HomeMy WebLinkAbout01-2123 FX
FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
ONE PENN CENTER AT SUBURBAN ST A nON
1617 JOHN F. KENNEDY BOULEY ARD
SUITE 1400
PHILADELPIDA, PA 19103-1814
(215) 563-7000
MANUFACTURERS AND
TRADERS TRUST COMPANY
ONE FOUNTAIN PLAZA
BUFFALO, NY 14203
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
v.
NO. 01 -,;1,/).3
Go; CT~hr
Plaintiff
CUMBERLAND COUNTY
DALE L. CROMER
TAMMY L. CROMER
448 NORTH PITT STREET
CARLISLE, PA 17013
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 ajudgment 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
HA YB 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 17013
(717) 249.3166
Loan #: 9787037
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I. Plaintiff is
MANUFACTURERS AND
TRADERS TRUST COMPANY
ONE FOUNTAIN PLAZA
BUFFALO, NY 14203
2. The name(s) and last known addressees) ofthe Defendant(s) are:
DALE L. CROMER
TAMMY L. CROMER
448 NORTH PITT STREET
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) ofthe property hereinafter described.
3. On 10/30/89 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to FARMERS TRUST COMPANY which mortgage is recorded in
the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 957, Page
312. PLAINTIFF is now the legal owner of the mortgage and is in the process of
formalizing an assignment of same.
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 411/00 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
3/1/00 through 4/1/0 I
(Per Diem $4.36)
Attorney's Fees
Cumulative Late Charges
10/30/89 to 4/1 /0 1
Cost of Suit and Title Search
Subtotal
$19,005.19
1,730.92
800.00
143.76
550.00
$22,229.87
Escrow
Credit
Deficit
Subtotal
0.00
0,00
$ 0.00
TOTAL
$22,229.87
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. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. S1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
9. 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
$22,229.87, together with interest from 4/1/01 at the rate of$4.36 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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1 sl Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
DATE: January 11, 2001 FORECLOSURE
TO:
Dale L. Cromer
448 N. Pitt Street
Carlisle, P A 17013
Tammy L. Cromer
448 N. Pitt Street
Carlisle, P A 17013
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, 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.
This is an official notice that the mortgage on your home is in default and the lender intends to foreclose.
Soecific information about the nature of the default is oroyided in the attached oages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to helo to save
your home, This Notice exolains how the orogram works.
To see ifHEMAP can helo. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DA YS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet the
Counseling Agencv.
The name. address and ohone number of Consumer Credit Counseling Agencies serving your County are
listed at the end of this Notice, If YOU haye any questions, you may call the Pennsylvania Housing Finance
Agencv toll free at 1.800-342-2397. (Persons with imoaired hearing can call (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 also want to contact an
attorney in YOllr area. The local bar association may be able to help you find a lawyer.
LA NOTlFlCAClON EN ADJUNTO ES DE SUMA IMPORT ANCIA, PUES AFECT A SU DERECHO A
CONTINU.\R VIVlENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A
NOTlFlCAClON OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRlBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SAL V AR SU CAS A DE LA FERDIDA DEL DERECHO A REDIMAR SU HlPOTECA.
EXHIBiT fA
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STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): Dale L. Cromer and Tammy L. Cromer
PROPERTY ADDRESS: 448 N. Pitt Street, Carlisle, P A 17013
LOAN ACCT. NO.: 9787037
ORIGINAL LENDER: Farmers Trust Company
CURRENT LENDERlSERVICER: M&T Mortgage Corp,
HOMEOWNER'S EMERGENCY MORTGAGE ASS1STANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN 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 ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE.
. IF YOUR DEF AUL T HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
. IF YOU HAVE A REASONABLE PROSPECT 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 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 counseling agencies listed at the
end of this Notice. THIS 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 DEF AUL T" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING 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 telephone numbers of designated
consumer credit counseling agencies for the county in which the properlY is located are set forth at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Adyise your lender immediately
of your intentions.
APPLICA nON FOR MORTGAGE ASSIST ANCE- Your mortgage is in a default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your defaul!.) If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for [mancial
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 this 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,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
EXHIBIT A
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AGENCY ACTION-Available funds for emergency mortgage assistance are very 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.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
l BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If .yon have filed bankru tc au can still a I for Emer enc Mort a e Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to date).
NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located
at 448 N. Pitt Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
foJlowing amounts are now past due: Start/End: 4/1/00 thru 1/1/01 at $239.60 per month.
Monthly Payments Plus Late Charges Accrued $2,407.98
NSF: $0.00
In'pections: $0.00
Other: $0.00
(Suspense): $0.00
Total amount to cure default $2,407.98
B. YOU IIA VE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable): N/A
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,407.98,
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 or monev order made pavable and sent to: FEDERMAN AND PHELAN, L.L.P., One Penn
Center at Suburban Station, Suite 1400, 1617 John F. Kennedy Boulevard, Philadelphia, PA 19103-
1814, , Attention:Payoffs/Reinstatements Departmeut.
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter. (Do not use ifnot applicable.) N/A.
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means
that the entire outstanding balance of this debt will be considered due immediately 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 THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to
foreclose UDan your morte-ae:e oropertv.
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 anomey's
fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you
will have to pay all reasonable anomey's fees actually incurred by the lender even if they exceed $50.00.
Any attorney's fees will be added to the amount you owe lender, which may also include other reasonable
costs. Ifvou cure the default within the THIRTY (30) DAY period. vou will not be required to pav
attomev's fees.
OTHER LENDER REMEDlES- The lender may also sue you personally for the unpaid principal balance
and al I other sums due under the mortgage.
EXHIBIT A
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RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to
cure the default and prevent the sale at anv time UP to one hour before the Sheriff's Sale. You mav do so
bv paving the total amount then past due. plus any late or other charges then due. reasonable attorney's fees
and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as
specified in writing bv the lender and bv Derforrning anv other reouirements under the mortgage. 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 Sheriff's
Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of
this Notice. A notice ofthe actual date of the Sheriffs 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 whot the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
FEDERMAN AND PHELAN, L.L.P.
One Penn Center at Suburban Station, Suite 1400
1617 John F. Kennedy Boulevard, Philadelphia, PA 19103
Tel:(215) 241-1711
Attention: Phyllis Levin, PayoffslReinstatements Dept.
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 PAY OFF THE MORTGAGE DEBTOR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT.
. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO
CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
. TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
Very truly yours,
Ann: Carmen Otero
FEDERMAN AND PHELAN, L.L.P.
Account No.: 9787037
Mailed by I" Class mail/Certificate of Mailing and Certified Mail No: 7106457512941900
7673,7666
EXHIBIT A
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PENNSYLV ANlA 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 StrC<:1 P.O. Box 1328
WilIiamsport, PA 17703
(570) 326-{J587 FAX (570) 322-2197
CCCS ofNorthcas!l:m P A
20 I Basin Stre<:'
WilIiamsport, P A 17703
(570) 323-<i627 FAX (570) 323-<i626
COLUMBIA COUNTY
31 W. Markel Street
POB 1127
Wilkes-Barre, PA 18702
(570) 821-{J837 or (800) 922-9537
FAX (570) 821-1785
Commission on Economics Opportunity ofLuzeme County
163 Amber Lane
Wilkes-Barre. PA 18702
(570) 826-{J510 or (800) 822-{J359
FAX (570) 829-1 665-(Call Before Faxing)
(570) 455-1994 Hazellown
FAX (570) 455-5631-(Cal1 Before Faxing)
(570) 836-1090 Tunkhannock
CRAWFORD COUNTY
Booker T. Washington Center
1720 Holland Center
Erie, P A 16503
(814) 453-5744 FAX (814) 5749
John F. Kennedy Center, fnc.
2021 East 201ll Street
Erie, PA 16510
(814) 898-0400
FAX (814) 898-1243
CUMBERLAND COUNTY
eees of Western Pennsylvania.. Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 54t-1757
Urban League of Metropolitan Harrisburg
N. 6!JJ. Street
Harrisburg, PA 17101
(717) 234-5925 F A,X (7t 7) 234-9459
Communicy Action Comm of the Capilal Region
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757 FA,X (717) 234-2227
PENNSYL V Al'IIA BULLETIJII, VOL 29, NO. 23, JUNE 5, t999
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CCCS of Northeastern PA
1631 South Atherton St. Suite 100
Slate College, PA 16801
(814) 238-3668 FAX (814) 238-3669
1400 Abington Executive Park
Suite 1
Clarks Summi~ PA 18411
(570) 587-9163 or (800) 922-9537
FAX (570) 587-9134-9135
Greater Erie Community Action Committee
18 West91l1 Street
Erie, PA 16501
(814) 459-1581 FAX (814) 456-{J161
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrell. PA 16121
(412)981-5310
Financial Counseling Services of Franklin
31 West 3m Street....:.
Waynesboro. PA 17268
(717) 762-3285
YWCA of Carlisle
30 I "G" Stree,
Carlisi.. PA 17013 .
(717)243-3818 FAX(717,-731-9589
Adams County Housing Authoricy
139.143 Carlisle St
Gettysburg, PA 17325
(717) 334-1518 FAX 334-8326
EXH.err A
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ALL THAT CERTAIN lot or piece of land situate in the Fifth Ward of the
Borough of Carlisle. Cumberland County. Pennsylvania. bounded and
described in accordance with a survey and plan thereof made by Gerrit
~. Betz, Registered Surveyor, dated September 22. 1971, as follows:
BEGINNING at a point on the West side of North Pitt Street, said point
being 108.6 feet South of the Southwest corner of North Pitt Street
and "A" Street, thence along the West side of North Pitt Street South
10 degrees 30 minutes West 30 feet to a corner of premises nOW or
formerly of Ralph McKee, thence along said pr~mises and passing
through the center of a partition wall North 79 degrees '30 minutes
West 165 feet to a point on the East side of a 15 foot alley, thence
along said alley North 10 degrees 30 minutes East 30 feet to a corner
of land now or formerly of Charles C. Yinger, thence along said land
South 79 degrees 30 minutes East 165 feet to the point and place of
BEGINNING.
HAVING thereon erected a two story frame dwelling house. known and
numbered as 448 North Pitt Street. Carlisle.
BEING the same premises which Harry R. Poper and Carolyn L. Poper (now
known as Carolyn L. Olsen) by their deed dated June 11th, 1986 and
recorded in the Office of the Recorder of Deeds in and for Cumberland
County at Book 0, Vol. 32. Page 357. granted and conveyed unto Glenn
E. Hockenberry, Grantor herein. __....... ~_
PREMISES: 448 NORTH PITT STREET
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VERIFICATION
DENNIS GAWRON hereby states that he is BANKING OFFICER ofMANUF ACTURERS &
TRADERS MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter,
that he is authorized to take this Verification, and that the statements made in the foregoing
Ciyil Action in Mortgage Foreclosure are tme and correct to the best of his knowledge.
information and belief. The undersigned understands that this statement is made subject to the
penalties 6f 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to autllOrities.
BANKING OFFICER
DATE:
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02123 P
,
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUS
VS
CROMER DALE L ET AL
SHANNON M. SUNDAY
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
CROMER DALE L
the
DEFENDANT
, at 1930:00 HOURS, on the 17th day of April
, 2001
at 448 NORTH PITT STREEET
CARLISLE, PA 17013
by handing to
DALE L CROMER
a true and attested copy of COMPLAINT - MORT FORE
together with
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
So Answers:
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R. Thomas Kline
04/18/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before
By:
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Deputy Sheriff
me this d..~cft day of
A.D.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02123 P
,
, COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUS
VS
CROMER DALE L ET AL
SHANNON M. SUNDAY
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
CROMER TAMMY L
the
DEFENDANT
, at 1930:00 HOURS, on the 17th day of April
, 2001
at 448 NORTH PITT STREET
CARLISLE, PA 17013
by handing to
TAMMY L. CROMER
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
So Answers:
6.00
.00
.00
10.00
.00
16.00
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R. Thomas Kline
04/18/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before
By:
Sf~l11. ~
Deputy Sheriff .
me this J..~+.t;, of
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FEDERMAN AND PHELAN
By: Frank Federman, Esquire
Atty.l.D. No.: 12248
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Attorney for Plaintiff
MANUFACTURERS AND
TRADERS TRUST COMPANY
Plaintiff
Court of Common Pleas
CUMBERLAND County
No. 01-2123 CIVIL TERM
vs.
DALE L. CROMER
TAMMTL. CROMER
Defendant(s)
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.
06" -fl9 -0\
Date
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Frank Federman
Attorney for Plaintiff
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