the amount of the payments. If
nnder paragraph 21 the Property is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting from
damage to tbe Property prior to the acquisition shall pass to Lender to the extent of the snms secured by this Security Instrument
immediately prior to the acquisition.
6, Occupancy, Preservation, Mainrennnce and Protection of the Property; Borrower's Loan Application;
Leaseholds, Borrower shall oecupy, establish, and use the Property as Borrower's principal residence within sixty days after the
execution of tbis Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one
year after the date of occupancy, unless Lender othelWise agrees in writing, which consent shall not be unreasonably withheld,
or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or impair
the Property, allow the Property to deteriorate, or conunit waste on the Property. Borrower shall be in defanlt if any forfeiture
action or proceeding, whether civil or criminal, is begun that in Lender's good faitll judgment could result in forfeiture of the
Property or othelWise materially impair the lien created by this Security Instrument or Lender's security interest. Borrower may
cure such a default and reinstate, as pr9vided in paragraph IS, by causing the action or proceeding to be dismissed with a ruling
that, in Lender's good faith determination, precludes forfeiture of the Borrower's interest in the Property or other matcrial
impairment of the lien created by this Security Instrument or Lender's security interest. Borrower shall also be in default if
Borrower, during the loan application process, gave materially false or inaccurate Infonnation or statements to Lender (or failed
to provide Lender with any material information) in connection Wilh the loan evidenced by the Note, including, but not limited
to. representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a
leasehold, Borrower sl,all comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the
leasehold and the fee title shall not merge unless Lender agrees to the merger in writing.
7, Protection of Lender's Rights in the Property. If Borrower fails to perform the covenants and agreements contained itl
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, probate, for condemnation or forfeiture or to enforce laws or regulations), then Lender may do and
pay for whatever is necessary to protect the value of the Property and Lender's rights in the Property. Lender's actions may
include paying any sums secured by a lien which has priority over this Security Instrument, appearing in court, paying
reasonable attorneys' fees and entering on the Property to make repairs. Altbough Lender may take action under this paragraph
7, Lender does not have to do SQ.
Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this
Security Instrument. Unless Borrower and Lender agree to other tenus of payment, these amounts shall bear interest from the
date of disbursement at the Note rate and shall be payable, with interest, upon notice from Lender to Borrower requesting
payment.
S, Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan secured by this Security
Instrument, Borrower shall pay the premiums required to maintain the mortgage insurance. in effect. If, fnr any reason, the
mortgage insurance coverage required by Lender lapses or ceases to be in effect, Borrower shall pay the preminms required to
obtain coverage substantially equivalent to the mortgage insurancc previously in effect, at a cost substantially equivalent to the
cost to Borrower of the mortgage insurance previously in effect, from an alternate mortgage insurer approved by Lender. If
substantially equivalent mortgage insurance coverage is not available, Borrower shall pay to Lender each month a sum equal to
one-twelfth of the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or eeased to
be in effecl. Lender will accept, use and retain these payments as a loss reserve in lien of mortgage insura~e. Loss reserve
lJ1ltlal&:~
~ ~6AINJI {96081.02 Pega3 of 6 form 3031 9/90
..
payments may no longer be required, at the option of Lender, if mOrlgage insurance coveraW' (in the amount and [or the period
that Lender requires) provided hy an insurer approved by Lender again becomes available and is obtained. Borrower shall pay
the premiums required to maintain mortgage insurance in effect, or to provide a loss reserve, until the reqnirement for mortgage
insurance ends in accordance with any written agreement between Borrower and Lender or applicable law.
9. Inspection. Lender or its agent may make reasonable entries upon and inspections uf the Property. Lender shall give
Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection.
10. 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 lieu of condemnation, are hereby assigned and
shall be paid to Lender.
In the event of a total taking of the Properly, the proceeds shall be applied to the sums secured by this Secnrity Instrument,
whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair
market value of the Property immedi'ately before the taking is equal to or greater than the amount of the sums secured by this
Security Instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by
this Security Instrument shall he reduced by the amount of the proceeds multiplied by the following fraction: (a) Ule total
amount of the sums secured immediately before the taking, divided by (b) the fair market value of the Properly immediately
before the taking. Any balance shall be paid to Borrower. In the event of a partial taking of the Properly in which the fair
market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the
taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall
be applied to the sums secured by this Security Instrument whether or not the sums are then due.
If the Property is abandoned by Borrower, or if, after notice hy Lender to Borrower that the condemnor offers to make an
award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given,
Lender is authorized to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums
secured by this Security Instrument, whether or not then due.
Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or
postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the amount of such payments.
11, Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for 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 Borrower's successors in interest. Lender sllall not be required to
commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amorlization
of the sums secured by this Security Instrument by 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, Successors and Assigus Bound; Joint and Several Liability; 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 17. 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 couvey that
Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally ohligated to pay the sums
secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or
make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent.
13. Loun Charges. If the loan secured by ulis Security Instrument is subject to a law which sets maximum loan charges,
and that law is finally interpreted so that Ule interest or other loan charges collected or to be collected in connection with the
loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce ule charge
to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to
Borrower. Leuder may choose to make this refund by reducing the principal owed under the Note or by making a direct
payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment WitllOut any
prepaymeut charge under the Note. \
14. Notices. Any notice to Borrower provided for in this Seenrity Instrument shall be given by dclivering 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 other address Lender designates by notice to Borrower. Any notice provided for in this
Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph.
15. 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 severahle.
16, Borrower's Copy. Borrower shall be given one conformed copy of the Nute and of this Security Ins~;ellt.
Inll'~!s' ~
~~6R(N"')t9608102 PIIge4of6 'orm3031 9/90
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17. Transfer of the Property or a Beneficial Interest in Borrower, If all or any part of the Property or any interest in it
is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without
Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this
Security Instrument. However, tbis option shall not be exercised by Lender if exercise is prohibited by federatlaw as of the date
of this Security Instrument.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of nor
less than 30 days from tbe date the notice is delivered or mailed within which Borrower must pay all sums secured by this
Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies
permitted by this Security Instrument without further notice or demand on Borrower.
18. Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower shall have the rigbt to have
enforcement of this Security Instrument discontinued at any time prior to ~le earlier of; (a) 5 days (or snch other period as
applicable law may specify for reinstatement) before sale of the Property pursuant to any power of sale comained in this
Security Instrument; or (b) entry of a judgment enforcing ~Iis Security Instrument. Those conditions are that Borrower: (a) pays
. Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b)
cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument,
including, but not limited to, reasonable a\torneys' fees; and (d) takes such action as Lender may reasonably require to assure
that the lien of this Security Instrument, Lender's rigbts in the Property and Borrower's obligation to pay the sums secured by
this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the
obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall
not apply in the case of acceleration under paragrapll 17.
19. Sale of Note; Change of Loan ServiceI'. The Note or a partial interest in lhe Note (together wilh this Security
Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (known
as the" Loan Servicer") that collects monthly payments dne WIder the Note and this Security Instrument. There also may be ooe
or more changes of the Loan ServiceI' unrelated to a sale of the Nole. If there is a change of the Loan Servieer, Borrower wiil be
given wri\ten notice of the change in accordance Witll paragraph 14 above and applicable law. The notice wiil state the name and
address of the new Loan ServiceI' and the address to whicb payments should be made. The notice wiil also contain any other
infonnalion required by applicable law,
20, Hazardous Substances. Borrower shall not cause or pennit 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, anyUling affecting the
Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to lhe presence, use, or
storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to nonual
residential uses and to mainteuance of the Property.
Borrower shall promptly give Lender wrillen 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 which Borrower bas actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that
any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promp~y take
all necessary remedial actions in accordance with Environmental Law.
As used in tilis paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous substances by
Environmental Law and the following suhstances: gasoline, kerosene, olher flammable or toxic petroleum products, toxic
pesticides and herbicides, volatile solvents, materials containing asbeslos or fonnaldehyde, and radioactive materials. As used in
this paragraph 20, "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 agree as follows:
21. Acceleration; Remedies, Lender shall give notice to Borrower prior 10,acceleration following Borrowel"s breach
of any covenant or agreemenl in this Security Instrument (but not prior to' acceleration under paragraph 17 unless
applicable law provides otherwise), The notice shall specify: (a) the default; (b) the action required to cure the default;
(c) a date, not less than 30 days from the date tbe notice is given to Borrower, by wbicb the default must be enred; and
(d) that failure to cnre the default au or before Ihe date specified in the notice, may resnlt in aeeeleration of the sums
secured by tbis Security Instrument, foreclosure by judicial proceeding amI sale of the Property. TIle noliee shall further
inform Borrower of the right to reinstate after acceleratiou and Ihe right to assert in the foreclosure proceeding the
non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured on
or before the date specified in the notice, Lender, at its option, may require immediate payment in fnll of all sums
secured by this Security Instrument without fnrther demand and may foreclose this Security Instrument by jndicial
proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph
21, including, bnt not limited to, attorneys' fees and costs of tille evidence permitted by Rules of Court.
ll. ""~.. 0""" ,.,""", ",". - """red b, .. S=;, --. ""d. ..." ~"'" <b. f~''''"''''~'
without charge to Borrower. Borrower shall pay any recordation costs.
mtt\9Is.
. .6RINJ) 19608102 Page 5 or 6 Form 3031 9/90
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23, No Claim of Credit for Taxes, Borrower will not make deduction from or claim credit on the principal or interest
secured by this Security Instrument by reason of any governmental taxes, assessments or charges. Borrower will not claim any
deduction from the taxable value of the Property by reason of this Security Instrument.
24, Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this
Security InStrument, the covenants and agreements of each suclt rider shall be incorporated into and shall amend am! supplement
the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument.
[Check applicable box(es)]
D Adjustable Rate Rider
D Graduated Payment Rider
D Balloon Rider
D VA Rider
D Condominium Rider
D Planned Unit Development Rider
D Rate Improvement Rider
UJvther(s) [specifYI L~....L-
01-4 Family Rider
o Biweekly Payment Rider
D Second Home Rider
BY SIGNING BELOW, Borrower accepts and agrees to tlte te
in any rider(s) executed hy Borrower and recorded with it.
S' aled and delivered in the presence of:
d covenants co tained in this Security Instmment and
1...-.---
(Seal)
Ie 0
-Borrower
~_~AW .iliJ
SUZA NE M. STE I
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(Seal)
-Borrower
(Seal)
(Seal)
-Borrower
~Borrower
STATEOF~~~~J~~l\.Lc.... @
0-U-m~
County ss:
On this day of
VICTOR B. STEZIN and SUZANNE M. STEZIN
, before me, the subscriber, personally appeared
who. r am satisfied)
tlley
are the person(s) named in and who executed the with'
signed. sealed and delivered the same as thei r
..c.........\
l Nolarial Seal
Suzanne L_ Cramer, Notary Pl.lblic
Hampden Twp., Cumberland COl.J~lty
My Commission Expires May 20, L~()~:.._,.
t-iiember, P\:nM)'lvania. A5socia\ion orNota\'\es
4Q ~6RINJ1196081.02
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Form 3031 9/90
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SENDER: COMPLETE TH(S SECTION
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. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can retum the card to you.
. Attach this card to the back of the mailpiece.
or on the front if space permits.
1. AnitJe Addressed to; ,
A. Signature
3. Servl
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4. Restricted Delivery? (Extra Fee) DYes
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CERTIFIED MAIL RECEIPT
(DomestIc Mall Only; No Insurance Coverage ProvIded)
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E1SENBERG. GOLD & CETTEr
A PROFESSTONAL CORPORUION
~~~d ~p
NINE TANNER STREET, WEST ENTRY
HADDONFIELD. NEW JERSEY 08033
W1LLlAM V, EISENBERG.
JANET L GOLD"
DO;-.JNA L CETTEJ '"
(856)795-0351
FAX {856J429-.'l272
jgold@egclawfirrn.com
"'MEMBER NJ AND PA BAR
. RljLE ] :40 APPROVED MEDIA TOR
February 20, 2004
File No. EF-503-G
CERTIFIED MAIL. R.R.R.
AND FIRST CLASS MAIL
Victor B. Stezin
807 South Market Street
Mechanicsburg, P A 17055
RE: Equity One, Inc. v. Victor B. Stezin and Suzanne M. Stezin
Act 91
Notice to Take Action to Save Your
Home From Foreclosure
COMBINED ACT 6/ ACT 91 NOTICE
This is an official notice that the mortgal!e 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 paees.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to
help to save your home. This Notice explains how the prOl!ram works.
To see if HEMAP can helD. yOU must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice
with vou when yOU meet with the Counseling Agencv.
The name, address and phone number of Consumer Credit Counseling
Agencies serving your County are listed at the eud of this Notice. If yOU have any
Questions. yOU may call the Pennsylvania Housing Finance Agencv toll free at
1-800-342-2397.(Persons with irnpaired 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 an attorney in your area. The local bar association may be
able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTIl\'UAR VIVIENDO EN SU CASA. SI NO COMPRE)','DE EL CONTENlDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDlTAMENTE LLAMANDO EST A AGENClA
(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
SAL V AR SU CASA DE LA PERDlDA DEL DERECHO A REDlMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Victor B. Stezin and Suzanne M. Steziu
807 South Market S1., Mechanicsburg, P A 17055
N/A
Equity One, Inc.d/b/a Popular Financial Services
Equity One, Inc. d/b/a Popular Financial Services
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 ELIGIBLE FOR EMERGENCY
"'IORTGAGE 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-face" meeting with one of the consumer
credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR
WTTHIN 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 - 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 telephone
numbers of designated consurner credit counseling agencies for the county 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,
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 posunarked 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 DENTED.
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 Pelllisylvania 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 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: 807 South Market Street, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT
because:
A. You HAVE NOT MADE THE FINAL MORTGAGE PAYMENT under the loan and the
following amounts are now past due: Loan matured August 2 2,2003: Principal
$256,591.50; Interest on Principal $9,313.16; Late Charges $465.68; Extension Fees
$679.38; Processing Fee $25.00.
TOTAL AMOU!'IT PAST DUE: $267,074.72 as of 2/22/04 with a per diem of $60.58.
B. You HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot applicable):
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
$267,074.72, plus any interest payments and late charges which become due during the thirty
(30) day period. Payrnents must be made either by cash. cashier's check. certified check or
money order made payable and sent to: Equity One, Inc., 400 Lippincott Drive, Marlton, NJ
08053, Attn: David Cyhan.
IFYOUDONOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30)DA YS
of the 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 be
considered due immediately. If fuII 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.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the
Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you
cure the delinquency before the lender begins legal proceedings against you, you will still be
required to pay the reasonable attorney's fees that were actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actualIy incurred by the lender even if they exceed $50.00. Any attorney's fees
wiII 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 you personally for the unpaid principal
balance and all other surns due under the mortgage.
RIGHT TO CURE THE DEF AUL T PRIOR TO SHERIFF'S SALE - If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you stili 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
performing any other requirements under the mortgage. Curing your default in the manner
set forth in this notice will pay off your mortgage.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estirnated that the earliest date that such
a Sheriffs Sale of the mortgaged property could be held would be approximately eight (8)
months from the date ofthis Notice. A notice of the actual date of the Sheriffs Sale will
be sent to you before the sale. Of course, the amount needed to cure the default will increase
the longer you wait. You may find out at any time exactly what the required payment or
action will be by contacting the lender.
How TO CONTACT THE LENDER:
Name of Lender:
Address:
phone Number:
Fax Number:
Contact Person:
Equity One, Inc. d/b/a Popular financial Services
301 Lippincott Drive, Suite 100, Marlton, New Jersey 08053
(856) 396-2600, ext. 3695
(856) 396-2737
David Cyhan
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your
ownership of the mortgaged property and your right to occupy it. If you continue to live
in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and
other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You _ mayor --X- may not (CHECK ONE) 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 OBTATN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PA Y OFF THIS
DEBT.
To HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
To HAVE THE MORTGAGE RESTORED TO THE SAME POSmON AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THlS 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 LA WSUlT INSTlTUTED 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.
SEE ATTACHED CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
Very truly yours,
EISENBERG, GOLD & CETTEI
JANET L. GOLD, ESQUlRE
JLG:mw
Enclosure
. . .
.
. Complete items 1.2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailplece,
or on the front if space permits.
1:. .Article Addressed to:
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PS Fonn 3811, August 2001 Domestic Retum Receipt 102595-02-M-1S4{
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CERTIFIED MAIL RECEIPT
(DomestIc Mad Only; No Insurance Coverage Provided)
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EISEl\1BERG. GOLD & CETTEI
A PROFESSIONAL CORPORA nON
YIlm[/nd~ d ~
NINE TANNER STREET, WEST ENTRY
HADDONFIELD. NEW JERSEY 08033
W1LLlAM v. EISENBERG.
Jf\NETL GOLD *
DONNA L. CETTEI '"
(8561795-035]
FAX: (856)429-5272
Jgold@egclawnrm,com
*MEMBER N1 AND PA BAR
tRULE 1 :40 A.PPROVED MEDIATOR
February 20, 2004
File No. EF-503-G
CERTIFIED MAIL. R.R.R.
AND FIRST CLASS MAIL
Suzanne M. Stezin
807 South Market Street
Mechanicsburg, PAl 7055
RE: Equity One, Inc. v. Victor B. Stezin and Suzanne M. Stezin
Act 91
Notice to Take Action to Save Your
Home From Foreclosure
COMBINED ACT 6/ ACT 91 NOTICE
This is an official notice that the mortgage on your home is in default. and the
lender intends to foreclose. Specific information about the nature of the default is
provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to
help to save vour home. This Notice explains how the program works.
To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice
with yOU when YOU meet with the Counseling A2ency"
The name, address and Ilhone number of Consumer Credit Counseling
Agencies servin!:! your County are listed at the end of this Notice. If vou have any
questions, you may call the Pennsylvania Housing Finance A!:!encv 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 an attorney in your area. The local bar association may be
able to help you find a lawyer.
LA NOTIFICAClON 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 INMEDTTAMENTE LLAMANDO ESTA AGENClA
(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.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Victor B. Stezin and Suzanne M. Stezin
807 South Market St., Mechanicsburg, P A 17055
N/A
Equity One, Inc.d/b/a Popular Financial Services
Equity One, Inc. d/b/a Popular Financial Services
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 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-face" meeting with one of the consumer
credit counseling agencies listed at tlle end of this Notice. THIS MEETING MUST OCCUR
"'lTHIN 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 - 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 tlle date of this meeting. The names, addresses and telephone
numbers of designated consumer credit counseling agencies for the county in which the
propertv 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 immediatelv 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 namre
of your default.) If you have tried and are unable to resolve this problem with the lender,
you have the right to apply for financial assistance from the Homeowner's 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 PelU1sylvania Housing Finance Agency. Your
application MUST be filed or postmarked within thirty (30) days of your face-to-face
meeting.
You MUST FILE YOUR APPLICA TION 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 IMMEDIA TEL Y 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 PelU1sylvania 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 Pelillsylvania 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 AJ\l) SHOULD NOT BE 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).
NA HiRE OF THE DEF AUL T - The MORTGAGE debt held by the above lender on your property
located at: 807 South Market Street, Mechanicsburg, PA 17055 IS SERI01.;SLY IN DEFAULT
because:
A. You HAVE NOT MADE THE FINAL MORTGAGE PAYMENT under the loan and the
following amounts are now past due: Loan matured August 22, 2003: Principal
$256,591.50; Interest on Principal $9,313.16; Late Charges $465.68; Extension Fees
$679.38; Processing Fee $25.00.
TOTAL AMOUNT PAST DUE: $267,074.72 as of 2/22/04 with a per diern of$60.58.
B. You HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable):
How TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$267,074.72, plus any interest payments and late charges which become due during the thirty
(30) day period. Pavments must be made either bv cash. cashier's check. certified check or
money order made pavable and sent to: Equity One, Inc., 400 Lippincott Drive, Marlton, NJ
08053, Attn: David Cyhan.
IFYOUDONOTCURE 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. This means that the entire outstanding balance of this debt will be
considered due immediately. 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.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the
Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you
cure the delinquency before the lender begins legal proceedings against you, you will still be
required to pay the reasonable attorney's fees that were actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even ifthey 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 lenderrnay also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THEDEF AULT PRIOR TO SHERIFF'S SALE ~ If you have not cured the default
within the THIRTY (30) DA Y 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
perfonning any other requirements under the mortgage. Curing your default in the manner
set forth in this notice will pay off your mortgage.
EARl~IEST 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 eight (8)
months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will
be sent to you before the sale. Of course, the amount needed to cure the default will increase
the longer you wait. You may find out at any time exactly what the required payment or
action will be by contacting the lender.
How TO CONTACT THE LENDER:
Name of Lender:
Address:
Phone Number:
Fax Number:
Contact Person:
Equity One, Inc. d/b/a Popular Financial Services
301 Lippincott Drive, Suite 100, Marlton, New Jersey 08053
(856) 396-2600, ext. 3695
(856) 396-2737
David Cyhan
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your
ownership of the mortgaged property and your right to occupy it. If you continue to live
in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and
other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You _ mayor -X- may not (CHECK ONE) 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 PAYOFF 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.
SEE ATTACHED CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
Very truly yours,
EISENBERG, GOLD & CETTEI
JANET L. GOLD, ESQUIRE
JLG:mw
Enclosure
Homeowners' Emergency Assistance Program
Counseling Agency List for CUMBERLAND COUNTY as of 4/18/01
ADAMS COUNTY HOUSING AUTHORITY
139-143 Carlisle St.
Gettysburg, PAl 7325
(717) 334-1518
CCCS OF WESTERN P A
2000 Linglestown Road
Harrisburg, P A 17 I 02
(717) 541-1757
COMMUNITY ACTION COMMISSION OF CAPITAL REGION
15 14 Derry Street
Harrisburg, P A 17104
(7 I 7) 232-9757
FINANCIAL COUNSELING SERVICES OF FRANKLIN
31 West 3rd Street
Waynesboro, P A 17268
(717) 762-3285
LOVESHIP, INC.
2320 North 5th Street
Harrisburg, P A 171 10
(717) 232-2207
URBAN LEAGUE OF METROPOLITAN HaG
2107 N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
Homeowners' Emergency Assistance Program
Counseling Agency List for CUMBERLAND COUNTY as of 4/18/01
ADA:\IS COUNTY HOUSING AUTHORITY
139-] 43 Carlisle St.
Gettysburg, P A 17325
(717) 334-1518
CCCS OF WESTER. "I P A
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
COMMUNITY ACTlOi\! COMMISSION OF CAPITAL REGION
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
FINANCIAL COUNSELI:'I'G SERVICES OF FRANKLIN
3 I West 3rd Street
Waynesboro, PAl 7268
(717) 762-3285
LOVESHlP, INC.
2320 North 5th Street
Harrisburg, PAl 711 0
(717) 232-2207
UREA:\' LEAGUE OF METROPOLITAN REG
2107 N. 6th Street
Harrisburg, P A 171 0 1
(717) 234-5925
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2005-01831 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
EQUITY ONE INC
VS
STEZIN VICTOR B ET AL
R. Thomas Kline ,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
STEZIN SUZANNE M
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, STEZIN SUZANNE M
807 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
DEFENDANT IS BELIEVED TO BE LIVING WITH HER MOTHER
AT 11361 CASASTRANO COURT FORT MYERS, FL 33908.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
6.00
.00
5.00
10.00
.00
21.00
So answers: /
---
~-:::/::;r_ "-'>-"'f--''' /,,__,..-:-::.-._..r
---JZ::-.< -:.~ / r:~. / ..... ,-'..-
~--.~l/" ~,~:.:;;~~'~~".'-
R. Thomas Kllne
Sheriff of Cumberland County
EISENBERG GOLD CETTEI
04/12/2005
Sworn and subscribed to before me
this
"-,
H~
day of ~J
;2.('IJ5 A.D.
Q -
~<t;<--- }Z'l 1.l)t7H~
Pr th notary
..~
r
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-01831 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
EQUITY ONE INC
VS
STEZIN VICTOR B ET AL
RONALD HOOVER
Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
STEZIN VICTOR B
the
DEFENDANT
, at 1116:00 HOURS, on the 11th day of April
2005
at 98 CENTER ROAD
NEWVILLE, PA 17241
by handing to
PATRICIA STEZIN, MOTHER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
8.14
.00
10.00
.00
36.14
,/'/ / //
,~' ;:?~-1~
R. Thomas Kline
04/12/2005
EISENBERG GOLD CETTEI
Sworn and Subscribed to before
By:
l~~
Deputy Sheriff
/h'1'.
l~)t~<- e }7u1~, #
rot onotary
ISE:
JU(;J!
day of
me this
A.D.
JANET L. GOLD, ESQUIRE
Attorney 1.0. #38100
EISENBERG, GOLD & CETTEI, P,C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
EQuITY ONE, INC. D/B/A POPULAR i NO. OJ- 1!j3/ Clvl
FINANCIAL SERVICES, LLC
301 Lippincott Drive, Suite 100 i CIVIL ACTION - LAW
Maritan, New Jersey 08053
Plaintiff,
vs.
PRAECIPE TO REINSTATE
COMPLAINT
VICTOR B. STEZIN
98 CENTER ROAD
NEWVILLE, P A 17241
SUZANNE M. STEZIN
807 SOUTH MARKET
MECHANICSBURG, PA 17055
Defendant.
TO THE PROTHONOTARY:
Kindly reinstate the complaint in the above entitled matter.
EISENBERG, GOLD & CETTEI, P.c.
Attorneys for Plaintiff
By ~,JJ.. , \ 0
J C;o~~
Dated: May 17, 2005
---------/-
c.-.,
"":'"<'
JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Attorney 1.0. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P A
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A POPULAR i NO. 05-1831
FINANCIAL SERVICES, LLC
IN MORTGAGE FORECLOSURE
Plaintiff,
vs.
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
AFFIDAVIT OF SERVICE PURSUANT TO RULE PA.R.C.P. 404
STATE OF NEW JERSEY
ss.
COUNTY OF CAMDEN
Janet L. Gold, Esquire, being duly sworn according to law, upon her oath, deposes and says
that:
1. I am an attorney at law in the Commonwealth of Pennsylvania and I am familiar with
the facts set forth herein.
2. The Defendant, Suzanne M. Stezin, whose last known address, according to Plaintiffs
records is 807 South Market Street, Mechanicsburg, PA 17055.
3. Attempts to serve said Defendant at the last known address resulted in the Sheriff
being unable to serve the Defendant, Suzanne M. Stezin. The Sheriffs Affidavit of Service notes
"Defendant is believed to be living with her mother at 11361 Casastrano Court, Fort Myers, FL
33908. A copy of the Affidavit of Service is artached hereto and made a part hereof as Exhibit A.
An investigation has been made to determine the whereabouts of the Defendant and the reasons
why service cannot be made.
4. On May 17, 2005, I ran a PostalInquiry Search on the Defendant, Suzanne M. Stezin
inquiring as to the defendants current address as 11361 Capistrano Ct., Fort Myers, FL 33908-4034.
The search was returned to me showing the Fort Myers, FL address "good as addressed". A copy of
the Postal Inquiry is attached hereto and made a part hereof as Exhibit B.
5. On May 24, 2005, I served by regular and certified mail, restricted delivery, a copy
of the Notice to Defend and Complaint in Mortgage Foreclosure upon the Defendant, Suzanne M.
Stezin. The certified mail return receipt was returned signed by Suzanne Stezin on May 28,2005. A
copy of the executed green card is attached hereto and made a part hereof.
6. More than 15 days have passed since the mailing of the regular mail.
7. Based on the foregoing inquiries, I am satisfied and convinced that the defendant(s),
Suzanne M. Stezin, cannot be personally served in the State of Pennsylvania and it is my personal
knowledge and belief that the defendant(s), Suzanne M. Stezin, resides at 11361 Capistrano Court,
Fort Myers, FL 33908-4034.
\~~\}-
JANET . OLD, QUIRE
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 21st DAY
OF June, 2005.
~~.
~..\;1'O
~
DIll I€. MOUDAV
NOJAI\' PUIIJC Of NEW JIIISIY
CommlIIIollIxplrel SlW20IO
JANET L. GOLD, ESQUIRE (Equity One, Tnc.)
Attorney 1.0. #38100
EISENBERG, GOLD & CETTEI, P.c.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
EQUITV ONE, INC. D/I3/A POPULAR
SERVICES, LLC
301 Lippincott Drive, Suite 100
Marlton, New Jersey 08053
FINANCIAL !
NO, 05-1831
CIVIL ACTION - LAW
Plaintiff,
NOTICE TO DEFEND
vs.
VICTOR B. STEZlN
98 CENTER ROAD
NEWVILLE, PA 17241
SUZANNE M. STEZIN
807 SOUTH MARKET
MECHANICSBURG, PA 17055
Defendant.
~
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served by
entering a written appearance personally, or by attorney, and filing, in writing, with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail
to do so, the case may proceed without you and a Judgment may be entered against you by the Court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD
ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
Lawyer Referral Service
4th Floor,
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2005-0183~ 2
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
~-~>
EQUITY ONE INC
VS
STEZIN VICTOR B ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
STEZIN SUZANNE M
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, STEZIN SUZANNE M
807 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
DEFENDANT IS BELIEVED TO BE LIVING WITH HER MOTHER
AT 11361 CASASTRANO COURT FORT MYERS, FL 33908.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
6.00
,00
5.00
10.00
.00
21.00
So answ..ers:.. .~
~ -~/~
R. Thomas K1J.ne
Sheriff of Cumberland County
EISENBERG GOLD CETTEI
04/12/2005
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
(x. h \ \:).. -\ A
EISENBERG. GOLD & CETTEI
A PROFESSIONAL CORPORA nON
1~@~itW1l:ii\\
JUN 07 2005 J!!}
BY: __t.f.:_2)~.-,
Yf~ cd Yam
NINE TANNER STREET, WEST ENTRY
HADDONFIELD, NEW JERSEY 08033
WILUN.1 y, EISENBERG.
JANETL. GOLD '"
DONNA L CETTEI '"
(856)795-0351
FAX (356)429-5272
jgold@egclawfirm.com
"'l'v1ErvlBER NJ AND PA BAR
+RULE 1:40 APPROVED 11EDIATOR
May 17, 2005
File No. EF-503-G
Postmaster
Fort Myers, FL 33908
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER
INFORMA nON NEEDED FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if a boxholder) for the following:
NAME: Suzanne Stezin
&'0;;)
h
jJJ) D;u JJm
ADDRESS: 1136l Capistrano Ct. Fort Mvers. FL 33908-4034
.
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NOTE: The name and last known address are required for change of address information. The name, ifknown, and
post office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.5(d)(6)(ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR
265.6(d)(l) and (2) and corresponding Administrative Support Manual 352.44a and b.
l. Capacity of requester (e.g. process server, attorney, party representing himsel!): attornev
? Statute or regulation that employers me to serve process (not required when requester is an attorney or a party
acting pro se - except a corporation action pro se must cite statute):
3. The names of all known parties to the litigation: Equity One. Inc. vs. Victor B. Stezin and Suzanne M. Stezin
4. The Court in which the case has been or will be heard: Cumberland County
5. The docket or other identifYing number/if one has been issued: 05-1831
6. The capacity in which this individual is to be served (e.g. defendant or witness): defendant
E '( ~ \ 'C... \- "E
WARNING
rHEN SUBMISSION OF FALSE INFORMA TIONTO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN COI'I'NECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE UP ro 510,000 OR
IMPRISONMENT OR (2) TO A VOID PA YMENT OF THE FEE OR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN
5 YEARS, OR BOTH (TITLE 18. U.S.C. SECTION 100!).
I certify that the above infonnation is true and that the address infonnation is needed and will be used solely for service
of legal process in connection with actual or prospective litigation.
"GNA~
9 Tanner Street - West Entrv
STREET ADDRESS
JANET L. GOLD, ESOUIRE
PRINTED NAME
Haddonfield. New Jersev 08033
CITY, STATE, ZIP CODE
FOR POST OFFICE USE ONLY
'/
~ No change of address order on file.
Not known at address given.
Moved, left no forwarding address.
No such address.
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COMPLETE THIS SECTION ON DELlVER\'
. Complete items 1, 2. and 3. Also complete
nem 4 if Restricted Delivery is desired,
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of th,l! mallplece,
or on the front if space pennits. C \= - 5
1. Article Addressed to:
~~{\'t. ~a..\(\
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3~~-*~Y.
CJ Agent
CJ Addresse
\ C. Date of Deliver
5~"j, -6 ~
D. Is delivery add.... dlllerent from Item 11 CJ Yes
ff YES, e_ delivtlry address below: CJ No
3. IiY'lce 1YPo
lI.. Ce<1If\ed Moll iEllpma Moll
CJ Registered Retum Receipt for Merchandise
CJ InSUlOd Mall C.O.D.
4. Restricted Delivery? (Extra Fee) Yes
2. ArtiCle Number
(1'nmsf8rrtom servlc81sbe1)
.PS Fonn 3811, Februery 2004
7004 1350 0005 4659 0847
Domestic Return Aeceipt 102595-02-M-1540
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JANET L. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street. West Entry
Haddonfie1d, New Jersey 08033
(856) 795.0351
Attorney for Plaintiff
Attorney I.D. #38100
File No. EF.503.G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION ' LAW
EQUITY ONE, INC., D/B/A POPULAR: NO. 05.1831
FINANCIAL SERVICES, LLC .
Plaintiff,
vs.
! PRAECIPE TO ENTER JUDGMENT
VICTOR B. STEZIN AND
SUZANNE M. STEZlN
Defendant.
TO: Prothonotary of Cumberland County
Enter judgment by default in favor of Plaintiff and against Defendant(s) for failure of
Defendant(s) to file a responsive pleading to the Complaint within the time set forth by law.
I hereby certify that defendants were mailed a notice of plaintiff's intention to file the
Praecipe to enter the default pursuant to P A.R.C.P. 237.1 after the defendants failure to
plead to the complaint and at least ten (10) days prior to e date of the filing of this
Praecipe.
Assess damages as follows;
(a) Principal
(b) Interest frorn '1/22/04 to 8/31/05 at 8.5% per annum
(c) Attorneys' commission
(d) Late Charges
(e) Extension Fees
TOTAL
$ 256,591.50
$ 30.111.53
$ 3,000.00
$ 1.660.08
$ 2,717.50
$ 294,080.61
I certify tha t the foregoing assessment of damages is for specific amounts alleged to be
due in the Complaint and is calculable as a sum cert . m e plaint.
AND NOW, this .),.:),0c.4ay of fJ( L t ' 2005, judgment by default is entered in
favor of the Plaintiff and against the Defendant, nd damages are assessed' the sum of $
~
JANET L. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
AttorneyI.D. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A POPULAR' NO. 05-1831
FINANCIAL SERVICES, LLC
Plaintiff,
IN MORTGAGE FORECLOSURE
vs.
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
NOTICE OF INTENTION TO TAKE DEFAULT
TO: Victor B. Stezin
807 South Market Street
Mechanicsburg, P A 17055
DATE OF NOTICE:
June 21. 2005
IMPORTANT NOTICE
You are in default because you have failed to take action required of you in this case. Unless you act
within ten (10) days from the date of this notice as set forth above, a judgment may be entered against you
without a hearing and you may lose your property or other important rights. You should take this notice to
a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the follOwing office to
find out where you can get legal help:
LAWYER REFERRAL SERVICE
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
Telenhone: (717) 240-6200
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
J MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
R".i"d 'EISEllIEM. GOLD __ EKtR'l' .
tTAKIIER IT. .......
's Form 3817, January 2001
...
I:;
1 de su parte en este caso. A menos de que
registra una sentencia contra usted, sin el
5 importantes. Usted debe llevar este aviso
lede paga por los servicios de un abogado,
)uede obtener ayuda legal:
, LEGAL
:ourthouse
)0
L~.~~-
JAt'ffiT L. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C,
9 Tanner Street. West Entry
Haddonfield, New Jersey 08033
(856) 795.0351
Attorney for Plaintiff
Attorney I.D. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A POPULAR i NO. 05.1831
FINANCIAL SERVICES, LLC :
Plaintiff, i.. IN MORTGAGE FORECLOSURE
vs.
VICTOR B. STEZIN AND
SUZANNE M. STEZlN
Defendant.
NOTICE OF INTENTION TO TAKE DEFAULT
TO: Suzanne M. Stezin
11361 Capistrano Ct,
Fort Myers, FL 33908.4034
DATE OF NOTICE: June 21,2005
IMPORT ANT NOTICE
You are in default because you have failed to take action required of you in this case. Unless you
act within ten (10) days from the date of this notice as set forth above, a judgment may be entered against
you without a hearing and you may lose your property or other important rights. You should take this
notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the
following office to find out where you can get legal help:
LAWYER REFERRAL SERVICE
4th Floor, Cumberland County Courrhouse
Carlisle, PA 17013
- - - - '.00
u.s. POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil DOES NOT
PROVIDE FO~ lNSUAANCE-POSTMASTE '
Rec~e
Form 3817, January 2001
&
da de su parte en este caso. A menos de
Juede registra una sentencia contra usted,
lerechos importantes. Usted debe !levar
10 y no puede paga par los servidas de un
ir donde puede obrener ayuda legal:
, LEGAL
:ourthouse
)0
'L~
JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
856) 795-0351
Attorney for Plaintiff
Attorney J.D. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A POPULAR i NO. 05-1831
FINANCIAL SERVICES, LLC
Plaintiff,
vs.
AFFLDA VIT OF NON-MILlT ARY
SERVICE
AND CERTIFICATION OF ADDRESS
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
STATE OF NEW JERSEY
: ss.
COUNTY OF BURLINGTON /CAMDEN
Ouintin C. Cochran
, of full age, being duly sworn according to law, on
his/hcr oath deposes and says that I am Loss Mitigation Specialist
of Plaintiff; that
1 am authorized to make this Affidavit on behalf of the Plaintiff; that the above named Defendant(s)
Victor B. Stezin resides at; 807 South Market Street, Mechanicsburg, PA 17055 and that the above
named Defendant(s) Suzanne M. Stezin resides at 11361 Capistrano Court, Fort Myers, FL 33908-
4034 and that the Defendant(s) is/are not in the military or naval service of the United States or any
State or territory thereof, or its allies, as defined in the Soldiers and Sailors Civil Relief Act of 1940
and the Amendments thereto.
Deponent also certifies that the address of the Plaintiff is:
121 Woodcrest Road, Cherry HilI, NJ 08003
oI;;;f-' (i ~0lL ~€k - _
D SUBScazIBED
THI I DAY
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JANET L. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Attorney I.D. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A POPULAR: NO. 05-1831
FINANCIAL SERVICES, LLC '
Plaintiff,
vs.
; IN MORTGAGE FORECLOSURE
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
NOTICE PURSUANT TO RULE 236
TO: Suzanne M. Stezin
11361 Capistrano Ct.
Fort Myers, FL 33908-4034
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that
a judgment has been entered against you in the above proceeding as indicated below.
(J~
PROT~ONOTARY
JUDGMENT BY DEFAULT
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
JANET L. GOLD, ESQUIRE
(856) 795-0351
JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Attorney 1.0. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A POPULAR! NO. 05-1831
FINANCIAL SERVICES, LLC ;
Plaintiff,
vs.
! IN MORTGAGE FORECWSURE
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
NOTICE PURSUANT TO RULE 236
TO: Victor B. Stezin
807 South Market Street
Mechanicsburg, PA 17055
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified
that a judgment has been entered against you in the above proceeding as indicated below.
PR~~1
JUDGMENT BY DEFAULT
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
JANET L. GOLD, ESQUIRE
(856) 795-0351
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
Pa.R.C.P.3180-3183
EQUITY ONE, INC. D/B/A POPULAR: IN THE COURT OF COMMON PLEAS OF
FINANCIAL SERVICES, LLC : CUMBERLAND PENNSYLVANIA
: NO.... 1831................... Term 2005...................
Plaintiff,
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
vs.
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendants.
To the Prothonotary of Cumberland County
Issue Writ of Execution in the above matter:
Amount Due
$ 294,080.61
Interest from 4/7/05
$
and Costs.
~~~
Atto ey fOT a'
Note: Please attach description of Property.
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ilLEGAL DESCRIPTION"
ALL THA.T CERTAIN tract of land situat.ed in Upper Allen Township,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a point located on the ',astern right of way line of South
Market Street (50 foot right of way) at a common point with lands now
or formerly of Mechanicsburg Area Joint School System, thence from
said point, along said right of way, North 49 degrees 55 minutes 42
seconds West a distance of 8.28 feet to a point; thence along the
same, along a curve, curving to the :right with a radius of 1121.18
feet, an arc distance of 160.00 feet to a point; thence along lands
now or formerly of Larry M. and Jean A. Roth, North 72 degrees 15
minutes 00 seconds East a distance o:E 201.84 feet to an iron pin;
thence along lands now or formerly of Mechanicsburg Area Joint School
System, South 16 degrees 46 minutes 00 seconds East a distance of
150.50 feet to a point; thence along the same, South 73 degrees 26
minutes 00 seconds West a distance o:E 119. S9 feet to the point of
beginning.
Said area described containing 0.558 acres.
HAVING THEREON erected a two story frame dwelling and other improvements.
\
BEING THE SAME PREMISES which Charlotte E. Hertzler, widow. by deed
dated October 27, 1994 and recorded October 31, 1994 in the Cumberland
County Office of the Recorder of Deeds in Deed Book 114, Page 98
granted and conveyed to Victor B. Stezin and Suzanne M. Stezin,
husband and wife.
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JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Attorney l.D. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A POPULAR NO. 05-1831
FINANCIAL SERVICES, LLC
Plaintiff,
vs.
AFFIDAVIT PURSUANT TO RULE
3129.1
VICTOR B. STEZlN AND
SUZANNE M. STEZIN
Defendant.
STATE OF NEW JERSEY
COUNTY OF ~
ss.
Equity One, Inc., d/b/a Popular Financial Services, LLC, Plaintiff in the above-
captioned matter, sets forth as of the date of the Praecipe for the Writ of Execution was filed,
the following information concerning the real property located at 807 South Market Street,
Mechanicsburg, PA 17055 (see copy of the description attacned hereto as Exhibit A).
1. Name and address of owner(s) or reputed owner(s):
Name
Add ress
Victor B. Stezin
98 Center Road
Newville, PA 17241
Suzanne M. Stezin
11361 Capistrano Ct.
Fort Myers, FL 33908-4034
2. Name and address of Defendants in the judgment:
Name
Address
Victor B. Stezin
98 Center Road
Newville, PA 17241
Suzanne M. Stezin
11361 Capistrano Ct.
Fort Myers, FL 33908-4034
3. Name and last known address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name
Address
Cumberland County Tax Claim Bureau 1 Courthouse Square
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
Name
Address
Household Realty Corporation
25 Gateway Drive
Gateway Square - Suite 107
Mechanicsburg, PA 17055
Equity One, rnc" d/b/a Popular
Financial Services Corporation
121 W oodcrest Road
Cherry Hill, NJ 08003
5, Name and address of every other person who has any record lien on the
property:
Address
Name
Cumberland County Tax Claim Bureau 1 Courthouse Square
Carlisle, PA 17013
Domestic Relations
1 Courthouse Square
Carlisle, P A 17013
6. Name and address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
Name
Add~
Cumberland County Tax Claim Bureau 1 Courthouse Square
Carlisle, PA 170 13
7. Name and address of every other person of whom the Plaintiff has knowledge
who has any interest in the property which may be affected by the sale:
Name
Address
Tenant(s)
807 South Market Street
Mechanicsburg, P A 17055
1 verify that the statements made in this Affidavit are true and correct to the best of
my personal knowledge or information and belief. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to
authorities.
SWORN TO AND SUBSCRIBED
BEFORE E T IS Jl_ DAY
OF , 2005.
~~
NOTARY PUBLIC
SHERRIB.~A~EVVS
NOTARY PUBUC OF NEW JERSEY
Commission Expires 2/10/2fI1I
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JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Attorney LD. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION . LAW
EQUITY ONE, INC., D/B/A POPULAR! NO. 05-1831
FINANCIAL SERVICES, LLC j
Plaintiff,
vs.
NOTICE OF SHERIFF'S SALE OF
REAL PROPERTY
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
TO: Victor B. Stezin
807 South Market Street
Mechanicsburg, PA 17055
Your house (realestate) at807 South Market Street, Mechanicsburg, PA 17055, is scheduled
to be sold at Sheriff's Sale on March 8, 2006 at 11:00 a,m. in the Cumberland County Sheriff's
Office, One Courthouse Square, Carlisle, Pennsylvania to enforce the judgment of 294,080.61
obtained by Equity One, Inc., d/b/a Popular Financial Services, LLC.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Equity One, Inc. or its attorney Janet 1.. Gold,
Esquire the back payments, late charges, costs and reasonable atrorneys fees due. To find out how
much you must pay, you may call (856) 795-0351.
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 the 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.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFFS SALE DOES TAKE PLACE
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder,
You may find out the price by calling (856) 795-0351.
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 if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call (856) 795-0351.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner
of the property as if the sale never happened.
5. You have a 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 will bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the Sheriff on April 10,
2006. This schedule will state who will be receiving the money. The money will be paid out in
accordance with this schedule unless exception (reasons why the proposed distribution is wrong) is
filed with the Sheriff within ten (10) days after April 10, 2006.
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
HA VEA LAWYER OR CANNOT AFFORD ONE, GOTO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
4'h Floor - Cumberland County Courthouse
Carlisle, PA 17013
ilLEGAL DESCRIPTIONII
ALL THAT CERTAIN tract of land situated in Upper Allen Township,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a point located on the eastern right of way line of South
Market Street (50 foot right of way) at a common point with lands now
or formerly of Mechanicsburg Area Joint School System, thence from
said point, along said right of way, North 49 degrees 55 minutes 42
seconds West a distance of 8.28 feet to a point; thence along the
same, along a curve, curving to the right with a radius of 1121.18
feet, an arc distance of 160.00 feet to a point; thence along lands
now or formerly of Larry M. and Jean A. Roth, North 72 degrees 15
minutes 00 seconds East a distance of 201.84 feet to an iron pin;
thence along lands now or formerly of Mechanicsburg Area Joint School
System, South 16 degrees 46 minutes 00 seconds East a distance of
150.50 feet to a point; thence along the same, South 73 degrees 26
minutes 00 seconds West a distance of 119.59 feet to the point of
beginning.
Said area described containing 0.558 acres.
HAVING THEREON erected a two story frame dwelling and other improvements.
\
BEING THE SAME PREMISES which Charlotte E. Hertzler, widow, by deed
dated October 27, 1994 and recorded October 31, 1994 in the Cumberland
County Office of the Recorder of Deeds in Deed Book 114, Page 98
granted and conveyed to Victor B. Stezin and Suzanne M. Stezin,
husband and wife.
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JANET 1. GOLD, ESQUffiE
EISENBERG, GOLD & CETTEI, P,C,
9 Tanner Street - West Entry
Haddonfie1d, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Attorney LD. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A POPULAR NO. 05-1831
FINANCIAL SERVICES, LLC
Plaintiff,
vs.
NOTICE 0]< SHERIFF'S SALE OF REAL
PROPERTY
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
TO: Victor B. Stezin
98 Center Road
Newville, PA 17241
Your house (real estate) at807 South Market Street, Mechanicsburg, PA 17055, is scheduled
to be sold at Sheriff's Sale on March 8, 2006 at 11:00 a.m. in the Cumberland County Sheriffs
Office, One Courthouse Square, Carlisle, Pennsylvania to enforce the judgment of 294,080.61
obrained by Equity One, Inc., d/b/a Popular Financial Services, LLC.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Equity One, Inc. or its attorney Janet 1.. Gold,
Esquire the back payments, late charges, costs and reasonable attorneys fees due. To find out how
much you must pay, you may call (856) 795-0351.
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 the 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.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PlACE
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder.
You may fmd out the price by calling (856) 795-0351.
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 if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call (856) 795-0351.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner
of the property as if the sale never happened.
5 . You have a right to remain in the property until1:he full amount due is paid to the
Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer will bring legal proceedings
to evict you,
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the Sheriff on April 10,
2006. This schedule will state who will be receiving the money. The money will be paid out in
accordance with this schedule unless exception (reasons why the proposed distribution is wrong) is
filed with the Sheriff within ten (10) days after April 10, 2006.
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
HA VEA LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
4'h Floor - Cumberland County Courthouse
Carlisle, PA 1;g013
*
JANET . OLD UiRE
ilLEGAL DESCRIPTIONII
ALL THAT CERTAIN tract of land situated in Upper Allen Township,
Cumberland County, Pennsylvania, bounded and described as follows:
. BEGINNING at a point located on the ,eastern right of way line of South
Market Street (50 foot right of way) at a common point with lands now
or formerly of Mechanicsburg Area Joint School System, thence from
said point, along said right of way, North 49 degrees 55 minutes 42
seconds West a distance of 8.28 feet to a point; thence along the
same, along a curve, curving to the right with a radius of 1121.18
feet, an arc distance of 160.00 feet to a point; thence along lands
now or formerly of Larry M. and Jean A. Roth, North 72 degrees 15
minutes 00 seconds East a distance o,E 201.84 feet to an iron pin;
thence along lands now or formerly o,E Mechanicsburg Area Joint School
System, South 16 degrees 46 minutes DO seconds East a distance of
150.50 feet to a point; thence along the same, South 73 degrees 26
minutes 00 seconds West a distance of 119.59 feet to the point of
beginning.
Said area described containing 0.558 acres.
HAVING THEREON erected a two story frame dwelling and other improvements.
\
BEING THE SAME PREMISES which Charlot.te E. Hertzler, widow, by deed
dated October 27, 1994 and recorded October 31, 1994 in the Cumberland
County Office of the Recorder of Deeds in Deed Book 114, Page 98
granted and conveyed to Victor B. St.ezin and Suzanne M. Stezin,
husband and wife.
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JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
HaddonfieId, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Attorney LD. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMB1ERLAND COUNTY, PA
CIVIL ACTION - LAW
EQuITY ONE, INC., D/B/A POPULAR i,:". NO. 05-1831
FINANCIAL SERVICES, LLC
Plaintiff,
vs.
NOTICE OF SHERIFF'S SALE OF REAL
PROPERTY
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
TO: Suzanne M. Stezin
11361 Capistrano Court
Fort Myers, FL 33908-4034
Your house (real estate) at807 South Market Street, Mechanicsburg, PA 17055, is scheduled
to be sold at Sheriff's Sale on March 8,2006 at 11:00 a.m. in the Cumberland County Sheriff's
Office, One Courthouse Square, Carlisle, Pennsylvania to en~~)fce the judgment of 294,080.61
obtained by Equity One, Inc., d/b/a Popular Financial Services, ILLC.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Equity One, Inc. or its attorney Janet 1. Gold,
Esquire the back payments, late charges, costs and reasonable attorneys fees due. To find out how
much you must pay, you may call (856) 795-0351.
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 the 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.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder.
You may find out the price by calling (856) 795-0351.
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 if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call (856) 795-0351.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner
of the property as if the sale never happened.
5. You have a 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 will bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the Sheriff on April 10,
2006. This schedule will state who will be receiving the money. The money will be paid out in
accordance with this schedule unless exception (reasons why the proposed distribution is wrong) is
filed with the Sheriff within ten (10) days after April 10, 2006.
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
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
4'h Floor - Cumberland County Courthouse
Carlisle, PA 17013 C
JANETJt~RE
"LEGAL DESCRIPTION"
ALL THAT CERTAIN tract of land situated in Upper Allen Township,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a point located on the eastern right of way line of South
Market Street (50 foot right of way) at a common point with lands now
or formerly of Mechanicsburg Area Joint School System, thence from
said point, along said right of way, North 49 degrees 55 minutes 42
seconds West a distance of 8.28 feet to a point; thence along the
same, along a curve, curving to the right with a radius of 1121.18
feet, an arc distance of 160.00 feet to a point; thence along lands
now or formerly of Larry M. and Jean A. Roth, North 72 degrees 15
minutes 00 seconds East a distance of 201.84 feet to an iron pin;
thence along lands now or formerly of Mechanicsburg Area Joint School
System, South 16 degrees 46 minutes 00 seconds East a distance of
150.50 feet to a point; thence along the same, South 73 degrees 26
minutes 00 seconds West a distance of 119.59 feet to the point of
beginning.
Said area described containing 0.558 acres.
HAVING THEREON erected a two story frame dwelling and other improvements.
\
BEING THE SAME PREMISES which Charlc,tte E. Hertzler, widow, by deed
dated October 27, 1994 and recorded October 31, 1994 in the Cumberland
County Office of the Recorder of Deeds in Deed Book 114, Page 98
granted and conveyed to Victor B. Stezin and Suzanne M. Stezin,
husband and wife.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
1'0 05-1831 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EQUITY ONE, INC. D/B/A POPULAR FINANCIAL
SERVICES, LLC., Plaintiff (s)
From vrCTOR B. STEZIN AND SUZANNE M, STEZIN
(I) 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 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 (s) and from delivering any property ofthe 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $294,080,61
Interest FROM 417105
L.L. $,50
Atty's Comm
%
Due Prothy $1.00
Other Costs
Arty Paid $139,14
Plaintiff Paid
Date: SEPTEMBER 30, 2005
(Seal)
(J/Ih Ifl~
Piothonotary-----~
By:
Deputy
REQUESTING PARTY:
Name JANET L. GOLD, ESQUIRE
Address: EISENBERG, GOLD & CETTEL, P.c.
9 TANNER STREET - WEST ENTRY
HADDONFIELD, NJ 08033
Attorney for: PLAINTIFF
Telephone: 856-795-0351
Supreme Court lD No. 38100
JANET L. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Att'lrncy 1.0. #38100
Ftle No. EF,503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, lNC., D/B/A POPULAR: NO. 05-1831
fiNANCIAL SERVICES, LLC
Plaintiff,
MOTION 1'01 REASSESS DAMAGES
vs.
VICTOR B. STEZlN AND
SUZANNE M. STEZIN
Defendant.
TO THE HONORABLE JUDGES OF THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY:
Plaintiff, Equity Onc, Inc., by its attorney, Janct 1.. Gold, Esquire, rcspectfully
rcprcscnts thc following in support of a rcqucst to reasscss damages in the above mattcr:
I. On April 7, 2005, Plaintiff filcd its Complaint in Mortgagc Foreclosure.
2. Thc Defendants wcrc servcd and Praecipc to Entcr Judgment by Default
was entcred and damagcs wcre assesscd in the amount $294,080.61 on August 22,2005.
3. Sincc the datc the judgment was cntered, damagcs havc incrcased as
Illllows:
.
Unpaid Principal Balance
$256,59 I .50
Late Charges
$ 2,214.45
Interest through 0l/03/06
$ 37,684.66
Extension Fees
$ 3,170.42
Real btat" Tax"s Advanced on 12116/05
(See Exhibits "A" and "B" attached)
$ 9,997.87
Attorney's Commission
$ 3,000.00
Total
$312,658.90
4. No other motions have been ruled upon in this matt"r.
WHEREFORE, Plaintiff Equity One, Inc., requests that this Honorable
Court r"assess damages in the amount of $312,658.90.
EISENBERG, GOLD & CETTEl, P.c.
Attorney for Petitioner
By () ~ ,,,,,--
JtJ~ L. ~ ESQUIRE
VERIFlCA TION
Janet L. Gold, Esquire, hereby states that she is the attorney 1(11' the Petitioner in
this action, that she is authorized to take this Affidavit, and that the statements made in
the f()1'Cgoing Petition to Reassess Damages are true and correct to the best of her
knowledge, information and belief.
The undersigned understands that this statement herein is made subject to the
penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to ,1uthorities.
Date; J;muary 3, 2006
BY;~.~
J L. LD, ESQUIRE
A rney for Petitioner
JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street. West Entry
Haddonfield, New Jersey 08033
(856) 795.0351
Attorney for Plaintiff
,\ttorney LD. #38100
hie No. EF-S03-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND, PA
CIVIL ACTION - LAW
EQuITY ONE, INC., D/B/A POPULAR. Docket No.: 05-1831
FINANCIAL SERVICES, LLC
P18intiff,
vs.
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
MEMORANDUM OF LAW IN SUPPORT OF
MOTION FOR REASSESSMENT OF DAMAGES
On April 7, 2005, Plaintiff filed its Complaint in Mortgage Foreclosure. Defendant
Victor B. Stezin was served on April 11, 200S and Defendant Suzanne M. Stezin was
,crved on May 28, 2005. The Defendant(s) were properly served and failed to answer and
:dler proper notice pursu,mt to Pa.R.C.P. 237.1 Judgment by Default was entered
pur,ua11l to Pa.R.C.P. 236.
The Prothonotary entered Judgment and assessed damages at $294,080.61 on
August 22, 2005.
Since the date that the Judgment was entered by the Prothonotary, Plaintiffs
,Lunage, have increased as a result of Defendant's failure to real estate taxes and due to
t1w delay in the Sheriffs Sale caused by waiting for a date from the Sheriffs Office as to
interest which has accrued. Up to and including December 30, 200S, Plaintiffs damages
h:lVe increased from $294,080.61 to $312,658.90.
Pa.R.C.P. 103 7 (b) provides that the Prothonotary, on Praecipe of the Plaintiff shall
enter Judgment against the Defendant for failure to file within the required time an
Answer to a Complaint which contained a Notice to Defend. In the case at har, Plaintiff
ilk'cl :1 Complaint with a Notice to Defend to which Defendant failed to answer.
Pa.R.C.P. 1037 (b) (1) provides for the Prothonotary to assess damages to which the
PLlintiff is entitled if it is a sum certain or which can be made certain by computation.
Plaintiffs Complaint was one in Mortgage Foreclosure. The damages are a sum certain or
readily :lscertainable by computation. The unpaid principal halance, interest, late
charges, attorney's fees, real estate taxes and court costs arc aU readily ascertainahle and
pwperty :lssessed by the Prothonotary.
However, as time passes, interest on the unpaid principal balance accrues and
incre:lses. Furthermore, some of the other charges also increase such as the need to pay
unpaid real estate taxes to protect the lien of the mortgage. Each and every one of these
increases in Plaintiffs damages are certain or certain by computation.
WHEREFORE, Plaintiff, Equity One, lnc., respectfully requests that this
Ilonor:lhlc Court reassess damages up to and including Decemher 31, 2005 in the amount
01 ~ 312,658.90.
~
BY:
L}\ TED: January 3, 2006
Respectfully submitted,
EISENBERG, GOLD & CETTEI, P.c.
. ~
JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795.0351
Attorney for Plaintiff
!\ltorney l.D. #38100
hIe No. EF.503.G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION. LAW
EQl1ITY Ot\E, INC., D/B/A POPULAR: Docket No.: 05.1831
II!\JANCIAL SERVICES, LLC
Plaintiff,
vs.
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant. .
CERTIFICATION OF SERVICE
I, Janet L. Gold, Esquire, caused to mail to Victor B. Stezin at his last known
:Icldress of last known address of98 Center Road, Newville, PA 17241 and Suzanne M.
:otczin at ller last known address of 11361 Capistrano Court, Fort Myers, FL 33908-4034,
:1 copy of Motion Cover Sheet, proposed form of Order, Motion to Reassess Damages,
Memorandum of Law and Certification of Service on January 3, 2006 by way of certitled
1l1:1I1. return receipt requested and regular mail.
I certify that the foregoing statements made by me are true. I am aware that if any
(JI. tile j()regoing statements made hy me are willfully false, I am subject to punishment.
~~
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LJ:lled: J:\I1uary 3, 2006
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQI [TY ONE, INC., D/B/A POPULAR: Docket No.: 05.1831
FINANCIAL SERVICES, LLC
\',';.
VICTOR R STEZIN AND
Sl:ZANNE M. STEZIN
Plaintiff,
Defendant.
ORDER
AND NOW, this
\~t\. dayof:X '2.J7uv ') ,2006, damages against
Ddcmlant(s) previously assessed at $294,080.61 are now reassessed to the sum of
SlI2,658.90
INTERESTED PARTIES:
J/tctm I). Stezin
9K Center Road
Newville, P A 17241
,;(:~\l1J1" M. Stezin
II 361 Capistrano Court
j-"It Mvers, FL 33908-4034
[. I ocni)LC(j" , (,old.
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JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street. West Entry
Haddonfield, New Jersey 08033
(856) 795.0351
Attorney for Plaintiff
Attorney LD. #38100
File No. EF.503.G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P A
CIVIL ACTION . LAW
EQUITY ONE, INC., D/B/A POPULAR i NO. 05-1831
FINANCIAL SERVICES, LLC !
Plaintiff, ,
vs.
AFFIDAVIT OF SERVICE
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
Janet L. Gold, of full age, according to law, upon her oath, deposes and says that:
1. I am the attorney for plaintiff in the above captioned matter.
2. On October 14, 2005 I served upon the following party a copy of the of Sheriffs
Sale Notice of Real Property, via first class mail and certified mail, restricted delivery,
postage prepaid which certified mail was signed for by the Defendant on October 21, 200S:
Suzanne M. Stezin
11361 Capistrano Court
Fo" MY'''' FL 33908-4~
JANET OL
SWORN TO AND SUBSCRIBED
BEFORE ME THIS DAY
OF , 2006.
NOTARY PUBLIC
.. .
.
COMPLETE THIS SECTION ON DELIVERY
. Complete items 1, 2. and 3. Also complete
~em 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that We can return the card to you.
. Attach this card to the back of the maHpiece.
or on the front if space permits. ~ ' 'Si>~
~. Artlel dressecl to:
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Agent
o AddreSSEK
3. Service Type
~ Certified Mall 0 Express Mail
D Registered ~e. turn Receipt for Merchandise
o Insured Mall O't.O.D. .
4. Restricted Delivery? (Extra Fee) Yes
2. Article Number
(Transfer from service label)
PS Fonn 3811, February 2004
7004 1350 0005 4659 3077
Domestic Return Receipt
102595-02-M-1541
.
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EISENBERG, GOLD' cm~:c, e.f;!2Q~.;
ITANNER ST. WEST EtlRlf -- ..-
HADDONFIILD, NJ 08033
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JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street. West Entry
Haddonfield, New Jersey 08033
(856) 795.0351
Attorney for Plaintiff
Attorney I.D. #38100
File No. EF-S03-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION. LAW
EQUITY ONE, INC., D/B/A POPULAR i NO. OS-IS31
FINANCIAL SERVICES, LLC :
Plaintiff,
vs.
AFFIDAVIT OF SERVICE OF
NOTICE OF SHERIFF'S SALE
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
STATE OF NEW JERSEY
: SS.
COUNTY OF CAMDEN
Janet 1. Gold, of full age, according to law, upon her oath, deposes and says that:
1. I am the attorney for plaintiff in the above captioned matter.
2. On October 11, 2005, I served upon the following parties, via first class mail,
postage prepaid, with a 3817 Certificate of Mailing, a copy of the Notice of Sheriffs Sale of Real
Property pursuant to Pennsylvania Rules of Civil Procedure 3129.1:
Cumberland County Tax Claim Bureau
1 Courthouse Square
Carlisle, P A 17013
Tenant(s)
807 South Market Street
Mechanicsburg, PA 17055
Household Realty Corporation
25 Gateway Square. Suite 107
Mechanicsburg, PA 17055
3. On Fehruary 3, 2006, I served upon the following parties, via first class mail,
postage prepaid, with a 3817 Certificate of Mailing, a copy of the Notice of Sheriffs Sale of Real
Property pursuant to Pennsylvania Rules of Civil Procedure 3129.1:
Domestic Relations
1 Courthouse Square
Carlisle, P A 171 03
4. Copies of the Notices and 3817 Certificates of Mailing are attached hereto and
made a part hereof as Exhibit A.
5. On January 11, 2005 the Defendant, Victor B. Stezin, was personally served with
the Notice of Sheriffs Sale at his residence of98 Center Road, Newville, PA.
6. On January 9, 2006, the property was posted with the Notice of Sheriff Sale and
the original Affidavit is attached hereto for filing.
7. On October 21,2005, I served the Defendant, Suzanne M. Stezin, by certified
mail, return receipt requested, restricted delivery and regular mail a Notice of the Sheriffs Sale at
his/her last known address of 11361 Capistrano Court, Ft. Myers, FL 33908-4034. A copy of the
returned envelope/ signed return receipt is attached hereto as Exhibit B.
1 hereby certify that the foregoing statements made by me are true to the best of my
knowledge, information and belief. I am aware that if any of the foregoing statements made by
me are willfully false, 1 am subject to punishment.
~
JANET . G LD
SWORN TO AND SUBSCRffiED
BEFORE ME THIS 1oi1-l DAY
OF f:e.bCuc..fY ,2005.
__~,._' ~D.:d~
NOTARY PUBL C
QIIIIt HOUDAY
UAW PUBlIC Of NEW JEISEV
i~Il'''ll'l1t1i\Ol! ExpIIes 3/W2010
, .
EXHIBIT "A"
EISENBERG. GOLD & CETIEI
A PROFESSIONAL CORPORATION
Counselors at Law
NINE TANNER STREET. WEST ENTRY
HADDON FIELD. NEW JERSEY 08033
WILLIAM V. EISENBERG.
JANET L GOLD'"
DONNA L. CETTEI ..
"'MEMBER ~J AND PA BAR
+RL'LE 1:40 APPROVED !l.IEDIATOR
October 11,2005
(856)795.0351
FAX, (856) 4Z9.5272
jgo\d@egclawfum.com
File No. EF-503-G
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
T enant(s)
S07 South Market Street
Mechanicsburg, PA 17055
OWNER(S):
Victor B. Stezin and Suzanne M. Stezin
PROPERTY:
S07 South Market Street
Mechanicsburg, PA 1705S
The above-captioned property is scheduled to be sold at Sheriffs Sale on March S,
2006 at 11:00 a.m. in the Cumberland County Sheriffs Office, One Courthouse Squire,
Carlisle, Pennsylvania to enforce the Courtjudgmentof$294,080.61 obtained by Equity One,
Inc., d/b/a Popular Financial Services, LLC. Our records indicate that you may hold a
mortgage or judgment on the property which will be extinguished by the sale. You may wish
to attend the sale to protect your interests.
U.s. PqiSTAL SERVICE CERTIFICATE
MAY BE .0SEO FOR DOMESTIC AND INTERNATION
PROVID ,t FOR ,INSURANCE POSTMASTER
ReceilledFrom:
PS Form 3817, January 2001
iff on a date specified by the Sheriff
be made in accordance with the
IYS after the filing of the schedule.
uly yours,
ERG, GOLD & CETTEI, P .C.
~ L. GOLD, ESQUIRE
IRNEY I.D. NO.: 38100
EISENBERG. GOLD & CETIEl
A PROFESSIONAL CORPORATION
Counselors at Law
NINE TANNER STREET - WEST ENTRY
HADDONFIELD. NEW JERSEY 08033
WILLlA}.1 V. EISENBERG.
JANET 1. GOLD *
DONNA 1. CETTEI "
(856)7<15-'1351
F.'I,X {B56l4Z9-5Z72
jgold@egdawnnn.com
*ME:-.mER NJ AND PA BAR
. Rl:LE 1:40 APPROVED ~IEDlA TOR
October 11, 2005
File No. EF.S03-G
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
Household Realty Corporation
2S Gateway Square - Suite 107
Mechanicsburg, PAl 7055
OWNER(S):
Victor B. Stezin and Suzanne M. Stezin
PROPERTY:
807 South Market Street
Mechanicsburg, P A 17055
The above-captioned property is scheduled to be sold at Sheriff's Sale on March 8,
2006 at 11:00 a.m. in the Cumberland County Sheriffs Office, One Courthouse Squire,
Carlisle, Pennsylvania to enforce the Court judgment of$294,080.61 obtained by Equity One,
Inc., d/b/a Popular Financial Services, LLC. Our records indicate that you may hold a
mortgage or judgment on the property which will be extinguished by the sale. You may wish
to attend the sale to protect your interests.
Receiv dFrorn;
Affix fee herein slamps
tageana
nquireof
for current
Jf on a date specified by the Sheriff
be made in accordance with the
ys after the filing of the schedule.
A crh"",-l..L" r-,.( ,J:~.._;L_ .'
0111
U.S. POSTAL SERVICE
MAY BE USED FOR DOMESTIC AND INTERN
PROVIDE OR INSURANCE POSTMASTER
tly yours,
eRG, GOLD & CETTEl, P.C.
L. GOLD, ESQUIRE
~EY I.D. NO.: 38100
PS Fmm 3817, January 2001
EISENBERG. GOLD & CETTEI
A PROFESSIONAL CORPORATION
Counselors at Law
NINE TANNER STREET "WEST ENTRY
HADDON FIELD. NEW JERSEY 08033
WILLIAM v. EISENBERG.
JA;-';ET L GOLD ..
DONNA L. CETIE! ..
"MEMBER NJ AND PA BAR
+RULE 1:40 APPROVED ~lEDIATOR
October 11, 2005
(856)795-0351
FAX, (S56}429.mZ
jgold@egcmwfinn,com
File No. EF-503.G
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
Cumberland County Tax Claim Bureau
1 Courthouse Square
Carlisle, P A 17013
TO:
mVNER\S).; .
,
Victor B. Stezin and Suzanne M. Stezin
,."
PROPERTY :
807 South Market Street
Mechanicsburg, P A 17055
The above-captioned property is scheduled to be sold at Sheriffs Sale on March 8,
2006 at 11:00 a.m. in the Cumberland County Sheriffs Office, One Courthouse Squire,
Carlisle, Pennsylvania to enforce the Court judgment of$294,080.61 obtained by EquitY One,
Inc., d/b/a Popular Financial Services, LLC. Our records indicate that you may hold a
mortgage or judgment on the property which will be extinguished by the sale. You may wish
to attend the sale to protect your interests.
ReceivedF m:
U,S. POSTAL SERVICE
MAY BE USED FOR DOMESTIC AND INTERNATION MIll
PROVIDE FOR SURANCE POSTMASTER v"
LING
One piece of ordinary mail addressed 10:
\ ~"'~. ... '-
\;,~l.... ~C\' \
PS Form 3817, January 2001
"iff on a date specified by the Sheriff
I be made in accordance with the
ays after the filing of the schedule.
'uly yours,
3ERG, GOLD &CETTEI, P.C.
r L. GOLD, ESQUIRE' ·
)RNEY I.D. NO.: 38100
.' ~ <
l,'!"
EISENBERG. GOLD & CETTEI
A PROFESSIONAL CORPORATION
Counselors at Law
NINE TANNER STREET. WEST ENTRY
HADDONFIELD. NEW JERSEY 08033
WILLIAM V. EISENBERG.
]ANITL GOLD *
DONNA L. CEDE! .
*~fE:VIBER NJ AND PA BAR
+RULE 1:40 APPROVED MEDIATOR
February 3, 2006
iaS:6)79$-03S1
FAX: (856)429-5172
jgold@egclawfirm.com
File No. EF-503.G
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
Domestic Relations
1 Courthouse Square
Carlisle, P A 17013
OWNER(S) :
Victor B. Stezin and Suzanne M. Stezin
PROPERTY:
807 South Market Street
Mechanicsburg, P A 170S5
The above-captioned property is scheduled to be sold at Sheriff's Sale on March 8,
2006 at 11:00 a.m. in the Cumberland County Sheriffs Office, One Courthouse Squire,
Carlisle, Pennsylvania to enforce the Court judgment of$294,080.61 obtained by Equity One,
Inc., d/b/a Popular Financial Services, LLC. Our records indicate that you may hold a
mortgage or judgment on the property which will be extinguished by the sale. You may wish
to attend the sale to protect your interests.
U . POSTAL SERVICE
CERTIFICA
AILING
M Y BE USED ~OR DOMESTIC AND lNTERNA TI
PROVIDE FOR INSURANCE POSTMASTER
T
ReceiveoFrom"
PS Form 3817, January 2001
f on a date specified by the Sheriff
Je made in accordance with the
s after the filing of the schedule.
1- yours,
RG, GOLD & CETTEI, P.C.
L. GOLD, ESQUIRE
NEY J.D. NO.: 38100
EXHIBIT "B"
-
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1~_1!::1l...J
. Complete items 1, 2. and 3. Also complete A. ~ature .... .11 Ai. '"
item 4 If Restricted Delivery is desired. X'D ~ V"_
. Print your name and address on the reverse
so that ml can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits. .; .. ~~
1. Artlcl
.. .
.
C'\ ~ 'S.\<. i.. i'\
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2. Article Number
(Transfer from servfce fabeI)
!I'"l"!'l' 'l'IH'1I 'I'{'t' 'l'I~'>>I1\i!J81'1lf'4btfM~R004
COMPLETE THIS SECTION ON DELIVERY
,
Agent
o AddresseE
3. Service Type
lX. Certified Mail 0 Express Mail
o Registered ~etum ReceIpt for MerchandisE
o Insured Mail 0 't.O.D.
4. Restricted Delivery? (Extra Fee) Yes
7004 1350 0005 4659 3077
102595-02-M-154
Domestic Return Receipt
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Real Estate Sale # 14
On December 13,2005 the Sheriff levied upon the
defendant's interest in the real property situated in
Upper Allen Township, Cumberland County, PA
Known and numbered as 807 South Market Street,
Mechanicsburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: December 13,2005
By:<J~ f iAALtl
~
~
~
Real Estate Sergeant
-
\(:\1'<;/ (-lJO~BBI
'J~JJ-~f\h~ ?,\],o.:,::\"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-1831 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EQUITY ONE, INC. D/B/A POPULAR FINANCIAL
SERVICES, LLC., Plaintiff (s)
From VICTOR B. STEZIN AND SUZANNE M. STEZIN
(I) 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $294,080.61
Interest FROM 4/7/05
L.L. $.50
Ally's Comm %
Ally Paid $139.14
Plaintiff Paid
Date: SEPTEMBER 30, 2005
Due Prothy $1.00
Other Costs
erof.~
(Seal)
By:
Deputy
REQUESTING PARTY:
Name JANET L. GOLD, ESQUIRE
Address: EISENBERG, GOLD & CETTEL, P.C.
9 TANNER STREET - WEST ENTRY
HADDONFIELD, NJ 08033
Attorney for: PLAINTIFF
Telephone: 856-795-0351
Supreme Court ID No. 38100
"LEGAL DESCRIPTION"
ALL THAT CERTAIN tract of land situated in Upper Allen Township,
Cumberland County, Pennsylvania, bounded and described as follows:
'BEGINNING at a point located on the eastern right of way line of South
Market Street (50 foot right of way) at a common point with lands now
or formerly of Mechanicsburg Area Joint School System, thence from
said point, along said right of way, North 49 degrees 55 minutes 42
seconds West a distance of 8.28 feet to a point; thence along the
same, along a curve, curving to the right with a radius of 1121.18
feet, an arc distance of 160.00 feet to a point; thence along lands
now Or formerly of Larry M. and Jean A. Roth, North 72 degrees 15
minutes 00 Seconds East a distance of 201.84 feet to an iron pin;
thence along lands now or formerly of Mechanicsburg Area Joint School
System, South 16 degrees 46 minutes 00 seconds East a distance of
150.50 feet to a point; thence along the same, South 73 degrees 26
minutes 00 seconds West a distance of 119.59 feet to the point of
beginning.
Said area described containing 0.558 acres.
HAVING THEREON erected a two story frame dwelling and other improvements.
\
BEING THE SAME PREMISES which Charlotte E. Hertzler, widow, by deed
dated October 27, 1994 and recorded October 31, 1994 in the CUmberland
County Office of the Recorder of Deeds in Deed Book 114, Page 98
granted and conveyed to Victor B. Stezin and Suzanne M. Stezin,
husband and wife.
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You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder.
You may find out the price by calling (856) 795-0351.
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 if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call (856) 795-0351.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner
of the property as if the sale never happened.
5. You have a 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 will bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the Sheriff on April 10,
2006. This schedule will state who will be receiving the money. The money will be paid out in
accordance with this schedule unless exception (reasons why the proposed distribution is wrong) is
filed with the Sheriff within ten (10) days after April 10, 2006.
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
HA VEA LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
4m Floor - Cumberland County Courthouse
Carlisle, P A 17013
"
J
JANET L GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI. P.C.
9 Tanner Street - West Entry
Haddonfield. New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Attorney J.D. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A
FINANCIAL SERVICES, LLC
Plaintiff,
vs.
NOTICE OF SHERIFF'S SALE OF REAL
PROPERTY
VICTOR B. STEZlN AND
SUZANNE M. STEZlN
Defendant.
TO: Suzanne M. Stezin
11361 Capistrano Court
Fort Myers, FL 33908-4034
Your house (real estate) at 807 South Market Street, Mechanicsburg, P A 17055, is scheduled
to be sold at Sheriff's Sale on March 8, 2006 at 11 :00 a.m. in the Cumberland County Sheriff's
Office, One Courthouse Square, Carlisle, Pennsylvania to enforce the judgment of 294,080.61
obtained by Equity One, Inc., d/b/a Popular Financial Services, LLC.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Equity One, Inc. or its attorney Janet L. Gold,
Esquire the back payments, late charges, costs and reasonable attorneys fees due. To find out how
much you must pay, you may call (856) 795-0351.
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 the stop the sale through other legal proceedings.
~
"LEGAL DESCRIPTION"
ALL THAT CERTAIN tract of land situated in Upper Allen Township,
cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a point located on the eastern right of way line of South
Market Street (50 foot right of way) at a common point with lands now
or formerly of Mechanicsburg Area Joint School System, thence from
said point, along said right of way, North 4S degrees 55 minutes 42
seconds West a distance of 8.28 feet to a point; thence along the
same, along a curve, curving to the right with a radius of 1121.18
feet, an arc distance of 160.00 feet to a point; thence along lands
now Or formerly of Larry M. and Jean A. Roth, North 72 degrees 15
minutes 00 seconds East a distance of 201.84 feet to an iron pin;
thence along lands now or formerly of Mechanicsburg Area Joint School
System, South 16 degrees 46 minutes 00 seconds East a distance of
150.50 feet to a point; thence along the same, South 73 degrees 26
minutes 00 seconds West a distance of IIS.59 feet to the point of
beginning.
Said area described containing 0.558 acres.
HAVING THEREON erected a two story frame dwelling and other improvements.
\
BEING THE SAME PREMISES which Charlotte E. Hertzler, widow, by deed
dated October 27, ISS4 and recorded October 31, 19S4 in the CUmberland
County Office of the Recorder of Deeds in Deed Book 114, Page S8
granted and conveyed to Victor B. Stezin and Suzanne M. Stezin,
husband and wife.
.,'
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3. You may also be able to the 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.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder.
You may find out the price by calling (856) 795.0351.
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 if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call (856) 795.0351.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner
of the property as if the sale never happened.
5. You have a 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 will bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the Sheriff on April 10,
2006. This schedule will state who will be receiving the money. The money will be paid out in
accordance with this schedule unless exception (reasons why the proposed distribution is wrong) is
filed with the Sheriff within ten (10) days after April! 0, 2006.
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
HA VEA LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
4th Floor. Cumberland County Courthouse
Carlisle, PA 17013
JANITL.GO~-
I.,J,
/
JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETIEI, P.C.
9 Tanner Street - West Entry .
Haddonfie1d, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Attorney 1.D. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A POPULAR! NO. 05-1831
Plaintiff,
vs.
NOTICE OF SHERIFF'S SALE OF
REAL PROPERTY
VICTOR B. STEZIN AND
SUZANNE M. STEZIN
Defendant.
TO: Victor B. Stezin
807 South Market Street
Mechanicsburg, PA 17055
Your house (real estate) at 807 South Market Street, Mechanicsburg, P A 17055, is scheduled
to be sold at Sheriff's Sale on March 8, 2006 at 11 :00 a.m. in the Cumberland County Sheriff's
Office, One Courthouse Square, Carlisle, Pennsylvania to enforce the judgment of 294,080.61
obtained by Equity One, Inc., d/b/a Popular Financial Services, LLC.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Equity One, Inc. or its attorney Janet L. Gold,
Esquire the back payments, late charges, costs and reasonable attorneys fees due. To find out how
much you must pay, you may call (856) 795-0351.
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.
,~
6. Name and address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
Name
Address
Cumberland County Tax Claim Bureau 1 Courthouse Square
Carlisle, P A 170 1~3
7. Name and address of every other person of whom the Plaintiff has knowledge
who has any interest in the property which may be affected by the sale:
Name
Address
Tenant(s)
807 South Market Street
Mechanicsburg, PA 17055
I verify that the statements made in this Affidavit are true and correct to the best of
my personal knowledge or information and belief. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. !l4904 relating to unsworn falsification to
authorities.
SWORN TO AND SUBSCRIBED
BEFORE E T IsJl_ DAY
OF , 2005.
~
NOTARY PUBLIC
SHERRIB."'A~~
NOTARY PUBUC OF NEW JERSF{
Commission Expires 2/10/2G09
Suzanne M. Stezin
11361 Capistrano Ct.
Fort Myers, FL 33908.4034
2. Name and address of Defendants in the judgment:
Name
Address
Victor B. Stezin
98 Center Road
Newville, PA 17241
Suzanne M. Stezin
11361 Capistrano Ct.
Fort Myers, FL 33908-4034
3. Name and last known address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name
Address
Cumberland County Tax Claim Bureau 1 Courthouse Square
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
Name
Address
Household Realty Corporation
25 Gateway Drive
Gateway Square - Suite 107
Mechanicsburg, P A 170S5
Equity One, Inc., d/b/a Popular
Financial Services Corporation
121 Woodcrest Road
Cherry Hill, NJ 08003
5. Name and address of every other person who has any record lien on the
property:
Name
Address
Cumberland County Tax Claim Bureau 1 Courthouse Square
Carlisle, PA 17013
Domestic Relations
1 Courthouse Square
Carlisle, P A 17013
-
..... . ...
JANET 1. GOLD, ESQUIRE
EISENBERG, GOLD & CETTEI, P.C.
9 Tanner Street - West Entry
Haddonfield, New Jersey 08033
(856) 795-0351
Attorney for Plaintiff
Attorney 1.0. #38100
File No. EF-503-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
EQUITY ONE, INC., D/B/A POPULAR i NO. 05-1831
FINANCIAL SERVICES, LLC
Plaintiff,
vs.
AFFIDAVIT PURSUANT TO RULE
3129.1
VICTORB. STEZIN AND
SUZANNE M. STEZIN
Defendant.
STATE OF NEW JERSEY
COUNTY OF ~
ss.
Equity One, Inc., d/b/a Popular Financial Services, LLC, Plaintiff in the above-
captioned matter, sets forth as of the date of the Praecipe for the Writ of Execution was filed,
the following information concerning the real property located at 807 South Market Street,
Mechanicsburg, P A 17055 (see copy of the description attached hereto as Exhibit A).
1. Name and address of owner(s) or reputed owner(s):
Name
Add ress
Victor B. Stezin
98 Center Road
Newville, PA 17241
"
Levy
Surcharge
Postage
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
15.00
40.00
.78
341.00
287.60
21.05
25.00
39.50
$ 901.25
Sworn and subscribed to before me
2006, A.D.
S~"/ ~.
r~~~
R. Thomas Kline, Sheriff
By,j~/~
Real Estat Sergeant
c...J<-cJ.<Y'-
.]0 .I!D
J.~1)
~ 5' 35O,'{
/Z..-. /'7713:1
Equity One, Inc. d/b/a Popular Financial
Services, LLC
VS
Victor B. Stezin and Suzanne M. Stezin
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2005-1831 Civil Term
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that
on January 11,2006 at 3:15 o'clock PM, he served a true copy of the within Real Estate
Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the
within named defendant, to wit: Victor B. Stezin, by making known unto Victor Stezin,
personally, at 98 Center Road, Newville, Cumberland County, Pennsylvania, its contents
and at the same time handing to him personally the said true and correct copy of the
same.
Shawn Harrison, Deputy Sheriff, who being du1y sworn according to law, states
that on January 09,2006 at 2:23 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 Victor B. Stezin and Suzanne M. Stezin located at 807 South Market Street,
Mechanicsburg, 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
defendant, to wit: Victor B. Stezin, by regular mail to his last known address of 98
Center Road, Newville, PA 17241. This letter was mailed under the date of January 12,
2006 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being du1y sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on March 8, 2006 at 10:00 o'clock A.M. He sold the same for the
sum of $1.00 to Attorney Janet Gold for Equity One, Inc. It being the highest bid and
best price received for the same, Equity One Inc. of 121 Woodcrest Road, Cherry Hill,
NJ 08003 being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of
$901.25.
Sheriff's Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Certified Mail
$30.00
17.68
15.00
15.00
30.00
10.00
.50
1.00
18.48
3.66
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND } SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriffs Deed in which Eauitv One Inc is the grantee the same having been sold to said grantee on
the 8th day of March A.D., 2006, under and by virtue of a writ Execution issued on the 30th day of fu;m,
A.D., 2005, out of the Court ofCornmon Pleas of said County as of Civil Term, 2005 Number 1831, at
the suit ofEauitv One Inc dba Popular Fin Serv LLC against Victor B Stezin & Suzanne M is duly
recorded in Deed Book No. 273, Page 4637.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this
10
day of
~
,
, A.D. 0 ~
11?4I\v t!J ~ d , M'~
I I' Recorder of Deeds
_llIDood1.~OaurIW.ClIIIIlI.M
MyCOull.ll . .............".:2b7D
,..~.,.w.,._'
..
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
Michael Morrow, being duly sworn according to law, deposes and says:
That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of
the Commonwealth of Pennsylvania, with its principal office and place of business at 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 exacdy as printed and published
in their regular daily and/or Sunday! Metro editions which appeared in the 24th and 31st day(s) of January and
the 7th day(s) of February 2006. 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, Page 317.
PUBLICATION
COPY
SALE#14
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
.
.
.
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16,1929), P. L.1784
STATE OF PENNSYL VANIA :
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly swom, 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,
V1Z:
January 20, 27, February 3, 2006
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 tme.
,
o AND SUBSCRIBED before me this
day of Febmarv. 2006
;":<,~""""&"",,,,,",,,,,",~,,"bIQtal'Y. -"'...""""'.....
~, NOTARiAL SlAl
~ .
, LOiS E SNYDER, Notary Public
~ Ca'iis!e Bora, Cumberland Count.'
~ \'~'; ;'>':,:"::ni",~jor'i Expires Ma~t:h S, 200!1
',^",-,,,"","',"""":'.'''.O~h...~_:;'',,,-,,,~,,'',.LV'' "
-. WNW .... 110. 14
Writ No. 2005-1831 Civil
Equity One, Inc. d/b/a
Popular Financial Services, LLC
vs.
Victor B. Stezin and
Susan M. Steztn
Atty.: Janet Goid
"LEGAL DESCRIPTION"
ALL TIfAT CERTAIN tract of iand
situated in Upper Allen Township.
Cumberland County, Pennsylvania,
bounded and described as follows:
BEGINNING at a point located on
the eastern right of way line of South
Market Street (50 foot right of way)
at a common point with lands now
or formerly of Mechan1csburg Area
Joint School System, thence from
said point, along said right of way,
North 49 degrees 55 minutes 42
seconds West a distance of 8.28 feet
to a point; thence along the same.
along a CUlve. curving to the light
with a radius of 1121.18 feet, an
arc distance of 160.00 feet to a
point; thence along lands now or
fennerly of Larry M. and Jean A.
Roth, North 72 degrees 15 minutes
00 seconds East a distance of
201.84 feet to an iron pin; thence
along lands now or formerly of
Mechanicsburg Area Joint School
System, South 16 degrees 46 min-
utes 00 seconds East a distance of
150.50 feet to a point: thence along
the same, South 73 degrees 26 min-
utes 00 seconds West a dIstance of
119.59 feet to the pOint of begln-
nlng.
Said area described contalnlng
0.558 acres.
HAVING THEREON erected a
two story frame dwelling and other
improvements.
BEING THE SAME PREMISES
which Charlotte E. Hertzler. widow.
by deed dated October 27. 1994
and recorded October 31. 1994 in
the Cumberland County Office of the
Recorder of Deeds in Deed Book
114. Page 98 granted and conveyed
to Victor B. Stez1n and Suzanne M.
Stezin. husband and wife.