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FEDERMAN AND PHELAN
By: FRAJiKFEDERMAN,ESQUTIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000
ATTORNEY FORPLMNTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
LASALLE NATIONAL BANK, AS TRUSTEE
UNDER THE POOLING AND SERVICING
AGREEMENT DATED 6/1/98 SERIES 1998-2
ONE RAMLAND ROAD
ORANGEBURG, NY 10962
TERM
Plaintiff
v.
NO. 00 - 377,/
CUMBERLAND COUNTY
G"u .{T€AJ'IL
CHARLES F. DREW
GENA R DREW
27 EAST LOCUST STREET
MECHANICSBURG, PA 17055
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 THIS 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 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. 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 #: 0800801912
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L Plaintiff is
LASALLE NATIONAL BANK, AS TRUSTEE
UNDER THE POOLING AND SERVICING
AGREEMENT DATED 6/1/98 SERIES 1998-2
ONE RAMLAND ROAD
ORANGEBURG, NY 10962
2. The name(s) and last known addressees) of the Defendant(s) are:
CHARLES F. DREW
GENA R DREW
27 EAST LOCUST STREET
MECHANICSBURG, PA 17055
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 4/24/98 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to PUBLIC SAVINGS BANK which mortgage is recorded in the
Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1448, Page
697. By Assignment of Mortgage dated 4/24/98 the mortgage was assigned to
ALLIANCE FUNDING, A DIVISION OF SUPERIOR BANK, FSB which Assignment
is recorded in Assignment of Mortgage Book No. 580, Page 506. PLAINTIFF is now the
legal owner of the mortgage and is in the process offormalizing an assignment of same.
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"
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6. The following amounts are due,on the mortgage:
Principal Balance
Interest
1011/99 through 5/1100
(Per Diem $19.49)
Attorney's Fees
Cumulative Late Charges
4/24/98 to 5/1100
Cost of Suit and Title Search
Subtotal
$66,356.40
4,151.37
3,317.00
187.14
550.00
74,561.91
Escrow
Credit
Deficit
Subtotal
TOTAL
0.00
0.00
0.00
$74,561.91
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 $50,000.00.
9. 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 "A"
10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(L) 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 "A"; or
(iL) 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
$74,561.91, together with interest from 511/00 at the rate of$19.49 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.
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FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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ACT 91 NOTICE
TAKE ACTION
YOUR HOME FROM
FORECLOSURE
TO
SAVE
DATE:
TO:
May 12, 2000
Charles F. Drew
27 East Locust Street
Mechanicsburg, PA 17055
Gena R. Drew
27 East Locust Street
Mechanicsburg, PAl 7055
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. TillS 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. IF
YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, 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
This is an official notice that the mortgage on your home is in default and the lender intends to foreclosure.
Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) 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 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 hearing 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 fmd a lawyer.
LA NOTlFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUEDE 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
LLAMA DO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SAL V AR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): Charles F. Drew and Gena R. Drew
PROPERTY ADDRESS: 27 East Locust Street - Mechanicsburg, PA 17055
LOAN ACCT. NO.: 0800801912
ORJGINAL LENDER: Public Savings Bank
CURRENT LENDERlSERVICER: Superior Bank, Servicing Division
EXHIBIT A
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HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE 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 MAYBE 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 ELlGIBILlTY REQUIREMENTS ESTABLlSHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, yon 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. IP YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOnCE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit
counseling agencies listed at the end oflhis.noticethe 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 agencies 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.
APPLlCA nON FOR MORTGAGE ASSISTANCE-Your mortgage is in a 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 fmancial
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 TIDS 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 set 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
PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
EXHiBifA
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HOW TO CURE YOUR MORTGAGE DEFAULHBring it UP to date).
NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located
at: 27 East Locust Street - Mechanicsburg, P A 17055 IS SERIOUSLY IN DEF AUL T because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amonnts are now past due: StartlEnd: 11/1/99 thru 5/1/00 at $623.71 per month.
Monthly Payments Plus Late Charges Accrued $4,833.82
NSF: $0.00
Inspections: $12.00
Other: $890.56
(Suspense): $130.73
Total amount to cure default $5,605.65
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use ifnot applicable): N/A
HOW TO CURE THE DEF AUL T~ Y ou 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 $5,605.65,
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check, certified
check or monev order made pavable and sent to: FEDERMAN AND PHELAN, Suite 900,Two Penn
Center Plaza, Philadelphia, PA 19102, attention: Reinstatement Department.
You can CUre any other default by taking the following action within THIRTY (30) DAYS of the date of
this letteL (Do not use if not applicable.) N/A.
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 The means
that the entire outstanding balance of this debt will be considered due immediately and yon 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 attorney to start legal action to
foreclosure upon your mortgage property.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage 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 amqunt to 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 pay
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
by 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.
EXHdBrr A
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-8IX (6) MONTHS from the date of
this Notice. A notice of the actual date of the Sheriff's Sale will be sentto 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.
HOW TO CONTACT THE LENDER: AttorneyRepresenting Lender:
FEDERMAN AND PHELAN
Suite 900, Two Penn Center Plaza, Philadelphia, PA 19102
Phone: (215) 563-7000 Fax Number: (215) 563-5534
Contact Person: Pbyllis Levin, Reinstatement Department
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 mayor _ X_may not (CHECK ONE) sell or transfer
your borne to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost 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 PAYOFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF 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 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 LA WSUIT 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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
Very truly yours,
FEDERMAN AND PHELAN
Cc: Superior Bank, Servicing Division .
Attn: Keith Fitzgerald
Account No.: 0800801912
Mailed by 1" Class mail and by certified Mail No: 7099-3220-0003-6386-2402,2303
EXHIBIT A
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Pennsylvania Housing Finance Agency
Homeowner's Emergency Mortgage Assistance Program
Consumer Credit Counseling Agencies
(Rev. 5/99)
Lycoming-Clinton Counti
Commission For C 08.
2138 Lincoin Stre,.t ommwuty Action (STEP)
P. O. Box 1328
Williams
(570) 32~~t'\ 17703
FA.'{ (570) 322-2197
cees of Northeastern Pi\.
201 Basin Street -
Williams
(570) 323~~lA 17703
FA.'{(570) 323-6626
CLINTON COUNTY
eees of Northeastern Pi\.
1631 S Atherton St -
Suite 100
State College, PA 16801
(814) 238-3668
FA.,{ (814) 238-3669
COLUMBIA COUNTY
eecs of Northeastern Pennsvlvania
1400 Abington Executive Park
Suite I
Clarks Summitt PA 18411
(570) 587-9163 or (800) 922-9537
FAX(570) 587-913419135
31 W. Market Street
POB 1127
Wilkes-Barre. PA 18702
(570) 821-0837 or (800) 922-9537
FA.'{ (570) 821-1785
Commission on Economics Opportunity of Luzeme County
163 Amber Lane
Wilkes-Barre, PA 18702
(570) 826-0510 or (800) 822-0359
FAX (570) 829-1665--CALL BEFORE FA.'GNG
(570) 455-4994 HAzELTON
FAX (570) 455-5631-CALL BEFORE FA.'GNG
(570) 836-4090 TUNKHANNOCK
Booker '1', Washington Center
1720 Holland Street
Erie, PA 16503
(814) 453-5744
FAX (814) 453-5749
John F. Kennedy Center, Inc_
2021 East 20th Street
Erie, PA 16510
(814) 898-0400
FAX (814) 898-1243
CCCS of Westem Pennsylvania, Inc,
2000 LinglestoW11 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 S~t
Harrisburg, PA 17104
(717) 232-9757
FA.'{(717) 234-2227
CRAWFORD COUNTY
Greater Erie Community Action Committee
18 West 9th Street
Erie, PA 16501
(814) 459-4581
FAX (814) 456-0161
Shenango Valley Urban League, Inc
601 Indiana Avenue
Farrell. PA 16121
(412) 981-5310
CUMBERLAND COUNTY
Financial Counseling Services of Franklin
31 West 3rd Street
Wayn08boro. PA 17268
(717) 762-3285
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(71 7) 243-3818
FA.1: (717) 731-9589
Adams County Housing Authorit'J
139-143 Carlisle St
Gettysburg, PA 17325
(717) 334-1518
F.'\X(717) 334-8326
EXHJBITA
PENNSYLVANIA BULLETIN, VOl. 29, NO. ~ JUNE 5, 1_
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All that certain house and lot of ground situate on the north
side of East ~ocust Street, (Second Ward), in the Borough of
Mechanicsburg, County of Cumberland, State of Pennsylvania,
bounded and described as follows, to wit:
BEGINNING at a point on said East Locust Street at corner of lot
formerly of Sallie A_ Huston, now or formerly of ~ida sel.fjit;;;
thence by said Locust Street eastward twenty-one (n) feet. f;"hree
(3) inches to corner of lot now or formerly of Catharin~" .'="
Klinedinst; thence by said lot northward one hundred (100) "'feet,
more or less, to Stouffer Alley; thence by said Alley westward
twenty-three (23) feet, more or less, to lot now or former~y of
said Lida. Sellers; thence by said lot southward one hundred (100)
feet, mQre or less, to the place of BEGINNING.
BEING the same premises which Mabel S. Anderson, widow, by deed
dated April :L6,1959, and recorded April 16, 1959, in the Office
of the ~ecorder of Deeds in and for Cumberland County,
pennsylvania, in Record Book E, Volume 19, Page 154, granted and
conveyed unto Donald A.E. Hammond and Joyce A. Hammond, his wife_
PREMISES: 27 EAST LOCUST STREET
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VERIFICA nON
KEITH FITZGERALD hereby states that he is FORECLOSURE MANAGER of SUPERIOR
BANK, FSB mortgage servicing agent for Plaimiffin 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 Imowledge, information and belief The undersigned understands that this
statement is made subject to the penalties of 18 Pa. CS. Sec. 4904 relating to unsworn falsification to
authorities.
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DATE:
&/;)106
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-03774 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK
VS
DREW CHARLES F ET AL
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland county, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
DREW GENA R
the
DEFENDANT
, at 1906:00 HOURS, on the 13th day of July
at 537 BRADT AVE,
, 2000
NEW CUMBERLAND, PA 17070
by handing to
GENA DREW
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
IO,54
.00
10.00
.00
38.54
So Answers:
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R. Thomas Kline
07/14/2000
FEDERMAN AND
Sworn and Subscribed to before By:
me this ~~ day of
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2000-03774 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK
VS
DREW CHARLES F ET AL
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
DREW CHARLES F
the
DEFENDANT
, at 2005:00 HOURS, on the 13th day of July
, 2000
at LAND OF LAKES (PLACE OF
EMPLOYMENT)
MT. HOLLY SPRINGS, PA 17065
by handing to
CHARLES DREW
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
4,34
.00
10,OO
.00
20.34
So Answers: "
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R, Thomas Kline
07/14/2000
FEDERMAN AND
Sworn and Subscribed to before By:
me this M ~ day of
1tJ:;; . A.D.
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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
ATTORNEY FOR PLAlNTWF
LaSalle National Bank, as Trustee Under The
Pooling and Servicing Agreement Dated 6/1/98
Series 1998-2
v,
Cumberland County
Court of Common Pleas
Civil Division
No, 00-3774 Civil Term
Charles F. Drew
and Gena R. Drew
PRAECIPE
TO THE PROTHONOTARY:
_A.
Plaintiff hereby withdraws the complaint filed in this matter. Please mark this case
discontinued and ended without prejudice,
_X_B.
Please mark this case settled, discontinued and ended.
?/; 5/;rJ
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Frank Federman
Attorney for Plaintiff
Date