The URL can be used to link to this page

Home My WebLink About00-08750 ." -,,=' ~, . . ~ ~ -. /' KIVITZ & KIVITZ, P.C. BY: Jay E. Kivitz, Esquire ID# 26769 7901 Ogontz Avenue P.O. Box 27368 Philadelphia, PA 19118-0308 (215) 549-2525 NON JURY Attorney for Plaintiff AURORA LOAN SERVICES, INC. 601 Fifth Avenue Scottsb1uff, NE 69361 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY v. OC> - J>1$(j C;o~l~ JEFFREY A. REIM and EILEEN A. REIM 225 Springfield Road Shippensburg, PA 17257 Defendant # 1999-3145 : : CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE NOTICE TO DEFEND 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 AN 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 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. " I, ,I I' I I, I II I I ~ I: I' ~ CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 =" " ." I", I- ~ '-',1- NOTICE PURSUAN'1' TO FAIR DEBT COLLECTION PRACTICES ACT ~is is an at~~ to collt;"ct a debt and any i,?-formation obtained wi1.l be used for that purpose. unless you dispute the vall.dity of th18 debt, or any portion thereof, within thirty (30) days after receipt of this notice, the debt ,:,i1.l be a~su.med.to be va1.id by our offices. If you notify our offices, in writing, thirty (30) days of recel.pt of th1S not1ce that the debt, or any portion thereof, is disputed, our offices wi1.l provide you with verification of the debt or copy of the Judgment against you, by mail. Upon your written request, within thirty (30) days, this office wil1. provide you with the name and address of your original creditor concerning this debt, if different from the current creditor. 1. Plaintiff is Aurora Loan Services, Inc., 601 Fifth Avenue, Scottsbluff, NE 69363. 2. Defendant(s) is/are as follows: A. Mortgagor(s): Jeffrey A. Reim and Eileen A. Reim, who reside at 225 springfield Road, Shippensburg, PA 17257. B. Real Owner(s): is/are the mortgagors. 3. The date of the mortgage is April 23, 1990. 4. A description of the land and property subject to the mortgage is set forth in Exhibit "A", incorporated herein by reference. 5. The mortgagee is Margaretten and Company, Inc. 6. The mortgage was recorded in the Recorder's County in Record Book 974 page 425 et seq. and reference herein as though fully set forth at length. Office of Cumberland is incorporated by 7. The mortgage was assigned. 8. The most recent assignment was to the plaintiff herein, is in the process of being recorded in the Recorder's Office for Cumberland County, and is incorporated by reference as though fully set forth at length. 9a. 1974 is mortgage written Notice of Intention to Foreclose, pursuant to Act not required because the original principal amount of was in excess of $50,000.00. 6 of the b. Written Notice of Homeowners' "Emergency Mortgage Assistance Act of 1983", pursuant to Act 91 of 1983, is not required because the mortgage is insured by the Federal Hou~ing Administration. 10. The mortgage is in default because monthly payments of principal and interest upon said mortgage due August 1, 2000 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one (1) month, the entire principal balance and all interest due thereon are collectible forthwith. Tender of payment, if any, was rejected because the amount tendered did not represent the amount due at the time of tender. .__ ,~~~o. -.- .., , ~.;I ... 11. The following amounts are due on the mortgage: Principal Balance Information Certificate Prothonotary - File Complaint Escrow Deficit Interest from 7/1/00 to 12/19/00 at $14.69 per diem Late Fees Accrued from 8/1/00 to 12/19/00 at $24.10 per month Attorney's Fees (5%) $52,870.02 325.00 45.50 660.41 2,526.68 TOTAL ..... 120.50 2,808.88 $ 59,356.98 12. 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 Sheriff's Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on the work actually performed. WHEREFORE, Plaintiff requests the Court to enter judgment of mortgage foreclosure against the mortgaged property for the amount set forth above, interest and late charges at the contract rate until the date of Sheriff's Sale, foreclosure of said mortgage and a judicial sale of the mortgaged premises. KIVITZ & KIVITZ, P.C. Jh ~",ITr-;SQUIRE Attorney for Plaintiff - I I_I . -, , - 'c;_ ~ L:i DESCRIPTION ALL the following described real estate lying and being Situate in North Newton Township, Cumberland County, Pennsylvania, more particularly described as follows: BEGINNING at an existing nail in the center line of TR 333 at corner of lands now or formerly of Harper Hershey; thence by said lands now or formerly of Hershey, South 38 degrees 2 minutes 30 seconds East 340 feet to a set iron pin at comer of lands now or formerly of Donald F. VanScyoc; thence by said lands now or formerly of VanScyoc, South 51 degrees 57 minutes 30 seconds West 150 feet to a set iron pin; thence by the same, North 38 degrees 2 minutes 30 seconds West 354.8 feet to an iron pin on the line to a set nail in the center line of TR 333, North 57 degrees 35 minutes 32 seconds East 150.73 feet to an existing nail, the place of beginning, containing 1.196 acres as per draft prepared by Larry V. Neidlinger, R.S., dated March 27, 1984, recorded in Cumberland County, Pa., Plan Book 45, page ll5. Tax Parcel # 30-1O-0616-008A . '~~ V 1-- L,,_, .;;. -,- '--""""''',- \ VERIFICAtION the undersigned does hereby verify subject to the penalties of 18 PA.C.S. i4904 relating to unsworn falsifications to authorities, that helshe is Krista.Gingrich Asst. Vice President of (Title) Aurora Loan Services, Inc. (Company) . plaintiff herei~, that he is duly authorized to make this Verificafion,and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. 12/19/00 tu..J--.; < , iw.;liiiJ - " -w.,~;W,*,;,-,.,ticM~'"'UL--ill:,~~jji!Wj~''''' ' i - ., ,_ ';,\p!~ItU1!~Ml~ffi -,;...~;~~ -- o-MXli:t~~ "- . ' 0; -,~_,~,,"O III - liY.ilitml?Jiti!ilf .' <" ~." ~ <.! II II I 1 Ii II \1 I! I ~ l "<Q.. (') C) ~', , , c: 0 -," ~ ~ :5: ,C-, .lr1 .0 -Om ~'-q ~~{! c"') 8 ~ ~ Zt;::: "0 ........ U]cc ~~:~~J ~ ~ G Gt~:' .'"0 ~~if~ :::.-- :Ji: ~ J I ..,.. -..... Z{'-~ /-".;:rn -... ~ ~ ;;2= 1'3 '-j z """ :r;; =< :n - .t:'" .-<: $ ,-=' ,~ .." ~ , ,~-- . -".~-- ,.,^ -~. ~ , . -~. __"."^.,z '"''~~.~d~_'''1~''-"-='''';~_'''~''--''' <. l, ~~ ,.,~, _JiIiI1Ii~ ... !L- CASE NO: 2000-08750 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AURORA LOAN SERVICES INC VS REIM JEFFREY A ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE REIM JEFFREY A was served upon the DEFENDANT , at 0011:30 HOURS, on the 28th day of December, 2000 at 225 SPRINGFIELD RD. SHIPPENSBURG, PA 17257 by handing to JEFFREY A. REIM a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Pocketing Service Affidavit Surcharge 18.00 8.68 .00 10.00 .00 36.68 So ;;~~ R. Thomas Kline 12/29/2000 KIVITZ & KIVITZ Sworn and Subscribed to before me this 3"^- day of ~ ;LrnJ( A.D. ~, () ~ ~ P othonotary . BY~LJ~.~ , Deputy s~riff '^~_""""'."_""""__"""'-"'" ,--~~ ,~ ~ .~~-'" t"'lt l' CASE NO: 2000-08750 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AURORA LOAN SERVICES INC VS REIM JEFFREY A ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon REIM EILEEN A the DEFENDANT , at 0011:30 HOURS, on the 28th day of December, 2000 at 225 SPRINGFIELD RD. SHIPPENSBURG, PA 17257 JEFFREY A. REIM (HUSBAND) by handing to 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 .00 .00 10.00 .00 16.00 So Ans:~/~,,,!, ..,....-""~~.I ~'" R. Thomas Kline 12/29/2000 KIVITZ & KIVITZ Sworn and Subscribed to before BY:~LJ~ Deputy S riff me this 3.d- day of q ('" A'I :lMJ ( A.D. c+t~Q.~ ~ rothonotary I - -'-". <. -- .--;~, "'I KIVITZ & KIVITZ, P.C. BY: JAY E. KIVITZ, ESQUIRE I.D.# 26769 7901 Ogontz Avenue P.O. Box 27368 Philadelphia, PA 19118-0308 (215) 549-2525 ATTORNEY FOR PLAINTIFF Aurora Loan Services, Inc. V. Jeffrey A. Rein and EiJ.een A. Reim COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 00-8750 PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the Complaint in the above captioned matter. KIVITZ & KIVITZ, P. C. Jh~IRE Attorney for Plaintiff " .:d.""'"'r'td'i!iMlllmii\'lHi1I!,g~~j~ll!iMll}~Iifl!lJj~~~:&"Mfl!:;i!~,,~:;,*,-',"i',l,i~i~.A,Mtg;~~.vkl -~_Ji!c.r - . -" ~ ~~- .," -~~ _~. "' .- .l, cc' ,~. p '" ~-",.c _,0 .~_, ". ---," 1ii'M1'.''''-''''''''''''''''' ,,~_~c" o c:. <:' -r;;:-T' ITi(i' ~:3 r:: \,,::' t-~ ,~-_ -',>". .' j~~~ :::1 ~.< ."'" C~J -." ,";"j ,_::' \,''<> (" ,,', -~ -<,. --,-c 1 I; f !" ~; r:- :::> U:;:'" - ~j.l, -, . ~, ~-" , ..