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GERMANTOWN SAVINGS BANK,
Plaintiff
VS.
PETE R. SANCHEZ and
BETTY E. SANCHEZ,
Defendants
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
C O M P L A I N T
1. Plaintiff, GERMANTOWN SAVINGS BANK, is a corporation with an
office at City Line and Belmont Avenues. Bala Cynwyd, PA 19004.
2. Defendants, PETE R. SANCHEZ and BETTY E. SANCHEZ, are adult
individuals whose last known address is 511 State Rd., West Fairview,
PA 17025.
3. On or about June 23, 1988, the said Defendants executed and
delivered a Mortgage Note in the sum of $19,300.00 payable to YEGEN
EQUITY LOAN CORPORATION, which Note is attached hereto and marked
Exhibit "A".
4. Contemporaneously with and at the time of the execution of the
aforesaid Mortgage Note, in order to secure payment of the same,
Defendants made, executed and delivered to original Mortgagee, a
certain real estate Mortgage which is recorded in the Recorder of
Deeds office of the within County and Commonwealth in Mortgage Book
908, Pg. 883, conveying to original Mortgagee the subject premises.
The mortgage was subsequently assigned to GERMANTOWN SAVINGS BANK as
recorded in the within County in Volume 351, pg. 554 on June 30,
1988. The Mortgage and Assignments are incorporated herein by
reference.
5. The land subject to the mortgage is: 511 State Rd., West
Fairview, PA 17025, and is more particularly described in Exhibit
"B" attached hereto.
6. The said Defendants are the real owners of the land subject to
the Mortgage.
7. The Mortgage is in default due to the fact that Mortgagors have
failed to pay the installment due on September 28, 1993, and all
subsequent installments thereon, and the following amounts are due on
the Mortgage:
(a) Unpaid principal balance
(b) Interest at $4.9437 per day
from 8/28/93 to 4/28/94
(based on contract rate of 11.25%)
(c) Late Charges
(d) Property Search & Appraisal
(e) 5$ Attorney's Commission
TOTAL
$16,039.88
1,201.32
-0-
220.00
873.06
$18,334.26*
*Together with interest at the per diem rate noted in (b) above after
April 28, 1994 and other charges and costs to date of Sheriff's Sale.
The attorney's fees set forth above are in conformity with the
Mortgage documents and Pennsylvania law, and will be collected in the
event of a third party purchaser at Sheriff's Sale. If the Mortgage
is reinstated prior to the sale, reasonable attorney's fees will be
charged that are actually incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
9. Notice of intention to foreclose and to accelerate the loan
balance has been given to the Mortgagors in accordance with Section
403 of Pennsylvania Act No. 6 of 1974, but the Mortgagors have failed
to reinstate the Mortgage in accordance with the provisions thereof.
A COPY of the Notice is attached hereto and made a part hereof as
Exhibit "C".
10. Defendants are not members of the Armed Forces of the United
States of America, nor engaged in any way which would bring them
within the Soldiers and Sailors Relief Act of 1940, as amended.
li. Plaintiff has complied with the procedures required by
Pennsylvania Act 91 of the 1983 (Homeowners' Emergency Mortgage
Assistance Payments Program) and Defendants have either failed to
meet the time limitations as set forth therein or have been
determined by the Housing Finance Agency not to qualify for
assistance.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
against Defendants for the aforementioned total amount due together
with interest at the rate of 11.25% ($4.94 per diem), together with
other charges and costs including escrow advances incidental thereto
to the date of sheriff's Sale and for foreclosure and sale of the
property within described. /112„
By -
eon PLJ . Haller
Attorney for Plaintiff
I. D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
THISAGREEMENT IS SUBJE"YTHE PROVISIONS OFTHE SEC^': 1ARY MORTGAGE LOAN ACT
COMBINATIONTRUTH•I.("NDING DISCLOSURE STATEME,C .'.NO PROMISSORY.NOLLT??E?q-/?? p
the wolda "Waif ard'•yo a Mw to LwK%L TM words "I," "tee" wrd "Mi" rater to borrower and Co•bwrowSy SWINtd8tT1(b1b.0 8
_, rtF?alanoN OF AYOUM FlNANCED AND
ANY NAME • y"n Equity Lawn Corp. Amounts P34 t) Others On My BW
SS "3920 Yarkat St., belts 10 To Public Oman
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BORROWER(S) NAMES AND ADONES;(ES) T°mSYgrca Cuban's
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•W t Faittiawb PA 19025 for TmaEaamrubon6TU
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Abstract Fee ................. 3
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°/s S 20 752.00 S 19 300.00 $ ?A,032.00 for Credit deport Fee ........... S .00
tawiter,1 an ghtrp you a Security Intw"t In the reel..teds located at; To
CITZ"lrr First i .14.089.06
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frePatheal Ml pry oft ear1K 1 will not havc to Day 291104611Y.
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III no dtaob"ra le applicable duty h WS boa [114 Msdud, In
u seaaltyaniongaW mm/7°dW dwelling to
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........ S 141-SAI
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firero• tee eaquisnbn of Wiled construction of that dwelling. Sdrnsdrs buying my Grass Balance on Prior Loan A=rd
horns D may. subjed to corMnbne. D may not a"um• da rarnalndar of the niort• No. S _An
pap•on ins onplhel rums. Not applicable +Arsnrcdlnterest.Bary....... $ -nn
Sea tee Contract documents for any additional Infdrrutbn about nonyYrinent. +Latetharges.hany ......... S -nn
default, any required rpaymrlt In lull before the Scheduled date, ad psp•ymmt Less Refunds, If ay:
rotunda And "curry lndwnL Interest .................. S nn
-c•rrwnaanewsrwe. Credit Lila Ins. Rnn.......... S _nn
. tnerawpe Credit life r ^" is not reaurd to Oblalnuemt arc will not to Pro-
nad agree to pay the addltlonsl cost. YUrasnPa. If provided. Is for
vbed urr"s°I Credit Odabsy Ins. Prem......
Pro" Ins. Pram........... 3 _nn
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tetann atthelameding on the Final Psymnit DueDaterdwlll Cover Only ow life Auto Cdllsbn dCmp.liti . i _nn
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TYPE ? -,WXA7U%E (2) Not Balance on Pr or Loa. I.e..
Qdh want -AldumPadonMYhwourt... ......f -nn
1 Llls BlpPalwe: ri
- nauanca , (3) AmoudCinnNMIDlcdy... ...... $1 7142
.-Pis tYrwn°°rreguWodtobomalntakMbeawbprOaernmagaintb"ola
see reel eetwe described above far the M11n 1•rrn Of We ban. Lmu
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t (1) RvpWFffwo ...........
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ale a"
o
mayutWnealat• (6) AmouotFwrcd 11+2+3-51 •••.S-19w30D,
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rwrnlarts ofoavrage u you reauus,with lo" payable climate) "IWaclwy toyou. IIreby adhorlis your b naka the ddn =Mtl bled at
DEFAULT
Tarr will charge M Interval on the unpaid Principal at IM Me Set With eel" ender "Roma" to P•Y" until my ban is paid In lull.
Nlam WCbweldrigay if of any payinwd w It l do not complywitn arryother into Nols Or the rid properlYnottripWilling
:.r eseaNpt I 10uroaq IPW4pMadsound°dulpatdM~wigba0arrrdue,11youtlatn,anwthedMMryol,artl•splelbnollMtim
.9 proved sA ley notice requiredby rw. t
-?fEymplapa Wsrorr thaheda of An anornery fwoolrttbn, l"lopay ¦ reasonable attorney's fee aauahyinuied DIM 01 abate. N any
°som rMlawealwryou wft youa•[Vllyarel"t wdowc'r1'wawpeness. It wl0 be Paid toth@Drauerpally emnled to IL tee it my
MOMYr SUN- rp, l W" to Pay YM the balance.
CHECK OOIlffiTION CIIAROE
Nl=*Aapspw by Mech. rnpolleDls order of withdrawal. stun draft W wee negotfeblc Instrur we AdthataWrranentrrstumdwdin
• franard fcrwyeenon, l rvlll pry roar • duck crowlelectio?.ns?oelr.r)pc The errCen of I" Charge will be any mount pasta u to you.by any financier
pfr3TiiNi?nrr?AMnwwh:.t,C?-7-•tt? ...•..••.__?;•'••'
abMWdpt dMnereNanm/paYnerdeMeduleNO*"wtoPaymybanblullwanyliar.
YnrrerlMwgswOkAYOuhas rot yet °ern d. YousamawprsOAO rarriprswrrg• of aretreeareCarr swswsshmt.enm.nw,uwrnarmnr n.
psyrrkwael?adataWla kPA -17025 1 6T
•,?iataitlraatlfFl.'dlmt7, v.:raliTlrNatom. . ,.••^ .•.• _
ititadW 0114-8"Past 160 .aspwaraAN all naaneewaadlr4iteaaprwarua -
an the
faosbpflafon w WM h? minaol "Ch•JOCn and wesvtrs parbaodpsa Zarsh. Zvelasioansnl°ordn MUn ale
aareesvdaraaoprwrnsws or drwg" whits atwpad brrywpbbalcrnpc.
1 wlw All maMU1 dp", I ncadng all rights of down end watery, hmmtnd errlnpllole AM all oth W aswrptlwe M Wba to the real e"a
? ?'?'SFr t\I ?j?r?trd !.!1.
(21 No Bamnv an Prior I=. i.e.,
Chat" rant AurMPaoan My Atmutd.........i
tub n 13) AmounlGnnb Me $1 7.112 01
tnawsna 8gnatus: ;
11,294.72 -nn
-pop.rtyw, larsoulnatoe.maimakWbym.boml.ayouaoOMIMolar (11 F.lunearouns .................i
amepe to it, MM aewe described ebM lot pr erdln harm of we ioV. lily. (5) Ropmal hWO Dumps............ i
m.yutuusala• (5)MroatFMnmE(1+2+5-5) .•••i
agoonraMtpAmuloewnnr,rw.w•rul.rarrlwwwu"mndinwh (y)ptnc0jI+2+7+q........... i 19 300 00
•unpnuaoowrpauyourpWn.MN1o?Pyaplaoln?al.)wlaaclo7lo you- I lr1by mupptn you b lrWU the dfh nffwb&M SM.
°ON1gip.rneathm n,tMp„paW nytapaltlur nt.n1fain ero+ruw"Ronuss to Pay" until my ban Is paid M full.
Illam ma he WON ungu Wert auryprymsnt Or H l do rot ON" with ?yourtcoqunrwnsofW. Holm Orthefew POPE My nwltpaps ascul"
DJS Ibts,ilraanee Wlhbalpatwaccrued wvpameithr"witlbsoonrchat ll ywWWa•anar the dean" of.w uplntwn oftheGM
Otto prwbsd heryrotbs requited by few aprw e
?..w?. w p::.N•nv Y I.n areo.aumarl htwt aid os0ucl YOUerptrss.O will to tMpa eons bpaly emtltWd to It _Outer It any
DY tglo b tM' mon Man mY DMI+tM ednduM tapubw Or to pay my ban b tW tl berry tWW
pay in IW shred of aMaduls.
1 hM plwn s moripaps In the MW saute described bbr and Its; oasda Y security for this w any (NUn bYL'
I" Estate (Description) ,
511 State Rd.
.Want paftwiau. PA 17025 ,
Cuaharlaad 4sunty, V. Paittilav Toro.
•Uued look 24-S Page 160 lop.InerWith apnapmemwfmw.lmpa.rnrna.
To upue this loan, l anion to you. and direct any lnsunr to agif to you, any funds which may batch payable through Insurance on the
endorse any dnn This aulpmient lnc4Mee murn or
riwiinwad wamcafffiv uioosW p:mumcre «rtirp.. which 'they be aWlleCo1 N unpaid immumoms bat ce.
1 rwe W eternal rights, ur LWkV all fghts of dora w crdtspt honueend wwtptlona and all others:ernplions retalinp to tlr rw eatale
dsecrbad abon.
•HloiOig o ylr -?•o.?
IpnO mnasepvyyouellsebranch onlse btdatadtM emit prbdpalltgserwlN ananer bepbninpon o6/ag.yea a1lM nts
01 1111% %pt annum on the unpaid fRYpbat soocrdup loth* pm,o - sal A w tonn.l wise mid mwaaM m ttiy pov ? b
-0phnYq On the nisi IS ) 01 Derr Data Yawn ahws and con inuft a1 Ms same au of each following) moan Will my loan Is paid In full.
•APPLWJQ10NOfgp' DM
ciP?a ps" be 41 Me fin asclUed Interval to the ate of pronent w the n nalnder to unpaid Principal except psymtds for cellar
gpomvm -
wi
II you aosept wit payments a pattw psyments, It will not effect any othW rants you he" under this loan.
•BcrrowwQSBanwedmoe'la02 e reOalptoleomolaledcooyof
iris NOTEANDDISCt.O"EST Fwapse toes of Mtrma.
' pe4e-H. ?
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l...Tlhf .:t T ?.?t t.' ? .r .. ... J.?.r,4t'J?. 1n?w\ .e?y7 ??r'• t\ , 1?. ?\Y•
• / ...urn ::'??: '•?..•
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a{..\'- ..L• ..ttyw 'V?_. I• L. .err r ?. ?.. "-T_"-?l? _ ...., .. •M/rMi'
Its
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r.,. a. In IILI'da sweet A COIII•aRAriort. A,t Hel.
042000
?•?t? ?1n?•ettturr, .
CCAC ?N •?
f ube tile day afi? A. D. one thousand mama
hundred and seventy-two (1972) between tlu Corporation by the name,
style and tide of 11. C, WOLBERT, INC., a corporation duly organized and-existing under
and by virtue of the laws of the Commonwealth of Pennsylvania, herainafter called
"Grantor" party of the tine put and PETE R. SANCHM and BETTY E. SANCHLZ, his wife,
of West Fairview, Pennsylvania, hereinafter called
XX 1XXX7jw
MMXXXXXXXXKXKXM)IIRJIxcw Grantees, parties of the other part Milnfgnrill
That the aid Grantor for and in con•
siders6on of the sum of ($3,600.00) THREE THOUSAND SIX HUNDRED -=---------
------------------------t---Dollar', lawful money of the United States, to at in hind paid by she uiJ
Grantees
It she time of the execution herrof, the receipt whenof is hereby acknuwidgd. his treated, bargained, told,
alknd, enfmRd, released and confirmed, and by them presents dues gnn4 lurgain, sell,sUen, enfeotf, slam and
confirm unto the said Grantees, their heirs
and anizns,
all 91111 cm-4i p;cce or parcel of land, situate in the Borough of West Fairview, Cumberland County,
Pennsylvania, bounded and described in accordance with a survey and plan thereof
made by Gerrit J. Batz, Registered Surveyor, dated June 8, 1972, as follows:
BEGINNING at a point on the North side of State Street said point being
ninety-eight and thirty-four one-hundredths (98.34) fact West of that Ndrthwest
comer of State Street and Fairview Street; thence along the North side of State
Street North seventy (70) degrees forty-eight (48) minutes West twenty-five and
sixty-six one-hundredths (25.66) feet to a corner of premises of Homer Fortenbaugh,
known as No. 513 State Street; thence along said premises North nineteen (19)
degrees twelve (12) minutes East one hundred fifty (150) feet to a fifteen (15)
feet vide alley; thence along the same South seventy (70) degrees forty-eight (48)
minutes East twedty-five and sixty-six one-hundredths (25.66) feet to a comer
of premises known as No. 509 State Street; thence along said premises and passing
through the center of a partition wall South dineteen (19) degrees twelve (12)
minutes West one hundred fifty (150) feet to the point and place of BEGINNING.
BEING a part of Lot No. 5 an the connected plan of lots laid out by Arthur R.
Ruplay as recorded in Deed gook "0", Volume 6 page 600 Cumberland County records.
HAVING thereon erected a two and one-half story frame dwelling known as
No. 511 State Street.
BRING a part of the as= premises which Helen N. Hess, widow, by dead dated
April 23, 1962, and recorded in the Office of the Recorder of Deeds in and
for Cumberland County, Pennaylvanite, in Deed Book "H", Volume 20. at page 710
granted and conveyed to H. C. Wolbort, Inc.
. Cumb. Co., Pa.
It Asti Gbl. Tne,lu Is.
1-1 } C..
all. r 4 ? lie \te '_l't}_?
e..e. Cs. Dia. 61. Asa. r
1i
ecoxJ24fiC[ 160
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0"13VT a
December 10, 1993
Mrs. Betty E. Sanchez
511 State Road
-D 4 West Fairview, PA 17025
GOWANMVM SlateJDS B"
Re: Account #998-20-0604-042008
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by Germantown Savings Bank (hereinafter we, us or ours) on your
property located at 511 State Rd., West Fairview, PA 17025 , IS IN SERIOUS DEFAULT
(because you have not made the monthlypaymentsgf222.4Q'orthemonths ofSeptegtber 28,1993
and ad=M:p Mnr. all nayments there after
Late charges (and other charges) have also accrued to this date in the amount of 0.00 . The total amount now required to cure
this default, or in other words, get caught up in your payments, as of the date of this letter, is$ 514.18
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $ 514; 18
plus any additional monthlypaymenu and late charge which mayfall due during_this period. Such payment must be made either
by cash, cashier's check, certified check or money order, and made at any ercantown cravings Bank Brznch
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments.
This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance
to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30)
DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sher(p'to pay off the mortgage debt. If we refer your case to our attorneys,
but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees,
actually incurred, up to 550.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's
fees even if they are over S50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable
costa. Ifyou cure the default within the thirty day period, you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage.
If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure
the default andprevent the sale at anytime up to one hour before the Sherffsforeclosure sale. You may do so bypaying the total
amount ofthe unpaid monthlypaymenu plus any late orothercharges then due, as well as the reasonable attorney'sfees and costs
connected with theforeclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date
that such a Sheriffs sale could be held would be approximatelp-13-i4. A notice of the date of the Sheriff 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
exactlywhatthe required payment will be by calling us atthc following numbero 3:i-bZ 1 4. This paymentmustbeincash, cashier's
check, certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you
continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you.
You have additional rights to help protect your interest in the property. YOU 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. I YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE
PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE
MORTGAGEDEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S
FEES AND COSTS ARE PAID PRIORTO OR ATTHE SALE, ) AND THAT THE OTHER REQUIREMENTS UNDER
THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS
RIGHT MIGHT EXIST). YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF.
If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not
entitled to this right to cure your default more than three times in any calendar year.
IPas Doc No 62769. Had ApnI 27. 1987. 9.00 • m I
Certified rrail P 381 628 i5z
Cony regular ma:l
80-00255 483 ,a.'t1?1O.
December 100 1993
Mr. Pete R. Sanchez
t =?? Z- 511 State Road
. West Fairvic?:l, P.4 17025
GERMANTOtv" SWINGS a" Re: Account 4998-20-0604-042008
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by Gertranta:n Savings Bank (hereinafter we, us or ours) on your
property located at 511 State Rd., West Fairview, PA 1'7025 , IS IN SERIOUS DEFAULT
(becauseyouhave notmade themonthlypaymentsof222.40Iorthemonths ofSeptember 28, 1993
and . and/or because alt p,:: =nt- there afrer
Late charges (and other charges] have also accrued to this date in the amount of u • Uu . The total amount now required to cure
this default, or in other words, get caught up in your payments, as of the date of this letter, is $51; .16
You may cure this default within THIRTY (30) DAYS of the date of this letter, ?by;sp?a`yni?ng? to u?sh the above amount q( $ 914 s 12
plus any additional monthlypaymentsandlate charge which mayfalldued?,r?F?'YY
(rtgtt Ytrat7t?v11" p1 v?tt s catUC°dls? n
by cash, cashier's check, certified check or money order, and made at
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments.
This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance
to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30)
DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. ff the mortgage is
foreclosed your mortgaged property will be sold by the Sherigto pay q(fthe mortgage debt If we refer your case to our attorneys,
but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees,
actually incurred, up to S50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's
fees even if they are over S50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable
Costs. (/'you cure the default within the thirty day period you will not be required to pay attorney's Jett.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage.
If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure
the default and prevent the sale at anytime up to one hour before the Sherifs foreclosum sale. You may do so by paying the total
amount ofthe unpaid monthlypaymentsplus any late orothercharges then due, as well as the reasonable attorney 'sfeesandcosts
connected with theforeclosure sale (and perform any other requirements under the mortgage]. It is estimated that the earliest date
that such a Sheriffs sale could be held would be approximatelyb-13-94 A notice of the date of the Sheriff sale will be sent to you
before the sale. Of course, the amount needed to cure the default will increase the longct you wait. You may find out at anytime
exactly what the required payment will be by calling us at the following number... o o u-n o :. This payment must be in cash, cashier's
check, certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you
continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you.
You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELLTHE PROPERTY
TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER
LENDING INSTITUTION TO PAY OFF THIS DEBT. ]YOU MAY HAVE THE RIGHT TO SELL ORTRANSFERTHE
PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE
MORTGAGEDEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S
FEES AND COSTS ARE PAID PRIOR TO OR AT TH E SALE, ] AND THAT TH E OTHER REQUIREMENTS UNDER
THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS
RIGHT MIGHT EXIST). YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF.
Ifyou cure the default the mortgage will be restored to the same position as if no default had occurred. However, you are not
entitled to this right to cure your default more than three times in any calendar year.
IP,B Doc No 21469. Fdtd Apn11). 1937. 9.00 am l
certified mail ;? 381 :.:u Lol
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COMPANY NAME: GERMANTOWN SAVINGS HANK
VERIFICATION
I verify that the statements made in the foregoing Complaint
are true and correct.
I understand that false statements herein are made subject
to the penalties of 18 Pa. C.S. section 4904 relating to unsworn
falsification to authorities.
Dated: April 13, 1994
Title Assistant Vice Pres
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SHERIFF'S RETURN
CCK40NWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
Germantown Savings Bank
VS
Pete R. Sanchez and Betty E. Sanchez
Michael E Barrick , SMdC=X or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law, says,
that he served the within Complaint in Mortgage Foreclosure and Notice
upon Pete R. Sanchez and Betty E. , the defendant, at 10:24 o'clock
A M. 1N'x/ EDST, on the 2nd
511 State Road, West Fairview
11 Pennsylvania, by handing to
E. Sanchez
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 94-2236 Civil Term
Complaint in Mortgage Foreclosure
and Notice
day of May , 19 94at
Cumberland County,
Pete R. Sanchez for himself and Betty
a true and attested copy of the Complaint in Mortgage Foreclosure and , Notice
and at the same time directing his
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
Docketing 18.00
Service 8.96
Affidavit
Surcharge 4.00
$ 30.96
pd by atty 5-3-94
Sworn and subscribed to before me
this 5?2t day of 1)t j„
19 A.D. ??
Prothonotary
attention to the contents thereof and
So answers
R. Thomas Kline, Sheriff
by 9-L,:?
Deputy Sheriff
SAVINGS BANK,
PLAINTIFF
VS.
PETE R. SANCHEZ and
BETTY E. SANCHEZ,
DEFENDANTS
f""t
PURCELL, KRUG & HALLER
Leon P. Ha
Attorney for Plaintiff
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
NO. 94-2236-CV
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Kindly Settle and Discontinue the above matter of record.
DATE: May 31. 1994
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