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HOMESIDE LENDING, INC., SUCCESSOR BY
MERGER TO BANCPLUS MORTGAGE CORP.
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
Defendant
ACTION OF MORTGAGE FORECLOSURE
'7zt,.o/-f/99 C?ud 7~
GREGG E. ROHRBAUGH
TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PUlRPOSE OF COLLECTING THE DEBT.
NOTICE
You have been sued ill court. If you wish to defend against the claims set forth ill the following pages, you must take action
within twenty (20) days after the Complaillt and notice are served, by entering a written appearance personally or by attorney and
filillg ill 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
claim in the Complaint offor eny other claim or relief requested by the Plailltiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS POPER 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 LAWYER REFERRAL SERVICE
Cumberland County Bar Association 2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
A VISO
LE HAN DEMANDADO A USTED EN LA CORTE, SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE
SER SERVIDO CON ESTA DBMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO,
REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION
CONTRA LAS QUEJAS EN BSTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU
P ARTICIP ACION, ENTONCBS, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMAND ANTE Y
REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA
DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES,
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA
DE ABOGADOS), (215) 238-6300.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
Cumberland County Bar Association 2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
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HOMESIDE LENDING, INC., SUCCESSOR BY
MERGER TO BANCPLUS MORTGAGE CORP.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
GREGG E. ROHRBAUGH,
Defendant
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT
COLLECTION PRACTICES ACT, 15 U.S.c. 1601
The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any
information obtained will be used for that purpose. The amount of the debt is stated in this
Complaint Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty
(30) days after your receipt of this notice disputes the validity of the aforesaid debt or any
portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is
valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day
period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall
obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon
written request by Debtor to the undersigned attorney within said thirty (30) day period, the
undersigned attorney will provide debtor with the name and address of the original creditor if
different from the current creditor.
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, P A 171 02
(717) 234-4178
Attorney LD.# 15700
Attorney for Plaintiff
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HOMES IDE LENDING, INC., SUCCESSOR BY
MERGER TO BANCPLUS MORTGAGE CORP.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
vs.
Defendant
ACTION OF MORTGAGE FORECLOSURE
f7..t,.OI- I'IQ1 ~ I..v-
GREGG E. ROHRBAUGH,
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff, HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE
CORP., is a Corporation, with an address of8120 NATIONS WAY, BUILDING 100,
JACKSONVILLE, FLORIDA 32256.
2. Defendant, GREGG E. ROHRBAUGH, is an adult individual, whose last known address is 18 EAST
PORTLAND STREET, MECHANICSBURG, PENNSYLVANIA 17055,
3. On or about, November 28, 1994 the said Defendant executed and delivered a Mortgage Note in the sum
of$89,775.00 payable to BANCPLUS MORTGAGE CORP., which Note is attached hereto and marked
Exhibit "A".
4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to
secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain
real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and
Commonwealth in Mortgage Book 1243, Page 412 conveying to original Mortgagee the subject
premises. HOMESIDE LENDING, INC. is the successor by merger to BANCPLUS MORTGAGE
CORP. The Said Mortgage is incorporated herein by reference.
5. The land subject to the Mortgage is: 18 EAST PORTLAND STREET, MECHANICSBURG,
PENNSYLVANIA 17055 and is more particularly described in Exhibit "B" attached hereto.
6. The said Defendant is the real owner of the property.
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7, The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on
November 1,2000 and all subsequent installments thereon, and the following amounts are due on the
Mortgage:
UNPAID PRINCIPAL BALANCE
$83,790.84
Interest at $18.65 per day
From 10/01/2000 To 04/01/2001
(based on contract rate of8.125%)
$3,394.30
Accumulated Late Charges
$124.32
Late Charges at $31.08
Per month for 6 months
$186.48
Escrow Deficit
$143.43
Attorney's Fee at 5% of Principal Balance
$4,189.54
$91,828.91
**Together with interest at the per diem rate noted above after April 1, 2001 and other charges and costs
to date of Sheriff s Sale.
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 that are actually
incurred by Plaintiff.
8. No judgement has been entered upon said Mortgage in any jurisdiction.
9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No.6 of
1974 is not required in that the original principal balance exceeds $50,000.00.
10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any
way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended.
11. The within Mortgage is insured by the Federal Housing Administration under Title II of the National
Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983.
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WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned
total amount due together with interest at the rate of 8.125% ($18.65 . m), together with other charges and
costs including escrow advances incidental thereto to the d eriffs Sale and for foreclosure and sale of
the property within described.
B
L, KR HALLER
, Esquire
A ey for Plaintiff
J.D. # 15700
1719 N. Front Street
Harrisburg, PA 17102
(717-234-4178)
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NOTE
STATE OF .filmsY.LllA~M>
DA 11! 1lQlll;M\II1IUI..JllJ4
FHA Case No.
44t-494448-0~72P
LOAN II: t0848613
J.LE..l!ORILAf!IIl....SIBE~E.ctr.e.NICsaU8.G....fA..JZAs6
Property Address
t. PARTIES
"Borrower'" means each person signing" the time of this Note. and the person"s
successors and assigns. "Lender" lTWIans ..ElAt<<tfLus...MP.BIti~_~l!....k.QBP
and its successors and ass~ns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In r~turn for a loan. received from Leneter, Borrowel' promisss to pay the ~ :-Ir.cipal
swn of __________.___w____________~_____~______~~__~_____w_____w_~
EIGHTY llIN. THDUSA~D S~llElLtilJNDB~fULE.lJlJLANIU/.QLl=---
Dollar_IUS. saq.776.g0w__uw_', plu$1nterest. to lhe order of lender, Interest wlll be
charged on unpaid principal. from the date, of disbursement of the loan proceeds hI'
Lender. at the ratB of _________________________~__.___~__w_______~~_____
1tULJlND THREE FDlIaIHs-c---------------------------------___l_____
per cent 18....1S.Q::.=.==..:. - '" per year', The Interest rate may changa in accordance with
Paragraph 5fO -of this Note.
3. PROMISE TO PAY SeCURED
Borrower's promIse to pay is secured bV a mortgage. deed of trust or similar security
instrument that is dated the same date as this Note and called lhe ~Securitv Instrument-
That Securitv rnstrument protects the Lender from 10ssAs which might result If Borrower
defaults under thIs Nole.
4. MANNER OF PAYMENT
WTlnM
Borrower shall make a paymen~ of prlncip11 and Interest to Lender on the first day of
each month beginning on JANUABY--:.- ,_ . ...lllll.!L " An~' principal' and Interest
~emal.,lng on the first day of .Jll;.ce~-D.I;.R.....-_ . .29.1.L.. . will be du.J on that dale,
which Is called the -Maturitv Date,-
(B) Plaoe
payment shan be made at 9601 MCALL.tmJL.fl3~~W~
SAN ANTO~I(). TX 7~16 ' . or at such other
place as Lander. may_ designata In writing by notice to B\.)rro~er.
(CJ Amount
InltiaIIV. each monthlv payment of principal an,d Interest will be in the amount of
81iJl2.J.8--n~:--=. This amount will be pari of a'larger monthly payment requIred bV
the Security In.U'ument thai shall be applied to principal. inter.est and otl!e,. Items In
FHA MUltlslate AdJu'stabl$ Rate UI)Ce ~ 02/81
L94 1 03194
Page 1 of 4
2XIi\IVit'IA"
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the ortlsr described In the Security Instrument This tlmount may change in accordancB
with Faragraph 5a of this- ~ote.
5. INTEREST RATE AND MONTH!~'i PAYMENT CHANGES
W ChanSG Date
The interest rate may chan,ge on the first day of APIllk-_.:--" 1.~6 . and
on that day of each succeeding year. "Change Date" means each date on whfch the
Interest rat;, could change.
(al lh. Index
Begiming with the firet Change O~te. ths interest rate will be based on an Index.
"tndex" means the weekly average ~hi!ld on United States lrsasurv Securitiell adjusted
to a constant maturi1v Qf one Vear. BS made available bV the Federal Reserve Board.
"Cvrrent Inde,," me.aM Ihg most recent 'Index figure availilble 30 days before Ihe
C~e Oate. If the Indell: (as dofined abovel is no longoI' available, lender will use as
a now Inde~ any index prescribe!! by the Secrotary (as defined In Paragraph 7181.
lender will give Borrower notice: of U\O new Indell:.
Ie) CalculaUOh of Interest Rata Changos
Before each Change Date, lender will calculate a new interest rate by adding a margin
of lW!LAbltLQtiE.....E..O~BItlw - ~ ~ -- - --- - ~ -;"'-' ~ -- =-:..~ - -~ -:. - ..percentage polnt(sl
17.....2JiO~-------%1 10 u'e Current Index and roundingthe ,um to the naatest
one-eighth of one percentage point (0.125%1. Subject to the limit$ !tated in Paragrapti
5(01, of this Note, lhis rounded amount will be the nllw interest rate until the MS)l.t
C~.aMge Date. t
lD) LImits on Interest Rale cmmges
The Interest rate wlli nQver Increase or decrease by more than one percentage point
11.0%1 on any single Change Date. The interest rate will never be mora than five
percentage points 150%1 higher or lower than thD Initial interest rate slated in
Patagraph 2 of this Note.
(E) CaloulaUon of Paymenl Change
If the interest rate changes on a Change Oate, Lender ,will calculate the amount of
monthly payment of principal and interest which would be necessary to repay the
unpaid prlnclpat b.alance in full at th3 Matt1rify DatB at tho new Inwest rate through
substantially equal payments. In ITtaking such calculation. lender will use the unpaid
principal balance which would be owed on the Change Date if there had been no
default In paynl;):'t O~ the Note. (educed bV the amount of any prepayment to
principal The result af this cal!;ulation will be the amount of the new monthly payment
of principal and interest
(F) Notlco of Changes
Len~er will give notic. to Borrower of any change, In the inlerest rate and monthlv
payment amount The notice must be given at least 25 davs before tho new monthly
payment amount is due, ;nd must set forth )11 the date of the notice,. Vi: the. Chotnge
Date. liiil the old interest rate, liv) Ule new interest rate, 1\11 the n~w monthly payment
amount. Ivl) the Current Index and the date it was publlshad. Mil the method of
calculating the chango In monthly payment amount.. .and Mm .tOy other information
which may be ~equlrcd bV law from time to time.
FHA MlIUlsfat8 Adjustabre Rate Nof. ~ 02191
1941 03/94
Page 2 of 4
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1m Eff.cUv. Oat. of Chanses
A new Inter.st ratllo calculated in accordance with Paragraphs SIC) and 5tO) of this
Note wUl become .ffectlv", on the Chanee Date. Borrower shall malte a pavmQnt In
the' new rr.cnthlv wn.. ".It UeQ'imYl,",! an the first payment date wt-Jeh accur4 .tt least 25
days after lender has gluen Borrowtll' the Mtic.. of changes required by Paragraph
Slf) of \hI, Note. Borl'ower shaD have no ob6gatlon to pay any Increase In 'the monthly
payment amount ,calculatllld 'm accordance with Paragraph 5lE) of this Note i.:~ any
piyment date occurring less than 25 days after Lendet h8$ given the required /lotice.
If the monthly payment amCla.1t calculated in accordance with Paragraph 5JE) of this
Note decreased, but lender failed to glue tlmGlV notice of the dea'"fl'lI$tI and Borrower
made env n\Clntf1IV payment 'amounts exceeding thll payment amount which' should hove
been .fated rn a timely notice, d1Qn Borrower has the optio" to eifhel' (iJ demand the
retutn to BOI1'ower, of any eillCQss payment. with interest thel80n at the Note rate la
rate !lqual to the Interesl rate which ~ould have. been stated In a timely n()ticel. or fill
~equ8St that any excess payment with Interest thereon at the Note rate, be appned as
i)a"ment of prinr;:ipal. Lender's obligation to return any excess payment with 'nter,:n on
demand is nt)t ass.lgnsble even if tros Note J.s o~etwl$. BSSfgnad before thlt dlffl1and
for return Is made.
6, BORROWER'S RIGHT TO PREPAY
QorrOWef has the right to PI?' the debt G\lldenced by this Note, in whole or in patt,
without chal'ge 'or ,penaltV, on the fltat day of any month.
7, BOmIOWER"S FAilURE: TO PAY
tAl lilt. Charse' fOr Ov.rdue Payments
If Lender haa not received the full monthly payment required bV the ~curitv
lnItrumllfrt. 89 descri~d In Par;agraph 41C) of this note, bV the end of flftoen c'lilendal"
days after ,the payment 'Is dLIQ. lender may collect a late charge tn thlJ amount .;;f
.f..QUR percent (4....Q.Q-----%1 of the overc;fus amount of each payment
(SJ o.,.urr
If. BorroweI' defaults bV failing to pay in full any mont):llv payment, th"n Lender may.
except as limited by regulations of 1he Secretary In the case of payment defaults.
require Immediate. payment in full of the principal balanc:e remaining' due llnd all
accr'Uet! Interest. lender may choose not 10 exercl.e this optIon without waivIng its
rlghb: In the event of' any .subsequent d6falJlt This Nole does nor authorize
acceleratlo,n when not permitted bV HUD'regulatlons. A9 used In thl; Note. ~SecretarV"
mean.a lt1e $ecretarv of Hou::ing and Urban Development or his oar her designee.
te) Payment of CoatS and EXptlnsea
If Lender has requited immediate pa)lment In fult as described above, Lender may
require Borrowel' to pay costs 'and expense3 Including reasonable and customary
attorltey's fees for enforcil1{l this Note. Such feGs and costlJ shall bear' Interest from
the 4ate of disbu:'sermrnt st,li:e ~e ~ate as ths principal of this Note.
8. WAI'.tERS
Borrower' and any other person who has obligations under lhls Note wailJe the right!
0# prBSINlfmBnt ffJd notice of dishonor. "Presentmenr ml1all$ ths rigllr to requlra l6llder to.
demand payment of amounts due. "Notice of dIshonor. means lhe right to require lender to
give notice, to other pflrsons th~l amounts due have not been paid.
FHA Multlstatlll AdJustli.ble Rate Nola w 02/91
L941 03/94
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9. "GIVING OF NOTICES
Unless applicable law reqt<ire;;; a different method. any notlco Vlat must be given to
Borrower c;.;IW thJs Note wiD ,t.e fi'lan b, delivering it or bV mailing it by first class mail
to l3ol1'ower at the pro~ertv ldii'"ess above or at a different addrl'lSS If Borrower has
giv.n Lender a notice of Borrower"s different address.
Any notice tha: mu!t Li' lIiven to Lender under this Note will be Riven bV first class
mail, to lendltt al the addnss suted in Paragraph 4lBI or .t a dIfferent address if
Borrower is given a notice of that different address.
10. OBLIGATIONS Of PERSONS UNDER TI-'IS.NOTE
. If more than one person sigP.$ this Note, each person Is fully and personally obligated
to ~eep all of the promises made in this Note, including the rromlse to pay the full amount
OW~d Anv person who Is it. guarilntor. surety or endorser 0 this Note Is 811;0 obllgatod to
do 1t\ess things. Any person who takes over these, obBs.tlons, Including the obligations of a
guarantor,. surety or endorser of ~s Note, is also cbllgated t"l keep all of the promises
r.lll~e in this Note. Lender maV enforclJ Its rights under this Note against each person
Indl\rldlJallv cr against all signatories together. AnV one person signing this Note may be
I'equired to pay all of the amoU!'ts owad under .~s Note.
NOl'ICE TO BORROWER: This dOCUn1Qnt contains provisions for a varIable Interest rata.
BY SIGNING BElOW, Borrower accepts and agrtlA$ to the lerms and ,covenants
contained In this notlt.
Borrowerls1: , ~ i\
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Witness/est.
Witnessles}:
Witnasslesl:
MAILING ADDRESS:
18 E. PORTLAND STREEt
Ml:CHANICSBURG. PA 17055
FHA MulUstate Adjustable RII,e Naee w 2/91
L941W 03/94
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LEGAL DESCRIt'TION
ALL THAT CERTAIN frame house and lot of ground situate on
the South side of,Sast Portland Street, in tha Borough of
Mechanicsburg, County of cumberland, .and State of pennsylvania
bounded and described as follow~, to wit:
BEGINNING at a point on the southerly side of B. Portland
Street, which point is f81.2,feet in a westerly direction from
cbe souLhwest corner of B. Portland Street and Arch Street; thence
South 10 degrees 4 minutes S6 seconds Bast, a distance of 160.50
feet to a pin on creamery AlleYi thence South 79 degrees 30 minutes
West, a distance of 21,50 feet to a concrete nail; thence North
10 ~~9rees 30 minutes, West, a Qistance,of 160.50 feet to a pin;
the.~ct.~ North 79 d.egrees 30 minutes East, a distance of 22.67 feet
to ;i Fo':Jint and place of BEGtNH!NG.
. ~V3;NG THEREON ERECT~ a 2 1/2 story frame dwelling house
ltnown and numbered as 18 East tJortland Str,eet.
, BEING'the same premisE's which Lucie S.. Cl.ark, single woman,
by ber,deed to be recorded simultaneoualy herewith, in the office
of the Recorder of Deeds .-.. Cunmerland. county I ~ranted and conveyed
unto Gregg E. Rohrbaugh.
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COMPANY NAME: ID1ESITE LEN:IIN;. E. 9 I I ''''''''11{ BY MERm 'lD
mN:PllE M:RlG'G: cr:RP.
VERIFICATION
.
I verify that the statements made in the foregoing Complaint are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa. c.s.
Section 4904 relating to unsworn falsification to authorities.
Dated M=:h 14. 2001
~
By
Title Leanne Galvin, Vice President
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-01499 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOMES IDE LENDING INC
VS
ROHRBAUGH GREGG E
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
ROHRBAUGH GREGG E
the
DEFENDANT
, at 0019:47 HOURS, on the 22nd day of March
, 2001
at 18 EAST PORTLAND ST
MECHANICSBURG, PA 17055
GREGG E. ROHRBAUGH
by handing to
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:
Docketing
Service
Affidavit
Surcharge
18.00
5.58
.00
10.00
.00
33.58
So Answers:
~~~~~~~
R. Thomas Kline
03/23/2001
PURCELL, KRUG & HALLER
Sworn and Subscribed to before
me this J.tj~
day of
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HOMES IDE LENDING, INC., SUCCESSOR
BY MERGER TO BANCPLUS MORTGAGE
CORP.
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
PLAINTIFF
VS.
NO. 01-1499 CIVIL TERM
GREGG E. ROHRBAUGH
CIVIL ACTION - LAW
DEFENDANT
IN MORTGAGE FORECLOSURE
P RAE C I P E
TO THE PROTHONOTARY:
Kindly Settle and Discontinue the above matter of record.
PURCELL, KRUG & HALLER
BY'~
Leo . P. Haller
Attorney for Plaintiff
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: April 24. 2001