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Home My WebLink About01-1705 FX , ,,~ FLEET MORTGAGE CORP, F/KJA FLEET REAL ESTATE FUNDING CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW . vs. JOSEPH D. MASZLE AND MARY E. MASZLE ACTION OF MORTGAGE FORECLOSURE flo.O/- /70{" ~ Ju-. Defendants 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 PURPOSE OF COLLECTING THE DEBT. NOTICE 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 the 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 claim in the Complaint of 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 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 COWlty 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 DEMANDA 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 OBJECCJON CONTRA LAS QUEJAS EN ESTA DEMANDA, RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACJON, ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISJONES 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" (SERVICJO DE REFERENCIA DE ABOGADOS), (215) 238-6300, CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland COWlty Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ,. ~T~'~'''''~"" ' ." 1-' -I I -, I -'I r " FLEET MORTGAGE CORP. F/KJA FLEET REAL ESTATE FUNDING CORP., : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CML ACTION LAW : ACTION OF MORTGAGE FORECLOSURE JOSEPH D, MASZLE AND MARY E. MASZLE, Defendants 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 ofthe aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. Ifthe 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 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff "'~5f H f! -,! I I :, FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW vs. JOSEPH D. MASZLE AND MARY E. MASZLE, ACTION OF MORTGAGE FORECLOSURE ILo.OI' J7D)~ I~ Defendants COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., is a Corporation, with an address of P.O. BOX 1169, DEPT 2665, MILWAUKEE, WISCONSIN 53201. 2, Defendant, JOSEPH D. MASZLE, is an adult individual, whose last known address is 233 WEST RIDGE, CARLISLE, PENNSYLVANIA 17013. Defendant, MARY E. MASZLE, is an adult individual, whose last known address is 233 WEST RIDGE, CARLISLE, PENNSYLVANIA 17013. 3. On or about, December 6,1993, the said Defendants executed and delivered a Mortgage Note in the sum of $69,847.00 payable to FLEET REAL ESTATE FUNDING CORP The said Note is not accessible to Plaintiff and is believed to have been lost. In further answer thereto, a copy is believed to be in the possession of Defendants. Plaintiff also avers that the within Mortgage Foreclosure complaint is based upon the Mortgage and that the attachment of a copy of the Note is unnecessary pursuant to Rules 1019(h) ad 1141(a) of the Pennsylvania Rules of Civil Procedure, 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants 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 Book1185, Page 25 conveying to original Mortgagee the subject premises. FLEET REAL ESTATE FUNDING CORP. is now known as FLEET MORTGAGE CORP. The Said Mortgage is incorporated herein by reference. "'I'" I , , I' I;' -"1 ~ , " 5. The land subject to the Mortgage is: 229 CHESTNUT STREET, MOUNT HOLLY SPRINGS, PENNSYLVANIA 17065 and is more particularly described in Exhibit "A" attached hereto. 6. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on October 1, 2000 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $64,012.05 Interest at $12.27 per day From 09/01/2000 To 04/01/2001 (based on contract rate of7.000%) $2,60124 Accumulated Late Charges $0.00 Late Charges at $22.47 Per month for 7 months $15729 Escrow Credit $89.63 Attorney's Fee at 5% of Principal Balance $3,200.60 $69,881.55 **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. Ifthe 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. ;;;1(< T ,>- I'~' - , I " 10. Defendants are not members ofthe Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1083 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.000% ($12.27 per diem), together with other charges and costs including escrow advances incidental thereto to the date of s Sale and for foreclosure and sale of the property within described. ELL, Leon P. H , squire Attorney for Plaintiff !.D. # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) :"~C . .' I--~ t,r- - , r .--", , . Fmc34575 (1696x2~OOx2'tiff) [13] SCHEDULE A (Continued) File No. 11936 policy No. M 178-825821 LEGAL DESCRIPTION '. l\hL 'l'llJ\'r CEIl.'l'1\lN tJ:i\ct of 1 and wi th tho impr:ovelllt::nls lh.ereoJl erected 5i tuate on the Hes t side of Chestnut street. Letwet'll Butler and Church streets, in the Borough of Mount Ilolly sl'ri:l~~. Cumbetland County, Pennsylvania, bounded and described us follows: BEGINNlNG at the int.ersection of the curb line of the western side of Chestnut st.reet and southern side of an allrlCf: thence southerly 50 feet. more or less. along said clw~lnllt street t~.the line of other land now or formerly of sheaffrerj thence westerly alol)9 sai.d other lands noW or formerly or Sheaffer Q19 feet, more or less, to the eastern side of an ~\ieY; \thence along said alley in a northwesterly dirl2ction 64 feet, ~ote'or less to the southerly side of an alley; thence easl~rly along said alley 248 feet, more or less to the place of BEGINNING. BEING improved Hith a tHO story frame dwelling hou~e and outbuildings, known as 229 Chestnut stroet, HOllot Holly spnn9s,. n 17065. BEING THE SAME PREHISES which Harvey E. Guise and Deborah or. l;uise, husband and wife by Deed dated Hay 31, 1990 and recorded June 4, 1990 .in 'leed Book P, Volume 34, page 221, granted and conveyed unto Joseph D. ~l"s.,le. """ ~lary E. ~lasz1e, husband and wife. E~h\o;t D. 1, " II I~.. HSfDrmlMPTRMS Rev. 04J2719J .'""1"""""- -. 1-' "1 '"I "T~__."'("" . . . COMPANY NAME: FlEEr M:RlQ\GE CIRP. F /KIA FlEEr REAL ESmIE RN:lIlIG CIRP. 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:Ird1 21, 2001 B~ EN ORLANDO Title VICE PRESIDENT ;'")(..."T"''''''''-' , ,c~"'"__ ." _'. ,. SHERIFF'S RETURN - REGULAR CASE NO: 2001-01705 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FLEET MORTGAGE CORP VS MASZLE JOSEPH D ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MASZLE JOSEPH D the DEFENDANT , at 0014:05 HOURS, on the 9th day of April , 2001 at 223 WEST RIDGE CARLISLE, PA 17013 by handing to JOSEPH MASZLE 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 3.10 .00 10.00 .00 31.10 S~~~ R. Thomas Kline 04/10/2001 PURCELL, KRUG & HALLER ~ :J.-v-ol A.D. ~ Q 1111/#'. ttJ!tu;- r thonotary '-,~/ Sworn and Subscribed to before me this .;{.'I ~ day of "'~~ ~, I" , ,. '~l "f"'lr:lll<~~ ~ - ~ " SHERIFF'S RETURN - REGULAR CASE NO: 2001-01705 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FLEET MORTGAGE CORP VS MASZLE JOSEPH D ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MASZLE MARY E the DEFENDANT , at 0014:05 HOURS, on the 9th day of April 2001 at 223 WEST RIDGE CARLISLE, PA 17013 by handing to JOSEPH MASZLE 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 ;'92:~~~ R. Thomas Kline 04/10/2001 PURCELL, KRUG & HALLER Sworn and Subscribed to before By: me this .:2'1 ~ day of ~ 021><..) ( A.D. ~a~ ~ Prothonotary cy~ -, : - r , ""j"- __~ " c SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-01705 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FLEET MORTGAGE CORP VS MASZLE JOSEPH D ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, TERRE TENANT OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named TERRE TENANT , OCCUPANT NO TERRE/TENANTS AT ABOVE ADDRESS, PROPERTY IS EMPTY Sheriff's Costs: Docketing Not Found Return Affidavit Surcharge 6.00 5.00 .00 10.00 .00 21. 00 ;, Thomas K~-:~' Sheriff of Cumberland County PURCELL, KRUG & HALLER 04/10/2001 Sworn and subscribed to before me this .lit: day of If';/ e:2tn.91 A.D. g~L () Ihl,&' .ttft4 Pr t onotary ":'"'-"'-r I ~ ,H_"_ r I I" ~.~-=~ ". , '-"' . FLEET MORTGAGE CORP. FfK./A FLEET REAL ESTATE FUNDING CORP, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CNIL ACTION - LAW vs. JOSEPH D. MASZLE AND MARY K MASZLE ACTION OF MORTGAGE FORECLOSURE 710 0/- /70S- ~ -r:.... Defendants 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 PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. !fyou wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attomey and filing in writing with the court your defenses or objections to the claims set forth against you, You are wamed 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 of 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 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 BAN 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 DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, ELPUNTO DE VISTA DE USTED Y CUALQUlER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE 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 r RUE Copy FROM RECORD In Testimony whareof, I hare unto set my haM sea! of said COljrt ai Carlisle. Pa. 11Iis ll1d.3Y ot~A~.. .... :2-/ . ( ~1" 0 If) .~:{f l\'othon :'/:"""_--1-" "~'" .~--, . '-'I, ~,<" ~ " - ,- ~...,~"~~~ ,..~ ~~'~,~ - ~~ - .~; " . , FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION LAW : ACTION OF MORTGAGE FORECLOSURE JOSEPH D. MASZLE. AND MARY E. MASZLE, Defendants 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 ofthe 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 17102 (717) 234-4178 AttorneyI.D.# 15700 Attorney for Plaintiff -,t:nJPPI__,"V: 0-. ~'! ' Tl!l T~-' ~1Il , , . . FLEET MORTGAGE CORP. FIK/A FLEET REAL ESTATE FUNDING CORP., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION -LAW vs. JOSEPH D. MASZLE AND MARY E. MASZLE, ACTION OF MORTGAGE FORECLOSURE ~,b 1- /70" 6;;;;p (LA-. Defendants COMPLAINT IN MORTGAGE FORECLOSURE L Plaintiff, FLEET MORTGAGE CORP. FIK/A FLEET REAL ESTATE FUNDING CORP., is a Corporation, with an address of P.O. BOX 1169, DEPT 2665, MILWAUKEE, WISCONSIN 53201, 2. Defendant, JOSEPH D. MASZLE, is an adult individual, whose last known address is 233 WEST RIDGE, CARLISLE, PENNSYLVANIA 17013. Defendant, MARY E. MASZLE, is an adult individual, whose last known address is 233 WEST RIDGE, CARLISLE, PENNSYLVANIA 17013. 3. On or about, December 6, 1993, the said Defendants executed and delivered a Mortgage Note in the sum of $69,847.00 payable to FLEET REAL ESTATE FUNDING CORP The said Note is not accessible to Plaintiff and is believed to have been lost. In further answer thereto, a copy is believed to be in the possession of Defendants, Plaintiff also avers that the within Mortgage Foreclosure complaint is based upon the Mortgage and that the attachment of a copy ofthe Note is unnecessary pursuant to Rules 1019(h) ad 1141 (a) of the Pennsylvania Rules of Civil Procedure. 4. Contemporaneously with and at the time of the execution ofthe aforesaid Mortgage Note, in order to secure payment of the same, Defendants 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 Book1185, Page 25 conveying to original Mortgagee the subject premises, FLEET REAL ESTATE FUNDING CORP. is now known as FLEET MORTGAGE CORP. The Said Mortgage is incorporated herein by reference. '1""'" '-- - ~, . ~ 1--'" I' 1-1 I ' .'~~-'~" ,----- . 1 5, The land subject to the Mortgage is: 229 CHESTNUT STREET, MOUNT HOLLY SPRINGS, PENNSYLVANIA 17065 and is more particularly described in Exhibit "A" attached hereto, 6, The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on October 1,2000 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $64,012.05 Interest at $12.27 per day From 09/01/2000 To 04/01/2001 (based on contract rate of 7.000%) $2,601.24 Accumulated Late Charges $0.00 Late Charges at $22.47 Per month for 7 months $157.29 Escrow Credit $89,63 Attorney's Fee at 5% of Principal Balance $3,200.60 $69,881.55 **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, I ,,,,,, r ~ ~- , -1.1 1'7". I, ,.. " -I~ -'"'~ " , . 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1083 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.000% ($12.27 per diem), together with other charges and costs including escrow advances incidental thereto to the date of s Sale and for foreclosure and sale of the property within described. By:' :e LL, Leon P. Ha , squire Attorney for Plaintiff !.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) -""'-I <-- ~I-,' ~'"~'" -' . Fmc34575 (1696x2200x2 tiff) [13) '. SCHEDULE A (Continuedl Policy No. M 178-825821 File No. 11936 ~EGAL DESCRIPTION '. 1\LL 'l'H1\.'r CER'l'I\l~ tract of land with I:hl~ imprOVeIJl(:J)cS th.ereCltl €!rected situate on the Hest side of Cheztnut St:reet, LctWtH:l1 Butler and Church streets, in the Boroug}l of HOUIlt 11011y sl'ri:l~", Cumberland County, Pcnn.9ylvClnia. bounded and described a$ f 011 O~lS: nS<;[NNING at th~ intet"section of the curb fine of. thr~ western side of Cbestllut St.reet and southerJ) side of ,Ill .11 J '€''f: thel\Ce southerly 50 feet, more or less. along said Cl~tlstnut Street. tC;; -the line of other land now or formerly of Sheaff:rer; thence westerly along said otha~ lallds now or formerly of She~ffer ~19 teet, more or less, to the eastern side of an ~1}~1; ,thence along said alley in a northwesterly dir~ction 64 feet, ~nore-cr less to the southerly side of an alley; thence ea9l~rfy ~long said alley 248 feet8 more or l~ss to the place of BEGHW1NG, BEING impt'oved Hitl! u tt~o story frame dwelli~9 hou~~e and outbuildings, Kllo,..n ~.s 229 Chestnut,sttcet. Haunt lIolly SPt"1I1$'G. Ph 17065. BEINt;; THE SAME PRENISES which Harvey E. Guise arid Deborah 'r. (;uise, husband and wife by Deed dated May 31, 1990 and recorded June 4, 1990 in Deed Book Pr Volume 34, page 221, granted and conveyed unto Joseph Do. N(ls~de aid Nary E. Maszle, husband and wife. .:.._ I t.~ ,~_,; ..... L~,I\,U, I r." '\I, -~... II~"''' SWSFctm "rMfTtRMS Rl1v. (J<f/2TIiJ3 , . ) COMPANY NAME: FIEEI' ~ <:m'. F/K/A FIEEI' RffiL ESlME RN:lIffi <:m'. VERIFICATION ~ I verify thatthe 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 Mm:h 21, 2001 h": ..... -e;:- Title VICE PRESIDENT ""'''l.~'.. .,~ I' --I , . io?,!i~t!li<;",,",k~~h"""M,J'G'i'" ~,-,',,",~--'-V"bi';'\I."'-''''',''''J<''''''-~,li~;'''i.l~'~~' -'M,;,"d;,.\;,\,.'i,i'-'"";y_",,~",,~',,,,(ilfJi,williHi'i_~~~''''-'''~'~""~ """"'"i:Il141"' "l:n~I",~M Serve: Tennant/Occupant at: ~ 229 Chestnut St L~ Mt. Holly Spgs, PA 17065 'oaeJ ;:@ r"---'''''l :';!'~i!''''fJi <" ~~ - ""~ OFFICE ~F P!'E SHERIFF Clll1r:,r^', '~.'- ~~;UHTY ,; r' ~ c. '. - , " M~R ZZ 3 ~i11 35 111 UI r- ~';, ~l ;:~~, t,:..(~ < :~~:. , ' pt.Nr1,:,\LVnMIA ) ~"v,. ,',< . ,'''''' _'..0 ~,."""-",,, ",~. - jjjliIt" ",. liiill.et ~ ~ "~ 'J"It'tJ ::::- ,.'!teJ (~_:} , ,--~ ..... . r&( . , FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. NO. 2001-1705 JOSEPH D. MASZLE and MARY E. MASZLE CIVIL ACTION - LAW DEFENDANTS IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY: Kindly Settle and Discontinue the above matter of record. & HALLER By: Leon P. Haller Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: June 5. 2001 ~r__" r ~ " ,,-, "'.., :,~_'-__;_-"\_--J;'~.'_ ~_-" - 'I:' 'I' '" - -',-', ~ ,.-" - -~ 'j -.- ,~- . , ," ~" , ;-