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Home My WebLink About05-3872 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS NATIONAL CITY MORTGAGE COMPANY F/KIA INTEGRA MORTGAGE CORP. PO Box 1820 Dayton, OH 45401-1820 OF Cumberland COUNTY CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. PAMELA R. DLUZESKI Mortgagor and Real Owner 200 South Enola Drive Enola. P A 17025 Defendant Term c' O{ I_f~ ,r 'v --...,....." NooOJ-387:l.. L 0 CIVIL ACTION: MORTGAGE FOF1ECLOSURf 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 the 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 claim in the Complaint of 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMAND ANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSffiLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA, SI USTED NO TIENE UN ABOGADO, V A Y A 0 LLAME POR TELEFONO LA OFICINA FUADA AQUI ABAJO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE P AGARLE A UN ABOGADO, EST A OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 TIDS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE, 1). Call an attorney, For referrals to a qualified attorney calI either ofthe following numbers: 717-243- 9400 or . 2). Call Pennsylvania Housing Finance Agency at 800-342-2397 for a counseling agency in your neighborhood. 3). Visit HUD'S website www.hud.gov/offices/hsg/sfhlecon/econ.cfm for Help for Homeowners Facing the Loss of Their Homes. 4). Call your lender 866-804-7257 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call Carol at 215-825-6329 or fax 215-825-6429, The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418, Please reference our Attorney File Number of NC-0955. Para informacion en espanol puede communicarse con Loretta aI215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE I. Plaintiff is NATIONAL CITY MORTGAGE COMPANY F/KIA INTEGRA MORTGAGE CORP., PO Box 1820, Dayton, OH 45401-1820. 2, The name and address of the Defendant is PAMELA R. DLUZESKI, 63 Ashford Drive, Enola, PA 17025, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On October 02, 1992 mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to CONSOLIDATED MORTGAGE CORP., which mortgage is recorded in the Office ofthe Recorder of Deeds of Cumberland County as Book 1092, Page 840. The mortgage has been assigned to: NATIONAL CITY MORTGAGE COMPANY F/K/A INTEGRA MORTGAGE CORP. by Assignment of Mortgage, which is recorded November 9,1994 in Book 485, Page 827, The Mortgage and Assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g) which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A". 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due April 01, 2005, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 03/01/2005 through 07/31/2005 at 7,7500% Per Diem interest rate at $9.67 Reasonable Attorney's Fee If the Mortgage is reinstated prior to a Sheriffs Sale the Attorney's Fees may be less than this amount based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff reserves its right to collect Attorney's fees of up to 5% of the remaining principal balance ($2,244.82) in the event the Property is sold to a third party purchaser at Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Late Charges from 04/01/2005 to 07/31/2005 Monthly late charge amount at $19.67 Costs of suit and Title Search $44,896.47 $1,479.51 $1,250.00 $78.68 Fees $900.00 $48,604.66 +$18,00 Monthly Escrow amount $136.72 $48,622,66 7. Plaintiff is not seeking a judgment of personal liability (or in personam judgment) against the Defendant in this Action but reserves it's right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge oftheir personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant has not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $48,622,66, together with interest at the rate of $9,67, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms ofthe Mortgage and Pennsylvania law, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property. ~~ G DBECK McCAFFERTY & VER By: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Laura Cauper, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa, C.S. 4904 relating to unsworn falsification to authorities. ./ Date: 1- Z 7 -0') ~C'rr Laura Cauper NATIONAL CITY MORTGAGE COMPANY " I I, , I: " \. 07/13/2085 12:08 /'Z..,)'Cl ': ,'1\ I' I i! I ! i 1626218 KORNERSTONER PAGE 83 r:~K':.t,.t:e' =:n:"I~ ,.r~ l__DooIi... Ill'" ~bi~ llttbt ...., <9d1b.t10 n1nel1-t...o MAD/!: TlllI ,.oND Df Me?' Lord 1m," UlQt&Ptlod. .. h.U1t4ra BETWEEN IIOWAJilD J, nl:J'l1!S ond JUDITlI A. lI1.HRS. huabu"d lInd wih, and FRtW 11. JUNKINS and DOkIS J. JUNkiNS, IlUsUilnd Qlld w1h G.d PAMtU. R. DLUZI!5KI. ain,lo \<tOllltlll, of IhnrlSb1.u"c, Pennsyhllni,a w/TNESS!J.'TH, UI4l i. llloMid4rcaIUl1l../ Sillty~ofle thQusllnd---------- --.----------------.----------~----($~l.OOO.OO)----------~--------- in helM J)l1id, thlll "4m~t vh.,-eof;:' "'PJrebv lUlhr&Qwt-d#ad. tAl Mild DNmor Ilo Mrttr fu"d IXHlllq '" lhl ,aid ,f'fHltt:~ . AU. 'llIAT CElITAIN trsc.t or pllrcel of lend lit Cliett! in &$t p~naboro TIM/nslll,. CUalberl&ruJ Count)', Pann:syhunh, 1l10TIt p!lrtic:u1llrl~ l.Ioundtld And dllscrilllt4.. follows. to Id,t: UOOlNNING .c 8 point. Lhe SolJthwut ,ol"ner of Manor Menu.o. and nut I.lIt,. as .!'Ihown on Conn.c::tlld PIen of Lots ot ArLhur R. kupley, thence lIeslward.1 SB;1cJ Menor Avanue 011. Itundntd fiEt)'-Clv. (lS~) he:L IJn (5) illehe. to l" Sut.a Ro~ lead!n, f1'OlII We.t Feitvitt'ol 1:.0 Sterrtitt'l1 c.",: lbant.e Sou,",WU\ . t....enty-nin. (29) f..,t alone, hid Stete Rood La Lot No. 10 on .lIlIid PIai'll t Ea.stward alon& "Aid Lot No. 10 01'10 Inlndred Dlld fifty (ISO) feet to Fir"t AI lh.nce .tonll, sal...t n:re.t. "1.1."'1 "urt\n~;I15LWat1S l:Ia>tetlty (10) leet to the plttt ", of BEGINMING. COKTAINIHG. t..,.t>t,"n.1,.... (2.9) reet ii' hunL ()II lnll 5\.0\:1I Road 111'14 _.Ilt_niIl_l a10"1I Manbr Avenue pile bundred fifl.y-fi.e (55) end E)"t: (S) :inchu tll FA,...' AUey r l1ein:, e/ituot.d on the Suutheul COI'lIcr Road. Be1Ne Lot No. 11, SocL:1oll Il, 8cc.on1J118 Lo Lhe PIIUI of Lau laid out Brill by Lhe said ^rt.htlt ~. Rupl~y. SBi~ Plan ve1nu r~corded in Ll~ County or Clullborland aforesdd in Record Book O. Vol\Jllle 6, Pale 600. 1l,,'IIINC erected thareon e two a~ Qrle"'half story fre.me sina)_ d_llln, hOll" at N(). 200 Stet_ R~<I, South ET,ol., PA, noW knwto a~ 200 South ERa!a lIr., N. :t " BEING TIlE SAHB PREMISES which Ruth p. Brown, widow, and John L. Shearer MorIon!! K. Shur.t, JlU.,UBnc! and ",He. by DCieV tltlled Jun. 18, 1983 _00 flC' JUJU! 25, 19B5 j,n th. R_eorder of Diledil Offil;:. j,n IInd lor Cu.b.tl.nd o,tIlIl, in DOtId Uook :)1-1, raSo 298, 8nnt~ end c:onlll!ycd unto Ilowerd J. 11\110' ...a' Jc,ul:i th ^. 1111d&, hu.sbal'd and wHe. ami Fred II, JlJllkillA al\d. Dorta J. Jo.lttlLl-. husballd end wLfe, t.he arlJnLors herein. k\~7; r~^^S~~. 8ohool 01.. Cumbo eo.. r., ...t'll.lIu!ESlf.I_1l'tMter1'M D:;.1 0)-"'''''' AIrrl'1 ,!j'~ ""b."P.:a.,I.r Cumto Co, 01,(. Col.,\gt. ~ .,;JJ'..."j~ .TIl~lpot , Cumtl, CP.. ra. jYo 1\,11 "'~. tlWllfw'" o.~ IO-("YL AInt. '3 oS.a,e ftnberlI': Zi.ctl" eu",b Cn. D~L Col.Aft- bo6~ )(35 tA,t 674 NationalCily.., i\lort~;age Co. National City Mortgage Co. A Subsidiary of N21tional City Bank a/Indiana 3232 Newmark Drive. Miamisburg. Ohio 45342 Telephone: (937) 910-1200 Mailing Address: P.O. Box 1820 Dayton, Ohio 45401-1820 June 03, 2005 Pamela R Dluzeski 200 S Enola Dr Enola PA 17025 Loan No. 849024-6 Current Servicer: National City Mortgage Co. 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: 200 S Enola Dr Enola PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) 04/01/2005 - 6/1/2005 and the following amount(s) are now past due: Monthly Payments Late Charges Less Suspense Balance Total Due 1,629.49 1,590.15 39.34 .00- YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) : HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days HOW TO CURE THE DEFAULT of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,629.49, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, cash or money order made payable and sent to: National City Mortgage Co. Attn: Customer Counseling Department 3232 Newmark Dr. Miamisburg, OH 45342 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable) DR672 JCS Page 1 - ACT 91 NOTICE NationalCity@ Ivlort~jage Co, National City Mortgage Co. A Subsidiary 01 National Cily Bank 01 Indiana 3232 Newmark Drive. Miamisburg, Ohio 45342 Telephone: (937) 910-1200 Mailing Address: P.O. Box 1820 Dayton. Ohio 45401-1820 June 03, 2005 Pamela R Dluzeski 63 Ashford Dr Enola PA 17025 Loan No. B49024-6 Current Servicer: National City Mortgage Co. 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: 200 S Enola Dr Enola PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) 04/01/2005 - 6/1/2005 and the following amount(s) are now past due: Monthly Payments Corporate Fees Late Charges Non-Sufficient Funds Other Fees Less Suspense Balance Total Due 1,590.15 .00 39.34 .00 .00 .00- 1,629.49 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) : HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days HOW TO CURE THE DEFAULT of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,629.49, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, cash or money order made payable and sent to: National City Mortgage Co. Attn: Customer Counseling Department 3232 Newmark Dr. Miamisburg, OH 45342 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable) DR670 JCS PAGE 1 ACT 91 NOTICE TAKE ACTION TO SAVE 'lOOl=lHOM'E FROM FORECLOSURE . . - . . .'. . This .18 an offlclarilotlce that thlJ. ~origage ?n your home Is In default, and the lender Intends to Foreclos~. Specific Information about the nature of the default . Is provided In the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help save your home. This Notice explains how the progral]1~ works. To see if HEMAP can help. you must MEET WITH A CONS.I)Mj::R CREDIT COUN- . SELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. TaKet!1!~" .. Notice with you when.youmeet with the Coul1seflng-illlency. ThEHlame. address and phone number of Consumer Credit Couns~lingAgencies serving your County ate included with this No1ice.llvQu have an~stion3h.Yo!l may call the Pennsylvania Housinc;l Fina[lceP.9!~D.9\L!Qlt frc!2.QL1c.900-342-23_97~ (Persons with impaired hearing can_ca!lfZ1Ili'.!H)-J!t@), This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agencv mf'Y 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, rUES AFECTA SU DERECHO A CONTINUAR VIVIEN DO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FI- NANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEOES SERELEGIBLE PARA UN PRESTAMO paR 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 :::~~;-0:C;:fi(;Y f.J'C'F ",":' 'ie'u MAYJ}!.'.];LLGJi:ll"E cDfi.ElNAl'lCtJ1,. ^ JQJIRJ:lQ~1_~__ fFlQ~,~ FQ~-lFG~_:Q_$~ j~;{r 1\ 'cO"~ UI,..'Li\(,,3t': t ._,,,"-,1;-:\1"\\.,::: .,' HUGf.~ .;',;i.;1 !_,C-l,~jCt Vi+<'(' - . --,'--- , ,-..', .. ...,u \"UMPlY WITH THE rROVISIONS OF THE HOMEOWNER'S EMERGENCY ~",)RTGi\GE ASSIST/\r~CE ACT OF 1983 (THE "ACT"), YOll MAY BE ELIGIBLE ,- .,r, "'''ERG'''~I{'>V .."r,~r' . -~ A'S<,;'" "C'" -t.li ~,Wl _' ~HV" ..l'vi n,;J,I,,'L,t:. _ 'lo..'1~ ~~'~j'f ~: · IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAYYOUR MORTGAGE PAYMENTS, AND ~ If: YOU MEET OTHER ELlQIBIUfY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a tempo- rary stay oj forecl0su, e 011 your Illortgage for \!1!rty (3Q) dllYs fromthedat& of this No-', . 'ice. During that time' you mOst arrange and attend a "face-to~face' meeting with one of :ihe consumer credit counseling agenCies ilated at tMerld of this Notice. THIS MEET- ING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORT- GAGE DEFAULT'. EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER GBr;Pll~Q!lNSEL1NG AGENCIES -If you meet ""ith one of the con- . surner credit counseling agencies listed at the end of this notice, the lender may NOT - take action against you for thirty (30) days after the date 01 this meeting. The names. addresses and telephone numbers of deillgnated consumer credit counseling agencies for the cOllil1Y.in..which the Rroperty is located are set forth at H1,LeOl:L9i1l:l[S Notice. It is only necessary to schedule one lace-to-lace meeting. Advise your lender irnmediatejy of your intentions APPLICATION FOR MORTGAGE ASSISTANQJ; - Your mortgage is in default for the reasons set forth laler in this Notice (see following pages for specitic inlonnation 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 applicfltions for the progran1 and they wl1l assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-ta-face nlfJotlng. YOU MUST_FILE YOUR APPLICATION PROMPTlY IF YOI' f"~ -:: ~,~ ::;0 vrilf V0J~' DO ~:C: i= "". .-, __ t'-:HEr: -; :;,.c ;:OCHIC,OS SET FORTH IN THIS IFTIEP.. FORECLOSURE ~.,1(\y nO,nr'~,~8 t,8,t,,;~; " i 11.~" ~'~C'~','E l,:';:;',~.":~!,~.<; .~::..., .-\ND ; '::: t..:-- ;')L.:.~;" 'jrl fGAGE ASSF~Tl\~5CE WILL DE DENiED. '-C-:\t^'\! t k; : ,I)! Yclgt~' )(:c i_1I i; vor)! , , Thuy vilil il'l Ui.'ihli SHi by the Agency undor \110 eligibility criteria ostablished by thfJ Act The Pennsylvania Housing Finance Agency has sixty (60) days to make a decisic!n aftef il receives your application. During that time, 110 foreclosure proceedings will be pursued against you if you have met the time requirements set fOlth above, You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. ;.;..... NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN I3ANKRUPTCY, 'THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO '4(;~c;.,~4lI'~it. (lfyouhll\l9file'dba$fuf)tcy, you can 1;tl1l apply for Emergency Mortgage Assistance.) IFYOU DO NOT CURE THE DEFAULT(see page 11-lfyoudo not cure the default within THIRTY (30) DAYS ofthe date ofthis Notice. the lender Intends to exercise its tights to accelerate the mortqaQe debt. This means that the entire outstanding balance of this debt will be considered due ifTImediately and you may lose the chance to pay the . mortgage in monthly Installments. If full payment of the ~otal amount Pllst'due is not made withi!) THIRTY (30) DAYS; the lender also intends to' instruct its attorneys to start legal action to foreclose upon your mortgage property. '. . IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually it:1curred. upio $50.00. However, if legal proceedings are started agairist you, you will have to pay all . reasonable attorneys' 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 {30J DAY period. you will not be @gllired to lli!Y attorney~~fees. GrljER LD;QER ;:;Et\llEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU still have the rigbt to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so bv payinq the total amountthen past due, plus anY late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale alld_anv other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing aQY_ other requirements under the mortQaQe. Cur- ing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POS~II'l1.~t;$HERIFF'$ SALE DA TE- 1\ is (C'it1;c;\cd tiiitl ii 1(0 earlies! 'I"'Y thD~ ~; U~~~j ~i :'; ,t,'j ;ji ;, >':::\1'2 (II the n;crt~;(::lgt:li l.IIupeny could be held would bp apprcx) mat€:ly FOUR~4) n)0t~~!;~ frorn th~ (idk, of ~'~,;~ :'1otlce. .!\ rl of ~:~c; c;..:;tu;:d ddlt:; oT me < c. :;,.1,1:: iJ' ,-',I" If.' YOll before \I'e ,Ilk. ''of course. the cHllount [Ih'eled to cu'''' (he c]~;fault '."i'lli ifi(lCBsr, rllf~ lon~)er you \/~v,l~ 'n~'; -:,v\ I'ut "d ::' ';., iJt ( ,\ Ii: LiC ~;\_':i' ~\.:[:i lendef . \. /iQlfL-'O CONTACT THE LENDER: Name of Lender: National City Mortgage I\ddl\)ss: 3232 Newmark Dr. Mlamisburg OH 45342 Phone Number: 1.80t).523.8654 . Fax Number: (937) 910-4057 Contact Person: COLLECTIONS DEPT. !:FFECT OF SHERIFF'S SALE - You should realiz.e that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it If you continue to live in the '.~ttec..lb&.S./ile6ff,~.~.iaJa\ll.$ilUo,r~~"l.l;aody,OIJfJ,fU{'liGWli'El_;Qtber 'Wknglngs oou1clbe stllrtedby the1enOOr at anyf:lrne, ASSUMPTION OF MORTGAGE- You mayor may not be able to sell or transfer your home to a buyer or transferee who will assume the mortgage debt. pi ovided that pI! the out.standing payments, chargel.) C\nd attorney's fees and ~o~ts are pail! prior to of'at the sale and thatthe'othiu fEjquitements of the mortgage are satisfi.ed, For additional informa- tiQn please contactlhe.Collectlon Dept..': '. . .., . . .>, YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OF F THIS DEBT. .' TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ONYOUR BE- HALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DE- FAULT HAD OCCURRED, IF YOU CURE THE DEFAULT <HOWF 'fER. YOU CO ~:C; HAVf:: nus HIGHT TO CURE YOUR DEFAULT MORE THAt~ THr~EE TIMES IN MrY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF DEFAULT IN ANY FORECLOSURE PRO- CEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCU- MENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW A. - .(i' ~ ~ --.l -t> ~ (\~ ~ ~'b u .\ () ().\ ~ \::.. ~ 2; () :::'~?I .n ~ (,", ~ -.' ," 1....0 '"i ~ ".' cr-, ~ - SHERIFF'S RETURN - REGULAR CASE NO: 2005-03872 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY MORTGAGE CO ETAL VS DLUZESKI PAMELA R JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DLUZESKI PAMELA R the DEFENDANT , at 1904:00 HOURS, on the 8th day of August , 2005 at 63 ASHFORD DRIVE ENOLA, PA 17025 by handing to PAMELA DLUZESKI a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge 18,00 12.00 ,00 10,00 .00 40,00 So Answe~iJ/_~~ R, Thomas Kline 08/09/2005 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscribed to before me this q day of ~ dpo,s- A,D, if' J ;';<o1{J;::!;;;r - ~ By: ~ eriff GOLDBECK McCAFFERTY & McKEEVER BY: Jose'ph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONAL CITY MORTGAGE COMPANY F/KJA INTEGRA MORTGAGE CORP. PO Box 1820 Dayton, OH 45401-1820 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION LAW PAMELA R DLUZESKl (Mortgagor(s) and Record owner(s)) 200 South Enola Drive Enola, PAl 7025 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 05-3872 CIVIL TERM ORDER FOR JUDGMENT Please enter Judgment in favor of NATIONAL CITY MORTGAGE COMPANY FfKJA INTEGRA MORTGAGE CORP., and against PAMELA R, DLUZESKI for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $49,573.66. \ ' Q I 0., . ,I 'I,' ." _ VbL, I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is NATIONAL CITY MORTGAGE COMPANY FfKJA INTEGRA MORTGAGE CORP, PO Box 1820 Dayton, OR 45401-1820 and that the name(s) and last known addressees) of the Defendant(s) is/are PAMELA R, DLUZESKI, 63 Ashford Drive Enola, PA 17025; \ \, \ GOL BEC;K BY: J eph Attorney "- CAFFERTY & McKEEVER oldbeck, Jr. Plaintiff l ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $44.896.47 Interest from 03/01/2005 through 10/05/2005 $2,117,73 Reasonable Attorney's Fee $1,250.00 Late Charges $118.02 Costs of Suit and Title Search $900,00 Escrow Balance Deficit Monthly Escrow Amount Fees $291.44 +$273.44 +$18.00 $49,573,66 AND NOW, this /{J7# day of ~ , 2005 damages are assessed as above. ,rotZ~ In the Court of Common Pleas of Cumberland County NATIONAL CITY MORTGAGE COMPANY F/K/A INTEGRA MORTGAGE CORP. PO Box 1820 Dayton, OH 45401-1820 Plaintiff vs. PAMELA R. DLUZESKI (Mortgagor(,) and Record Owner(,)) 200 South Enola Drive Enola. PA 17025 No, 05-3872 CIVIL TERM Defendant(') PRAECIPE FOR JUDGMENT THIS LAW FIRM ISA DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT, Enter the Judgment in favor of Plaintiff and against PAMELA R. DLUZESKI by default for want of an Answer. Assess damages as follows: Debt $49,573,66 Interest - 03/01/2005 to 10/05/2005 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default oc,,\,rred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached, R,C,P. 237,1 '., I, \ / L ~ Jo ep . A,. oldbeck, Jr. A ,'rney or Plaintiff LD,'llJJi132 AND NOW , Judgment is entered in favor of NATIONAL CITY MORTGAGE COMPANY F/K/A INTEGRA MORTGAGE CORP. and against PAMELA R. DLUZESKI by default for want of an Answer and damages assessed in the sum of$49,573.66 as per the above certification, Prothonotary >. c1;; I::;: LLI~~:': ( .., ~J ::-:;:;'1,,:' , , , ,--\:.": U.J;.,L {t~::~ F- LL o r- o en Cl !-- (.:- 6 u'''' c..s c:J C-.4 " VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1, That the above named Defendant, PAMELA R. DLUZESKI, is about unknown years of age, that Defendant's last known residence lS 63 Ashford Drive, Enola, PA 17025, and is engaged in the unknown business located at unknown address. 2, That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments, ( r A . \\ ' '. li\ ('\+ ~, ~lm~ , \ j Date: NC-0955 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 29, 2005 TO: PAMELA R. DLUZESIO 200 South Enola Drive Enola, P A 17025 NATIONAL CITY MORTGAGE COMPANY FIK!A INTEGRA MORTGAGE CORP, PO Box 1820 Dayton,OH45401-1820 IN THE COURT OF COMMON PLEAS of Cumberland County CIVll. ACTION - LAW Plaintiff vs. PAMELA R, DLUZESKI (Mortgagor(s) and Record Owner(s)) 200 South Enol. Drive Enola, PA 17025 ACTION OF MORTGAGE FORECLOSURE Term No, 05.3872 CIVIL TERM Defendant(s} TO: PAMELAR.DLUZESIO 200 South Enola Drive Enola, P A 17025 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITI'EN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WlTII TIffi COURT YOUR DEFENSES OR OBJECfIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACf WITHIN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WrrnOUT A HEARING AND YOU MAY WSE YOUR PROPERTY OR OTIlER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE TIffi OFFICE SET FORTII BEWW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO lITRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITII INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 CUMBElU.AND COUNTY BAR ASSOClA TION 2 Liberty Avenue Carlisle, PA 17013 C cCAFFER EVER B' ph A Goldbeck, Jr.. Esq, Attorney for Plaintiff Suite 5000 - Mellon Independence Center 701 Morl<etS_ Philadelphia, fA 19106 215-627.1322 NC-0955 , :rRIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 29, 2005 TO: PAMELA R. DLUZESKl 63 Ashford Drive Enola, P A 17025 NATIONAL CITY MORTGAGE COMPANY FfK/A INTEGRA MORTGAGE CORP, PO Box 1820 Dayton. OR 45401-1820 In the Court of Cornmon Pleas of Cumberland County CIVIL ACTION . LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE VS, PAMELA R. DLUZESKI (Mortgagor( s) and Record Owner( s)) 200 South Enola Drive Enola, P A 17025 Term No, 05-3872 CIVIL TERM Defendant(s) TO: PAMELA R. DLUZESKI 63 Ashford Drive Enol., P A 17025 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WIlli TIIE COURT YOUR DEFENSES OR OBJECTIONS TO TIIE CLAIMS SET FORlli AGAINST YOU, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TIIE DATE OF THIS NOTICE, A ruDGMENT MAY BE ENTERED AGAINST YOU WIlliOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OlliER IMPORTANT RIGHTS, YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE TIIE OFFICE SET FORlli BELOW. TInS OFFICE CAN PROVIDE YOU WITII INFORMATION ABOUT lllRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TInS OFFICE MAY BE ABLE TO PROVIDE YOU wrrn: INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERlAND COUNlY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ?JIt~ GOLDBECK McCAFFERTY" McKEEVER BY: Joseph A. Goldbeck. Jr.. Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Rule ot civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NATIONAL CITY MORTGAGE COMPANY FIKIA INTEGRA MORTGAGE CORP. PO Box 1820 Dayton. OH 45401-1820 Plaintiff No. 05-3872 CIVIL TERM vs. PAMELA R. DLUZESKI (Mortgagors and Record Owner(s)) 200 South Enola Drive Enola, P A 17025 DefendantCs) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. By: ,- / If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 n "" ~ c;,;> 0 C.:::I "- '-'< "-'" -n ~ ~ u ""- c :;:! C') ~ (\; ~ --I iO - ~ 0 CO "3 ~ " T"" E:" 5Q- -., "', ~ ';;(? ~ =- ~..., ':; ~ ~ =.-~ c::' -;:.. ~ -< ~D ~ {;" .< ~ IT r:- Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, JI. Attorney LD, #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONAL CITY MORTGAGE COMPANY F/K/ A INTEGRA MORTGAGE CORP. PO Box 1820 Dayton, OH 45401-1820 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW PAMELA R. DLUZESKI (Mortgagor(s) and Record Owner(s)) 200 South Enola Drive Enola, P A 17025 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 05-3872 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 NATIONAL CITY MORTGAGE COMPANY F/K/A INTEGRA MORTGAGE CORP" Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 200 South Enola Drive Enola, P A 17025 l.Name and address ofOwner(s) or Reputed Owner(s): PAMELA R DLUZESKI 63 Ashford Drive Enola, P A 17025 2. Name and address ofDefendant(s) in the judgment: PAMELA R DLUZESKI 63 Ashford Drive Enola, P A 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg, - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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, TENANTS/OCCUPANTS 200 South Enola Drive Enola, PA ]7025 (attach separate sheet if more space is needed) ] verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. ] understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~ '\ (\ DATED: October 5. 2005 i? ", C::::.)o c~;.,;) ,~ o 'n '-I :C_" nl~-..: t--. ;:n C) C') ~-I o ~,'_"J '''' :::::J C) 'l,'n ~::l :i~ .-< Cl /'oJ 05-3872 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD,#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PAl 9106 215-627-1322 Attorney for Plaintiff NATIONAL CITY MORTGAGE COMPANY F/KfA INTEGRA MORTGAGE CORP, PO Box 1820 Dayton, OH 45401-1820 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs, PAMELA R, DLUZESKI Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 200 South Enola Drive Enola, PAl 7025 Term No, 05-3872 CIVIL TERM Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DLUZESKl, PAMELA R. PAMELA R. DLUZESKI 63 Ashford Drive Enola, PAl 7025 Your house at 200 South Enola Drive, Enola, P A 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 08,2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $49,573.66 obtained by NATIONAL CITY MORTGAGE COMPANY FIKIA INTEGRA MORTGAGE CORP. against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to NATIONAL CITY MORTGAGE COMPANY FIKJ A INTEGRA MORTGAGE CORP., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause, 05-3872 CIVIL TERM 3. You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale, (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT 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 bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To find out if this has happened, you may call the Sheriff of7 I 7-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale 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 may bring legal proceedings to evict you, 6. You may be entitled to a share of the money which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 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 LA WYER 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, LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOClA TION 2 Liberty Avenue Carlisle. P A 17013 - - (") r--' 0 c:;:) c- C"...;;,;:> -n ,::...n C c-; -", 0 ~., -- () :.-_5,Tl Co." -, ~--i 0 ~~ -) .-- J',:> Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 ~ Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONAL CITY MORTGAGE COMPANY FIKIA INTEGRA MORTGAGE CORP. PO Box 1820 Dayton, OH 45401-1820 Plaintiff IN THE COURT OF COMMON PLEAS vs. of Cumberland County PAMELA R. DLUZESKI Mortgagor(s) and Record Owner(s) 200 South Enola Drive Enola, PA 17025 CNIL ACTION - LAW Defendant( s) ACTION OF MORTGAGE FORECLOSURE NO. 05.3872 CNIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A, Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiffin this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiffhas complied with all the provisions of the Act. \ Joseph' . " eck, Jr, Attomey"{or' laintiff ,-J Q c, r-' '6 cj1 o CO _-t -- c:' o -n 0- _1_-(1, pl~-- \):"; "---' :i loR o i,l \i)\ --.-\ /.,. :L.. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P,R,C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney LD.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONAL CITY MORTGAGE COMPANY F/KIA INTEGRA MORTGAGE CORP. PO Box 1820 Dayton. OH 45401-1820 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. CIVIL ACTION - LAW PAMELA R. DLUZESKI Mortgagor(s) and Record Owner(s) 200 South Enola Drive Enola, P A 17025 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No, 05-3872 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY, Issue Writ of Execution in the above matter: Amount Due Interest from 03/0 1/2005 to 10/05/2005 at 7.7500% $49,573,66 (Costs to be added) 'Q ~ ~ ~~ ".~ ~o ~U~ ".",0 ~~ ~~ "";;l 0.0 oU ~~ ". ~ <C ~ "" 'r ~,,; ~~ OU U'" "'~ ~O O~ ~o 0$ ;~ 0\5 ~~ ~ "" ~ ~ ,;, ,. ;;:0. ~ ';; ,,'" ... ~ " ~o'~ N~P~ ;:;g$r- _ ., 0..... Op!''''<C . -0 '" p.. ~ "'.s ^ .d.C3~~ ~~~g ~'Og'" 4:. ~M p..~ ~ ~ ". ;;l U ~~ ,..2- O~ ".'$ ~,.. ;>: .. ,. " ~;:. ,..i \.l ~ U 1 ~ .;J,'P " .a "$ ,g".. "O~ os. ,,", <ce ~o ~~ o ~ 'il ",1', t~ .')" ~ ~ -g ~~~.... ~ ~l~? ?:>~rJ1 ~ "i:,"'-'''' p.. I Q,>a.~ e<ft- ~.... '..-! .~("J I\'t~~~...o uS~~J. ~~-.g~ ~,e.0$ '" I r- '$ "0 p.. ~g _if> o " r.,::)'~ J, ALL THAT CERTAIN tract or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more pal1icularly bounded and described as follows, to wit: BEGINNING at a point, the Southwest corner of Manor Avenue and First Alley, as ShO'\\l1 on Connected Plall oLLots of Arthur R. Rupley, thence westward along said Manor Avenue 155 feet 5 inehes to the State Road leading from West Fairview to Sterrett's Gap; thence Southwestwardly 29 feet along said State Road to Lot No.1 0 on said plan; thence Eastward along said Lot No, 10, 150 feet to First Alley. thence along said First Alley Northeastward 70 teet to the place of beginning. CONTAINTNG 29 feet in ti'ont on the State Road and extending back along Manor Avenue 155 feet and 5 inches to First Alley, being si tuated on the Southeast corner of Manor Avenue and the State Road. BEING Lot No. 11, Seetion B, according to the Plan of Lots laid out by the said Arthur R. Rupley, said plan being recorded in the County of Cumberland aforesaid in Record Book 0, Volume 6, page 600, HA VING ereeted thereon a two and one half story frame single dwelling house at No, 200 State Road, South Enola, P A, now known as 200 South Enola Dri ve, Enola, P A , BEING THE SAME PREMISES which Ilowal'd J. Himes a11d Judith A. Himes, husband and wile, Fred H. Junkins and Doris J, Junkins, husband and wife, by deed dated 10/2/90 and recorded 10/6/92 in Book 35X, page 674 in Cumberland County Recorder of Deeds Otlice, granted and conveyed to Pamela R, Dluzeski. single woman. PARCEL NO. 9-15-1291-216 r-' 0 (") .-::::> c: c;;:') -n c....-' -' 0 :r:-n ~ ""I C-)\ \"1'lf-=:. ~ ~ ~ \::~j ""- <>'\ 9,j )\.,:, :-<l ""-. c' ,:1) ~ 0 -- 0 JlJ '6 ':-'I ..~- \ d 'a _ -T'~ ~ 8 8 -'-"'" ,--~-.~~ d 0 ~ 0 ....F? '.:::4 -= -,,", -,~ "- ~ ? f= ' . ,"',.., 6"- ~ '>.... :"l (;:::; :< 2J -'~. (,;) ::d ~ b' = g'J I1v :;:: >C C) ~ [' V- ~ r WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N005-3872 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONAL CITY MORTGAGE COMPANY FIKlA INTEGRA MORTGAGE CORP, PO BOX 1820, DAYTON, OH 45401-1820 Plaintiff (s) From PAMELA R. DLUZESKI, 200 SOUTH ENOLA DRIVE, PA 17025 (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DISCRIPTlON (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 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 helshe has been added as a garnishee and is enjoined as above stated. Amount Due$49,573.66 Interest from 3/1105 to 10/5/05 at 7.7500% L.L.$.50 Atty's Comrn Atty Paid $122.00 Plaintiff Paid Date: Octobert 10, 2005 % Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR. Address: GOLDBECK McCAFFERTY & MCKEEVER MELLON INDEPENDENCE CENTER - SIDTE 5000 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: Plaintiff Telephone: 215-627-1322 Supreme Court ID No. 16132 TRUE COPY FROM RECORD In T(~a"imoIlY whereof, ! hero unto set my ham! and tlla sea 01 said Court t Carlisle Thl day . J.1/U~/~UU:) 10;1U J:<.U ;;:;1:) 0;;:;1 f f'>li I.:rULl).b!:.v!\ ~ vLlJ.U.Dr..l'..L..t~...rlj.u .:lV ~ VV.1.1 VVl. GOLDBECK McCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION SUITE 5000 . MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106.1532 (215) 627-1322 FAX (215) 627.7734 JOSE:PM A. GOlOBECK. JR.. GAR't E. McCAfFERT't' MICHA&. T. McKEEVER November 9, 2005 R. Thomas Kline SHERIFF OF CUMBERLAND COUNTY Sheriff's Office 1 Courthouse Square Carlisle. PA 17013 Cumberland RE: NATIONAL CITY MORTGAGE COMPANY FIK/A INTEGRA MORTGAGE CORP, vs. PAMELA R. DLUZESKI Term No, 05-3872 CIVIL TERM Property address: ./ 200 South Enola Drive Enela, PA 17025 Sheriff's Sale Date: March 08. 2006 Dear Sir/Madam: Kindly stay the Sheriff's Sale with reference to the above-captioned matter and return any unused costs. I collected $44,896.47 in urincipal towards my client's debt. Thank you for your cooperation. Cj~f!Ch tJrJ~1ECK, JR JAG/1mb Nov. 10, 2005 - Original writ returned to the Prothonotary's office. Nov. 10, 2005 - Copy of writ and $1500.00 check (#238557) returned to Attorney Goldbeck's office. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONAL CITY MORTGAGE COMPANY F/KJA INTEGRA MORTGAGE CORP. PO Box 1820 Dayton, OH 45401-1820 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. PAMELA R DLUZESKI (Mortgagor(s) and Record owner(s)) 200 South Enola Drive Enola, PA 17025 No. 05-3872 CIVIL TERM PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs only. ?"~ JOSEPH A. GOLDBECK, JR., ESQUIRE f'j _<J f"" ;-'i... ~, ...-:: en (..;,)