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Home My WebLink About96-05444 ~ ~ ~ , ~ I '- b ..~ " ..... \... "\: ~ ~ ~ ....... '.. 2 o - ~ ! ! t ~ I l.c) . ~I ~l ~I I ! i \ ~ , , I J / . A FEDERMAN AND PHELAN, P.C. By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215\ 563-7000 .,<> ATT?~~Y FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION MELLON MORTGAGE COMPANY 9225 INDIAN CREEK PARKWAY SUITE 300 OVERLAND PARK, KS 66210-2000 Plaintiff v. NO. qb- J444- CL.Jfl Defendant(s) CUMBERLAND COUNTYGj .lEJ.. Itr 9r; FE:'C;c~ t ~,JIi:. FHelAN .'r":",':>~.'::'" FILE COPY HI ,,-". .:...1 PLEASE RETURN ROBERT J. TRIMMER, II ERICA M. TRIMMER 1559 SPRING ROAD CARLISLE, PA 17013 CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE This is an attsr:lPt to c;iIe:t a debt and any lr.iormatIon obtained wID be usee for !hat purpose. You have been sued in Court. If you wish to defend agninst 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 tiling 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 clalm~or relief requested by the Plaintiff. You may lose money or property 'or other rights important to you. _ ~:' YOU SHOULD TAKE THIS PAPER TO lOUR LA'-"iER AT ONCE. If' YOU 00 N~ HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHON:BTHf;'PFFlSE SET FORTH BELOW TO FINO OUT WHERE YOU CAN GET LEGAL ~~.:.:. ~'~ ., ~ ... . .- ...., CUMBERLAND COUNTY ~,'-:'O COURT ADMINISTRATOR . .. .:::." :::> -. 4TH FLOOR -: -:) ~ CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 FEDERMAN AND PHELAN ATTORNEY ALE COPY PlEASE RETURN FEDERMAN AND PHELAN ATTORNEY filE COpy PlEASE RETURN We heItby certft lit' wlth!n to be a tl'ullnd correct copy of the ung:naIliIed of record FEDERMAN AND PHElAN FEDERMAN AND PHELAN, P.C. By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215\ 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION MELLON MORTGAGE COMPANY 9225 INDIAN CREEK PARKWAY SUITE 300 OVERLAND PARK, KS 66210-2000 Plaintiff v. NO. CUMBERLAND COUNTY ROBERT J. TRIMMER, II ERICA M. TRIMMER 1559 SPRING ROAD CARLISLE, PA 17013 Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE This Is an atts!':'~ 1tI cciiect a debt and any 'nlctma1lon obtained wID be i.l!&C Ie; that purpose. 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 TAXE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FINO OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 .. ~ "-~.. .e.. 6. The following amounts are due on the mortgage: Principal Balance $52,865.67 .:...... Interest 2,954.40 . 'iI'~ 2/1/96 through 9/27/96 (Per Diem $12.31) Attorney's Fees 2,643.00 cumulative Late Charges 140.49 1/15/92 to 9/27/96 Cost of suit and Title Search 550.00 Subtotal 59,153.56 Escrow Credit 0.00 Deficit 496.50 Subtotal 496.50 TOTAL. $59,150.0' 7. 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. 8. The mortgaged premises are vacant and abandoned. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. S 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different trom above. WHEREFORE, PLAINTIFF demands 3udCJlllent against the o.fendant(.) in the sum of $59,650.06, toqether with interest from 9/27/96 at the rate of $12.31 per diem to the date of Judqment, and other costs and charges collectible under the mortgage and for the toreclosure and sale of the mortgaged property. I ~...- .. . .. . .. ,.., m L..-.i , .. r;r.{ n;,t.rJiJI 1.1 Frank Fed.raan FRAN1C FE.DERJIlAN, ESQUIRE Attorney for Plaintiff r":'IE C"'~'.' r~"".~ rECORD L ~ " ,,'..1 d ,.J; , rJ. ,,,..- c! C~( ,,~. '" ..._..... ~y of' . 1. .c. h....~l~.... r .~& .ytf -' PI o:t:,.:ncl.-.,'f " FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (2151 563-7000 Attorney for Plaintiff MELLON MORTGAGE COMPANY Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs. ROBERT J. TRIMMER, II AND ERICA M. TRIMMER cumberland County No. 96-5444-CIVIL Defendants PRU:CIPB '1'0 RBI.STATB CIVIL ACTIO./lfO.NAGB ~~.URJI TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. Date: Dee..bl!tr 30. 1996 ~ Mlww.J FEDERMAN, ESQUIRB Attorney for Plaintiff ~ " :: If.! I ~ :r: ~ ~~ <"J ~ N ?:: ?" ~;l~ -j~ -.... ~~.. .....~ ?>O . <..1 .#7- ., -, t~iE d FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (2151 563-7000 Attorney for Plaintiff COURT OF COMMON PLEAS MELLON MORTGAGE COMPANY Plaintiff CIVIL DIVISION vs. cumberland County ROBERT J. TRIMMER, II AND ERICA M. TRIMMER No. 96-5444-CIVIL Defendants VERIFICATION I hereby certify that a true and correct copy of the civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by reqular and certified mail, return receipt requested, to the following person, to ROBDT J. 1- '7~9'7 TRIMKER, II at 155' SPRIHG ROAD, CARLI8LB, PA 17013, OD , in accordance with the Order of Court dated DZCIXBD 11, 1"'. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. FEDERMAN. !SQUIRE DATil J - 7 -9 7 , - r- ?::. ~ .:: ;:-"i...,.- tR .. \:': ,,)-,,;' .- ...)0",:. ~. .- ... .;- ,... .. ~~.j ~,~ cr> <~ ~;; j~'~ u::.t I .~::,~..~ et- -". ,Ul~ ..:;; t,~ ;:. -:J ~:_~ '-'- E; b 0 FEDERMAN AND PHELAN BY: Francis S. Hallinan, Esq. Atty. 1.0. #62695 Ste. 900/TwO Penn Center Plaza Philadelphia, PA 19102 (215\ 563-7000 MELLON MORTGAGE COMPANY ATTORNEY FOR PLAINTIFF vs. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 96-5444-CIVIL ROBERT 3. TRIMMER, II AND ERICA M. TRIMMER "'~E~ _ day of ~ ' 1996, upon consideration of Plaintiff's Motion and the Affidavit of Reasonable Investigation attached AND NOW, this J<i~ thereto, it is hereby ORDERED that Plaintiff may obtain service of the complaint on the above captioned Defendant, ROBERT J. TRIMMER, II, by mailing a true and correct copy of the Complaint by certified mail and regular mail and by posting of the premises 1559 SPRING ROAD, CARLISLE, PA 17013, by the Sheriff. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. In the event that Notice of Sheriff Sale cannot be made in the manner provided in Pa. R.C.P. 402(a) or Pa. R.C.P. 403, service shall be made by regular and certified mail to Defendants last known address and by posting of the premise. by the Sheriff. J. FEDERMAN AND PHELAN BY: Francis S. Hallinan, Esq. Atty. 1.0. #62695 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (2151 56)-7000 MELLON MORTGAGE COMPANY ATTORNEY FOR PLAINTIFF vs. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 96-5444-CIVIL ROBERT J. TRIMMER, II AND ERICA M. TRIMMER MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Francis S. Hallinan, Esquire, moves this Honorable Court for an Order directing service of the complaint upon the above-captioned Defendant by Certified mail and regular mail and by posting of the premises, 1559 SPRING ROAD, CARLISLE, PA 17013 and in support thereof avers the following: 1. Attempts to serve Defendant with Complaint have been unsuccessful, as indicated by the Sheriff's Return of Service by the Sheriff's Office attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Reasonable Investigation setting forth the spec if ic inquiries made and the results therefrom is attached hereto as exhibit "B". WHERKFORB, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rul.. of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail and by posting of the premises. \ , I ,:, · _--'"-._.......a.....~_ francis S. Hallinan, Esquire ^TtO~N[Y rON PLAINTIff .. ,< ~ ~ . I/!. ." " "L i. {t' w. JI- FEDERMAN AND PHELAN BY: Francis S. Hallinan, Esq. Atty. 1.0. #62695 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 12151 563-7000 MELLON MORTGAGE COMPANY ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 96-5444-CIVIL vs. ROBERT J. TRIMMER, II AND ERICA M. TRIMMER MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (.1 If ..rvic. c.nnot b. ..d. und.r the applic.bl. rul., the pl.intiff .ay move the Court for a .p.ci.l ord.r dir.cting the ..thod of ..rvic.. Th. Notion .hall b. accomp.ni.d by an Affidavit .t.ting the n.tur. .nd .xt.nt of the inv.stig.tion which h.. b..n ..d. to d.t.rmin. th. wh.r..bout. of th. D.f.nd.nt and the reason. why ..rvic. cannot be ..de. Notel A Sheriff'. return of "Not Found. or th. fact th.t . D.f.ndant ha. moved witbout l..ving . n.w forwarding addr.s. is insuffici.nt evid.nc. of conceal..nt. Oon,ale. vs. l2l!l, 238 'a. Super. 362, 357 A.2d 580 (1976). "Notice of intended .doption ..il.d to last known addr.s. require. a good f.ith effort to discov.r the corr.ct addr..... AdoDtion of Walk.r, 468 ,.. 165, 360 A.2d 603 (1976). An i11u.tr.tion of good faith effort to locate the def.ndant include, (1) inquir.. of po.tal .uthoriti.. including inquiri.s pursuant to th. Freedom of Information Act, 39 C.r.R. P.rt 265, (2) inquiri.. of relatives neighbors, fri.nd. and ..ploy.r. of th. Def.nd.nt and (3) e...in.tioDs of local telephone directories, voter regiatration record., , local tax record., and .atar vebiel. records. As indicated by the attached Sheriff's Return of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Complaint. A good Faith effort to discover the whereabouts of the Detendant has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit "B". WHEREFORE, Plaintiff respecttully requests service of the Complaint by certified mail and regular mail and by posting of the premises by the Sheriff. Re~pecttully submitted: \ t, , _ " ' , '1'/ 1,.11:- --.! ',t,ff l::~ Francis S. Hallin4n. Esquire Attorney tor Plaintiff COMMONWEALTH OF PENN5YLV ANIA: 55: COUNTY OF PffiLADELPffiA: On this the 06th day of November, 1996, before me, Ronda 5. Page, the undersigned officer, personally appeared THEODORE A PAGE, known 10 me 10 be the person whose name is subscribed 10 the within affidavit, and acknowledged thaI he execuled the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal I ; 1 (MycommiC...,n e..p;.Q ..o._,...___._.',' ~'::.~,:';'-, <.Xu ?;~t,,>\l ,......-t)<e (,;,;} .:"-f~-^,;~".",.t,, Pr~a cO'....'lfy ~ Gl."nm\t.;.\;0t! ~l:'!3'S J.:ff; t(t 'S9"J ) REASONABLE INVESTIGATION, INC. TWO PENN CENTER PLAZA SUITE 900 PHILADELPHIA, PA 19107-1799 (215) 563-7000 November 5, 1996 POSTMASTER Carlisle, PA 17013 R.qu..t for Ch.ng. of Addr... of Boxhold.r Inform.tion N.ed.d for S.rvic. of Leg.1 Proc... Pl.... furni.h th. n.w .ddr... or th. n... and .tr..t addr... for th. followingl NAMIlI Rob.rt J. Tri_.r, Jr. ADDRESS. 1559 Spring Road Carli.le, PA 17013 NOTS. Th. n... .nd l..t known .ddr..s .r. r.quir.d for ch.ng. of addr... information. Th. n..., if known, .nd post offic. box .ddr... .r. r.quir.d for boxhold.r inform.tion. Th. following information i. provided in .ccordanc. with 39 erR 265.5(d)(6)(ii). Ther. i. no f.. for pro..iding boxhold.r information. Th. f.. for providing ch.ng. of .ddr... information i. w.i..ed in .ccordanc. with 39 CRr 265.5 (d) (1 land (2) .nd corr..ponding Administr.ti... Support Manu.l 352.". .nd b. 1.Capacity of Requester: Attorney 2. Statue or regulation that empowers me to serve: nla 3.The names of all parties to the litigation: Robert J. Trimmer, Jr. 4.The court in which the case has been or will be heard: civil Divisionl cumberland county 5.The docket or other identifying number: 96-544 6. The capacity in which this individual is to be served: Defendant in a Mortqaqe Foreclosure Action lfAMING TIIJI lIUBMISIIOII or rA1.llI INrolUlATIOII 'I'O OBTAIN AIID USE CRANGE GF ADDUSI INrolUlATIOII roR IOIIOLDIII IIIPOIUlATIOII ro. AllY PUaPOI. 0'l'IlER T1IAN TIlE SERVICE or LEGAL P.OCESS IN COIQIBCTIOII IfITIl ACTUAL OR PlOIPICTIYI LITIGATIOII COULD USULT IN CRIMIIIAL PENALTIES INCLUDING A rlllll or UP '1'0 $10,000 Oil 1....1__....'11 o. (2) '1'0 AVOID 'AnIIIIT or TIlIl re roll CRANGIl or ADDUSS IlrolUlATIOII or IfO'r NOD TIIAIl 5 1'1:AJlI. OR IIO'nI (TIrLB II UIC SIlCTIOII 1001) I c.rtify th.t the aboY. information i. true .nd that the .ddr... information 1. n.eded .04 will b. u.ed .ol.lr for ..rvic. of leg.l proc... in connection with .ctu.l or pro.peeti... litig.tion. c-~).." ., ~~~""- Lawrenc. Phelan Attorne~ 1.0. No. 32227 Two pennt:'enter Plara, Ste 900 Philadelphia, PA 19102 ----------------------------rOR POST OFFICE USE ONLY------------------- No chanqe of address order on file. NEW ADDRESS (name' street address) 'i- rCoOd-;';~r.8S~ ~not Known at .ddr@ss qlv@n no luch addr.ss mov~d, left no forwarding address , . .966/8 t AOIi I , , I f I I I I I I I I t I i ! I ! i j } ~ ,:1 . " <, ""'i-,'<.;:"":;j.,l F" !t"'!'>'IUNW~":ALfH i:!," j"r;f,N;c'rL\'t.t; < .'\: i.tiliNf"I vr CU~!tn'hLANt) o f-L! .:..!.JLJ~.:~-j h 1J~~.2i~,__~.~:~____._________~,..~.,_ \':'. ~~5 );.1: tl ;~!i.J::~\.2J.~&f.:l_.L_ .11 _' .r.~~L_.~L... ~. _.. _ I tl~'o: ~.l :.iY:: _,f~JJJ5:_~~ !,..:" . . .....-. *~ . .' . , ~ 2\5' j'" :- r ';.;' 1t:J . .-) : 3". ':;:'7;i.:;~ . ~ ~13 ':. h ':- ..;;; ,_; ":: -:" . -J,. tn .1-..';': ... ~ ;'.. 'Iii i- ~ t, f, ._ ,) v "e: '":fVj:, +- t ..:.. l t T~n ~~~f 't' ! . we.-,:: ", a t' 1"2 t 0 ~ (, ;";i'" ;-~ .; ",,' ";: i.. .. ~."'" .-- ,r,._ ., >.' 'Ii: ~, ... ,'-i'. :". r'o.t NL " .. ;' t ,..'\ t:'t" '.! . "''''' . ....... ~;..... ... ,.-~. ., -. .'.", -; ;.... . ~ ~ ,t .,.. . J<<- . (1;, II.,'-c .hu. ).),..1..) 7-0?J . :=:Ht>~F; r FF' HETUfdi ht:GULAR CAS~ NU: 19'6-05441 P CUMMUNWt::...LTH IJF I'r:NNSYLVAlHA: CUUNTY U~ CUM8~RLAND Mr;I,I.UN MURTGAGr; CO ------ v'" -'.. Tfil_MMUi ROBt:R r , n ET ~A1~__..~_ -' ..F.U!:l.':;FiT L. FINK, GR. _".".__,..,...._....,....:;!hl"'o:f! 0, l'""puty Sh€'r H! of CUMBERLAND County, P.nnaylvao1a, who being duly BW0rn ~caOrd1ng t.o law, says. the "'i~hln ~~~"E.:"~~~_.JN.T ..:.~_!1c..~B.I,,,J:SJB..~->-.,__~____._,_~~.c;_-:..-... was Q$~rvi?d upen .TRIMMER ~RICA M th!? d!?f>?octant. at 1010:00 HOVRS~ cn ~ b foE' ._:i.!~ t~ :j~;' c! C,:;tGt'Er . . ~,- --- ------~-..~-_._- 13';'~ at ....J3?0. CRANES G!\I,RQntL. ,....""..~.~__...,."~ . ,_~ ._,~~,.",._M'......_.,__'.v_~~_."~'_'~_"_'''''''''''' .-.'..__,_......"'____..__...._"_,................._ \:'~flJJ.:; L t;t..Ll:L.L'01 L....__.,__ _.~_______..____.___ ,._..____..' :;, U !'1f;.Bi~'l D",_.___. \.~ ,:-:'lJnt y. P€'onsyl Vanl;)" by h;tf.:1l f;;") T: <::. t;;.BILLI,BJJttt~F;,__.., __~_....~'.,'____~____..--~_,_,~~_,__ a trv~ and at-tE-sted: COPy 0t tho? __'~;c:~l~~l~;.JiT.. .__1:P'!::tf~L",[~lr<E ..______.",,_.,.,___<-_# t ('g€'t h~r vi ttl ~.QI1h';~_,~~"__",,,_, and <it the S;3lmE- \ 1 me d 1 r !f'(:' t J [;9 H.~" ii t t i:rn t 1 ,::-n t_~~.) t h.;" G (\(\ t;pnts tne-rp,_; t. '..:~~erii!.'~ (DEot$: i,j':)'::"t-:'€'tln,;;} S;prvl':~p . "'.: f J".:13.....1. ~ '::'..J!" c.:harq-'f' ;;i(;; -,..."",.,.~ ~ ,",'.""" A r' ,;...t:t.-:~ .~ h'~---"~: ::-':;-;~;;'::;~TT;:.{"7-'''.'!~Ie-;~~:r--''''''--"----''--'~~''" ...~. ~ ~,..~.-;-.I~.~rll.r:rh""tA~~ ,:;'.<i~: ~'HA-L.A,H H~0'" :Y""'~~$J-L "''''''.f an,j ,,\;t,,':'nl.'F~ heL." '. fd s f/~~,,, "1 ,~(' tt!J4k ; 0' U. ' '-t.. · .1.. 'J ;(<.'." ..", " JUt ( .... 1 , ... -.... - FEDERMAN AND PHELAN, P.C. By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 12151 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COKKON PLEAS CIVIL DIVISION MELLON MORTGAGE COMPANY 9225 INDIAN CREEK PARKWAY SUITE 300 OVERLAND PARK, KS 66210-2000 Plaintiff v. NO. Yb-- j y 4 q (i l'tl~C CUMBERLAND COUNTY ROBERT J. TRIKKER, II ERICA M. TRIKKER 1559 SPRING ROAD CARLISLE, PA 17013 Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICB ThIs Is an attempt Ie c;iIect a debt and any Infcnnation obtalned wi be used for !hat purpose. You have been sued in Court. If you wish to defend against the claims Bet 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 filinq in writing with the court your defenses or objections to the claims Bet forth aqainst you. You are warned that if you fail to do BO the case may proceed without you and a judqment may be entered aqainst 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 riqhta important to you. YOU SHOULD TAXE 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 COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 2040-6200 We ~ ClJrtl', ~ wmvr. t",) bo Q tn.~ and <::woct \.'OI.ly ot :~ Cr" Jj,1t\I ftl~ oIlrcom FEL.I...;;\\""~ h \ ,~~ AN . " .,,< 1. Plaintiff is MELLON MORTGAGE COMPANY 9225 INDIAN CREEK PARKWAY SUITE 300 OVERLAND PARK, KS 66210-2000 2. The namees) and last known addressees) of the Defendantes) are ROBERT J. TRIMMER, II ERICA M. TRIMMER 1559 SPRING ROAD CARLISLE, PA 17013 who is/are the mortgagores) and real owneres) of the property hereinafter described. I i \ I I , I j ! 3. On 1/15/92 mortgagores) made, executed and delivered a mortgage upon the premises hereinafter described to SEARS MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1043, Page 166. By Assignment of Mortgage recorded 10/8/92 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 428, Page 636. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 3/1/96 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all inter.st due thereon are collectible forthwith. .....~ ,\ ~ l \ .1 ~:' , i , l, ., " ..'- 0 , ti" ., .....~ -- FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 suite 900 Two Penn Center Plaza Philadelphia, PA 19102-1799 (2151 563-7000 Mellon Mortqaqe Corporation Attorney for Plaintiff . . Court of Common Pleas : civil Division v. . . cumberland County No. 96-5444 Civil Robert J. Trimmer, II Erica M. Trimmer . . TO: Robert J. Trimmer, II 1559 Sprinq Road carlisle, PA 17013 DA~. 01' IIO'rICB. ..hruarY 7. ltt7 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. DIPOR'fMl'1' IIO'rICI You are in default because you have failed to take action required in this case. unless you act within ten (10) days frOll the date of this notice, a Judqaent .ay be entered aqainst you without a hear11\9 and you .ay lose your property or other bportant 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 tollowil\9 office to find out where you can qet legal help: CWlberland County Court Adainiatator 4th Floor CUJlberland County COurthouse carlisle, PA 17013 (717)240-6200 ~~~~._~ rm , lIQUID Attorney tor Plaintiff l. ' ( -,. i C ... p . f- .; j;"' .J -:t 0 ,.. If) ~ :r r' Ij _ 7 ]~ . 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V , . iiiiii -a ]. ,&"R 1L"& 80000') ~o- 1l)L{) a- C'l)oO<T l{)(b ~ I!l T ~ lIT ~ 'IJ ~ ~ ~ u ~ i ~ -0 d ..j 1i,J..1 ~ 8 2 ('b- rQ - '9 , . --..- WEDERKAH and PHBLAN By I nAIfK WBDBRKAH Identification No. 12248 suite .00 Two Penn Center Plaia Philadelphia, PA 1.102 (215) 5&3-7000 ATTORNBY WOR PLAIHTIrr ULLOM MORTGAGE COMPANY I CUMBERLAND COUNTY I COURT OF COMMOM PLIAS I CIVIL DIVISION vs. I ROBDT J. '1'IlIMMD DICA M. '1'IlIIDIBR I HO. "-5444 CrvIL VERIFICATION OF NON-MILITARY SDVICE FRANX FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintift in the above-captioned matter, and that on inforaation and belief, he has knowledge ot the following fact., to witl Ca) that the defendantCs) is/are not in the Military or Naval Service ot the United State. or it. Allie., or otherwise within the provisions of the Soldiers' and Sailors' Civil Reliet Act ot Congress ot 1940, as amended. (b) that detendant ROIDT J. '1'IlIMMD is over 18 year. ot age and resides at 155. "lING ROAD, CARLI'LE, 'A 17013. Cc) that defendant DICA M. '1'IlIIDIBR is over 18 years ot 8g., and r.sid.. at 1450 CRAHBI GAP lOAD, CARLI'LI, 'A 17013. This stat...nt is ..d. subject to the penalti.. of 18 Pa. C.S. Section 4904 relating to unsworn falsitication to authoritie.. .......-lua *'\./:' ~~{t-.~ .- - fRANX nOIJUCAM, ESQUIU Attorney for Plaintiff . ~. ......... '- : MILLON MORTGAGE COMPANY I CUMBERLAND COUNTY I COURT OP COMMON PLEAS I CIVIL DIVISION vs. I ROBERT J. TRIMMER ERICA K. TRIMMER I NO. 96-5444 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) MELLON MORTGAGE COMPANY , Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1559 SPRING ROAD. CARLISLE. PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): HAIlE LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) OICA II. 'l'RIIOIER 1559 SPRING ROAD CARLISLE. PA 17013 1450 CRANES GAP ROAD CARLISLE. PA 17013 2. Name and address of Defendant(s) in the judgment: ROBERT J. TRIMMER IWlE LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAID AS UOVB 3. Name and address of evelY judgment creditor whose judqment is s record lien on the real property to be sold: &III LAST KNOWN ADDRESS (i f address cannot be reasonably ascertain.d, please so indicate) 110IIII 4. Ma.. and addr.s. ot the last recorded hold.r of .v.ry IIOrtqage of record: &III LAST KNOWN ADDRESS (i f addr... cannot be r.a.onably ascertained, pl.... so indlcat.) fOR 5. Name and address of every other person who has any record lien on the property: ~ LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 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: ~ LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) Non 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: IWSE LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 'l'DfAlft'/OCCUPAH'l' 155' SPRING ROAD CARLISLB. PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of l8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ..rob C. 1117 --:tt41\.jj .[t~'I'V DATE f'RANX FEDERMAN, ESQUIRE Attorney for Plaintiff .- - , , ..~ - -.,. I , I I..: " , , I..'.~ ", '- "'i <;- c- t.. ..if ,-. . \' <- ::.~ , I ~ \.....- ~-', U , . - ~,' . , s t" <...' " (J: -<': '. ;'1 l~. ~1~- - t{:1 , ~ .,... - 'J.-~ C. .~:. i~ .."c "' ;\ .- . t". d t~; <:1' MELLON MORTGAGE COMPANY I I CUMBERLAND COUHTY COURT OF COMMON PLEAS va. I CIVIL DIVISION ROBERT J. TRIMMER ERICA M. TRIMMER I I NO. 96-5444 CIVIL TOI ROBERT J. TRIMMER 1559 SPRING ROAD CARLISLE, PA 17013 !RICA M. TRIMMER 1450 CRANES OAP ROAD CARLISLE, PA 17013 THIS NOTICE IS SENT TO YOU IN AN A'rI'EMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICB OF SHERIFF'S SALE OF REAL PROPERTY Marcb 6, 1997 Your house (real estate) at 1559 SPRING ROAD. CARLISLB. PA 17013, is scheduled to be sold at the Sheriff's Sale on JUNE 4. 1997 at 10:00 a.m. in the cumberland County Courthouse, South Hanover Street, CarliSle, PA 17013, to enforce the court jUdgment of .61.61t.66 obtained by MBLLON MORTGAOE COMPANY (the mortgagee) against you. NOTICE OF OWH!R'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take t...4Hliate aetioD: 1. The sals will be cancelled if you pay to the aort9agee the back payments, late charq.s, costs and reasonable attorney's fees due. To find out how much you auat pay, you may call: f2151 563-7000. 2. You may be able to stop the sale by f1lih9 a petition asltinq the Court to strike or open the judgaent, it the judCJ1lent was improperly entered. You may also aslt the Court to poatpone the a.l. for good cause. J. You may also be able to atop the sale throuqh other 18CJa1 proceedinga. 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 on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVB YOUR PROPBRTY AND YOU HAVB OTHER RIGHTS EVEN II' THE SHBRIFF'S SALE DOBS TAKB PLACB. 1. be sold calling If the Sheriff's Sale to the highest bidder. 12151 563-7000. is not stopped, your property will You may find out the price bid by 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. =>. 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 (215) 563-7000. 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 on . 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 (lO) days after . 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU IHOULD TUE '1"8IS 'A'Ell TO YOUR LAWYEll AT ONCE. II' YOU DO IfOT BAVE A LAWYD OIl CAJllfOT AFFORD on, GO TO OR TBLBPHOIfE '1"88 OFFICE LII'!'G BaLOW TO FIG OUT nUl YOU CAlI GET LEGAL HELP. CUMBDLAlID COUllTY COUR'!' ADIIllfUTRATOR Uh floor cuab.rl.a4 Couaty Courthous. (717) 140-1200 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 on page two on how to obtain an attorney.) YOU HAY STILL BB ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVBN IF THB SHERIFF'S SALE DOES TAKE PLACE. 1- be sold calling If the Sheriff's Sale to the highest bidder. 12151 563-7000. is not stopped, your property will You may find out the price bid by 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 (215) 563-7000. 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 on 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 (lO) days after 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU 8HOULD TUB THIS PAPER 'to YOUR LAWYER AT ONCB. IF YOU DO HOT HAVI A LAWTER OR CANNOT AFFORD ONE, GO TO OR 'tBLBPHONB THE OrFICE LI8'l'1D BELOW TO rIlItl OUT WHERB YOU CAlf GET LEGAL HELP. CUMllDLANtl COOtfTY COURT ADMIlfI8TRATOR 4tb floor CUaberlaa4 Couat, courtbou.. (1171 UO-UOO *legal description* ALL THAT CERTAIN tract of land improvements thereon erected in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as per the attached Survey dated January 10, 1992 by fisher, Mowery and Rosendale bounded and described as follows: BEGINNING at a point on the right-of-way lien of Carlisle Road (SR0034l; thence by acurve with a radius of 691.78 feet a distance of 45.85 feet to an iron pin; thence by property now or formerly of Irvin E. and Debra Bidelspach South 51 degrees 43 minutes 45 seconds East 156.04 feet to an iron pin; thence along lands now or formerly of Abrams C. and Kathleen M. Bert South 39 degrees 21 minutes 25 seconds West 29.51 feet to a fence post; thence North 57 degrees 14 minutes 17 seconds West 87.45 feet to an iron pin; thence North 58 degrees 26 minutes 10 seconds West 67.85 feet to an iron pin, the place of beginning. BEING Tax Parcel #29-181-369-0l9. TITLE TO SAID PREMISES IS VESTED IN Robert J. Trimmer, II and Erica M. Trimmer, husband and Wife, by Deed from robert E. Swavola and Joyce A. Swavola, husband and wife, dated 1/l5/92 recorded 1/16/92 in Deed Book M35 page 151. AND the sid Erica M. Trimmer and Robert J. Trimmer were divorced by Final Decree entered in #2482-vic-1995 on 3/14/96.