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Home My WebLink About00-01060 . ,-~ " " ~ ~ I ~j:, FEDERMAN AND PHELAN By: FRAJiKFEDERMAN,ESQumRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FORPLMNTITF COURT OF COMMON PLEAS CIVIL DIVISION GE CAPITAL MORTGAGE SERVICES, INC. . 4680 HALLMARK PARKWAY SAN BERNARDINO, CA 92407 TERM Plaintiff n . -, :r-:._ NO. .;1&7Jl)- JO(.,O ~ r~-_ v. CUMBERLAND COUNTY JEFFREY L. FRYMOYER 312 PINEWOOD DRIVE SHIREMANSTOWN, PA 17011 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE **THIS 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 twen1y (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 TillS PAPER TO YOUR LAWYER AT ONCE. IT 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 #: 9069642 ~ ='; ~ Ll1ii~J!\lk, I 1. Plaintiff is GE CAPITAL MORTGAGE SERVICES, INC. 4680 HALLMARK PARKWAY SAN BERNARDINO, CA 92407 2. The name(s) and last knOWIl address(es) of the Defendant(s) are: JEFFREY L. FRYMOYER 312 PINEWOOD DRIVE SHIREMANSTOWN, PA l701l who is/are the mortgagor(s) and real oWIler(s) of the property hereinafter described. 3. On 10/25/91 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to UNITED SAVING ASSOCIATION OF TEXAS, FSB which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1032, Page 1132. By Assignment of Mortgage dated 3/2/92 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Miscellaneous Book No. 424, Page 1169. 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 11/1/99 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 notice is attached as Exhibit "A." ~ " ....:Ill , J "-";e, 6. The following amounts are due on the mortgage: Principal Balance Interest 10/1199 through 2/1100 (Per Diem $11.64) Attorney's Fees Cumulative Late Charges 1 0/25/91 to 2/1100 Cost of Suit and Title Search Subtotal $49,968.50 1,431.72 2,498.00 118.17 550.00 54,566.39 Escrow Credit Deficit Subtotal 47.08 0.00 47.08 TOTAL $54,519.31 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 Sheriffs 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. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. S1680.403c on thedate(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. 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 Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; 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 $54,519.31, together with interest from 211/00 at the rate of $11.64 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. 1:cl~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff 02/08/00 18:13 FAX 317 808 2477 Allison Payment Systems . J - -.-" )IaI088_ ~! GE Cap\tal M/Jrtgage S.mcc.. Inc. 4680 Jiallmario; Parkway San BeI'IllIrdiIw CA 92407 Date: 0 J/04/00 _IIJJ.wtIIO ~'~'I ,_*' '81101'" 1.,.111,"111",11I11".11.11.,.1.1",1.11..,1",11,,1.11.,,1I ~EFFREY L FRYMDYER 312 PINEWODD DRIVE SHIRENAI\ISTDWN PA 17011 RE: GE Loan #: (~;~069~2~ Property: 312 PlNE~RIVE SHlREMANSTOl'A 17011 4st.Paid: 10/01199 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an officilll notice that the mortl!alle on yom home is in default. and the Ienrl<:r intends to foreclose. Scecific infonnaIion abou~ the nature of the default is DroYided in the anached oalleS. The HOMEOWNtR'S MORTGAGE ASSISTANCE PROGRAM (HEMP) nlav be able to helo 10 save your home, This Notice ex131l1ins how the PIORrnm works. To see if m:~can helD YOU must MEET WITH A CONSUMER CREllIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with vou when vou meet with the Counselinl! A.e;ency. The name. address and nhone nmnher of ConsnmP'r Credit ConnsclinlZ' ~nr.1fl'1i;, scrvin~ vour County are listed at the P.l1tf of this Notice. Ii YOU have any auesrions. YOu may call the Pen:nsvlvaDia. Housine: Fi.uancc Ae:encv toll ERe at 1-800-342-2397. ~. with imnaired hearimr can call 17171 780-1869\, This notice conralns impOIta1lt legal infonnaIion. If you have any questions. representatives at the COl\SWJIeI' Credit Co\lIlseling Ag~ may be able to explain it. You may also WanllO contact an atlOJUey in your area. The local bar association may be able 1.0 help you find a lawyer. La Nolifica1iDD ell adjuDto es de lIWDa imponllllCill, pures aIecta 8lI derecbD a coD1iDaar viviendo en ... case. Si DO comprende el cOlltenldo de esta notificacioa obteDga una traduccioD immediatamente Uamando esta ageoc:lll (PeIlnsylvanla Housiag Finance Agency) sin cargos aI numero meocionado arriba. Puedcs ser eleglblc para liD prestamo por el program.. Uamado ":RomeoWben' Emergency Mortgage Assistancc Program" aJ cural p~de salvar su casa de la perdida del derecho a redimir 511 hipoteca. HOMEOWNER'S N.AME: .lEFF.REY L FRYMOYER PROPERTY ADDRESS: 312 PlNEWOOD DRIVE SHlREMANSTOPA 17011 1.QAN ACCOUNT NO.: 0009069642 CURRENT LENDElVSER VlCE.R: GE Capital Mortgage Services, Inc. - T"'lVUT"la.lll:11 EXHIBIT A "_~ ~., ";. c 02/08/00 18:13 FAX 317 808 2477 d ',-', Allison Payment Systems .~-, ~J087 . . . HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FORFlNANCIAL ASSISTANCE WIDeR CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FIlTURE ~ORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"). YOU MAYBE ELIGmLE FOR THE EMERGENCY MORTGAGE ASSISTANCE: . IF YO\IR DEFAULT BAS BEEN CAUSED BY CIRCUMSTANCES BEVOND YOUR CONTROL. . Ill' YOU lU.VE A lU1.ASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . rF YOU MltET OTHER ELIGmILlTY REQUlREMENTS ESTABLISHED BY THE PENNSYLVANIA DOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a tc:mpcra.ty stay of foreclosure on your mortgage {or thirty (30) days from the dare of this Notice. During that time you must ammge and atb:nd a "iace-to-fa.cc" meeting wIth one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR IN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPL Y FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF 11IlS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT",EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with onc of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action apinst you for thiIty (30) days aiter the Oate of this meeting. The names addresses and telellhonc nnmbm of desiQnllted COIlSlllllllI credit counscline ~......,,;~. for the count\' in which the ll1'o!>CrtV is located arc set forth allhe end of this Nolice, It is only necessazy to schedule one face-to-face me6ting. Advise your lender,immediatelv ofyouT intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in dcfiwlt for the reasons set forth later in this Notice (see following pages for specific infonnation about the nature of your default). If you have uied aJJd are unable to resolve this problem with the !ellder. you have the right to apply for financial assistance from the Homeowner's Eaiergcncy Mortgage Assistance Program. To do so, you must fill out, sign ami file a completed Homeowner's .&nergcncy Mortgage Assistance Program Application with one of the designated COIlSll1IlCf credit counseling agencies listed at the end of this Notice. Ooly consumer credit counseling agencies have applications for the program and thcy will assist you in submitting a complete applicaIion to the Pennsylvania Housing Finance Ag=::y . Your application MUST bc filed or postmarked within the thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPUCATION PROMPTLY. IF YOU FAIL TO DO SO OR Il1 YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER. FORECLOSURE MAY PROCEED AGAlNST YOUR HOME IMMEDlATEI.Y AND YOURAPPUCATION FOR ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance arc very limited. They will be disbursed by the Agency UJlCier 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 llgainst you if' you haw met the time tequimnents set fonh above. You will be notified directly by the Pcnnsylvama Housing Finance AgQlcy of its del:ision on your application. NOTE: IF YOU ARE CU'RRENTLY PROTECTED BY THE FILING OF A PEnnON IN BANKRUPTn. THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY ~D SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergeucy Mortgage A.!isUtance.) __.1tGo1/0Cl n'lI'V'CdlOIlIh""" EXHIsrr A 02/08/00 18:14 FAX 317 808 2477 Allison Payment ystems 1I0W TO CURE YOUR MORTGAGE DEFAULT (Brin!! ii~D to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above: lender on 312 PINEWOOD DRIVE. SHIREMANSTO PA 17011, IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the foU~monrhs and the followiDg amounts are now past due: 3 Total of mumbly payments from 11/01/99 to 01/01/00 01101100 to 0 I/O 1/00 Including all Accrued late charges, ::r any dcfCITCCIlate cbarges Property im]ledions and NSF check Cbarges. if any expenses Other chargcs aCi:I1led, if any (forced placed insurance AtLamey's fees, ere.) Property Presel"lltion Total $ 2,998.83 HOW TO CURE THE DEFAULT- You may cure the defau.lrwithin THlRTY (30) DAYS ofthedareofLhisnotice BY PAYING TIlE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS S 2,998.83, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH HAVE BECOME DUE DURING THE THlElTY (30) DAY PERIOD. Payments must be made either by cash. caShier's check. certified check or money order made llBVable and sent to: propeny located at: $ 2.920.05 $ 1.113.62 $ 78.78 GE Capital Moagage SCIVices. Inc. 625 MaIyvillc Centre Drive Sl. Louis. MO 63141 1 (800) 317-4322 IF YOU DO NOT CURE THE DEPAUL T - If you do DOt cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intend. to exercise its ril!ht to accelerate the mo~al!e debt. This means that tM emir. OUlSWlding balam:e ofIllis debt will bc considered due immf'rl;aII"Jy and you may lose the chance to pay the BIlllIgage in moPthly installments. If full payment of the IOtal amount past due is not made within THIRTY (30) DAYS, the lender also intends to inslJuct its attomey's to SW't legal action to foreclose llpOn your mol1eazed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sherifl'to pay the mongage debL Ifthc lender refers your case to its attomeys, but yoll cure the lkJinquency before the lender begins legal plocecdings against you, you will still be required IO pay the reasonable attomey's fees thaL were actually im:u.rrcd, up to $50,00, However, iflega! proceedings are srart.ed against you, you will have to pay all reasonable aaomcy's fees actually incurred by the lender even ifIhey exceed $50.00. Any anomcy'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 he required to pay attorney's fees. OTHER LENDER REMEDIES ~ The lender may also sue you personally for the unpaid principal balance and all orbor sums due under the mongage. lUGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - lfyou have DOt cured the de1liult witbin the THIRTY (30) DAY period and forecloSUI'e proceed; Dgs have begun, vcni still have the rieht to cure the default and wevent the sale al any time UIl to onc hour before the Sheriffs Sale. You mav do so by uavina the total amount then uast due. IlltlS any late or other chlU'J\cs then due. reasonable allomevs fees and COsLs cOlln'"""el;l with the foreclos\IIC sale and anv other cosLs cormP.rted with the Sheri:fl's Sale as SllCCined in writinl! by the lender andbv lleJfolm;no any other reauiremems under the mommce Curing yonr default in the manner set fonh in this notice will restore your mortpge to the.ame position as if YOll had neva- defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE'- It is estimated thaI the earliest date that a Sherifrs Sale of the mort.,"3ged property could be held would be approsimate1y Ii months from the date of the Notice. A notice of the actual date of the Sheriff's Sale will be sent to you befo:re !.he s.le. Of cour.e, the amoWlL needed to cure the default will increase the longer you waiL You may find out at any Lime exactly what the required payment or action will be by conw:ting the ICDdcr. - --'-'- 'r.I'..1....,..,,1~ EXHIBIT A '-,r~ ~' 1 0 . Allison Paymen. Sys.ems " - .-,-J 141089 L,:" 02/08/00 18:14 FAX 317 808 2477 HOW TO CONTACT THE LENDER: ~ I, j I I I , ; Nam~ of Leader: (rE Capital Mortgage Services. 1II~ Address: 4680 HaI/1!JaI"k Parkway San Bel"lJudiDo CA 92407 Phone Number: 1 (800) 317-4322 EXTENSION 6509 Fax Number: (909) 880-4880 Contact Pers!>n: LOAN REl'RESENTATlVE ,j EPFECT OF SHERIFF'S SALE - YOll shonld realize tha"t a Sheriff's Sale will end your ownetShip of the mongagell propeny and your rig:hr to occupy it. If you continue to Jive 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 aL any time. ASSUMPTION OF MORTGAGE - You ...ay or may Dot sell of transfer your home to a buyer Of transferee who will assume Ihe mongage debt. provided that all the outStanding paYlIIeIl1s, charges and anomcy's fees and costs lIIe paid prior 10 or at the sale and that the other reqWremeJlLS of the mangagc ue satisfied. YOU MAY ALSO HAVE THE RIGHT: . TO SElL THE PROPERTY TO OBTAIN MONEY TO PAY OFF TIm MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THlS DEBT. . TO HA VB TIllS DEFAULT CURED BY A.i.W THIRD PARTY ACTING ON YOUR BEHALF. . TO HA VB THE MORTGAGE :RESTORED TO THE SAME POSmONS AS IF NO DEFAULT HAD OCCURRED, fF YOU ClJRE THE DEFAULT. (HOWEVER. YOU DO NOT HAVE TIllS RIGHT TO CURE YOUR. DEFAULT MORE TIiAN THlU:E TIMES IN A CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDTNG OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. · 'ro ASSERT ANY OTBERDEFENSE YOU BELIEVE YOU MAYHA VB TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LA W. EXHIBIT A ',," "-'. IL '~,~. Penn,y!vllnill Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) Leycoming-Clinton Counties amm' . ;' 2138 u:i::' S:e~ommunity Ac:ion (STEP) P. O. Box 1328 w::.illi.:unsport, PA 17703 (5.0) 326..0587 p-~"'{ (570) 322-2197 eccs of Nor-J1e3Stern P!\. 201 Basin S~et . W"tlliams (..0) port, PA 17703 ~ I 323-6627 FA..",{ (570) 323-5526 CLIN'I'ON eOu"N'l'Y eecs of Northeastern P!\. 1631 S Atherton St . Suite 100 Sl::1te College. FA 16801 (814) 238-3668 FA.."{ (814) 238-3669 COLUMBL\ COW'o"l'Y cees of l'<ortheastern Pennsvlvania 1400 Allington E.'te<:'.ltive Park Suite 1 CIar!<s Summitt PA 18411 (570) 587.9163 or (800) 922.9537 FA."{ (570) 587.913-l19135 :11 W. Market S~et POB 1127 W'ill<es-Barre. PA 18702 (570) 821..0837 or (800) 922-9537 F.~"'{ (570) 821-1785 Commission on Economic:s Opportunity of Luzeme Count"! 163 .~ber Lane Will<es-Barre, PA 18702 (570) 826..0510 or (800) 822..0359 'F.~",{ (570) 829-1665-CALL BEFORE FA.'TING (570) 455-4994 HAZELTON F.~"'{ (570) 455.5631-CALL BEFORE F.~'TING (570) 836-4090 TUNKH.>"'''''NOCK Booker T. Washington Center '1720 Holland St:"eet Erie, PA 16503 (814.) 453-5744 FA.."{ (814) 453-5749 John F. Kennedy Center, Inc. 2021 East 20th Street Erie. PA 16510 (814) 898-0400 FAX (814) 898-1243 CCCS of Western Peo.n.svlvania. Inc. 2000 Linglestowu Road . aarr;.sburg, PA 17102 (717) 541-1757 Urban League of ~let:ropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 F.~",{(717)234-9459 Community Ac:ion Comm of the Capital Region 1514 Dercv Street Harrisbuz1:, PA 17104 (717) 232-9757 F.~"{ (717) 234-2227 CRAWFORD COU"'NTY Greater Erie Communit-; Action Committee 18 We.t 9th Street Erie. P.... 16501 (814) 459-4581 F.-\X (814) 456-0161 Shenango Valley Urban League, Inc 601 Indiana Avenue Farrell. P....16121 (412) 981-5310 . CUMBERLA.'lD COUNTY Financial Counseling Service. of Franklin 31 West 3rd Street Waynesbon>, P.... 17268 (717) 762.3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 F.~"{ (717) 731.9589 Adams County Housing Authorit-; 139-143 Carlisle SI: Gettysburg, P.... 17325 (717) 334-1518 F.~,,{(717)334-8326 PENNSYLVANIA BULl.ET1N. VOL.. 29. NO. 2:1, J\JNe 5, 1999 EXHIBIT A _li'_' d ~ --'--.-- .-. .... ---. -.-...-...---..---.---. . ALL THAT CERTAIN piece or parcel of land situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, being more particularly bounded and described as follows: BEGINNING at a point on the southern line of Pinewood Drive, said point being at the dividing line between Lots No. 7 and 8 on the hereinafter mentioned Plan of Lots; thence along said dividing line South 22 degrees 55 minutes East, one hundred twenty-two and seventy-seven hundredths (122.77) feet to a point; thence North 67 degrees 05 minutes East, ninety (90) feet to a point at the di viding line between Lots Nos. 8 and 9 on said plan; thence along said dividing line North 22 degrees 55 minutes West, one hundred twenty-two and seventy-four hundredths (122.74) feet to a point on the southern line of Pinewood brive: thence continuing along 'the southern line of Pinewood Drive, South 67 degrees 05 minutes West, ninety (90) feet to a point, the Place of BEGIN- NING. BEING Lot No.8, Block "Tn on Plan No. 8 of tension, said Plan being recorded in the Recorder's Office in Plan Book 23, Page 10. Shireman Manor Ex- Cumberland County BEING the same premises which Bel-Aire Homes, Inc. by their deed dated April 11, 1973 and recorded in the CUmberland County Recorder's Office in Deed Book C-25, page :807, granted and con- veyed unto Leonard J. Mudry and Maureen E. Mudry, his w~fe. UNDER AND SUBJECT, NEVERTHELESS, to easements appearing on record in said Plan and to the restrictions as set forth in the Cumber- land County Recorder's Office in Miscellaneous Record Book 167, 'page 435, and to amended restrictions as set forth in Miscel- laneous Record Book 169, page 685. /. \ l ~ PREMISES: 312 pulEWOODDRIVE ~ ~ ~ ,...~ ']1 " VERIFICATION SCOTT PATTERSON hereby states that he is ASSISTANT VICE-PRESIDENT of GE CAPITAL MORTGAGE SERVICES, INe. 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 relatiug to unsworn falsification to authorities. DATE: a fd40\) .~ ~ ~'~ . .' .~;! . , ~ ~ ~ ~ ...c: ~ C\ 0- , II) & 0 t r & ~ c ... 0 <'::l c- t' ~ c c ~r r; <_. ,~ ;~E; - c ':-7 .:::; -< ~' ,,~~' Ci (~ ..,., .~ -~J .~,) C'; ,.~-...., ,."j 1\.1 ;:) ..--1 :;:; -( ---- ,.- I t._-~~..oiilil>b.:, SHERIFF'S RETURN - REGULAR CASE NO: 2000-01060 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GE CAPITAL MORTGAGE SERVICES I VS FRYMOYER JEFFREY L 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 FRYMOYER JEFFREY L the DEFENDANT , at 0016:00 HOURS, on the 2nd day of March , 2000 at 312 PINEWOOD DRIVE SHIREMANSTOWN, PA 17011 by handing to JEFFREY FRYMOYER 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 So Answers: 18.00 8.68 .00 10.00 .00 36.68 r~~~ . omas Klin 03/03/2000 FEDERMAN & PHELAN Sworn and Subscribed to before me this ;}yCb day of BY:~YK-. ~ Deputy Sheriff ~ ;unnJ A.D. ~{2 ~.<J.~ rothonotary " -- ~ . .. FEDERMAN AND PHELAN By: Frank Federman, Esquire Atty. LD. No.: 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 AITORNEY FOR PLAINTIFF GE Capital Mortgage Services, Inc. v. Cumberland County Court of Common Pleas Civil Division NO.2000-1060-Civil Jeffery L. Frymoyer 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. Date lSS ~ DO ~~ ., /'--. Frank FJerman /- Attorney for Plaintiff j ",.;:,~ _~, c""_'_b',j:."~",,,=~~~:,,,,,~,",,_,_~,,,_,,c"_,,,,--,,,,,,"'_.-c"'",-,-",,",,,,,,--,,-,"-,,,_. 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