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Home My WebLink About01-0038 FX FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ,GMAC MORTGAGE CORPORATION OF P A 150 ENTERPRISE ROAD, SUITE 150 HORSHAM, P A 19044 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISIOT'J TERM Plaintiff NO.Ol-3'8' v. CUMBERLAND COUNTY SHANNON B. HUMES 112 HIGH STREET ENOLA, P A 17025 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE "TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS 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, P A 17013 (717) 249-3166 Loan #: 306770164 'IU, ~r I"!!'I"""~ ~ - . I. Plaintiffis GMAC MORTGAGE CORPORATION OF P A 150 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA 19044 2. The name(s) and last known address (es) of the Defendant(s) are: SHANNON B. HUMES 112 HIGH STREET ENOLA, P A 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 8/12/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to TIIE HUNTINGTON MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1563, Page 1110. By Assignment of Mortgage recorded 3/20/00 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 640, Page 639. 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 9/1100 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." "illll......._. _" __ ~ , :""""""I'1'j I " 6. The following amounts are due on the mortgage: Principal Balance Interest 811/00 through 12/1100 (Per Diem $14.32) Attorney's Fees Cumulative Late Charges 8/12/99 to 12/1100 Cost of Suit and Title Search Subtotal $66,376,51 1,761.36 3,318.00 97.02 550.00 $72, I 02.89 Escrow Credit Deficit Subtotal 0.00 20.33 $ 20.33 TOTAL $72,123.22 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 corne 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. ~ 1680A03c 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 Plaintiff's 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 $72,123.22, together with interest from 12/1100 at the rate of$14.32 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. ~/~ /sl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ',~ " ,,.,, .. ~ Servicing GMAC Mortgage Corporation P.O. Box 8507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 GMAC Mortgage Dme: November 13, 2000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an offici notice that the mort SpeciOe information about e on our home is in defaul and the lender intends to foreclose. e nature of the default is provided in tbe attached paees. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM CHEMAP) mav be able to help to save vour home. This Notice explains how the proeram works. To see if REMAP can help. VOn mnst MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with VOn when you meet with the Connseline AlreDCV. The name. address and phone nnmber of Consumer Credit Conn senne Aeeneies servine vonr Conntv are nsted at the end of this Notice. If yon have any .qnestions. von mavcaB the Penn:rtania Housill2 Finance Aeenev toB free at 1.800.342.2397. (Persens with impaired heariu can ea (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 abo want to contact an attorney in yonr area. The local bar association may be able to help you I"md a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORT ANCIA, PUES AFECT A SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENT~ LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSllNG FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA HOMEOWNER'S NAME(S): PROPERTY ADDRESS: SHANNON B. HUMES 112 HIGH STREET ENOLA, PA 17025 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: 306770164 N/A GMAC Mortgage Corporation EXHIBIT A :;1>0.,,_ 1'_" "I"!"] - HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICRCAN 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 MAY BE EUGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER EI1GIBILIlY REQlliREMENTS ESTABUSHED BY THE PENNSYLVANIA 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 cOlmseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITIDN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. TIlE PART OF TIllS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE Dff AULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSEI1NG AGENCIES .. If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting.The names. addresses and,telenhone munbers of desil!lllltedconsumer credit counseling agencies for the county in which the nropertv 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. APPI1CATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infonnation aboutthe.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 Homeowners Emergency Mortgage Assistance Program. To do so, you must fill out, sign and me a completed Homeowners Emergency Assistance Program Application with one of the designated consumer credit coimseling agencies listed at the end oftms Notice. Only consumer credit colmseling 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 posbnarked within thirty (30) days of you face-to-face meeting. YOU MUST FILE YOUR APPI1CATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTllER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPUCATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are vel)' 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. EXHIBIT A """'1"'0' _'1__ 1-1 n. - NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FllJNG OF A PETITION IN BANKRUPTCY, THE FOLWWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have moo bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAUI,TCBrin2 itun to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender is on YOllrproperty located at: 112 High Street Eno1a, PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTIIL Y MORTGAGE PAYMENTS for the following months and the following amounts are now past due: September 1, 2000 througn November 1, 2000. See attached Exhibit for payment breakdown. Monthly Payments Late Charges NSF Inspections Other Suspense 1,710.96 . 48.50 0.00 0.00 0.00 TOTAL AMOUNT PAST DUE: 1,759.46 .../ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot applicable ): HOW TO CURE THE DEFAULT -- YOllmay cure the default within THIRTY (30) DAYSofthe date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,759.46 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cash. cashiets check. certified check or money order made navable and sent to: Payment Processing GMAC Mortgage corporation PO Box 780 Waterloo, IA 50704-0780 You can CIlre any other defalllt by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not lIse if not applicable.) N tAl' b 1 o pp ~ca e IF YOU DO NOT CURE THE DEFAULT -. If you do not cure the default within THIRTY (30) DAYS ofthe date of this Notice, the lender intends to exercise its ri~hts to accelerate the mort2ar.e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may ose the chance to pay the mortgage in monthly installments. Iffull payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instrnct its attorneys to start legal action to foreclose unon your mortl!ll2ed property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to payoff 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 incllrred, up to $50.00. However, if legal proceedings are started against against YOll, you will have to pay all reasonable attorney's fees actually incllrred by the lender even ifthey exceed $50.00. Any attorney's fees will be added to the amOlmt you owe the lender, which may also include other reasonable costs. Ifvou cure the default within the TffiRTY (30) DAYS period. you will not be required to nav attorney's fees. . EXHIBIT A ~l':',. ,. ~ '1""1 - OTHER LENDER REMEDIES -- The lender may also sue you personally for the \U\paid 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 denult within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the ril!:ht to cure the default and prevent the sale at anv time UD to one hour before the Sherifl's Sale. You may do so bv Daying the total amOlmt then nast due.l>lus allY late or other chames then due. reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sale as smOOed in ",minl! by the lender and bv Derfonnml! anv other reauirements ,roder the mortl!al!e. 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 Sherifl's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sherifl's Sale will be sent to you before the sale. Of course, the amo\U\tneeded to elII'C the defa,dt will increase the 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: Name of Lender: Address: GMAC Mortgage Corporation 401 Mile of Cars Way National City, CA 91950 Phone Number: Fax Number: Contact Person: (800) 850-4622 (619) 470.5579 Collection Department EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs 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 fiunishings and other belongings cOldd be started by the lender at any time. ASSUl\1PTION OF MORTGAGE -- You mar or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that al the outstan~g payments, charges and attorney's fees and costs 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 ANOTIlER LENDING INSTITUTION TO PAY OFF TIllS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO TIlE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE TIllS RIGHT TO CURE YOUR DEFAULT MORE TIlAN TIlREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT TIlE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTIlER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTIlER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY TIlE LENDER. TO SEEK PROTECTION UNDER TIlE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SER\1NG YOUR COUNTY IS ENCLOSED EXHIB'T A ""'~ ~" - "'- ~,,''''I .r' EXHIBIT September 1, 2000 @ October 1, 2000 @ November 1, 2000 @ . "'~r. . , , . '" ~ ,""' ~ " 570.32 570.32 570.32 EXHlB\T A - PENNSYL VANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY Lycoming..clinton Counties Commision for Community Action (STEP) 2138 Lincoln SlIeet P.O, Box 1328 Williams port, P A 17703 (570) 326-0587 FAX (570) 322-2197 CCCS of North eastern P A 20 [ Basin Street Williamsport, P A 17703 (570) 323-6627 FAX (570) 323-6626 COl.UMBIA COUNTY 31 W. Market Street POB 1127 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 Commission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Barre. P A 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665-(Call Before Faxing) (570) 455-4994 Hazeltown FAX (570) 455-5631-(Call Before Faxing) (570)836-4090 Tunkhannock CRAWFORD COUNTY Booker T. Washington Center 1720 Holland Center Erie, P A 16503 (814) 453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East 20. SlIee! Erie, PA 16510 (814) 898.0400 FAX (814) 898-1243 CUMBERLAND COUNTY cces of Western Pennsylvania. fnc. 2000 Linglestown 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 Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 PENNSYLVANIA BULLETIN. VOL. 29, NO. 23, JUNE 5. 1999 .,,--- CCCS ofNorthe..rern PA 1631 South Athenon St, Suire 100 Slate College, PA 16801 (814) 238-3668 FAX (814) 238-3669 14QO Abin~,n Executive Park Suite I Clarks Summit P A 18411 (570) 587-9163 or (800) 922-9537 FA.'{ (570) 587-9134-9135 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 Financial Counseling Services ofFranJdin 31 West 3rd Street Waynesboro, PA 17268 (717)762-3285 YWCA of Carlisle 30 I "G" SlIee' Carlisle, PA 17013 . (717) 243-3818 FAX (717)731.9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, P A 17325 (717) 334-15 I 8 FAX 334-8326 EXHIBIT A r'. . All that certain lot ofland situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: . BEGINNlNG at a point on the eastern line of High Street S4 feet measured southwardly along the eastern line of High Street from the southeast comer of High Street and Highland Avenue; thence North 73 degrees East along a line at right angles with High Street 90 feet to Anderson Alley; thence south 17 degrees East along the western line of Anderson Alley 60 feet to an iron pin; thence South 73 degrees West along a line at right angles with High Street 90 feet to High Street; thence North 17 degrees West along the eastern line of High Street 60 feet to the point or place ofBEGINNlNG. BEING known and numbered as 112 High. Street, Enola, Pennsylvania. BEING the same premises which Howard D. Petennan and Carol Ann Petennan, husband and wife, granted and conveyed to Shannon B. Humes, single person, Borrower herein. -T'i_ ",., " - VERIFICATION FR/\.NK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this maUer, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification, and that the statements made in the foregoing Civil Action in Mortgage F orecIosure are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pac C.S. Sec. 4904 relating to unsworn falsification to authorities. ~~:r~ DATE: "~,J:t ,. . . e 1"'1 ~- ~~ III - "''''''''~~'r",,_,,",l,~ - -.. ~<'~~ ,0, h^' '."'- """ '~, ',"0 i--~-';'f YL""]f't '-:';'~-I IT'J",'~_'ytt':<frr:1jf'ii~-~-:~"&iitlW n c.: 1 0) (-; ,.c- I ~~=- (::> ~ -;-';t i p U ~J l:T:[, ,'n' i < ) .- ~ (\.1 .- i~ '" (-' ' .c_) d <ll r-': ""--"- <S }te, -~~I '-0'1 --.. (j;'-! (:) '- -u ~ ~2 i5:'~n J) ~ ~ -0 2': ~; I'- IJ, r:;;. rJ:I ~ =2 :.~) ~J -.J ~ c:> -< 0- f +l !$'I -. +- '\ :?l :il- c;> ~ €5 k"p ~ ~, ~~~" ,.-,.,~~",~-,...,", "",~.=_,~.!4l'~~iIl!lll,lljllij!~~,qllm'!f~IW:ce!,~<,!V,,,"",,<"'<w,'~,'''m-q"~"'",,,"", ,W ~~,nH:_Rf"~..,,,,~,,,,,,,.;tl~'lI,,*,"iI'~"":"'!!~o;'(""_"'-_'_7""[1"",~-"'iNM"-:{,,""f5:"'W'll- SHERIFF'S RETURN - REGULAR CASE NO: 2001-00038 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORP OF PA VS HUMES SHANNON B CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, was served upon says, the within COMPLAINT - MORT FORE HUMES SHANNON B the DEFENDANT , at 0013:46 HOURS, on the 5th day of January ,2001 at 112 HIGH STREET ENOLA, PA 17025 NELLE HUMES (SISTER) by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 Sworn and subscribed to before me this /0 t. day of ~ ><, AD Jy- 0 'fh,/L, ~ r thonotary , "'Ii. ,~__ __:Jl~ .~ ~~" "' "' _,~ ,,' So Answers: r~~.! R. Thomas Kline 01/08/2001 FEDERMAN & PHELAN ~ BY:~ /' D ut Sheriff FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire J.D. No. 12248 Lawrence T. Phelan, Esquire J.D. No. 32227 Francis S. Hallinan, Esquire J.D. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, P A 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION OF PA Plaintiff vs. SHANNON B. HUMES Defendant(s) Attorney for Plaintiff Court of Cornmon Pleas CUMBERLAND County No. 01-38 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 case discontinued and ended, upon payment of your costs only. /J./;7/o~ Date ( t I ',~ ",e. "" . , .,,..,. , - t, :' ?~S;:IjJ~ Frank Federman, Esquire Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Attorneys for Plaintiff ill .",~" .,~.~-,. , ,0 . _~o~fO__,< " ~., ~~ ~_-r, ~'I"'~ _l..~,il~H~1l'>~~'n"""'.'t(l~",'if>';_;l;''''''!!'''I')1,g_P~!!!l!......,,,. ','>'" ~,;;'~" ~"JiU" J_' ~'-" ,- f ii~""'-~~~'nl!r\"_""-':<',;ilt~;tfm~:Yr~~}k' j:f~L! - ,\' o c <~ d)~T ;~:f- . (/) "'-~::: c::(=) 19 2": -J -<. 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