HomeMy WebLinkAbout97-00517
".
c.- ',(1
.'. "
P:\' \_~,':
p:', :
C' .
(' '
I,' _U
L
~
~
. ~ '\ .
:\':)\
., ~ ~
.,. ~ \)
,. .
~ l' ~: )
~
~
~~
~ f'-
r<'l ~
.t
~\
;1 ~ en
.....
<11.... 5m
.... ',p
'M
~.~ !~
:a~
~~ ....
.~ 0!i1 Ii g2l 0
-
-
~~ I i B I I l;; ~
filwe
a: -
u.w~Z
i~~ ~ oa::IIl~;li
!:!a:~~~
~.; tt>-...~cD
~ oa::z:z~
~~ ;tOli:~-
~~~~~ 5lil!id~
~ a:: a:-
elM::>
NlD
,.1Il
N -
a:
a:
..
:r
, ,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
SCOTT VAN SWEARINGEN
BRENDA J. SWEARINGEN, hip wife,
Plaintiffs
CIVIL ACTION - LAW
.
.
.
.
NO. C}}. )'1') of-.uu:- C~(.rr.b-
v.
:
CITIZENS MORTGAGE CORPORATION,
Defendant
.
.
JURY TRIAL DEMANDED
COMPLAINT
COME NOW the Plaintiffs, Scott Van swearingen and Brenda J.
Swearingen, by and through their attorney, Gregory R. Reed,
Esquire, and for their causes of action allege:
1. Plaintiffs, Scott Van swearingen and Brenda J.
Swearingen, husband and wife, are adult individuals residing at
5031 Turtle Lane, Mechanicsburg, Cumberland County, Pennsylvania
(hereinafter referred to as "Plaintiffs").
2. The Defendant, citizens Mortgage Corporation, is a
corporation doing business within Cumberland County,
Pennsylvania, with corporate offices at P.O. Box 9147, Columbus,
Georgia 31908-9147 (hereinafter referred to as "Defendant").
3. On or about February 21, 1992 Defendant assumed a
mortgage on property located at 5031 Turtle Lane, Mechanicsburg,
Cumberland county, Pennsylvania in the amount of $72,500.00.
Said Mortgage was recorded in Mortgage Book 1049, Page 168.
4. Plaintiffs on the aforesaid date owned and continue to
own said real estate.
5. On or about March 18, 1996 Plaintiffs delivered a check
to Citizens Mortgage Corporation in the amount of $61,792.43 as
payment in full of the indebtedness (a copy of the cancelled
check is attached hereto, marked Exhibit "A" and incorporated
herein by reference).
6. On July l5, 1996 the mortgage had not been satisfied of
record so Plaintiffs' counsel wrote to Defendant, by first class
mail, asking Defendant to immediately satisfy the mortgage (a
copy of said letter is attached hereto, marked Exhibit liB" and
incorporated herein by reference).
7. On October 1, 1996 Plaintiffs' counsel again
corresponded with Defendant by first class mail requesting that
the mortgage be satisfied immediately (a copy of said letter and
return receipt are attached hereto, marked Exhibit "C" and
.
incorporated herein by reference).
8. Citizens Mortgage Corporation has and continues to
refuse to satisfy said mortgage.
9. Citizens Mortgage Corporation's refusal to satisfy the
mortgage within 45 days of Plaintiffs' request is capricious,
spiteful and done with malice and ill-will.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SCOTT VAN SWEARINGEN
BRENDA J. SWEARINGEN, his wife,
Plaintiffs
CIVIL ACTION - LAW
v.
NO. 97-Sl7 of 1997
CITIZENS MORTGAGE CORPORATION,
Defendant
.
.
JURY TRIAL DEMANDED
PRAECIPE
To: Lawrence E. Welker, Prothonotary
Please mark the above captioned action "discontinued,
settled and satisfied."
Date: +J~~/f7?
G<.~
2423 North Third street
Harrisburg, PA 17110
(717) 238-0434
Attorney 1.0. No. 23705
,,:",/
.
~, ..:J'
,
i f..:.:
II'!- Cd , --;
" ).
(.: ~. .
(, I ", ....
C' :~
, ,
, ,'~
Ii:: I ;;.i
'- c
C',: f;U
...,;: t:..
<-.' ....~..
~. )