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Home My WebLink About00-08691 . . ..-. _,'l -" A FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CENDANT MORTGAGE CORPORATION F/KJA PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MT. LAUREL, NJ 08054 Plaintiff TERM NO.co - 11..9/ (!Il..~l~ v. CUMBERLAND COUNTY ROBERT D. SMITH ANN M. SMITH 8 WALNUT LANE CAMP HILL, PA 17011 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEl\'IPTING 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, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE d:ONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT (}F A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defeno 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 !\gainst 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 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 FORlli BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, PHILADELPHIA COUNTY LAWYER REFERENCE SERVICE PHILADELPHIA BAR ASSOCIATION 1101 MARKET STREET, l1TIIFLOOR PHILADELPHIA, PA 19107 (215) 238-6300 (SEE ATTACHED ESPANOL AVISO) Loan #: 8395022 ~I' .':.,i , ."tj;!~"~--,w'1jr 1. Plaintiff is CENDANT MORTGAGE CORPORATION FIKJA PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MT, LAUREL, NJ 08054 2. The name(s) and last known address (es) of the Defendant(s) are: ROBERT D. SMITH ANN M. SMITH 8 WALNUT LANE CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) ofthe property hereinafter described. 3. On 4/19/96 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. 1317, Page 819. 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 3/1/99 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 n A. n ,.~l. j; 1< .' 6. The following amounts are due on the mortgage: Principal Balance Interest 2/1/99 through 11/1/00 (per Diem $20.65) Attorney's Fees Cumulative Late Charges 4/19196 to 11/1/00 Cost of Suit and Title Search Subtotal $88,683.82 13,216.00 4,000.00 306.90 750.00 $106,756.72 Escrow Credit Deficit Subtotal 0.00 2.123.18 $2.123.18 TOTAL $109,079.90 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. g1680A03c 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: (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 $109,079.90, together with interest from 11/1/00 at the rate of $20.65 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. ~_~L~ Is! Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff --.,. , b.1::LlljJi:, .Jj ;x_ ,Ii , , i 'ill:(~1 " , ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM DATE: November 24, 2000 FORECLOSURE TO: Robert D,Smith 8 WaInut Lane Camp Hill, PA 17011 Ann M, Smith 8 WaInut Lane Camp Hill, PA 17011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS 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 vour home is in default and the lender intends to foreclose, Specific information about the nature of the default is provided in the attached pages, The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to help to save vour home, This Notice explains how the program works, To see ifHEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet the Counseling Agencv, The name. address and phone number of Consumer Credit Counseling Agencies serving vour County are listed at the end of this Notice. Ifvou have anv auestions. vou mav call the Pennsvlvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-18691. 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES 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 PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA, EXHIBIT A ~I' ~J r . ........: , STATEMENTS OF POLICY HOMEOWNER'S NAME(S): Robert D. Smith and Ann M. Smith PROPERTY ADDRESS: 8 Walnut Lu.-Camp Hill, PA 17011 LOAN ACCT. NO.: 8395022 ORIGINAL LENDER: PHH US Mortgage Services CURRENT LENDER/SERVICER: Cendant Mortgage Corporation(NJ) HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE 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 TIlE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACTOF 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 ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL V ANlA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you 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. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF TIllS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES-Ifvou meet with one of the consumer credit counseling agencies listed at the end of this notice the lender mav NOT take action against vou for thirtv (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 orooerlY 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 immediatelv of your intentions. APPLICATION 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 financial 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 THIS 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 EXHIBIT A """ I, , ~ I , 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 ou have filed bankru te ou can still a I for Emer ene Mort a e Assistance. HOW TO CURE YOUR MORTGAGE DEF AUL T !Bring it uo to date ). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 8 Walnut Ln.-Camp Hill, P A 170111S SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Start/End: 3/l/99 thru 11/l/00 at $827.74 per month. Monthly Payments Plus Late Charges Accrued $17,689.44 NSF: $0.00 Inspections: $121.30 Other: $1,856.25 (Suspense): $0.00 Total amount to cure default $19,667.00 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not aoolicable): N/A HOW TO CURE THE DEFAULT-You may cure the default within TIlIRTY (30) DAYS of the date of this notice BY PAYING TIlE TOTAL AMOUNT PAST DUE TO TIlE LENDER, WHICH IS $19,667.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE TIlIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or monev order made oavable and sent to: FEDERMAN AND PHELAN, L.L.P., One Penn Center at Suburban Station, 1617 John F. Kennedy Boulevard, Suite 1400, Philadelphia, PA 19103- 1814, Attention: Payoff/Reinstatement Department. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not aoolicable.) N/A. IF YOU DO NOT CURE TIlE DEF AUL T -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. This means that the entire outstanding balance of this debt will be considered due immediately and you 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 foreclose uoan your mortllaQ:e orooertv. 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, iflegal 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 amount you owe lender, which may also include other reasonable costs. Ifvou cure the default within the TIlIRTY (30) DAY oeriod. vou will not be reauired to pav 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. EXHIBIT A <__I "~ ,,'", ~,"",__lli: " ,,"-,L. , --j~ '';: '. '. , ,w.-"", 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, vou still have the right to cure the default and Drevent the sale at anv time UD to one hour before the Sheriff's Sale. You mav do so bv Daving the total amount then Dast due. Dlus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and anV other costs connected with the Sheriffs Sale as sDecified in writing by the lender and by Derforming any other reauirements 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. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase tJ:te longer you wait. You may fmd out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: FEDERMAN AND PHELAN, LL.P One Penn Center at Suburban Station, Suite 1400 1617 Job" F. Kennedy Boulevard Philadelphia, PA 19103-1814 Tel:(215) 241-1711 Attention: Phyllis Levin, PayofflReinstatement Dept. 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 may or_X_may not (CHECK ONE) sell or transfer your home 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 PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACfING 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 LAWSUIT 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, Attn: Susan McFadden FEDERMAN AND PHELAN, L.L.P. Account No.: 8395022 Mailed by 1" Class mail/Certificate of Mailing and Certified Mail No: 7000 0600 0025 8584 2245,2238 EXHIBIT A " I~ I; " L' ,,-,,<\:- \ . ALL THAT CERTAIN house and lot of ground situate in the Township of Lower Allen, County of Cumberlanel and Commonwealth of Pennsylvania, bounded and. described as tollows, to wit; . BEG1NNING at .. point on the Northern line' ot Walnut Lane, (50 feet wide), at the dividing' Une between Lots Nos. 7 and 8, Block Itp". on the hereinafter mentioned Plan ot Lots; thence along Lot NO.7" Block liP", on said plan, North 31 degrees 39 minutes West, a distance of 85.00 teet to B. point; thenoe North '48 degrees 15 minutes East, a distance or 72.27 foet to a po~t on the line or Walnut Circle; thence along Walnut Circle by a curve to the right having a ra<lit;1S of 30.3 feet, a distance or 35..87 teet to a point; thence by the same South 31 degrees 39 mInutes East, a distance of 44..55 feet to a point ot a curve; thence by a Qurve to the right having a radius of' 25.0 teet, a distance of 39..21 feet to a point on the Northern line ot Walnut Lane, 50 teet wide, ",!oresafd; thence by the same, South 58 degrees 21 m1nutes West, a distanee or 65.00 teet to a point, the place ot Beginning'. BEING Lot No.8, Bloek "F", on th~ Plan of Lots of Cumberland Park, whloh said Plan Is recorded In tl1e Cumberland County Recorder's Office in Plan Book No.5, at Page 22. HAVING thereon erected a single family dwelling house known and numbered as 8 Walnut Lane, Camp liill, Pennsylvania. BEING THE SAME prem1se.swf11Ch.CCN.a Bank,:Exeoutpr of Ernei!'!t.P.iccolobyits Deed dated Septemb.eri:2::1"., 1989, and recorded in the Cumberland County Rec:orderls Office in Deed Book tlE'I, Volume 3.\, at Page 573., granted and conveyed unto Steven M.}En3tnIngel'l ~DlIanl1t.Ens.i1Jln#er~.~d.ebd/Yitte. AND :BEING ..the same premises wlilch Stev-en M~ .EnsmInger and Ji.bui1p.n Ensminger? husband and wife, by their Deed dated August 18, 1995-, and recorded on August 21, 1995, in the Office of the Recorder ot Deeds in and for Cumberland County, Pennsylvania, in Deed Book 126, at Page 1135, granted unto Louann Ensminger. PREMISES: 8 WALNUT LANE .i.1..l", , " . " "" ~- ",-, - -, i : " . ~ VERIFICATION MARK HINKLE hereby states that he is V.P. ofCENDANT MORTGAGE SERVICES 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. CS. Sec. 4904 relating to unsworn falsification to authorities. J4..;1tLJ DATE: I () !g~O , ~.....,- ~ii:ISi~IiI""'<-iilllii:;:,'~m'" '.~, . "C"""'.-' ,~~~_W'~"~ ."" _~ < ~ -- ~- ,,--, ,.~til~~~__ liiuioi - r.l~lllr~:li~~;,~~.'Mii'lli , ~---. - """ ~ - ~< ,. ,J . "",-"'-'.ftI.-n" "~ -~ ~. ,... _~_',<;;'~il'_' -',' , - . ~ lJ ~ ~ ~ () 0 0 ~ C <::) -'1 (i:. h 0 $~ ,:::) --I -On) Pl ~il ~TI & fT1rn C-) 8 ~ Z:u --'--1:'"1'1 ',- t:5 >~ ill ~';::{6 C\' "'- I -< .C ...... I r:::c I,j .. " ~ (~ >1--' -'."" ~~~ ~~ LJ z" ~ >?: r......J u '-... p:: -" ~ ~'1 -..r:::. :v 'J -<. (~ -< t "'< '" ........'. 11 " > -~--" FEDERMAN AND PHELAN By: Frank Federman, Esquire Atty. LD. No.: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CENDANT MORTGAGE CORPORATION F /K/ A PHH MORTGAGE SERVICES CORPORATION Plaintiff Court of Common Pleas CUMBERLAND County No. 00-8691 vs. ROBERT D. SMITH ANN M. SMITH Defendant(s) PRAECIPE TO WITHDRAW COMPLAINT. WITHOUT PREJUDICE, AND DISCONTINUE AND END TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark this matter discontinued and ended, upon payment of your costs only. 1:21 r~1 0-() Date U~ Frank Federman Attorney for Plaintiff -"! , ' ~mtt!iilf~lj[J tlll:m$ii;-jl'''''ill1~d(iHi~;Pll~~~i<~)hW~:,*iolJ~t~~~~~~~a.Lli. <~ )i;j ,1. ~ .. ~u () C 2: -oeD rn~-q ~~ !2C) zQ _C1 :J:>c ;z ~ .. o t::;:i c:> ,T\ n f',' o " ,,;,,":"j llilhl ~~D _, '-rJ -r--- ~)9 \~.~c} ~~~ ::::, )> ~ :1~ ::: '" (J1 " ,~-, .L~ ~, 11 ~""'" I =~~ ...."'_~j SHERIFF'S RETURN - REGULAR , ~- CASE NO: 2000-08691 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORP VS SMITH ROBERT D DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SMITH ROBERT D the DEFENDANT , at 1027:00 HOURS, on the 21st day of December, 2000 at 8 WALNUT LANE CAMP HILL, PA 17011 by handing to DERRICK SMITH, ADULT IN CHARGE 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 18.00 8.68 .00 20.00 .00 46.68 So Answers: ..-,,-,/, ./:'-'7' r'~/~ R. Thomas Kline 12/26/2000 FEDERMAN AND PHELAN Sworn and Subscribed to before By: ~ ,~~/1/~L Deputy Sherif I . me this .3.......L. day of etCH _Q" . AD r'-;thon~ ,~ "'__tl'~-- ~- 0..._ ...1, -'l'~~. SHERIFF'S RETURN - REGULAR ..,-"" CASE NO: 2000-08691 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORP VS SMITH ROBERT D DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SMITH ANN M the DEFENDANT , at 1027:00 HOURS, on the 21st day of December, 2000 at 8 WALNUT LANE CAMP HILL,. PA 17011 DERICK SMITH, ADULT IN CHARGE by handing to a true and attested copy of COMPLAINT - MORT FORE together with 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: ~~~ R. Thomas Kline 12/26/2000 FEDERMAN AND PHELAN Sworn and Subscribed to before By: g~~7f~ Deputy Sherlff ~ me this day of A.D. Q rothonotary