HomeMy WebLinkAbout97-06808
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COMPL6tNT IN MORTCAC,E FORECLOSURE
AND NOW, comes the Pl.Jintiff by its .Jttorneys, Louis P. Vitti ,1Ild Associ.Jtes, P.c.
and Louis P. Vitti, Esquire, .Jnd pursu,mt to the Pennsylv,mi.J Rules of Civil Procedure
Numbers 1141 through 1150, for its Complaint in Mortg,lge Foreclosure, sets forth the
following:
1. The Plaintiff is .I corpor.Jtion duly authorized to conduct business within
the laws of the Commonwealth of Pennsylvania, h,lVing.J principal place of business located
at. 4825 N. Scott St., Suite 200, Schillen P.Jrk, iL 60176.
2. The Defendant(s) is/,lre individuals with .I last known mailing ,uldress of
457 West Main St, Walnut Bottom, PA 17266. The property address is 457 West Main
Street, Walnut Bottom, PA 17266 and is the subject of this action.
3. On the 15th day of M.Jrch, 1993, in considerdtion of.J loan of Sixty Four
Thousand Four Hundred Twenty Six and 00/100 ($64,426.00) Dollars made by Meridian
Mortgage Corp., a PA wl'poration, to Defendant!s), the s.Jid Derendant(s) executed and
delivered to Meridi.Jn Mort~.Jge Corp., .I PA corpor.Jtion, " "Note" secured by .I Mortg.Jge
with the Defend,mt(s) .IS mortgagor(s) .Jnd Meridi,lIl Mortgage Corp., .IS mortgagee, which
mortgage was recorded on the' 6th d,ly of M.Jrch, 19')], in the Orfice of the Rewrder of
Deeds of CumberldllCl County, in Mortg.Jge Book Volume I 121, fJ.1ge 871. The ,.lid
COMPLAINT IN MORTGAGE FORECLOSURE
AND NOW, comes the Plaintiff by Its attorneys, Louis p, Vitti and Associates, P.c.
and Louis P. Vitti, Fsquire, and pursuant to the Pennsylvania Rules of Civil Procedure
Numbers 1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the
following:
1. The Plaintiff i; a corporation duly authori;:ed to conduct business within
the laws of the Commonwealth of Pennsylvania, having a principal place of business located
at 4825 N. Scott St., Suite 200, Schillen Park, IL 60176.
2. The Defendant(s) is/are individuals with a last known mailing address of
457 West Main St, Walnut Bottom, PA 17266. The property address is 457 West Main
Street, Walnut Bottom, PA 17266 and is the subject of this action.
3. On the 15th day of March, 1993, in consideration of a loan of Sixty Four
Thousand Four Hundred Twenty Six and 00/100 ($64,426.00) Dollars made by Meridian
Mortgage Corp., a PA corporation, to Defendant(s), the said Defendant(s) executed and
delivered to Meridian Mortgage Corp., a PA corporation, a "Note" secured by a Mortgage
with the Defendant(s) as mortgagor(s) and Meridian Mortgage Corp., as mortgagee, which
mortgage was recorded on the 16th day of March, 1993, in the Office of the Recorder of
Deeds of Cumberland County, in Mortgage Book Volume 1121, page 871. The said
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
.JUPITER MORTGAGE CORP., Assignee
of MERIDIAN MORTGAGE
CORPORATION
CIVIL DIVISION
NO. q7- 68'08 tW-i1./~
"
Plaintiff,
COMPLAINT IN MORTGAGE
FORECLOSURE
vs.
Code
MORTGAGE FORECLOSURE
KENNETH M. WINEBRENNER and
SUSAN M. WINEBRENNER,
Filed on behalf of
Plaintiff
Defendants.
Counsel of record for this
party:
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
COMJ,lLAINT IN MORTGAGE FO~ECL9SURE
NOTICE
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 THE ATTORNEY AND FILING IN
WRITING WITH THE COURT YOUR DEFENSES AND 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 MAYBE 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 THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU SHOULD 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 LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
3RD FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 697-0317
COMPLAINT IN MORTGA,0E FORECL.OSURE
AND NOW, comes the Plaintlrf by its allorneys, Louis P. Villi and Associates, P,C.
and Louis P. Villi, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure
Numbers 1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the
following:
1. The Plaintiff is a corporation duly authorized to conduct business within
the laws of the Commonwealth of Pennsylvania, having a principal place of business located
at 4825 N. Scott St., Suite 200, Schillen Park, IL 60176.
2. The Defendanl(s) is/are individuals with a last known mailing adcJress of
457 West Main St, Walnut Bottom, PA 17266. The property address Is 457 West Main
Street, Walnut Bottom, PA 17266 and is the subject of this action.
3. On the 15th day of March, 1993, in consideration of a loan of Sixty Four
Thousand Four Hundred Twenty Six and 00/100 ($64,426.00) Dollars made by Meridian
Mortgage Corp., a PA corporation, to Defendanl(s), the said Defendantls) executed and
delivered to Meridian Mortgage Corp., a PA corporation, a "Note" secured by a Mortgage
with the Defendant(s) as mortgagor(s) and Meridian Mortgage Corp., as mortgagee, which
mortgage was recorded on the 16th day of March, 1993, in the Office of the Recorder of
Deeds of Cumberland County, in Mortgage Book Volume 1121, page 871. The said
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
JUPITER MORTGAGE CORP.. Assignee of MERIDIAN
MORTGAGE CORPORATION.
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) No. 97-6808 Civil Term
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Plaintiff,
vs.
KENNETH M. WINEBRENNER and SUSAN M.
WINEBRENNER.
Defendants.
PETITION FOR SERVICE PURSUANT TO RULE 430
AND THE PENNSYLVANIA RULES OF
CIVIL PROCEDURE 400. ET SEQ.
NOW comes the Plaintiff by and through their attorneys, Louis P. Vitti & Associates,
P.c. and Louis P. Vitti, Esquire, and files this Petition requesting this Honorable Court permit
service pursuant to Pennsylvania Rules of Civil Procedure 400, et seq., and particularly Rule
430 whereof the following is a statement:
1. Plaintiff did file a Complaint at the dbove-captioned number in mortgage
foreclosure.
2. The property address is 457 West Mdin Street, Walnut Bottom, PA 17266, and
is the subject of this action.
3. The Sheriff did attempt to mdke service, but hds been un,lble to serve the
Defendant, Kenneth Winebrenner ,md Sus,m M. Winebrenner. See Exhibit "A".
1
4. Efforts to effectuate service by the Sheriff h,lVe met without success and service
has been frustrated requiring presentation of this Petition.
WHEREFORE, Plaintiff prays this Honorable Court enter an Order permitting service
by posting the property by the Sheriff.
Respectfully submitted,
LOUIS P. VITTI & ASSOC., P.c.
ill..
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BY: ./'" r)~ ,;/ t
louis P. ~itti, Esquire
Attorney for Plaintiff
:2
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1997-06808 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
JUPITER MORT3AGE CORP
VS.
WINEBRENNER KENNETH M ET AL
-B., Thom'lls Kline , Sherif!, who being duly sworn according
to law, says. that he made a diligent search and inquiry tor the within
named defendant. to wit: WINEBRENNER SUSAN M
but was unable to locate H..r in his bailiwick. He therefor.. returns
the COMPLAINT - MORT FORE
NOTICE
HOT FOUND. as to the within nam..d defendant
WINEBRENNER SUSAN M
DEFT. MOVED AND LEFT NO FO~RD~G ADDRESS WITH
THE POST OFFICE.
Shvriff's Costs:
Docketing
Serviee
Affidavi t
Surch'lll"ge
6.111111
.00
.111111
2.tZl0
So answers:
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fi.. Thomas I\l~no;>. 5hl!r~:t!
S8. IVI1I LOUIS P. VITTI
12116/1997
Sworn and'subscribed to bo;>fore me
this d'llY of
19 A. D.
i-r':l'.h<:lnotary
EXHIBIT"
A
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