HomeMy WebLinkAbout01-0748 FX
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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
CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE CORPORATION
6000 ATRIUM WAY
MOUNT LAUREL, NJ 08054
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
Plaintiff
NO. CJ/- 7cf1 w;J
v.
CUMBERLAND COUNTY
GARY T. EUSKE
DEBORAH L EUSKE,
NK/A DEBORAH LYNN EUSKE
55 LITTLE RUN ROAD
CAMP HILL, PA 17011
Defendant(s)
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING 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 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 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.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA ]7013
(717) 249-3 ]66
Loan #: 0002792596
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1. Plaintiff is
CENDANT MORTGAGE CORPORATION,
F/KIA PHH US MORTGAGE CORPORATION
6000 ATRIUM WAY
MOUNT LAUREL, NJ 08054
2. The name(s) and last known address (es) of the Defendant(s) are:
GARY T. EUSKE
DEBORAH 1. EUSKE,
AlKJA DEBORAH LYNN EUSKE
55 LITTLE RUN ROAD
CAMP HILL, PA 17011
who islare the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 11/1/91 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. 1035, Page 7.
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 1011/00 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."
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6. The following amounts are due on the mortgage:
Principal Balance
Interest
9/1100 through 2/110 I
(Per Diem $23.51)
Attorney's Fees
Cumulative Late Charges
1111191 to 211/01
Cost of Suit and Title Search
Subtotal
$100,963.11
3,620.54
4,000.00
171.32
550.00
$109,304.97
Escrow
Credit
Deficit
Subtotal
0.00
175.38
$ 175.38
TOTAL
$109,480.35
7. The attomey'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. ~1680.403c 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
$109,480.35, together with interest from 2/1101 at the rate of$23.51 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.
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FRANK FEDERMAN, ESQUffiE
Attomey for Plaintiff
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ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
DATB: December 11,2000 FORECLOSURE
TO: Gary T. Euske
55 Little Run Road
Camp Hill, PA 17011
Deborah L. Euske
55 Little Run Road
Camp Hill, PA 17011
THIS FIRM IS A DEBT COLLECfOR A TIEMPTING TO COLLECf A DEBT. THIS NOTICE IS
SENT TO YOU IN AN A TI'EMPT TO COLLECf 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 ATIEMPT TO
COLLECf A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERlY.
This is an official notice that the mort2a2e on your home is in default and the lender intends to foreclosure.
SDecific infonnation about the nature of the default is orovided in the attached DUes.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM lREMAP) may be able to helD to save
your home. This Notice eXDlains how the Dro21'llU1 works.
To see if REMAP can helD. YOU must MEET WlTII A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with YOU when YOU meet the
Counselin2 A2enCy.
The name. address and chone number of Consumer Credit Counselin2 A2encies servin2 your County are
listed at the end of this Notice. Ifvou have any ouestions. YOU may call the Pennsylvania Housin2 Finance
A2encv toll free at 1-800-342-2397. (Persons with imoaired hearin2 can call (717) 780-1869).
This Notice contains important legal infonnation. 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
attomeym your area. The local bar association may be able to help you flDd a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUEDE AFECfA 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 ELEGffiLE PARA UN PRESTAMO 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
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STATEMENTS OF POLICY
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCf. NO.:
ORIGINAL LENDER:
Corporation
CURRENT LENDERlSERVICER: Cendant Mortgage Corporation
Gary T. Euske and Deborah L. Euske
55 Little Run Road - Camp Hill, P A 17011
0002792596
Cendant Mortgage Corporation, CIkIa PHH US Mortgage
HOMEOWNER'S EMERGEl\ICYMORTGAGE ASSISTANCE PROGRAM
YOu MAYBEELIGmU FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HtlME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACf OF 1983 (THE "ACT), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE.
. IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
. IF YOU HAVE A REASONABLE PROSPECf OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
. IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED 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 fortbirty (30) days from the date of Ibis 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. TInS 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 THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT' EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-If vou meet with one of the consumer credit
counselinl! al!encies listed at the end oflbis notice the lender mav NOT take action al!ainst vou for thirtv
(30) daYS after the date oflbis meetinl!. The names. addresses and teleohone numbers of desil!llated
. consumer credit counselinv al!encies for the county in which the oroDerlV is located are set forth at.the end
of this Notice. . It is only necessary to scheduleoile face-to-face meeting. Advise your lender immediatelv
of your intentions.
APPLICATION FOR MORTGAGE ASSIST ANCE- Your mortgage is in a default for the reasons set forth
later in Ibis Notice (see following pages for specific information about the nature of your default.) !fyou
have Died and are unable to resolve Ibis problem with the lender, you have the right to apply for fmancial
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 Ibis 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,
EXHIBIT A
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FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPUCATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACfION-Available funds for emergency mortgage assistance are very limited. They will be
disbUlSed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency bas sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pUlSued against you if you bave met the time requirements set fonh
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 ATfEMPT TO COLLECT
THE DEBT.
If ou have filed bankru te ou can still a I for Emer enc Mor a e Assistance.
HOW TO CURE YOUR MORTGAGE DEF AUL TfBrin" it uo todatel.
NA TIJRE OF THE DEF AUL T- The MORTGAGE debt held by the above lender on your property located
at: 55LittJe Run Road-Camp Hill,PA 1701118 SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONfHL Y MORTGAGE PAYMENTS for the following months and the
following amounts are now past due: Start/End: 10/1/00 thro 1211100 at Sl,130.96 per month.
Monthly Payments Plus Late Charges Accrued S3,478.54
NSF: SO.OO
Inspections: $0,00
Other: $0.00
(Suspense): ~
Total amount to cure default $3,478.54
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACfIONS (Do not use if not aDDlicable): NIA
HOW TO CURE THE DEF AUL T- You may cure the default within TIllRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,478.54,
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified
check ormonev order made oavable and sent to: CENDANT MORTGAGE CORPORATION, 6000
Atrium Way, Mount Laurel, NJ 08054, Attention: Collections Department
You can cure any other default by taking the following action within TIllRTY (30) DAYS of the date of
this letter. (Do not use if not anolicable.) NI A.
IF YOU DO NOT CURE THE DEF AUL T-Ifyou do not cure the default within TIllRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its ri"hts to accelerate the mort"a"e debt The means
that the entire outstanding balance of this debt will be considered due i1mnediately 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 TIllRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to
foreclosure UDon your mortlla2e nrODertv.
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, if legal proceedings are started against you, you
will have to pay all teasonable attorney's fees actually incurred by the lender even if they exceed $50.00.
Any attorney's fees will be added to the amount to the lender, which may also include other reasonable
costs. If vou cure the default within the THIRTY (30) DAY Deriod. vou will not be reDuired to Dav
attornev's fees.
EXHIBIT A
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OlHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you bave not cured the default
within the TIIIRTY (30) DAY period and foreclosure proceedings bave begun, YOU still bave the rimt to
cure the default and Drevent the sale at any time no to one hour before the Sheriff's Sale. You may do so
bv Davin2 the total amount then Dast due. Dins any late or other chart!es then due. reasonable attorney's fees
and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as
$Decmed in writin2 bv the lender and bv oerfOrmin2 any other reauirements under the mortl!ll2e. Curing
your default in the manner set forth in this notice will restore your mortgage to the same position as if you
bad never defaulted
EARLIEST POSSffiLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's
Sale of the mortgage property could be beld 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 the longer you wait. You may find out at any time
exactly wbat the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER: Cendant Mortgage Corporation
6000 Atrium Way
Mount Laurel, NJ 08054
Tel: (800) 257-0460
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 PAYOFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITIJTION TO PAY OFF TIllS DEBT.
. TO HAVE TInS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSmON AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER. YOU NOT HAVE TIllS RIGHT TO
CURE YOUR DEFAULT MORE THAN UiREE TIMES IN ANY CALENDAR YEAR.)
. TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY O1lIE&LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER'
. TO SEEK PR.OTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER. CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATIACHED
Very truly yours,
CENDANT MORTGAGE CORPORATION
Cc: Cendant Mortgage Corporation
Arm: Collections Department
Account No.: 0002792596
Mailed by I" Class mail and by certified Mail No: 7106-4575-1294-1441-6647,6654
EXHIBIT A
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PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM
CONSUMER CREDrr COUNSELING AGENCIES
(REV. 8/00)
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LycomiDS.ctinrllll COUIIIics Commisicllllilr
Communily Action (S1EP) -
2138 Lincoln Su= P,O. Box 1328
WiUiamsport, P A 17703
(370) 326-0587 FAX (570) 3ZZ-2197
CCCSofN""""""'PA
201 SuiD Su=
WiUiamsport, PA 17703
(570)323~7 FAX(570)3~6
31 W. Market Su=
POS 1127
WiUra-Bane,PA 18702 .
(570) I12Hl837 0< (800) 922-9537
FAX (570) 112I-1715
CLINTON COUNTY
tDLlIMBlA COUNTY
Commission on E<OnOII1ics 0pp0rluDi&y ofl.uzine CCIUIIIy
163AmberLano
Wilka-Bam. PA 18702
(570) 826-0510 or (800) 822~3S9
FAX (570) 1129-166i-{CaII Bcfbn FaxiDsl
(570)455-4994 _
FAX (570) 455-563I~CaII Bcfbn FaxiDsl
(570) 836-4090 T........""""
Scokor T. Washin.... C....
rno Holland C_
Erie, PA 16503
(814) 453-5744 FAX (814) 5749
John F. Kennedy C....... In..
2021 East 20'" Su=
Elie, PA 16510
(814) 898-0400
FAX (814) 898-1243
CCCS ofWostem Pennsylwnil.lnc.
2000 LinslestllWll Road
Harrisburg, PA 17102
(717) 541.1757
Urban I.casuc ofM.....,.,.i.... HanislIurI .
N. 6. SIIeCt . .
Harrisburg, PA 17101'
(717) 234-5925 FAX(717)2J4094j9;,
Communily Aclion C_oldle Capilli a.pa
1314 Deny S_
Harrisburg, PA 17I00f';
(717)232-9757 FAX(117)234-22tt
r.'RA WJ'ORD COUNTY
CUMBDLlND COt1NTY
CCCS ofN............. PA
1631 SoulII_ St. Suillll00
SIlIlIlCollege, PA 16801
(814) 238-3668 FAX (814) 238-3669
. \4(JC) Abin..... Excc:ulive Puk
Sui1IlI
Clados SUlllDlit, PA 18411
(570) 587-9163 0<(800) 922-9537
FAX (570) 587-9134-9135
o...w Erie Communily Aclion Commi_ '
18 W... 9'" su=
Erie. PA 16501
(814) 45904581 FAX (814) 456-0161
'\lien.... Valley UrbaIl Loque, lnc.
601 IadiaIlaA_uc
FamI1. PA 16121
(412) 981.mO
F"manciaI CouaseIin!! Services ofFnnklin
31 W...3'"S_-'
Waynesboro, PA 11268
(117) 762-3285
YWCA of Carlisle
301 "G" S_
Carlisle,PA 11013 .
(717) 243-3818 .FAX (71~ 731-9S89
Adams COUllly Housina AuIhority
139-143 Carlisi. St.
00l1ysburg, PA 1732S
(717) 334-1518 FAX 334-8326
PE.'lNSYL VANIA BULU:TIN, VOL D. NO. 23,.JUNE 5. 1999
EXHIBIT A
ALL that certain piece or parce~ of land, situate in the
Town~h;o of Hamodeo, County of Cumberland, Commonwealth of
pennsylvania, more particularly l:>ounded and descril:>ed as
follows, to wit:
BEG~NNrNG at a point on the Southern line of Little Run Road
which point is at the dividing line between Lots Nos. 347
and 348 on Plan of Lots hereinafter mentioned;
THENCE South 1.2 degrees 3l minutes East and a1.ong the
dividing l.ine l:>etween Lots.Nos. 347 and 348 on Pl.an of Lots
hereinafter ment~onQd, a distance of 105.0S feet to a point
on the" rear lot line of Lot No. 209 on P1.an of Lots
hereinafter mentioned:
Tll.F;NCE North 77 degrees 29 minutes East and along parts of
rear lot lines of Lots Nos. 209 and 208, a distance of 80
feet to a point at the dividing line l:>etween Lots Nos_ 348
and 349 on Plan of Lots hereinafter mentioned:
and along the
on Plan of Lots
feet to a point
THENCE North 1.2 degrees 31. minutes West
dividing line between Lots Nos. 348 and 349
hereinafter mentioned, a distance of l05.05
on the southern line of Little Run Road;
THENCE South 77 degrees 29 minutes West and along the
Southern line of Litt~e Run Road, a distanoe of 80 feet to
a point, the point and place of BEGrNN~NG_
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BEING Lot No. 348 on Plan of Lots known as Part of country .-;;,
Clul:> Par]~ which plan is recorded in the Office of the,
Recorder of Deeds in and for Cumberland County in Plan Bool< 'j
37, page 80. .
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HAVING THEREON erected the premises known as and numbered '.~
55 Little Run Road, Camp Hill, Pennsylvania. ,
BE~l'lG the same premises which Howard C. Gale Development
Co. f Inc., a Pennsylvania corporation, by its deed dated.
July 1.2,1.982, and recorded in the Office of the Recorder
of Deeds in. and for Cumberland 'County. Pennsylvania, in Oeed
Sook v, Volume 29, .paqe 4381 granted. and conveyed unto
Michael. R. Folmer and Brenda Wake1.y-Folmer, his ..it.,
Grantors herein.
UNDER AND SUBJECT to the following restriction which shall .-
be construed as a covenant running with the land: '1'71. ,.;,
property herein described Shall not be used at any time tor ,.;;;,
a beauty parlor or barber shop. No trailers or mobile hO_" '.'
are to be permitted on the premises at any time. "
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AND the said grantors do hereby S P E C ~ ALL Y
the property hereby conveyed.
warrant
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IN WITNESS WJ:lEREOF I the said grantors have hereunto ..t .;.~
their hands and seals the day and year first above writ:t.e:n. &{
SIGNED, SEALED AND D~LIVERED
IN THE PRESENC~ OF
PREMISES: 55 LITTLE RUN ROAD
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VERIFICATION
MARK HlNKLE 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, infonnation and belief. The undersigned understands that this statement is made subject
to the penalties of 18 Pa. C.S, Sec. 4904 relating to unsworn falsification to authorities.
Jtb.t}/.d
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DATE:
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CASE NO: 2001-00748 P
SHERIFF'S RETURN - REGULAR
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COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CENDANT MORTGAGE CORP
VS
EUSKE GARY T ET AL
CPL. MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
EUSKE GARY T
was served upon
the
DEFENDANT
, at 0015:49 HOURS, on the 8th day of February, 2001
at 55 LITTLE RUN ROAD
CAMP HILL, PA 17011
by handing to
GARY T. EUSKE
a true and attested copy of COMPLAINT - MORT FORE
NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Aff idavi t
Surcharge
18.00
8.06
.00
10.00
.00
36.06
Sworn and Subscribed to before
me this J t- ~ day of
J'~-., "::.,1 J-6-o I A. D.
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Prothonotary ,~
So Answers:. ~
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.
R. Thomas Kline
02/09/2001
FEDERMAN & PHELAN
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SHERIFF'S RETURN - REGULAR
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~SE NO: 2001-00748 P
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COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CENDANT MORTGAGE CORP
VS
EUSKE GARY T ET AL
CPL. MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
EUSKE PEBORAH A/K/A DEBORAH LYNN EUSKE
the
DEFENDANT
, at 0015:49 HOURS, on the 8th day of February, 2001
at 55 LITTLE RUN ROAD
CAMP HILL, PA 17011
by handing to
GARY T, EUSKE (HUSBAND)
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
;;~~~~~
R. Thomas Kline
02/09/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before By:
me this Jt. ~ day of
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prothonotary I
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FEDERMAN AND PHELAN, LLP
BY: FRANCIS S. HALLINAN
Identification No. 62695
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Cendant Mortgage Corporation, F /KA
PHH US Mortgage Corporation
Plaintiff
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
v.
Cumber/and County
Gary T. Euske
Deborah L. Euske
A/KJ A Deborah Lynn Euske
Defendants
No. 01-748- Civil
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above referenced case Discontinued and Ended without
prejudice.
Please mark the above referenced case Settled, Discontinued and Ended.
Please mark Judgments satisfied and the Action settled, discontinued and
ended.
Please Vacate the judgment entered and mark the action discontinued and
ended without prejudice.
X Please withdraw the complaint and mark the action discontinued and
ended without prejudice.
Date:~
~dA (. ?ldl
rancis S. Hallinan, Esquire
Attorney for Plaintiff
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