HomeMy WebLinkAbout02-1878.*
Jay C. Scheinfield, Esquire
Atty. I.D. 23880
8234 West Chester Pike
Upper Darby, PA 19082
(610) 853-0300
BANK ONE, NA
N54 W13600 Woodale Drive
Menomonee Falls, WI 53051
Plaintiff
vs.
MARY M. JONES
406 N. Bedford Street
Carlisle, PA 17013
Defendants
Attorney for Plaintiff
COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
NO. C).?- -- /? 7?
C! u t ?-
CIVIL ACTION - LAW
NOTICE TO DEFEND
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
C:Ashare\Documents\Bank One\Complain ts\Notice To Defend\Cumberland.doc
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas
en las paginas siguientes, usted tien veinte (20) dias de plazo al partir de la fecha de la demanda
y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y
entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su
persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la
demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor
del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted
puede perer dinero o sus propiedades u otros derechos importantes para usted.
Lleva esta demanda a un abogado inmediatamente. Si no tiene abogado o si no tiene el
dinero sufficiente de pagar tal servicio. Vaya en persona o Ilame por telefono a la oficina
cuya direccion se encuentra escrita abajo para averiguar donde se puede consequir
asistencia legal.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT YOU ARE ADVISED THAT THIS
LAW FIRM IS DEEMED TO BE A DEBT
COLLECTOR ATTEMPTING TO COLLECT A
DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
Jay C. Scheinfield, Esquire
Atty. I.D. 23880
8234 West Chester Pike
Upper Darby, PA 19082
(610) 853-0300
BANK ONE, NA
N54 W13600 Woodale Drive
Menomonee Falls, WI 53051
Plaintiff
Attorney for Plaintiff
COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs. NO. 0 a - l P'ad'
MARY M. JONES
406 N. Bedford Street
Carlisle, PA 17013 CIVIL ACTION - LAW
Defendant
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff is
BANK ONE, NA
N54 W13600 WOODALE DRIVE
MENOMONEE FALLS, WI 53051
2. The name(s) and last known address(es) of the Defendant(s) are:
MARY M. JONES
406 N. Bedford Street
Carlisle, PA 17013
ef-u
Who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On September 30, 1999 mortgagor(s) made, executed and delivered a mortgage upon the
premises hereinafter described to Bank One, NA which mortgage is recorded in the
Office of the Recorder of Cumberland County. A true and correct copy of the mortgage
is attached as Exhibit "A."
4. The mortgage secures defendant(s) certain note dated September 30, 1999 in the amount
of $67,625.00, payable to plaintiff in monthly installments with simple interest at the rate
of 8.880 percent per annum. A true and correct copy of the note is attached as Exhibit
A"
5. The mortgage covers the real estate known as 406 N. Bedford Street, Carlisle, PA 17013
and described more fully in the Mortgage, which premises continue to be owned by
Defendant(s).
6. The mortgage and note are in default because monthly payments of principal and interest
upon said note and mortgage mortgage due April 5, 2001 and each month thereafter are
due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make
such payments after a date specified by written notice sent to Mortgagor, the entire
principal balance and all interest due thereon are collectible forthwith. A copy of such
default notice is attached as Exhibit "B."
7. The following amounts are due on the mortgage:
Principal Balance
Interest
4/5/01 through 2/28/02
(Per Diem $16.3882)
Attorney's Fees
Late Charges
Title Search
TOTAL
$67,361.60
$5,391.72
$3,368.08
$0.00
$100.00
$76,221.40
8. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
9. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
10. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P. S. § 1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "B."
11. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiff s written Notice to Defendants, a
true and correct copy of which is attached hereto as Exhibit `B," or
(ii) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum
of $76,221.40, together with interest from February 28, 2002 at the rate of $ per diem to the date
of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure
and sale of the mortgaged property.
for Plaintiff
VERIFICATION
I, Susanne E. Gale, state that I am a foreclosure specialist
for Bank one, the Plaintiff herein, that I am authorized to make
this verification on its behalf, and that the facts set forth in
the foregoing Complaint are true upon my personal knowledge,
information and belief.
I understand that my statements are made subject to 18 Pa.
C.S. Sec. 4904 providing for criminal penalties for unsworn
falsification to authorities.
Date: .3- )q- 002.1 '() 'L ,,
EXHIBIT "A"
• ROBERT P. ZIEGLER •
RECORDER-OF DEEDS
CUMBERLAND COUNTY-PA
t ?Fena.,M.d. '99 OCT 11 =,U,. Li.. F. Remang Dan
OPEN-END MORTGAGE
This Mortgage secures future advances
L DATE AND PARTIES. The date of this Mortgage (Security Instrument) is ........... t9gB..e .. Q? ..I X99.... and the
parties, their addresses and tax identification numbers, if required, are as follows:
MORTGAGOR: MW M JONES
UNMARRIED
406 N BEDEW ST
CARLISLE, PA 17013
? If checked, refer to the attached Addendum incorporated herein, for additional Mortgagors, their signatures and .
acknowledgments.
LENDER: BANK ONE, NA
Organized and existing tinder the laws of the United States of America
P.O. BCK 710097
OOIII4E0, CH 43271-0097
2. CONVEYANCE. For good and valuable consideration, the receipt and sufficiency of which is acknowledged, and to secure
the Secured Debt (defined below) and Mortgagor's performance under this Security Instrument, Mortgagor grants, bargains,
conveys and mortgages to Lender the following described property: • •
Refer to exhibit 'A' which is attached hereto and tirade a part hereof.
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The property is located in 0 .................................................... at ................................................
(County)
406.A.B1P F!o12D.nST .............................. ........ ?..fir............................, Pennsylvania .....17.414 ...........
(Address) (City) cm Code)
Together with all rights, easements, appurtenances, royalties, mineral rights, oil and gas rights, all water and riparian rights,
ditches, and water stock and all existing and future improvements, structures, fixtnres, and replacements that may now, or at
any time in the future, be part of the real estate described above (all referred to as "Property").
3. MAXIMUM OBLIGATION LIMIT. The total principal amount secured by this Security Instrument at any one time shall not
exceed $ 67, 625:.QU ..................................... This limitation of amount does not include interest and other fees and
charges validly made put== to this Security Instrument. Also, this limitation does not apply to advances made under the
terms of this Security Instrument to protect Lender's security and to perform any of the covenants contained in this Security
Instrument.
4. SECURED DEBT AND FUTURE ADVANCES. The term "Secured Debt" is defined as follows:
A. Debt incurred under the terms of all promissory note(s), contract(s), guaranty(s) or other evidence of debt described
below and all their extensions, renewals, modifications or substitutions. (When referencing the debts below it is
sngggestea that include items such as borrowers' names, note amounts, interest rates, maturity dotes, etc.)
PRCMISSCRy?N0M DATED SEPfII43M 30, 1999 SEaMW 710 PRINCIPAL AMXW OF
$67, 625.00 AND SIl: W BY MARY M JONES WrM A MA7U XIY DAIS OF OCICWR 5, 2014
PENNSYLVANW -MORTGAGE (NOT FOR FNMA, FNLMC, FHA OR VA USq eooi(3575rAGEx893 IpJQO 1 Or 6)
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B. All future advances from Lender to Mortgagor or other future obligations of Mortgagor to Lender under any promissory
note, contract, guaranty, or other evidence of debt executed by Mortgagor in favor of Lender executed after this Security
Instrument whether or not this Security Instrument is specifically referenced. If more than one.person a*= this Security
Instrument, each Mortgagor agrees that this Security Instrument will am all future advances and future obligations
that are given to or incurred by any out or more Mortgagor, or any one or more Mortgagor and others. All futttre
advances and other future obligations are secured by this Security instrument even though all or part may not yet be
advanced. All future advances and other future obligations are secured as if made on the date of this Security Instrument.
Nothing in this Security Instrument shall constitute a commitment to malm additional or future loans or advances in any
amount. Any such commitment trait be agreed to in a separate writing.
C. All obligations Mortgagor owes to Lender, which may later arise, to the extant not prohibited by law, including, but not
limited to, liabilities for overdrafts relating to any deposit account agreement between Mortgagor and Lender.
D. All additional sums advanced and expenses incurred by Leader for insuring, preserving or otherwise protecting the
Property and its value and any other sums advanced and expenses incurred by Leader under the terms of this Security
Instrument. . . _ _ ....
This Security Instrument will not secure any other debt if Lender fails to give any required notice of the right of rescission.
5. PAYMENTS. Mortgagor agrees that all payments under the Secured Debt will be paid when due and in accordance with the
terms of the Secured Debt and this Security Instrument.
6. WARRANTY OF TITLE. Mortgagor warrants that Mortgagor is or will be lawfully seized of the estate conveyed by this
Security Instrument and has the right to grant, bargain, convey, sell, and mortgage the Property. Mortgagor also warrants that
the Property is unencumbered, except for encumbrances of record.
7. PRIOR SECURITY INTERESTS. With regard to any other mortgage, deed of trust, security agreement or other lien
document that created a prior security interest or encumbrance on the Property, Mortgagor agrees:
A. To make all payments when due and to perform or comply with all covenants.
B. To promptly deliver to Lender any notices that Mortgagor receives from the holder.
C. Not to allow any modification or extension of, nor to request any future advances under any note or agreement secured
by the Lien document without Lender's prior written consent.
S. CLAIMS AGAINST TITLE. Mortgagor will pay all taxes, assessments, Rena, encumbrances, lease payments, ground rants,
utilities. and-other charges relating-to the Property when due. Lender-may requite Mortgagor to provide to I andtc copies of all
notices that such amounts are due and the receipts evidencing Mortgagor's payment. Mortgagor will defend title to the
Property against any claims that would impair the lien of this Security iastrumem. Mortgagor all to assign to Leader, as
requested by Leader, any rights, claims or defenses Mortgagor may have against patties who supply labor or materials to
maintain or improve the Property.
9. DUE ON SALE OR ENCUMBRANCE. Lender may, at its option, declare the entire balance of the Secured Debt to be
immediately due and payable upon the creation of, or contract for the creation of, any lien, eocumbanoe, truster or sale of die
Property. This right is subject to the restrictions imposed by federal law (12 C.F.R. 591), as applicable. This covenant shall
run with the Property and shall retrain in efface until the Secured Debt is paid In fulland this Security Instrument Is released.
10. PROPERTY CONDITION, ALTERATIONS AND INSPECTION. Mortgagor will keep the Property in good condition and
make all repairs that are reasonably necessary. Mortgagor shall not commit or allow any waste, impairment, or deterioration of
the Property. Mortgagor will keep the Property free of noxious weeds and grasses. Mortgagor all; that the nature of the
occupancy and use will not substantially change without Lender's pr}or written consent. Mortgagor will not permit any change
in any license, restrictive covenant or easement without Iender's prior vM" ? lootisent. Mortgagor will notify Lender of all
demands, proceedings, claims and actions against Mortgagor, and of any loss or damage to the Property.
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Lender or Lender's agents may, at Lender's option, enter the Property at any reasonable time for the purpose of inspecting the
Property. Lender shall give Mortgagor notice at the time of or before an inspection specifying a reasonable purpose for the
inspection. Any inspection of the Property shall be entirely for Lender's benefit and•Mortgagor will in no way rely on
Lender's inspection.
11. AUTHORITY TO PERFORM. If Mortgagor fails to perform any duty or any of the covenants contained in this Security
Instrument. Lender may, without notice, perform or cause thed to be performed. Mortgagor appoints Leader as att6racy in
fact to sign Mortgagor's name or pay any amount necessary for performance. Lender's right to perform for Mortgagor shall
not create an obligation to perform, and Lender's failure to perform will not preclude lender from ems rising my of Leader's
other tights under the law or this Security Instrument. If any construction on the Property is discontinued or not carried on in a
reasonable manner, Lender may take all steps necessary to protect Lender's security interest in the Property, including
completion of the construction.
12. ASSIGNMENT OF LEASES AND RENTS. Mortgagor irrevocably grants, bargains, conveys and mortgages to Lender as
additional security all the right, title and interest In and to any and all existing or finum leases, subleases, and any other written
or • verbal- agreements for the use and'' oecupaacy of any portion of the •Pmpwty, including any extenilons, renewals,
modifications or substitutions of such agreements (all referred to as "Leases') and rents, issues and profits (all referred to a:
"Rents"). Mortgagor will promptly provide Lender with true and correct copies of all existing and futttre T.eaaes. Mortgagor
may collect, receive, enjoy and use the Rents so long as Mortgagor is not in default under the terms of this Security
Instrument.
Mortgagor agrees that this assignment is immediately effective between the parties to this Security instrument and effaaive as
to third patties on the recording of this Security Instrument, and this assignment will remain effective until the Obligations we
satisfied. Mortgagor agrees that Leader is entitled to notify Mortgagor or Mortgagor's tenants to take payments of Rents due
or to become due directly to Lender after such recording, however Leader agrees not to notify Mortgagor's tenants until
Mortgagor defaults and Lender notifies Mortgagor of the default and demands that Mortgagor and Mortgagor's tenants pay all
Rents due or to biota due directly to Lender. On receiving notice of default.' Mortgagor will endorse and deliver to Leader
any payment of Rents in Mortgagor's possession and will receive any Rents in trust for Lender and will not commingle the
Rents with any other funds. Any amoimts collected will be applied as provided in this Security Instrument. Mortgagor warrants
that no default exists under the Leases or any applicable landlord/tenant law. Mortgagor also agrees to maintain and require
any tenant to comply with the terms of the Leases and applicable law.
13. LEASEHOLDS; COND0hWG IMS; PLANNED UNIT DEVELOPMENTS. Mortgagor agrees to comply with the
provisions of any lease if this Security instrument is on a leasehold. If the Property includes a unit in a condominium or a
planned unit development, Mortgagor will perform all of Mortgagor's duties under the covenants, by-laws, or regulations of
the condominium or planned unit development.
14. DEFAULT. Mortgagor will be in default if any party obligated on the Secured Debt fails to make payment when due.
Mortgagor will be in default if a breach occurs under the terms of this Security Instrument or any other document exacted for
the purpose of creating, securing or guarantying the Secured Debt. A good faith belief by Leader that Leader at any time is
insecure with respect to any person or entity obligated on the Secured Debt or that the prospect of any payment or the value of
the Property is impaired shall also constitute an event of default.
15. REMEDIES ON DEFAULT. In some instances, federal and state law will require Iender to provide Mortgagor with notice
of the right to cure or other notices and may establish time schedules for foreclosure actions. Subject to these limitations, if
any, Lender may accelerate the Secured Debt and foreclose this Security Instrument in a manner provided by law if Mortgagor
is in default.
At the option of Lender, all or any par of-the agreed fees and charges, accrued interest and principal shall become immediately .
due and payable, after giving notice if required by law, upon the occurrence of a default or anytime thereafter. In addition,
Lender shall be entitled to all the remedies provided by law, the terms of the Secured Debt, this Security Instrument and any
related documents. All remedies are•distinct, cumulative and not exclusive, and the Leader is entitled to all remedies provided
at law or equity, whether or not expressly set forth. The acceptance by Leader of any sum in payment or partial payment on
the Secured Debt after the balance is due or is accelerated or after foreclosure proceedings are filed shall not constitute a waiver
of Lender's right to require complete cure of any existing default. By not exercising any remedy on Mortgagor's default,
Lender does not waive Lender's right to later consider the event a default if it continues or happens again.
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16. EXPENSES; ADVANCES ON COVENANTS; ATTORNEYS' FEES; COLLECnoN COSTS. Except when prohibited
by law, Mortgagor agrees to pay all of Lender's expanses if Mortgagor breaches any covenant in this Security Inswtent.
Mortgagor will also pay on demand any amount incurred by Leader for Insuring, inspecting, preserving or otherwise
protecting the Property and Leader's security interest. These exposes will bear intoeat from the date of the payment until paid
in fWl at the highest interest rate in effect as provided in the terms of the Secured Debt. Mortgagor agrees to pay all coats and
expenses incurred by Lender in collecting, enforcing or protecting Lender's rights and remedies under this Security Instrument.
This amount may include, but is not limited to, attorneys' fees, court costs, and other legal expenses. This Security Instrument
shall remain in effect until released. Mortgagor agrees to pay for any recordation costs of such release.
17. ENVIRONMENTAL LAWS AND HAZARDOUS SUBSTANCES. As used in this section. (1) Environmental Law means,
without limitation, the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, 42 U.S.C. 9601
or seq.), and all other federal, state and local Iaws, regulations, ordinances, court orders, attorney general opinions or
interpretive letters concerning the public health, safety, welfare, environment or a hazardous substance; and (2) Hazardous
Substance means any toxic, radioactive or hazardous material, waste, pollutant or contaminant which has characteristics whicb
render the substance dangerous or poteatially dangerous to the public health, safety, welfare or environment. The term
includes; without limitation, any substances defined as "hazardous material,: .toxic substances,. "bxmrdous waste' or
"hazardous substance' under any Environmental Law.
Mortgagor represents, warrants and agrees that:
A. Except as previously disclosed and acknowledged m writing to Linder, no Hazardous Substance Is or will be located,
stored or released on or in the Property. This restriction does not apply to small quantities of Hazardous Substances that
are generally recognized to be appropriate for the normal use and maintenance of the Property.
B. Except as previously disclosed and acknowledged in writing to I ender, Mortgagor and every tenant have been, are, and
shall remain in full compliance with any applicable Environmental Law.
C. Mortgagor shall immediately notify Leader if a release of threatened release of a Hazardous Substance occurs on, under
or about the Property or there is a violation of any Environmental Law concerning the Property. In xwh an event,
Mortgagor shall take all necessary remedial action in accordance with any Environmental Law.
D. Mortgagor shall immediately notify Leader in writing as soon as Mortgagor has reason to believe these is any pending or
threatened investigation, claim, or proceeding relating to the release or threatened release of any Hazardous Substance or
the violation of any Environmental Law.
18. CONDEMNATION. Mortgagor will give Leader prompt notice of any pending or threatened xxion, by private or public
entities to purchase or take any or all of the Property through condemnation, eminent domain, or my other means. Mortgagor
authorizes Lender to intervene in Mortgagor's name in any of the above described actions. or claims. Mortgsgor.assigns to
leader the proceeds of any award or claim for damages connected with a condemnation or other taking of all or any part of the
Property. Such proceeds shall be considered payments and will be applied as provided in this Security Instrument. This
assignment of proceeds is subject to the terms of any prior mortgage, deed of trust, security agreement or other lien document.
19. INSURANCE. Mortgagor shall keep Property insured against loss by fire, flood, theft and other hazards and risks reasonably
associated with the Property due to its type and location. This insurance shall be maintained in the amounts and for the periods
that Lender requires. The insurance carrier providing the insurance shad be chosen by Mortgagor subject to Leader's approval,
which shall not be unreasonably withheld. If Mortgagor fails to maintain the coverage described above, I.ender may, at
Leader's option, obtain coverage to protect Lender's rights in the Property according to the terms of this Security Instrument.
All insurance policies and renewals shall be acceptable to Lender and shall include a standard "mortgage clanae0 and, where
applicable, "loss pays clause." Mortgagor shall immediately notify Lender of cancellation or termination of the insunana.
Leader shall have the right to bold the policies and renewals. If Lender requires. Mortgagor shall immediately give to Leader
all receipts of paid premiums and renewal notices. Upon loss, Mortgagor shall give immediate notice to the Insurance carrier
and Lender. Lender may make proof of loss if not made immediately by Mortgagor.
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Unless otherwise agreed in writing, ,All insurance proceeds shall be applied to the reatozat[on or repair of the Property or to the
Secured I>ebt. whether or not `then; due. at Leader's option. Any application of proceeds to principal shall not extend or
postpone the ,dde date of tiK: scheduled payment nor change the amount of any. payment. Any excess will be paid to. the
Mortgagor. If the Property is .acquired by Lender. Mortgagor's right to any insurance policies and proceeds resulting from
damage to the'Pioperty.beforp ihe•acquisition shall pass to Lender to the extent-of the Secured Debt immediately before the
acquisition. '
20. ESCROW FOR TAXES AND INSURANCE. Unless otherwise provided in a separate agreement, Mortgagor will not be
required to pay to lender funds for taxes and insurance in escrow.
21. FINANCIAL REPORTS AND ADDITIONAL DOCUMENTS. Mortgagor will provide to Lender upon request, any
financial statement or information Lender may deem reasonably necessary. Mortgagor agrees to sign, deliver, and file any
additional documents or certifications that lender rosy consider necessary to perfect, continue, and preserve Mortgagoes
obligations under this Security Instrument and Leader's lien status on the Property.
22. JOINT AND INDWIDUAL.LIABI ITY; CO-SIGNERS; SUCCESSORS AND ASSIGNS BOUND. All-duties under this
Security Instrument are joint and individual. If Mortgagor signs this Security Instrument but does not sign an evidencc of debt,
Mortgagor does so only to mortgage Mortgagor's interest in the Property to secure payment of the Soured Debt and
Mortgagor does not agree to be personally liable on the Secured Debt. If this Security Instrument secures a guaranty between
Leader and Mortgagor, Mortgagor agrees to waive any rights that may prevent Leader from bringing any action or claim
against Mortgagor or any party indebted under the obligation. These rights may include, but are sot limited to,. my
and-deficiency or one-action laws. Mortgagor agrees that Lender and any party to this Security Instrument may extend, modify
or mare any change in the terms of this Security Instrument or any evidence of debt without Mortgagor's consent. Such a
change will not release Mortgagor from the arms of this Security Instrument. The duties and benefits of this Security
Instrument shall bind and benefit the successors and.assigns of Mortgagor and Lender.
23. APPLICABLE LAW; SEVERABILITY, INTERPRETATION. This Security Instrument is governed by the laws of the
jurisdiction in which lender is located, except to the extent otherwise required by the laws of the jurisdiction where the
Property is located. This Security Instrument is complete and fully integrated. This Security Instrument may not be amended or
modified by oral agreement. Any section in this Security Instrument, attachments, or any agreement related to the Soured
Debt that conflicts with applicable law will not be effective, unless that law expressly or impliedly permits the variations by
written agreement. H any section of this Security Instrument cannot be enforced according to its terms, that suction will be
severed and will not affect the enforceability of the remainder of this Security Instrument. Whenever used, the singular shall
include the plural and the plural the singular. The captions and headings of the sections of this Security Instrument are for
convenience only and are not to be used to interpret or define the terms of this Security Instrument. Time is of the essence in
this Security Instrument.
24. NOTICE. Unless otherwise required by law, any notice shall be given by delivering it or by mailing it by first class mail to
the appropriate party's address on page 1 of this Security Instrument, or to any other address designated in writing. Notice to
one mortgagor will be deemed to be notice to all mortgagors.
25. WAIVERS. Except to the extent prohibited by law, Mortgagor waives any night to appraisement relating to the Property.
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26. OTBER TERMS. If checked, the following are applicable to this Security-hstrunien :
? Line of Credit. The Secured Debt includes a revolving line of credii' tpro6ision. Although the Secured Debt may be
reduced to a zero balance, this Security Instrument will remain in dfca until released.
? C
ondruction Loan. This Security Instrument secures an obligation incurred for the construction of an improvement on
the Property.
? Fixture Filing. Mortgagor grants to Lender a security interest in all goods that Mortgagor owns now or in the future
and that are or will become ftxt urn related to the Property. This Security lnstrument soffieea as a financing statement
and any carbon, photographic or other reproduction nay be filed of roomd for purposes of Article 9 of the Uniform
Commercial Code.
? Purchase Money. This Security Instrument segues advances by Lender used in whole or in part to acquire the
Property. Accordingly, this Security Instrument, and the lien hereunder, is and shall be construed as a purchase money
mortgage with all of the rights, priorities and benefits thereof under the laws of the Commonwealth of Pennsylvania.
? II?CREEST RATE. OWER: TWS DOCUMENT CONTAINS PROVISIONS FOR A VARIABLE
? Alders. The covenants and agreements of each of the riders checked below are incorporated into and supplement and
amend the terms of this Security Instrument. [Check all applicable boxes]
? Condominium Rider ? Planned Unit Development Rider ? Other ..........................................
? Additional Tams.
SIGNATURES: By signing below, Mortgagor, intending to be legally bound hereby, agrees to the terms and covenants contained
in this Security Instrument and in any attachments. Mortgagor also acknowledges receipt of a copy of this Security Instrument on
the date stated on page 1.
.. N.M.1bo ...... 1-1&419 ............................................................................
- - - (Ores) (s4now)
(w,e,in) --- ----- - ....... .......... (Wknm) ....................................
ACKNOWLEDGMENT.
COMMONWEALTH OF..?gT9W. lv#i};a ................... COUNTY OF .
ro+""'° a:
On this, the ............ th.... day of ...... ......
...999 .............l before me,.. •
the undersigned officer, personalty appeared K.. . ,.. .Q1R*AR...........................................
...................................... . ..
........................................... ., known to me (or satisfactorily person(s) whose name(a) is subscribed to the within instrument, recd he/she
for the purposes therein contained. acknowledged that he/she e orlly prom) to be
same
In witness whereof, I hereunto set my hand and off>cial
MY commission expires:
It is hereby certified that the address of the Lender within named is:
.................
01094 Sank" Sv,,n
11001575PAX
•
.'?i?Z?'QR97...
/pays 6 of 6/
I7"
ALL that oertaAouse and
So the olot li
South by y n at '
?. ; mot:
HAVING a trontag
distance of One Hundrei
Parcel #02-20-1800-258
Premium Rate $604.60
Endorsements $150.00
Found situate in the Borough of Carlisle, County of Cumberland and State of
ibed as follows:
State of Robert Miller, deceased, on the East by North Bedford Street; on the
Leonard, Jr., and on the West by an allay.
1 feet on said North Bedford Street and extending in depth at an even width a
120) feet, to said alley on the West
-NVN,X?\ ? 9
eou1575nm .899
(1999094116M)
PAYMENT RIDER
THIS PAYMENT RIDER is made this ..... 3Qth..... day of ......Sel e(a x...992...... and
is incorporated into and shall be deemed to amend and supplement the Mortgage, Deed of Trust or
Security Deed (the "Security Instrument") of the same date given by the undersigned (the
"Borrower") to secure Borrower's Note to .13AS.QNF...NIl...Qa+aarta,and.exa.:tz ........
.=A=.tb .7,W!?.QfAtA.T)kited.Sttt1e .Gf.Av=LVA ........................... (die "Lender")
of the same date and covering the property described in the Security Instrument and located at:
4K.N.> A..S?...QI +xSJ, ,..FA...VQl3 ............................ ._...........................
I Y.ware l N.VL to
I.AL
ADDITIONAL COVENANTS. In addiifion•to the covenantrand-agreements made in the
Security Instrument, Borrower and Lender further cdvenant and agree as follows:
A. SCHEDULED PAYMENTS OF PRINCIPAL AND MTERM '
The Note provides for scheduled payments of principal and interest,as follows:
3. PAYMENTS
(A) Scheduled Payments
C..:
I will pay principal and interest by making payments when scheduled:
III will make ..........3.7.9 ........... payments of $ .534.1% ....................... each on the
..................5th....................... of each ItKi Zh............................................
..................................................... beginning on ...NPV x.5...x992....... .
? I will make payments as follows:
19 In addition to the payments described above, I will pay a "balloon payment" of
$f A.Q90..9.9 ............... on ..Q=ob=..4...203A........ . The Note Holder will deliver or
mail to me notice prior to maturity that the balloon payment is due. This notice will state
the balloon payment amount and the date that it is due.
(B) Maturity Date and Ph" of Payments
I will make these payments as scheduled until I have paid all of the principal and interest
and any other charges described below that I may owe under this Note. My scheduled payments
will be applied to interest before principal. If, on ... MQ1? X..5...MA ........ I still owe amounts
under this Note, I will pay those amounts in full on that date, which is called the "maturity date."
I will make my scheduled payments at. .................
.Q?.7 -. QQ9:? ...................................... or at a different place if required by the Note Holder.
loage of 21
MULTIPURPOSE FIXED RATE PAYMENT RIDER (MULTISTATE) y1??\
l.Mrs Systmm Inc.. Su Ck 4 MN Pam MPFR•PRS an SAS
aaoK157.5PACk .9QO
1,0k?
B. FUNDS FOR TAXES AND INSURANCE (check one)
O Uniform Covenant 2 of the Security Instrument is waived by the Lender.
0 Uniform Covenant 2 of the Security Instrument is amended to read as follows:
1. The word "monthly" is changed to "scheduled."
2. Paragraph 3 is amended to read as follows:
If the funds held by Lender exceed the amounts permitted to be held by applicable law,
Lender shall account to the Borrower for the excess Funds in accordance with the requirements of
applicable law. If the amount of the Funds held by Lender at that time is not sufficient to pay the
Escrow Items when due, Lender may so notify Borrower in writing, and, in such can Borrower
shall pay to Lender the amount necessary to make up the shortage or deficiency. Borrower shall
make up the shortage or deficiency at Lender's sole discretion, subject to the requirements of
applicable law.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in
this Payment Rider. -
7 1z
uz
y M ...................................... (:o1?
.................................................................................. (seal)
an om
State of Pennsylvania
County of Cumberland 00
Recorded in the office for the recording of baeft
ect berland Coumy,
e3
in _erl =rag
witne y hand lot
Carlisle, Mjbis days fill..-
a.wm sVM. ace. &L aoud. MN sam MPMPNS atafe
' r
00Ki575Pace: Sol
ow" 3 of ?/
I ,
P.O. BM 10 M o N # 1870031754
14? N ECF Sr I Loan Number
P.O. HCnC 710097 406
COUA , CH 43271-0097 CARI ME, PA 17013 Date September 30. 1
Matter" Dale
LENDER'S KUM AND ADDIS Loan Anaunt
'You' means de Lander. its wceaaors and Y Rrewd of
WRR01NER7 NAME AND ADDRESS
TERMS FOLLOWING A ? APPLY ONLY IF CHECKED '1• kdlldes each Borrower above, jeindy and severely.
Secondary Mortgags Loan
This agr..m«it Is subject to the prov(slons of the Secondary Mortgage Loan Act.
For vale raealwd. I promise to pay to Vou at Your address Raw above the PMNCIPAL can at SIXW SEVEN 71i7[SM SIX Rirrt:ID
TWENTY MM and 3101100+' * e e e e r t e e e. a+ e DolWa167,625,00
abgle Adrian. I wrie re, 1 el of this principal rim on OctS. 99-4 . No additional advances are contampland under this now.
? Nipple Advance. The Principal win shown above is the maximum amount of principal 1 can borrow under this row. On
t will receive the amount of 1 and ham principal advances we plated.
You and I spree that I may borrow up to themarunum ody one time tend subject to all other conditional.
Condtlorn: The conditions for future advances we
MEREST: I agree to pay interest on the outstanding pri nciod toWee from October 5. 1999 at the
raw of 8.880 % pr yon until OCIUM 5. 2014
O V.Ilebis Raw: Notice to borrower: This document Ocntslrr provisions for a varlaMe btteret rate. This raw may then change
as stated below.
Choose Dave: Each date on which the interest raw may canoe le called a Clang. Date. The interest raw may change
and on every
The hdea: Beginning with the final Chenille Data. the Interest raw wIE be based on the following
thereafter.
The moat Vaunt Index value avelable N of the data O 4e days ? before each Change Dow
is called the "Current Index.'
Cmk brim of Clangs: Before each Change Data. the Lo der we celalWa the Interest raw, which will he
the Clrrem Index. The result of the calculation will be rounded
. The new Interval;
raft we become aR.edwe on each Change Dow. Subject to any limitations below, this we be the new Interest raw until the next Charge Dow.
Lidftaam-. The Interest raft will newer be Wagner then % or lass then %.
? The interest rate will navy dumps on WW single Change Dam by mors dust %.
Effect of Variable Red A charge in the merest rem we have the effect of charging the smoum of the scheduled luymums:
ACCRUAL METHOD: 1. to at will be calculated an a actual /365 basis.
POST MATURITY RATE: I agree to pay inherent on Me unpshd balance of this now owing after mnuritV, and until paid In full, as stated below:
21 on the sum fixed or variable ram basis m effect befea maturity lea indicated above).
? at a ram equal to
IR LATE CHARGE I agree to pay • Into charge on the panlon of arq, payment made more Men 15 days der m le dus equalta 5.000%
of the late Dawient
? ADOITxfigAL CHARGES: M addition to but reat. 1 agree to pay the following charges which Ore Ora not bahmded lo the PrYalsat amount
above:
PAYMENTS: I agree to env this now as follows:
179 payments ar $538.64 each on the 5th of each Depth beginning cn November 5, 1999
m ad&ticn to the payments described above, I will pay a 'balloon payment' of $54,000.99 on
October 5, 2014.
SECURITY: This now In secured by Idssorbe s quesw dowmmm by type lcq. mortg.gel and dam1:
MMUWM TO S== DEBT DATED SEMEM3ER 30. 1999 S'E7MIEU M = 29=PAL Ah4XW OF
$67.625.00
ADDITIONAL Made:
PURPOSE: The purpose of this ban is conelfner • REF2*=
Signal re far Lander
REAL ESTATE NOTE
gig". HMI, iMa aYSet aweenm. Nor. iL CWA MN r eMyA MII M WP IIGWIWA
SIGNATURES: 1 AGREE TO THE TERMS OF THIS NOTE (INCLUDING
THOSE ON PAGE 21. 1 have recelvsd a copy on redeye dew.
ea11.,s
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1saMt
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6
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eaW Masan
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` ? raw t of tl
EXHIBIT "B"
LAW OFFICES
JAY C. SCHEINFIELD .. '??
ATTORNEY AT LAW
8234 WEST CHESTER PIKE
UPPER DARBY, PA 19082
*LL.M..TAXATION (610)853-0300
FAX (610)853-3458
September 14, 2001
Mary M. Jones
406 N. Bedford Street
Carlisle, PA 17013
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on our home is
in default, and the lender intends to foreclose. Specific
information about the nature of the default is rovided in the
attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be
able to help to save your home
This Notice explains how the program works
To see if HEMAP can help, you must MEET WITH A CONSUMER
CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS
NOTICE. Take this Notice with you when you meet with the
Counseling Agency.
The name, address and phone number of Consumer Credit
Counseling Agencies serving your County are listed at the end of
this Notice. If you have any questions, you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397..
(Persons with impaired hearinq 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.
1
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO
COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER
ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA r.LAMADO "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
Mary M. Jones
406 N. Bedford Street
Carlisle, PA 17013
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER
001-000024-18700-31754
Bank One
Bank One
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 the end of this
Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF
YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING
YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO
CURE YOUR MORTGAGE DEFAULT EXPLAINS HOW TO BRING YOUR MORTGAGE
UP TO DATE.
2
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of
the consumer 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 of this meeting. The names, addresses and
telephone numbers of designated consumer credit counseling
a encies 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 postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO
SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN
THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY
AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage
assistance are very limited. They will be disbursed by the Agency
under the eligibility criteria established by the Act. The
Pennsylvania Housing Finance Agency has sixty (60) days to make a
decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have
met the time requirements see forth above. You will be notified
directly by the Pennsylvania Housing Finance Agency of its
decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A
PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS
FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED A
AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for
Emergency Mortgage Assistance.)
3
HOW TO CURE YOUR MORTGAGE DEFAULT (Brie it up to date)
NATURE OF DEFAULT - The MORTGAGE debt held by the above lender on
your property located at:
406 N. Bedford Street, Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the
following months and the following amounts are now past
due:
Payment of $538.64 per month for the months of April
2001 through September 2001
Other charges (explain/itemize):
Late Fees: N/A
TOTAL AMOUNT PAST DUE: $3,231.84
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use
if not applicable):
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 $3,231.84, PLUS ANY MORTGAGE
PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments must be made either by cash, cashier's
check, certified check or money order made payable and sent to:
Bank One
You can cure any
within THIRTY (30)
if not applicable.)
Not applicable.
C/O Jay C. Schein£ield, Esquire
8234 West Chester Pike
Upper Darby, PA 19082
other default by taking the following action
DAYS of the date of this letter: (Do not use
4
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the" default
within THIRTY (30) DAYS of the date of this Notice, the lender
intends to exercise. its rights to accelerate the mortgage debt.
This means that the entire outstanding balance of this debt will
be considered due immediately and you may lose the chance to pay
the mortgage in monthly installments. If full payment of the
total amount past due is not made within THIRTY (30) DAYS, the
lender also intends to instruct its attorneys to start legal
action to foreclose upon your mortgaged property.
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 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 if
they exceed $50.00. Any attorney's fees will be added to the
amount you owe the lender, which may also include other reasonable
costs. If you cure the default within the THIRTY (30) DAY period,
you will not be required to ay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for
the unpaid principal balance and all other sums due under the
mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have
not cured the default within the THIRTY (30) DAY period and
foreclosure proceedings have begun, you still have the right to
cure the default and prevent the sale at any time up to one hour
before the Sheriff's Sale. You may do so b 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 Sheriff's
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 restore your mortgage to the
same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the
earliest date that such a Sheriff's Sale of the mortgage property
could be held would be approximately five (5) months from the date
of this Notice. A notice of the actual date of the Sheriff's 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.
5
HOW TO CONTACT THE LENDER:
Name of Lender:. Bank One
Address: P.O. Box 2071
Milwaukee, WI 53201.
Phone Number: (800) 576-6730
Fax Number: (262) 502-6749
Contact Person: Brian Biernat
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 may or 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 PAY OFF THE
MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION
TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON
YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN
ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO
SUCH ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
6
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THIS PURPOSE. UNLESS YOU NOTIFY THIS OFFICE
WITHIN THIRTY (30) DAYS AFTER RECEIVING THIS NOTICE THAT YOU
DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, THIS
OFFICE WILL ASSUME THE DEBT IS VALID. IF YOU NOTIFY THIS OFFICE
IN WRITING WITHIN THIRTY (30) DAYS OF RECEIVING THIS NOTICE, THIS
OFFICE WILL OBTAIN VERIFICATION OF THE DEBT OR OBTAIN A COPY OF A
JUDGMENT, IF ANY, AND MAIL YOU A COPY OF SUCH VERIFICATION OR ANY
JUDGMENT. IF YOU REQUEST, THIS OFFICE WILL PROVIDE YOU WITH THE
NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE
CURRENT CREDITOR.
Sent Certified Mail No. 7001-0360-0002-8959-7847 and First Class
mail
cc: Philip Briganti, Esquire
7
PENNSYLVANIA HOUSING PINANCE AGENCY
HOMEOWNER'S MORGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
CCCS of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
Community Action Comm of the Capital Region
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
FAX (717) 234-2227
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St
Gettysburg, PA 17325
(717) 334-1518
FAX (717) 334-8326
R LAW OFFICES
JAY C. SCHEINFIELD
ATTORNEY AT LAW
8234 WEST CHESTER PIKE
UPPER DARBY, PA 19082
*LL.M.,TAXATION
March 22, 2002
DIRECTIONS TO SHERIFF
TO: SHERIFF OF CUMBERLAND COUNTY:
RE: BANK ONE, NA
Plaintiff
vs.
MARY M. JONES
Defendant NO.
Please serve the Defendant, Mary M. Jones, at the following address:
406 N. bedford Street
Carlisle, PA 17013
Date: Jay C. Scheinfield, Esquire
8234 West Chester Pike
Upper Darby, PA 19082
(610) 853-0300
(610)853-0300
FAX (610)853-3458
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SHERIFF'S RETURN - REGULAR
CASE NO: 2002-01878 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK ONE NA
VS
JONES MARY M
RONALD HOOVER Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
MARY M
the
DEFENDANT , at 0909:00 HOURS, on the 26th day of April , 2002
at 1405 BOILING SPRINGS RD
CARLISLE, PA 17013 by handing to
MARY M JONES
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 4.83
Affidavit .00
Surcharge 10.00
.00
32.83
Sworn and Subscribed to before
me this IA14- day of
,Z A. D.
1 i Yl J , I t?
r t onotary
So Answers:
R. Thomas Kline
04/29/2002
JAY C SCHEINFIELD
By:
?/i?aYla«" L ??aO+"1
Deputy She iff
Jay C. Scheinfield, Esquire
Atty. I.D. No. 23880
8234 West Chester Pike
Upper Darby, PA 19082
(610) 853-0300
Attorney for Plaintiff
BANK ONE, NA COURT OF COMMON PLEAS
N54 W13600 Woodale Drive CUMBERLAND COUNTY
Menomonee Falls, WI 53051 PENNSYLVANIA
Plaintiff
vs.
MARY M. JONES
406 N. Bedford Street
Carlisle, PA 17013
Defendant (s)
CIVIL ACTION - LAW
NO. 02-1878
PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Please enter a Judgment by Default in favor of Plaintiff and
against the Defendant for her failure to plead to the Complaint in this
action within the required time. The Complaint contains a Notice to
Defend within twenty (20) days from the date of service thereof. The
Defendant was served with the Complaint on April 17, 2002, and her
answer was due to be filed on May 7, 2002.
Attached is a copy of Plaintiff's written Notice of Intention to
File Praecipe for Entry of Default Judgment which, I certify, was mailed
by regular mail to the Defendant at her last known addresses on May 20,
2002, which is at least ten (10) days prior to the filing of this
Praecipe.
Please assess damages as follows:
Principal $ 67,361.60
Interest from 4/5/01 thru 6/10/02 $ 7,079.69
Attorney's Fees $ 3,363.08
Title Search $ 100.00
Real Debt 77,904.37
Plus continuing interest, attorneys' fees, and of er sts and
charges collectible under the mortgage and for for osup ?and sale
of the mortgaged property. r--1 ?1 _/ /
A*t- aey for Plaintiff /
AND NOW, /7 ? judgment is entered in faavvoorr of the
Plaintiff and against De endant and damages are assessed as above in the
sum of $
Prothonotary
I
JAY C. SCHEINFIELD, ESQUIRE
Attorney I.D. #23880
8234 West Chester Pike
Upper Darby, PA 19082
(610) 853-0300
BANK ONE, NA
N54 W13600 Woodale Drive
Mail Station Wll-4031
Menomonee Falls, WI 53051
Plaintiff
VS.
MARY M. JONES
406 N. Bedford Street
Carlisle, PA 17013
Defendant (s)
TO: MARY M. JONES
1405 Boiling Springs Road
Carlisle, PA 17013
DATE: May 20, 2002
(COPY
Attorney for Plaintiff
: COURT OF COMMON PLEAS
CUMBERLAND COUNTY
: PENNSYLVANIA
CIVIL ACTION - LAW
NO. 02-1878
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, 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:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
l L%'
for Plaintiff
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, AND
ANY INFORMATION OBTAINED WILL BE USED FOR DEBT COLLECTION
PURPOSES.
Jay C. Scheinfield, Esquire
Atty. I.D. No. 23880
8234 West Chester Pike
Upper Darby, PA 19082
(610) 853-0300
BANK ONE, NA
N54 W13600 Woodale Drive
Mail Station WI1-4031
Menomonee Falls, WI 53051
Plaintiff
COURT OF COMMON PLEAS
COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
VS.
MARY M. JONES
406 N. Bedford Street NO. 02-1878
Carlisle, PA 17013
Defendant
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DELAWARE
: Ss
I, JAY C. SCHEINFIELD, Esquire, being duly sworn according to
law, deposes and says that I represent the Plaintiff in the above
entitled case; that I am authorized to make this affidavit on
behalf of the Plaintiff; that the above named Defendant is over 18
years of age; that the last known address of Defendant is 1405
Boiling Springs Road, Carlisle, PA 17013; that the occupation of
Defendant is unknown; and Defendant is not in the Military Service
of the United States, nor any State or Territory thereof or its
allies as defined in the Soldiers' Civil Relief Act of 1940 and the
amendments thereto.
I, Jay C. Scheinfield, Esquire
depose and say that the facts
set forth in this Affidavit of
Non-Military Service are true
and correct and acknowledge that
I am subject to the penalties of
18 P.S. 4904 relating to unsworn
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Caption:
BANK ONE, NA
vs.
MARY M. JONES
TO THE PROTHONOTARY OF THE SAID COURT:
( ) Confessed Judgment
( ) Other
File No. 02-1878
Amount Due $77.904-37
Interest from June 17, 2002
-At*&
-c-os"
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland
for debt, interest and costs, upon the following described property of the defendant(s)
County,
Description of property is attached.
PRAECIPE FOR ATTACHMENT EXECUTION
County for debt, interest and
ty
issue writ of attachment to the Sheriff of ,
costs, as above, directing attachment against the above-named garnishee(s) for the following property
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the saia garnisneets).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate )of the
defendant(s) described in the attached exhibit.
Date September 6 2002 Signature:
Print Name:
Address: 8234 West Chester Pike
Upper Darby, PA 19082
Attorney for: Bank One NA
Telephone: (610) 853-0300
PRAECIPE FOR WRIT OF EXECUTION
(if real
Supreme Court ID No.:
(over)
Notes: If real property, supply six copies of description including improvements and an original and copy of
affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
P
ff
To index writ, file separate praecipe with writ.
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BANK ONE, NA COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY
vs. PENNSYLVANIA
MARY M. JONES
Defendant(s)
CIVIL ACTION
NO. 02-1878
LEGAL DESCRIPTION
ALL that certain house and lot of ground situate in the Borough of
Carlisle, County of Cumberland and State of Pennsylvania, bounded .
and described as follows;
ON the North by property of the Estate of Robert Millet, deceased, on
the East by North Redford Street; on the South by lot o£ ground of
Bene R. Leonard, Jr., and on the West by an alley.
HAVING a frontage of Twenty (20) feet on said North Bedford Street
and extending in depth, at an even width a distance of One Hundred
Twenty (120) feet, to said alley on the West.
BEING improved with the Northern half of a double 2 1/2 story fraam
dwelling house, known as and numbered 406 North Bedford Street.
i
PARCEL NO. 02-20-1800-258
BEING the same premises conveyed by deed of Ronald L. Wilson and Barbara J. Wilson
husband/wife dated November 28, 1980 and recorded in the Cumberland County Recorder of
Deeds on November 28, 1980 in Deed Book Volume T29, Page 475, granted and conveyed unto
Mary M. Jones, grantor herein.
Jay C. Scheinfreld, Esquire
Atty. I.D. No. 23880
8234 West Chester Pike
Upper Darby, PA 19082
(610) 853-0300
BANK ONE, NA
Plaintiff
Attorney for Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
MARY M. JONES
Defendant(s)
NO. 02-1878
AFFIDAVIT OF COMPLIANCE WITH ACT 91 OF 1983
I, Jay C. Scheinfield, Esquire, attorney for Plaintiff, do hereby certify that Plaintiff
mailed Defendant(s), Mary M. Jones, a combined Notice of Homeowners' Emergency Mortgage
Assistance Act of 1983 and Notice of Intention to Foreclosure Mortgage, in compliance with the
Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 on September 14, 2001. This
action does not come under Act 6 of 1974, 41 P. S. §101, et seq. since the original mortgage amount
exceeds $50,000.00.
Sworn to and subscri ed before me
this ? day of
2002
for Plaintiff
/ NOTARY PUBLIC
NOTARIAL SEAL
LIZABETH DEE, Notary Public
Upper Darby Tw laware County
M Commission 'As Dec. 22, 2003
0 a O
C flo ..f
q't'r,; M _?:t
jli?
Jay C. Scheinfreld, Esquire
Atty. I.D. No. 23880
8234 West Chester Pike
Upper Darby, PA 19082
(610) 853-0300
BANK ONE, NA
Plaintiff
Attorney for Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
MARY M. JONES
Defendant(s)
NO. 02-1878
AFFIDAVIT OF LAST KNOWN MAILING ADDRESS OF THE DEFENDANT(S)
I, Jay C. Scheinfield, Esquire, attorney for Plaintiff, hereby certify that the precise address of
the Plaintiff is N54 W13600 Woodale Drive, Menomonee Falls, WI 53051; and the precise address
of the Defendant(s), to the best of my knowledge, information and belief is:
1405 Boiling Springs Road
Carlisle, PA 17013
C'
Sworn to and subscribed before me
this day of JcA?
2002
cheinfield, Esquird
v for Plaintiff \ J
,
NOTARIAL SEAL
LIZABETH DEE, Notary Public
UPCo ppeer Darby Twpp., Delaware Coup
M mmi ssion Ex Tres Dec. 22, 2063
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-3
JAY C. SCHEINFIELD, ESQUIRE
ATTY. I.D. #23880
8234 West Chester Pike
Upper Darby, PA 19082
610-853-0300
Attorney for Plaintiff
BANK ONE, NA
Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND, COUNTY
PENNSYLVANIA
vs.
MARY M. JONES
Defendant(s)
NO. 02-1878
AFFIDAVIT PURSUANT TO RULE 3129.1
Bank One, NA, Plaintiff in the above action, 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
406 N. Bedford Street, Carlisle, PA 17013.
1. Name and address of owner(s) or reputed owner(s):
Name Address
Mary M. Jones
1405 Boiling Springs Road
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Name Address
Mary M. Jones 1405 Boiling Springs Road
Carlisle, PA 17013
3. Name and address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Name Address
4. Name and address of the last recorded holder of every mortgage of record:
Name Address
Bank One, NA N54 W13600 Woodale Drive
Menomonee Falls, WI 53051
Conseco Financial CDC 332 Minnesota Street, Suite 610
St. Paul, MN 55101
5. Name and address of every other person who has any record lien on the property.
Name Address
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
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
Tax Claim Bureau of Cumberland County
Address
One Courthouse Square
Carlisle, PA 17013
Darlene Moyer, Tax Collector
Domestic Relations
Sworn to and subscribe before me
this / day of
2002
NO ARY PUBLIC
RIAL SEAL
NO:DEE
LIZABET, Notary Pu
bUc
Upper Darby Delaware Op?ly
M CommlaaE 3 Dec. 22, 2003
P.O. Box 128
Carlisle, PA 17013
13 N. Hanover Street
Carlisle, PA 17013
for Plaintiff
n c=' o
-71
`_
JAY C. SCHEINFIELD, ESQUIRE
ATTY. I.D. 423880
8234 West Chester Pike
Upper Darby, PA 19082
610-853-0300
BANK ONE, NA
vs.
MARY M. JONES
Plaintiff
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION
Defendant (s)
NO. 02-1878
PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED
WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT
REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Mary M. Jones
1405 Boiling Springs Road
Carlisle, PA 17013
Your house (real estate) located at 406 N. BEDFORD STREET, CARLISLE, PA
17013 is scheduled to be sold at the Sheriffs Sale on December 4, 2002 at 10:00 A.M. at
County of Cumberland, One Courthouse Square, Carlisle, PA 17013 to enforce the
courtjudgment of $77,904.37 obtained by Bank One, NA (the mortgagee) against you. If
the sale is continued, the new date will be announced at the time of sale in compliance
with Pa. R.C.P., Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THE SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay,
you may call (610) 853-0300.
2. You may be able to stop the sale by filing a petition asking the Court to strike or
open the judgment, if the judgment was improperly entered. You may also ask the Court
to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice below on how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder.
You may find out the price bid by calling (610) 853-0300.
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 (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the
owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the
Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the Sheriff
within thirty (30) days from the date of the sale. The schedule shall be kept on file with
the Sheriff, and will be made available for inspection in the Sheriff's office. 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 filing of the schedule of
distribution.
7. You may also have other rights and defenses, or ways, of getting your home back,
if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
BANK ONE, NA COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY
vs. PENNSYLVANIA
MARY M. JONES
CIVIL ACTION
Defendant(s)
LEGAL DESCRIPTION
NO. 02-1878
ALL that certain house and lot of ground Situate in the Borough of
Carlisle, County of Cumberland and State of Pennaylvania, bounded
and described as follows;
ON the North by property of the Satate of Robert Mille, deceased, on
the East by North Bedford Street; on the South by lot of ground of
Dene R. Leonard, Jr., and on the West by an alley.
HAVING a frontage of Twenty (20) feet on said North Bedford Street
and extending in depth,at an even width a distance of One Hundred
Twenty (120) feet, to said alley on the West.
BEING improved with the Northern half of a double 2 1/2 story frame
dwelling house, known as and numbered 406 North Bedford Street.
i
PARCEL NO. 02-20-1800-258
BEING the same premises conveyed by deed of Ronald L. Wilson and Barbara J. Wilson
husband/wife dated November 28, 1980 and recorded in the Cumberland County Recorder of
Deeds on November 28, 1980 in Deed Book Volume T29, Page 475, granted and conveyed unto
Mary M. Jones, grantor herein.
C
for Plaintiff
n
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fr)
3
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N002-1878 Civil
CIVIL ACTION-LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BANK ONE, NA, Plaintiff (s)
From MARY M. JONES, 1405 BOILING SPRINGS ROAD, CARLISLE, PA 17013,
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $77,904.37 L.L. $.50
Interest FROM JUNE 17, 2002
Arty's Comm % Due Prothy $1.00
Ally Paid $104.83 Other Costs
Plaintiff Paid
Date: SEPTEMBER 10, 2002
CURTIS R. LONG
Prothonota
(Seal)
? ?-
By: 2e e
Deputy
REQUESTING PARTY:
Name JAY C. SCHEINFIELD, ESQUIRE
Address: 8234 WEST CHESTER PIKE
UPPER DARBY, PA 19082
Attorney for: PLAINTIFF
Telephone: 610-853-0300
Supreme Court ID No. 23880
JAY C. SCHEINFIELD, ESQUIRE
ATTY. I.D. #23880
8234 West Chester Pike
Upper Darby, PA 19082
610-853-0300
Attorney for Plaintiff
BANK ONE, NA COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
MARY M. JONES
Defendant(s) NO. 02-1878
AFFIDAVIT OF NOTIFICATION
Jay C. Scheinfield, Esquire, first having been duly affirmed according to law, deposes
and says that on or about the 25th day of October, 2002, he notified all lien creditors and any
other parties listed in the 3129.1 Affidavit of the Sheriff s Sale in the above-captioned action.
Notification was sent by regular mail. The 3877 Certificate of Mailing is attached hereto.
Affirmed and subscribed to
before me this 3Aa day of
Je4? 2002.
Azlxd?; C?" -
NOTARY PUBLIC
NOTARIAL SEAL
SANDRA R. HOCKING, NOTARY PUBLIC
NEWTOWN TWP., DELAWARE COUNTY
i Mr COMM16810N uplus MARCH 7, 2004
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JAY C. SCHEINFIELD, ESQUIRE
ATTY. I.D. #23880
8234 West Chester Pike
Upper Darby, PA 19082
610-853-0300 Attorney for Plaintiff
BANK ONE, NA COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL DIVISION
MARY M. JONES
Defendant (s)
NO. 02-1878
PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED
WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT
REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Mary M. Jones
1405 Boiling Springs Road
Carlisle, PA 17013
Your house (real estate) located at 406 N. BEDFORD STREET, CARLISLE, PA
17013 is scheduled to be sold at the Sheriffs Sale on December 4, 2002 at 10:00 A.M. at
County of Cumberland, One Courthouse Square, Carlisle, PA 17013 to enforce the
court judgment of $77,904.37 obtained by Bank One, NA (the mortgagee) against you. If
the sale is continued, the new date will be announced at the time of sale in compliance
with Pa. R.C.P., Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THE SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay,
you may call (610) 853-0300.
2. You may be able to stop the sale by filing a petition asking the Court to strike or
open the judgment, if the judgment was improperly entered. You may also ask the Court
to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice below on how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
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 by calling (610) 853-0300.
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 (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the
owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the
Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the Sheriff
within thirty (30) days from the date of the sale. The schedule shall be kept on file with
the Sheriff, and will be made available for inspection in the Sheriff's office. 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 filing of the schedule of
distribution.
7. You may also have other rights and defenses, or ways, of getting your home back,
if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
C) ?, n
UY p G.) _
y`t
.h7 a7
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 Sheriff's Deed in which Bank One N A is the grantee the same having been sold to said grantee on
the 4th day of Dec A.D., 2002, under and by virtue of a writ Execution issued on the 10th day of Sept,
A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 1878, at
the suit of Bank One N A against Marv M Jones is duly recorded in Sheriff's Deed Book No. 255, Page
1686.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this ( g- day of
J? -7 A.D.2003
Recorder of Deeds
Bank One, N.A.
VS
Mary M. Jones
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-1878 Civil Term
Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that
on September 19, 2002 at 10:45 o'clock AM, he served a true copy of the within Real
Estate Writ, Notice and Description, in the above entitled action, upon the within named
defendant, to wit: Mary M. Jones, by making known unto Steve Gantz, adult in charge,
at 1405 Boiling Springs Road, Carlisle, Cumberland County, Pennsylvania, its contents
and at the same time handing to him personally the said true and correct copy of the
same.
Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on
October 2, 2002 at 9:50 o'clock A.M., she posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Mary M. Jones located at 406 North Bedford St., Carlisle, Pennsylvania, according to
law.
R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named
defendants to wit: Mary M. Jones, by regular mail to her last known address of 1405
Boiling Springs Road, Carlisle, PA 17013. This letter was mailed under the date of
October 1, 2002 and never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, who being duly 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 Court House, Carlisle, Cumberland
County, Pennsylvania, on December 4, 2002 at 10:00 AM. He sold the same for the sum
of $1.00 to Attorney Jay Scheinfield for Bank One, NA. It being the highest bid and best
price received for the same, Bank One, NA of N54 WI3600 Woodale Drive, Menomonee
Falls, WI 53051, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum
of $647.34, it being costs.
Sheriffs Costs:
Docketing $ 30.00
Poundage 12.69
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 8.28
Certified Mail 2.07
Levy 15.00
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
20.00
223.55
174.55
25.20
25.00
39.50
S 647.34 paid by attorney 01/08/03
Sworn and subscribed to before me Sow l?
This I ' day of R. Thomas Kline, Sheriff
2003, A.D. cam, BY C&,?--' VvLk_ ( k
Prothonotary Real Estate eputy Ck 'iyby
A,
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
Frank J. Epler 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 8'12 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 8'12 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of October and the
5th day(s) of November 2002. 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 ,
.............................
Sworn to and subscribed before 14th day o ov r 2002 A.D.
REAL ESTATE SALE No. 28
Notarial Seal
Writ No 2000-611
Term
Civil
Civil Terry L. Russell, Notary Public
Finance
Co
onset Finance City Of Harrisburg, Dauphin County
My Commission Expires June 6,2006
I
NO ARY PUBLIC
Discount
Consumer
Company f/k/a member, Pennsylvania Association Of Notaries My commission expires June 6, 2006
Green Tree Consumer
Discount Company CUMBERLAND COUNTY SHERIFFS OFFICE
vs
Margaret S. Keever CUMBERLAND COUNTY COURTHOUSE
Atty:Torrence McCabe CARLISLE, PA. 17013
DESCRIPTION
ALL THAT CERTAIN lot or tract of land
situate in the Township of Hampden Statement of Advertising Costs
g
,
County of Cumberland, and State of To THE PATRIOT-NEWS CO., Dr.
Pennsylvania, more particularly bounded For publishing the notice or publication attached
and described as follows according to a
survey of Garrit J. Betz, Registered hereto on the above stated dates $ 172,80
Surveyor, dated January It, 1971, to wit. Probating same Notary Fee(s)
$ 1.75
BEGINNING at a point on the northern line Total $ 1 74
55
of Hampden Avenue, said point being by .
same measured in a southwesterly direction
90.0 feet from the northwest corner of publisher's Receipt for Advertising Cost
Clearview Drive and Hampden Avenue;
thence south 51 degrees 26 minutes West publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general
ci along said northern line of Hampden receipt of the aforesaid notice and publication costs and certifies that the same have
bE Avenue a distance of 72.0 feet to a hub;
thence North 38 degrees 34 minutes West
along the eastern tine of lands now or
formerly of George D. Sauers a distance of
By"""""""""""""
100.00 feet to an iron pipe; thence North 51 """' '
degrees 26 minutes East along the southern
line of lands now or formerly of Robert L.
Knecht and Jack H. Forten, respectively, a
distance of 72.0 feet to a hub; thence South
38 degrees 34 minutes Past along the line of
adjoiner between Lots Jos. 181 and 192 on
the hereinafter ment ed Plan of Lots a
distance of 100.0 feet to a hub, the point
and place of BEGINNING.
BEING Lots No. 191, Block "T' on the Plan
of Clearview Farm recorded W the
Rgcorder's Office of Cumberland comfy,
fewrded in Plan Book 9, Page 13.
HAVING THEREON ERECTED o one
AmY frame dwelling with carport knmwn
imd mmWmred m 4603 `{Wnpdeo Aveam:
PARCEL& 10-21-0279-195.
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L. 11, 784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
OCTOBER 25, NOVEMBER 1, 8, 2002
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE SALE NO. 27
Writ No. 2002-1878 Civil
Bank One, N.A.
vs.
Mary M. Jones
Atty.: Jay C. Scheinfield
LEGAL DESCRIPTION
ALL that certain house and lot of
ground situate in the Borough of Car-
lisle, County of Cumberland and State
of Pennsylvania, bounded and de-
scribed as follows:
ON the North by property of the
Estate of Robert Miller, deceased,
on the East by North Bedford Street:
on the South by lot of ground of
Dene R. Leonard, Jr., and on the
West by an alley.
HAVING a frontage of Twenty
(20) feet on said North Bedford
Street and extending in depth at an
Ro r M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
8 day of NOVEMBER, 2002
LOOS E. SN ER,1"Ctaf'] Public
5,
My fr.n ?sfi ; a3 , &
°
even width a disttanf et of to said n-
dred 'ltwenty
ley on the West.
BEING improved with the North-
ern half of a double 2 1/2 story frame
dwelling house, known as and num-
bered 406 North Bedford Street.
PARCEL NO. 02-20-1800-258-
BEING the same premises con-
veyed by deed of Ronald L. Wilson
and Barbara J. Wilson husband/
wife dated November 28, 1980 and
recorded in the Cumberland County
Recorder of Deeds on November 28,
1980 in Deed Book Volume T29,
Page 475, granted and conveyed
unto Mary M. Jones, grantor herein,
k5
101,