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Home My WebLink About00-00940 FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (? 1~) ~(i1- 7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE 4000 HORIZON WAY IRVING, TX 75063 TERM Plaintiff ~oq,- ~L/t/ ~ v. CUMBERLAND COUNTY ROBERT C. KECK TINA L. KINER ROBERT L. KECK 1908 GEORGE AVENUE CARLISLE, PA 17013 Defendant( s) CTVTT. ACTTON - T.AW MORTGAGR FORRCl.OSTJRR NOTTCR **TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS DEBT WAS NOT REAFFIRMED, TillS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 cowt 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 0009139916 r '"-""'~, - , .,- . i!If 1. Plaintiff is FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE 4000 HORIZON WAY IRVING, TX 75063 2. The name(s) and last known address (es) of the Defendant(s) are: ROBERT C. KECK TINA L. KINER ROBERT L. KECK 1908 GEORGE AVENUE CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 4/29/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1453, Page 835. 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 saidl mortgage due 10/1199 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. \, ~, -^ -,~ '-~'j>'- C" . r 6. The following amounts are due on the mortgage: Principal Balance Interest 9/1/99 through 2/liOO (Per Diem $22.71) Attorney's Fees Cumulative Late Charges 4/29/98 to 2/liOO Cost of Suit and Title Search Subtotal $110,867.88 3,474.63 4,000.00 385.79 550.00 119,278.30 Escrow Credit Deficit Subtotal 141.17 0.00 141.17 TOTAL $119,137.13 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. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an!!! rem Judgment against the Defendant(s) in the sum of $119,137.13, together with interest from 2/l/00 at the rate of$22.71 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. '"~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~ " ~'''_~O .. ", , . . ALL THAT C~RTAIN eract of 1and sieuate ~n North M~ddleton Townahi~. Cumbe~~and county, Pennsy~vania, bounded and aescribed in ~eaordance w~ch p1an of $ubdivisi..on for Ed~u CQrporat:.i..on dated. 4/'25/74 and recQrcled 1$/:12/"14 in the Recorder o~ Deeds Of~ice 1n and for che County of CUmber~and in Plan Book 25 page 43 as fo~1ows. BEGINNING at:: a poil.'lt: on I:.h.e werst-ern 1ine of SO 1:001:. wide George Avenl.J.e ill!:. the d.ividing l.i.ne bel:.ween Lot:s 2 and 2; thence from said poine at the p.l.ace ot begi..nn~ng a10ng ea~a divid~ng ~i..ne. North 83 degrees and ~5 m1nutea WasC, a dis~ance of 155 feet to a point on the eastern 1ine Qf 1and now or 1ate of vina1 S. Sowers; thenee a~Qng said ~ine of 1and now or former1y o~ Vina~ s. Bowers, No~th S degrees and 45 m~nute5 East, a ~~&tance of 44.23 feet eo an ~ron pin ~n ~~ne of ~and former~y of H.W. Fry, and now ~he Bouthe~n ~ine of.p~an of ~o~s known &$ P~an No.2 of Sehluaser V~~~~9a; chance a10ng said SOU chern ~~ne of 5a~d plan of lota, North sa degrees 4S minutes and 59 seconds Enst. a discance of 175.53 ~eet to an ~ron pin; thence a~oo9 ~he western ~~ne Q~ said so' foot wide George Avenue, Sout,h 6 degrees and 4$ minuces West, a distanoe o~ ~24.66 ~eet to _ point at the dividing line between Lots 2 anQ 3 at the p~ac& o~ BEGXNNING. CON'I'AIN:t.NG :1.3. 008 . 98 square fee:" _...Jd being a~~ o.f Lot :3 as shown on subdivision p~an of Edlu Corpor~cion recorded in P~an Book 25 page 43. aEING THE SAME PREMISES wnich Tim E. G~e5sner and Gary L. G~e$sn~r by deed a~ted November 19, 1~~7 and recorderl Dece~er 8, 1997 in ~h~ Reco~der'~ Office ~n ana for CumbQr~and County, PA. in Record Soak 1$~. Pase 53, gran.ted and convey~d u:n.t:.o Robe.rt:. C. Keel<. and Tina L. K:i.ner, mortgagors herei.n. PREMISES: 1908 GEORGE AVRNUE I -'. :1' VERIFICATION JUSTIN POLLOCK hereby states that he is ASSISTANT VICE-PRESIDENT of FT MORTGAGE COMPANIES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. 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. DATE: 2 \\~~ J , # ' ~" I I , . ~ ,~ ~ :'? 1--. '\ ~ ~~ c:J ~I.y~ ~ T~\ ~9st . ~ ~ o C) c' ~-= 6 ~:.,,' v -"~~ ~"'!n ['"10.. ,.., ' ir ~j "'......"-., '> ~8 J.....:' r-.J ~-' .. :..:> ~_ SJ -< ..' ",~ -' ' ;;~~ ...f ,1:"') ~ SHERIFF'S RETURN - REGULAR CASE NO: 2000-00940 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FT MORTGAGE COMPANIES ETC VS KECK ROBERT C ET AL SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KECK ROBERT C the DEFENDANT , at 0017:27 HOURS, on the 29th day of February, 2000 at 1908 GEORGE AVE CARLISLE, PA 17013 by handing to ROBERT C. KECK a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 so;:~~~ R. Thomas Kline 03/01/2000 FEDERMAN & PHELAN Sworn and Subscribed to before BY:~7n.~ Deputy Sheriff me this J.3...J-- day of ~ J.4?ro A.D. q''fJL Of')."OC,.. ~OA"C' P othonotary .~ , ~ < ',', ~~ , ~-~~~~,", " -- .~--. ~,",-, "-- ,roo, SHERIFF'S RETURN - REGULAR CASE NO: 2000-00940 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FT MORTGAGE COMPANIES ETC VS KECK ROBERT C ET AL SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KINER TINA L the DEFENDANT , at 0017:27 HOURS, on the 29th day of February, 2000 at 1908 GEORGE AVE CARLISLE, PA 17013 by handing to ROBERT C. KECK a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10,00 .00 16.00 So Answers: 1!"~~e R. Thomas Kline 03/01/2000 FEDERMAN & PHELAN Sworn and Subscribed to before By: Lh1EYL /11.~ Deputy Sheriff me this OL.3.,uC day of ~;)..{nrO A. D. ~, {l 'mAl,., A.fl.udi:' r thonotary , '''7-' ~..." .' . -17 ;' SHERIFF'S RETURN - REGULAR . CASE NO: 2000-00940 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FT MORTGAGE COMPANIES ETC VS KECK ROBERT C ET AL SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KECK ROBERT L the DEFENDANT , at 0017:27 HOURS, on the 29th day of February, 2000 at 1908 GEORGE AVE CARLISLE, PA 17013 by handing to ROBERT C. KECK a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16,00 S~ ::~~~~~! R. Thomas Kline 03/01/2000 FEDERMAN & PHELAN Sworn and Subscribed to before By: ~~~r~ me this ~ <3"uL. day of ~...4...' 0Unr0 A.D. n 11- "">'1A~}I'd A O~,,;: ~thonotary , '7"'7 ., . ' , FEDERMAN AND PHELAN By: Frank: Federman, Esquire Atty. I.D. No.: 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATIORNEY FOR PLAINTIFF FT Mortgage Compaines v. Cumberland County Court of Common Pleas Civil Division No. 2oo0-940-CIVIL Robert C. Keck Tina L. Kiner Robert L. Keck PRAECIPE TO THE PROTHONOTARY: X A. Plaintiff hereby withdraws the complaint fIled in this matter. Please mark this case discontinued and ended without prejudice. B. Please mark this case settled, discontinued and ended. 3\ LD\ 00 ~3 Date Attorney for Plaintiff ~,<m~l'I1l r-' ., .> =-. ., 'ri'" .. , (") 0 ~ f;,; 0 $. :x .-j -OW "" I-n m"""~ A) :""p 2::r,l N ""Urn ZC- :"0 (j).t:: .l7 ,3' "-(L ~..,o r'o ..." -r-T '< "J :iJ ~o :r. ~7(") ~8 ~ -""-rn ~ ~ N 5:; .;:- -< " .. ..