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HomeMy WebLinkAbout01-03337 L MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC,. IN THE COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff Ys. OJ ~d32 7 CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE ROBERT E. RIGNEY AND WENDY L. RIGNEY Defendants TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLffiNT. 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 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 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 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 ".., ' ,', ^ - ,--, ~,'" --',""'<,, ~,-,~, "~ ~ , .. . MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : CIVIL ACTION LAW : ACTION OF MORTGAGE FORECLOSURE ROBERT E. RIGNEY AND WENDY 1. RIGNEY, 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 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 -'''"'>" -" '" ,r'~l,r,',,,,,_" - ,,' ,,''f' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CNIL ACTION - LAW vs. ROBERT E. RIGNEY AND WENDY 1. RIGNEY, : ACTION OF MORTGAGE FORECLOSURE 11...0.0/- 3337 ~ ~ Defendants COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., herein after referred to as MERS, is the owner oflegal title to the Mortgage subject tot he Mortgage to this action and nominee for Fleet Mortgage Corp., which is the owenr of the entire beneficial interest in the Mortgage, with an address of P.O. BOX 1169, DEPT. 2665, MILWAUKEE, WISCONSIN 53201. 2. Defendant, ROBERT E. RIGNEY, is an adult individual, whose last known address is 207 NORTH 24TH STREET, CAMP HILL, PENNSYLVANIA 17011. Defendant, WENDY 1. RIGNEY, is an adult individual, whose last known address is 207 NORTH 24TH STREET, CAMP HILL, PENNSYLVANIA 17011, 3, On or about, December 29, 1994 the said Defendants executed and delivered a Mortgage Note in the sum of $80,000.00 payable to INTEGRA MORTGAGE COMPANY. 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 tot Rules 1019(h) and 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 ofthe within County and Commonwealth in Mortgage Book 1247, Page 624 conveying to original Mortgagee the subject premises. The Mortgage was further assigned to Fleet Mortgage Corp. recorded in the within County in Mortgage Book 658, Page 332 on October 25, 2000. The Mortgage was subsequently assigned to 'e~c"', ''''''''",,:~,,'''-''>;~,~~':__< ~,' c.,," !:"; ,,- ~, __',e" I MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC, and will be sent for recording. The Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 207 NORTH 24TH STREET, CAMP IDLL, PENNSYLVANIA 1701 I 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 February 1, 2001 and all subsequent installments thereon, and the foIlowing amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $75,411.04 Interest at $17.56 per day From 01/01/01 To 06/01/2001 (based on contract rate of 8.500%) $2,651.56 Accumulated Late Charges $30.75 Late Charges at $39.88 Per month for 6 months $239.28 Escrow Deficit $797.74 Attorney's Fee at 5% of Principal Balance $3,770.55 $82,900.92 **Together with interest at the per diem rate noted above after June 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 coIlected 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.. ''''''''''~- e,' _ ", ,l "__','" '!,,..,.,"'~1- - .,~,. <,"',', ;.J I 9, Notice ofIntention 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. 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 1983 (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 Pennsylvania Housing Finance Agency not to qualifY for Mortgage Assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8,500% ($17.65 per diem), together with other charges and costs including escrow advances incidental thereto to the date of . ff s Sale and for foreclosure and sale of the property within described. PURCELL, G & Leon P. Haller, Esquire Attorney for Plaintiff J.D. # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) By: "~ . , ,~,~ -,",,-,'~ - " ; "":' . . EXUIBl'!' A AI.L that certain piece or parcel of land situate in the Borol,lgh of camp Uill, County of cumberland, and state of Pennaylvania, mon:! particulary bounded i.lnd descri ul,nl 89 falloWd, to wit: BEGINNING at a point on the eastern line of 1wenty-fourth street (formerly Park Avenue), said point being fifty, (50) feet measured northwardly along Twenty-fourth street from the-northeast corner of Twenty-~ourth and Logan streets; thence in an easterly direction along the. northern line of land, now or late, of John O. W/?8ver, one hundred and forty (140) feet, mora or le09 to Low AlleYi thence in a northel.'ly direction along the we.tern line af Low Alley fifty {50) f--eet" to the southern line of land, now or late, af Charles T. Bowmani thence in a westerly direction along said last mentioned line one hundred and forty (140) feet, more or le9s, to 1'wenty-fourth streetj thence in a southerly direction along the eastarn line of 'I'wanly-fourth streot fifty (50') feet to the point or place of BEGINNING. BEING Lots NOB. 26. 27 and the northern ten (10) feet of Lot No. 25., as shown on plan of lots laid out by U. c. Zaclrl1riaa in the Borough of Camp uill: aajJ plan be.illg recorded in the cUmbe~land county Recorder's Office in Plan Book 1, Page 1. flAVING thereon erected a two and one-half story .frame dwelling house and frame 9aL4898, known as No. 201 North 24th stz:aet, Camp 1Iill. BElNG TUE SAME PUEMIS,RS which Alexander Putllam ~prague, Executor at the ~9tat;c of clarence Bartlett sprague, a/k/a c. BarlletL: S[lJ:"ague. deceased, by need bead.u~ date the 20th day of February, 194, and recorded in the office of the Recorder of Deeds foe CUIt\berland County, Pennsylvania, on the "It\) of l>larch, 1994, in Oeed Book 102, Page 39"/, granted and conveyed uuto Robert E. rt.i,gney and Wendy L. Uigney, husband and wife. ," t': \)f ?onnsylvania } 55 ".1\',' uf Cumberland '.: rhtJ in the office for the recording of Dead:; LL ,"fl(J ~>>i,44rnbe(land Count". fA I 1"\/-:\ Oo,JfIT..L. VOl_Page !2:r:r 'U, my hand oaJ of 01 cot . ":",10. PA t ' day d~5' Ethlbit '\1\':.... ::~.~.- ',~~..:~~'''':. .,._ 0, .,~, ~~~'" ~~. IfQ~~~ ~,J.~''''''''''';';;l.l!l~lJM, \l"!': , .~ ,~~~1~,oJfj~rr~}" ~ ; \g;.~~..""'L'"h ",. . <t\~ :'11'0 .'fl'''''l.ir.~Yf.<t~~J<;''''~ ,," V' <> W' ,...< . , \l,,~.,1 (",J,~~~~'\~ll;:~~ 'iF; o';~) ,..tct:?~\\. r~~~t:("-:-6,; ~l~~' ~.tl!ii. J~'-~' 7 -:--)"";": " t~;~_<:O<:,;..J" "f,..~~..: .. "~"..., ,.f'j'J>:."..,- ... ,;~;:f~;.,;;;,v'''' ~\'" ,., '.,..}.tfyl B E \"- .. ..... \'\...",:.;."':',.~., ...- .....;..- "";~~_~JIl ~". I COMPANY NAME: MRlm:E EJ:ECIR:NIC REGISIRZ\T.KN SYSlEM), OC. WIlli A SERJJClN3lGNT CF flEEr MRlm:E crnP. 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'ly 31, 2001 By KAREN QRLANDO Title VICE PRESIDENT ""'~'^"'7"""'" ,.'.- "_""","_ ,~",', . SHERIFF'S RETURN - REGULAR CASE NO: 2001-03337 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS RIGNEY ROBERT E ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RIGNEY ROBERT E the DEFENDANT , at 0018:38 HOURS, on the 7th day of June , 2001 at 207 N 24TH ST CAMP HILL, PA 17011 by handing to ROBERT E. RIGNEY 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 9.30 .00 10.00 .00 37.30 So Answers: f!'~~-<~ R, Thomas Kline Sworn and Subscribed to before 06/08/2001 'URCE~:: KR~=\. ~ Deputy Sheriff me this J.~~ day of C}... _ ).-uv I A. D. y~ a n-, de, - - +'i' P othonotary <::j!f.ir-..r~,,~ _',' " 'i- , " SHERIFF'S RETURN - NOT FOUND , CASE NO: 2001-03337 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS RIGNEY ROBERT E 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, DEFENDANT RIGNEY WENDY L but was unable to locate Her in his bailiwick, He therefore returns the COMPLAINT - MORT FORE NOTI CE , NOT FOUND , as to the within named DEFENDANT , RIGNEY WENDY L DEFT. IS NO LONGER RESIDING AT ADDRESS STATED ROBERT STATES THAT SHE IS IN CANADA, RETURN NOT FOUND AS PER KAREN, 6/8/01 Sheriff's Costs: Docketing Not Found Return Affidavit Surcharge 6.00 5.00 .00 10.00 .00 21. 00 omas Kline iff of Cumberland County & HALLER this Sworn and subscribed to before me ,{l' €Y day of ~ :l./TIJ'I A . D . ~Q.~~ Pr t onotary '~""~~,~" .r . , ." c - 1 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. DI-J;J7 CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE ROBERT E. RIGNEY AND WENDY L. RIGNEY Defendants TIDS 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 ilie claims set forth in ilie following pages, you must take action wiiliin twenty (20) days after the Complaint and notice are served, by entering ~ written appearance personally or by attorney and filing in writing wiili ilie 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 ilie Court wiiliout further notice for any money claim in ilie Complaint of for any oilier claim or relief requested by ilie Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS POPER TO YOUR LA WYERAT ONCE. IF YOU DO NOT RAVE 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 RAN 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 CUALQUlER OBJECCION CONTRA LAS QUEJAS EN ESTADEMANDA. 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 REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSffiLE QUE liSTED 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 TRUE cOPVF'ROM 'RECORD I n Testimony wnerllOf, I here unto-SlIt my hand . and the ~I of said Coortat carlisle PI. . fhiSSS'l-dap~ ,~ 1...... n...... ~...", 'notary "\ '-""'"'''', ".",,' '," ~ ",-",' ': ,e:.- ~~ ,,~ ~~ ,..f,M . MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : CIVIL ACTION LAW : ACTION OF MORTGAGE FORECLOSURE ROBERT E, RIGNEY AND WENDY L. RIGNEY, 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 infonnation 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, PA 17102 (717) 234A 178 Attorney LD.# 15700 Attorney for Plaintiff '-':'1"""'i" , ' , ,~ ... " MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW vs. : ACTION OF MORTGAGE FORECLOSURE ROBERT E, RIGNEY AND WENDY L. RIGNEY, Defendants COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC" herein after referred to as MERS, is the owner of legal title to the Mortgage subject tot he Mortgage to this action and nominee for Fleet Mortgage Corp., which is the owenr ofthe entire beneficial interest in the Mortgage, with an address of P,O. BOX 1169, DEPT. 2665, MILWAUKEE, WISCONSIN 53201. 2, Defendant, ROBERT E, RIGNEY, is an adult individual, whose last !mown address is 207 NORTH 24TH STREET, CAMP HILL, PENNSYL VANIA 17011. Defendant, WENDY L. RIGNEY, is an adult individual, whose last !mown address is 207 NORTH 24TH STREET, CAMP HILL, PENNSYL VANIA 17011. 3. On or about, December 29, 1994 the said Defendants executed and delivered a Mortgage Note in the sum of $80,000,00 payable to INTEGRA MORTGAGE COMPANY. 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 tot Rules 1019(h) and 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 Book 1247, Page 624 conveying to original Mortgagee the subject. . premises. The Mortgage was further assigned to Fleet Mortgage Corp. recorded in the within County in Mortgage Book 658, Page 332 on October 25, 2000. The Mortgage was subsequently assigned to ,r';.~ ,""~"'"""'!, >,' ""',,_ e, ~ < ' . ,'r '.' -" '. ["'~r,,'" ,,,", - . ,~ "- " MORTGAGE ELECTRONIC REGiSTRATION SYSTEMS, INC. and will be sent for recording, The Said Mortgage and Assignments are incorporated herein by reference. 5, The land subject to the Mortgage is: 207 NORTH 24TH STREET, CAMP HILL, PENNSYLVANIA 17011 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 February 1,2001 and all subsequent installments thereon, and thefollowing amounts are due on the Mortgage: UNPAID PRlNCIP AL BALANCE Interest at $17.56 per day From 01/01/01 To 06/01/2001 (based on contract rate of 8.500%) $75,411.04 $2,651.56 Accumulated Late Charges $30.75 Late Charges .at $39,88 Per month for 6 months $239.28 Escrow Deficit $797,74 Attorney's Fee at 5% of Principal Balance $3,770.55 $82,900,92 **Together with interest at the per diem rate not~d above after June 1,2001 and other charges and costs to date of Sheriffs 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 Sheriff s 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.. ""if'l'-!; ,~.J_"" ,~~",,", ,'~' "t ~ ?~ '. 1 9. Notice ofIntention 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. 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 1983 (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 Pennsylvania Housing Finance Agency not to qualify for Mortgage Assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8.500% ($17,65 per diem), together with other charges and costs including escrow advances incidental thereto to the date of . ff s Sale and for foreclosure and sale of the property within described. PURCELL, G & Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, P A 171 02 (717-234-4178) By: 'ifJ '0 ,t<", , ,,- ,<~ , ~ ;'7" " - '. , ... '~ " i,'. ..,6.".... . ~?'- ~'.. ':'~"~~'.:.'. \:'.. :.~\~~:::~\\~:} , ~.")'''''kW ~~t.r .r~ EXUrUl'l' A AI.L that certain piece or parcel of land situate in the Borough of Camp lIill, County of Cumberland. and. sta.te af Pent\lIylvania, nlara particulary bounded and descrihuu ao follows, to wit: BEGINNING a.t a. point on the eastern line of 1~enty-fotlrth street (formerly Pa~k AVenUe), said point being fifty, (50) feet measured northwardly along Twenty-fourth Street from the-northeast corner of Twenty~fourth and Logan streets; ~hence in an easterly direction along the northern line of land, now or la.te, of John D. Wlilaver, one hundred and forty (140) feet, more or leos to Low Alley; thence in a,northeL-ly direction along the weqtern line of Low Alley fifty (50 r feet' to the southern line of land, now or late, of Charles T. Bowman; thence in a westerly direction along said la:at mentioned line one hundred and forty (140) feet, lIIare or less, to '.rwenty-'fou~th street; thence in a southerly direction along the eastern line of 't'wanty-fourth streot fitty (50) feet to the point or placid of BEGINNING. BEING Lata Nos. 26, 27 a'nd the northern ten (10) feet of Lot No. 25, as shown on plan of lot a laid out by 11. c. Zacharias in the Borough of camp, nill, oaid plan being recorded in the cumberland County Recorder's Office in' plan nook 1, Page 1. HAVING thereon erected a two anu one-half story frame dwelling hOU91.! and frame garage, known as No. 207 North 24th stxoet, camp llill. BEING 't'UE SAME PUEHIS,ES which Alllxander Pulliam sprague, E.xecutor ot the El3tatu uf Clarence Bartlett spragua, a/k/a C. BarLlett Sprague, deceased, by Dead bearil1~ date the 26th day of February, 194, and recorded in the office of the Recorder of needs tor Cumberland county, pennaylvania, on the 7th of MtlL'ch, 1994, in Deed Book 102, Page 397, granted and conveyed UlltO Robert t::. n.i qnay and, wendy L. ni.gney, husband and wife. ;, . ; ", \\f Pcnnsylvania } 55 " .II~I 01 Cumberland '" (hd in the of lice for the recording 01 Oeo,1:; lL ;,nd ~..,~berland Count.". .f111 /"1/,\ llo(JfttL Val_Page !EC:r , . 'kJ., my hand eol of 01 ce I . '1;;.;lu, PA t day d~5' exhibit (\lr~... ""-e"-' ~~.."~'~'-. ~~ ""I "t__ ~ .. ~\ -!Jf'k~lilfIi:" ~f'<lJII~1 ~~ "!.l!'<ioo,(J"t,: , -~ . .~.. ~.!i't"~.. · ,,'; \g;.~:r..~~, ...Ii, ~ '",. . :!.tlj .vo ~fl,,,~;i ""':;1' A2~'~. ',' " \" . I 'If, 'to.1 \!."~"'i\:II' ~...;..., '.' ,',: ~ "..-;. ~ ~p.!'';,fi; ~:I~ :;. 0 ';", ;~,c;~i~~4u:r.;~,j "'f.':'{t~ (,Vh.d:'i.:...'")J.rq:;~~~tt~ ~~t~.~......~~ ..'jg-~.~.... '~/:rc.1i',\""'! \..\>. ". '\\'~": 1f'l1l E \'l. ...' \'\,'\..:,:'k":,.~" "'~,~~ ! \,,,,..., '~,'''. ~. , \ COMPANY NAME: M:Rll:KE EJ:ECIR)',I[C REGI:S:lffiT.KN SYSIEM3, :IN::. WTIH A SERJJClN3 l'GNr OF Hm M.lUGlCE crnP. 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. By ,?/' KAREN ORLANDO Title VICE PRESIDENT Dated Mly 31, 2001 \ ',~ , , 1 ~ _ ", , -",ry-' .._-" ;"~ -, c,_ ",~~M . =.. 1lJ!ffl,^__,~,o!:~. liMil__ _ ~ - " /' @1?) ~ ~ '_::l '.fUll (?!~;~ '<'''Q <, ./[") ?')<. ? (:....- /1': r;"> \..>.:,-.;-\i,. \:.~'P 'v'!NV/\1)SU'"13d -'I" ~, 10. lid 02 h IE AUH AINiiC:.' .',:;;IiJO .:J.:Jnt~HS ::'I..~ :10 .3:n~jo- ~~ ".I][,~~JIl! ~\1II~m1lj1"~Wi.~ ~_~ll;~"'!l'~Hi,),<>;~"'!~TI"~"\i'!.!'''''J':'''''''1''':'f'''\):'J>l\'i1-!-',Hll~~;W,%!!Wf'l'1i"'i':1''''''ji'!l.;i'Wo('",M'.;I~'*"iII., "., , -, ~- - .; P laintijf IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA FLEET MORTGAGE CORP. vs. CIVIL ACTION - LAW ROBERT E. RIGNEY WENDY L. RIGNEY ACTION OF MORTGAGE FORECLOSURE Defendants Term No. 01-3337 PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: September 17,2001 PURCELL, KRUG, & HALLER BY LeonP. H r 1719 North Front Street Harrisburg, Pa, 17102 Attorney for Plaintiff Attorney ID# 15700 -:;;."."p , ,~, ~,' '" , ,~, ," ~, F",'"' l' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-03337 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS RIGNEY ROBERT E ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: . RIGNEY WENDY L but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On October 2nd , 2001 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Co 29.25 .00 66.25 10/02/2001 PURCELL KRUG & HALLER Sworn and subscribed to before me this 'It:tc day of @~ ;Jfh.J1 A.D. qy~ Q.'"ri1Jp.. ~ Prothonotary -''<''''''''?'l'''''IIW>1,,4 , 'r~""" @ffitt of tlr~ ~1r~:riff William T, Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W, Rinehart Assistant Chief Deputy Dauphin Coun1y Harrisburg, Pennsylvania 17101 ph: (717)255-2660 fax: (717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania MORTGAGE ELECTRONIC REGISTRATION vs County of Dauphin RIGNEY WENDY L Sheriff's Return No. 2728-T - -2001 OTHER COUNTY NO. 01-3337 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for RIGNEY WENDY L the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, September 27, 2001 DEFENDANT MOVED TO 74 LEGACY DRIVE, MARKHAM, ONTARIO CANADA L354B5 PER HER EX-HUSBAND WHO LIVES AT 2959 GREEN ST., HBG., PA 17110 Sworn and subscribed to So Answers, JfrJM- before me this 27TH day of SEPTEMBER, 2001 C!-. ~aN.M) Sheriff of Dauphin County, Pa. PROTHONOTARY By Deputy Sheriff Sheriff's Costs: $29.25 PD 09/27/2001 RePT NO 154611 ~,~.<: """"^ , - . , ", ~ ,', " -'. In The Court of Common Pleas of Cumberland County, Pennsylvania Mortgage Electronic Registration Systems, Inc. VS. Robert E. Rigney et al Wendy L. Rigney , 01 No, 3337 civil SERVE: Now, September 20, 2001 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauohin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~,,,...~/-2-J> Sheriff ofCumherland County, PA Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of , 20 COSTS SERVICE MILEAGE AFFIDAVIT $ $ -),~,>""~ ", \]" ,- , "","" MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff YS. 01-33'67 CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE ROBERT E. RIGNEY AND WENDY L. RIGNEY Defendants THIS 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 ~ 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 mIS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT RAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE mE OFFICE SET FORm 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 RAN 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 OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON ELPROCESO 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 01ROSDERECHOS 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, PAl 70 I 3 717-249-3166 l:RtJE COPY FROM REOOAD In Tutimony Whereof, there unto set my hand and the seal of said COlIrt at Carlisle. PI.,'-- rtri~~ odaYQ~~n:'r.~O\ othonotary -ril1f.,~~~'" n" ~, .. -, fL MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., : IN THE COURT OF COMMON PLEAS ; CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. ; CML ACTION LAW : ACTION OF MORTGAGE FORECLOSURE ROBERT E. RIGNEY AND WENDY L. RIGNEY, 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. 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 I.D.# 15700 Attorney for Plaintiff ';?...--t_J: ". ,'1 8' T -,": , , MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC" : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION - LAW vs. , : ACTION OF MORTGAGE FORECLOSURE ROBERT E, RIGNEY AND WENDY 1. RIGNEY, Defendants COMPLAINT IN MORTGAGE FORECLOSURE 1. ' Plaintiff, MORTGAGE ELECTRONIC REGISTRATIO~ SYSTEMS, INC., herein after referred to as MERS, is the owner oflegal title to the Mortgage subject tot he Mortgage to this action and nominee for Fleet Mortgage Corp., which is the owenr ofthe entire beneficial interest in the Mortgage, with an address of P.O. BOX 1169, DEPT, 2665, MILWAUKEE, WISCONSIN 53201. 2. Defendant, ROBERT E, RIGNEY, is an adult individual, whose last known address is 207 NORTH 24TH STREET, CAMP HILL, PENNSYLVANIA 17011. Defendant, WENDY 1. RIGNEY, is an adult individual, whose last known address is 207 NORTH 24TH STREET, CAMP HILL, PENNSYLVANIA 17011. 3. On or about, December 29, 1994 the said Defendants executed and delivered a Mortgage Note in the sum of $80,000,00 payable to INTEGRA MORTGAGE COMPANY. 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 tot Rules 1019(h) and l14l(a) of the Pennsylvania Ru1es 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 Book 1247, Page 624 conveying to original Mortgagee the subj ect' . premises. The Mortgage was further assigned to Fleet Mortgage Corp. recorded in the within County in Mortgage Book 658, Page 332 on October 25, 2000. The Mortgage was subsequently assigned to ,~,.",~-c'_ . ----~; - '., "! ',-" ,~," ,,' , .. , , MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. and will be sent for recording, The Said Mortgage and Assignments are incorporated herein by reference. 5, The land subject to the Mortgage is: 207 NORTH 24TH STREET, CAMP HILL, PENNSYL VANIA 17011 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 February 1,2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: Interest at $17.56 per day From 01/01/01 To 06/01/2001 (based on contract rate of8.500%) $75,411.04 $2,651.56 UNPAID PRINCIPAL BALANCE Accumulated Late Charges $30.75 Late Charges at $39,88 Per month for 6 months $239,28 Escrow Deficit $797.74 Attorney's Fee at 5% of Principal Balance $3,770.55 $82,900.92 **Together with interest at the per diem rate noted above after June 1, 2001 and other charges and costs to date of Sheriffs 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.. '3\T~..",,~, " ~,,~, ~ -;c "',re,c,J",, ., --1 I,~r .. 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. 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 1983 (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 Pennsylvania Housing Finance Agency not to qualify for Mortgage Assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8.500% ($17.65 per diem), together with other charges and costs including escrow advances incidental thereto to the date of 'frs Sale and for foreclosure and sale of the property within described. PURCELL, G & Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) By: '.,,"~,! .,- . ," ". ".' "cr. . ,/.... ~~/ L::~i~,::;,:~~;l;;'" ' ~..'~k"" i~~r r~ EXlIIIHfJ' A ALL that certain piece or parcel of land si.tuate in the Borough of ca.mp Uillf county of CUKlberland, and state of penn1lylvania, R\O(U particulary bounded und descrihud as follows, La wi t: BEGINNING at a point on the eAstern line of 1~enty-fourth Street (formerly Park AvenOe), said point being fifty, (50) feet measured northwa.rdly along Twenty-fourth Street from the-northeast corner of TWenty-fourth and Logan streets: thence in an ea,9terlY direction along the northern ,line af land,.- now or late, of John o. W~aver, onB hundred and forty (140) feetl more or h~ss to Low Alley; thence in a northerly direction along the we"tE!rn line of Low Alley fifty (50) feet' to th.a southern line of land, now or late, of Charles T. Bowman; thence in a westerly direction along said last mentioned line one hundrell and forty (HO) feet, nlore or les9, to ~'wenty-fout:th street; thence in a southerly direction along the aaatern line of 'l'wanty-fourth Stl:60t fifty {50} feet to the palnt or placu of BEGINNING. BEING Lata Nos. 26, 27 and the northern ten (10) feet of Lot No. 25, as shown on plan of lots laid out by II. c. Zacharias in the Borough of Camp nill, Bajd 'plDn be,iulj recorded in the cumberland County Recorder'S office in Plan Book Il Page 1. JlAVING thereon erected a. two and one-half atory frAme dwelling hOU~lU 'and frame garage, known as No. 207 North 24th str(iet, camp nil!. , BEING 'J'II11.: SAME PUEMISES which Aluxander Putllam ~pra9ue, Executor of the Eotatu uf ClarencE!:' Bartlett Sprague, alkla C. BarLlett sprague, deceased, by need beari.ulj date the 28th day of February, 194, and recorded in the office of the Recorder of Deeds for Cumberland county. Pennsylvania, on the 7th af t-larch, 1994, in Deed Book. 102, Page 397, granted and conveyed Ullto RobeJ~t E. Rigney. and Wendy L. Ri.gney, husband and wife. ;.. "', ,Jf P""nsylvania } S5 '.,tt.} o( Cumberland ,';rhd in the office for the recording Qf 080{t~ W ,~nd ~}t]A44mberland Count'l{,_eal Ml'\ l3ooml. VOL_Page lEL't '.'kJ., my hand e.1 0101 ce 1 , . ',:;.;le. PA t . day d~5' tVhlbit \1".... ,.' ."''''''''''' "~~. \~ ,'\';' :"";:~"",,,' 'l ,~~;~~ ::;r;'Z'~'" " 4~,ru.,.~ lI,1;\1i'~I~I.lt,~tItl,(jo'f: ~ <<Il) .~~:tf1~,1'i'''~~ 4 ;;~ll~~ilJh:'" '. <l.\~ 'ilQ, ~,"'..jjt;~:;~ll;l'<o,>. ," ,(,) ~ ' ,-; .' I \l"'~It.' l"w.t;!{~'~~:~t.q 'co' ..,~) \1.\.r-fi~~~~t(~~'t(.';~,} ~i"~!f~ .;..~~" ~ --V..,,", f.... (i."';lc: .-". ".r,w..' ... " " ~t'~-\..,~Lio ..fj*~'..;" ~.\.rf~Hi':.v,":" \..,..... ~:.. .~,."." 1\1 B 1:.1'\. ...' \\,,;.,:.0:..:,..... Record r , ' I COMPANY NAME: M:RJJ:KE ElECIRMC REGISIl'ro'JrN SYSIEM3, E. WY.lli A SEWICIN3 P.GNr OF FrEEr M:RJJ:KE crnp. 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. By c/"/ KAREN ORLANDO Title VICE PRESIDENT . Dated M:!Y 31, 2001 '" 'i'.'lJ!il, ", < r,. _,." , .~_ ~--~ __4%',= .~ ~'"~,_ , ~. , '"" ,.1: ',:t."\,1 l 1. ~:~:! qJc\ i ~ j V \ i-\ \1 r."~ s \,\ N 3 d , '~\'_\ I.:" \ ", ' ;~ ~~, 1'1 1\ -0 C ll' 1 i~ b V A1Hi1(;~; ~,;il;:;H') 'j 6\ djS \G. V,ci oz \1 It k~~ , ~..,r., ";,, I j,: ,1 ';jtift,:j Hh"',\ c': J" C,c'\:i:iO H\\l3~') "ii.' .,., ".n , Gt:n0 ~J,)l.:HO <~<r"","",=","~ll!:T!!I""'~lIIliill'IJI,'I!Illl~gj~f$J~~!i&l"Yl"f"Wiilf'i""""'~I"'-'1''fl''i'J . . . I .': . ! : n . . 0 "" ift,: 1 5:: . , z' ". -I: "f0 ," ~r: ~i\ o (j1: ..~~ ' ~ lS;! >,~, m..1 ~.~ ~. ~~ , >""'"1 ,\ ~,"': r\ :;~ ~ r; . ~ !', ':. ': ".d -'I "" 2 '1 :5 ';!,\j \ Z d3S \ (} -'i';'- ., . ,. ., ,",; '; \!::~ ;',::~ 1'. ';, H. " " .~ >.'" '_, .~~' ;: ; ~\\o:.: Hhi(:1; I ..... \".' """,' ',' \ '1"3"5 ..')lljQ ';),,')::1 '-'. n.;:if1c:Cl fl\\-Idl\VG ~ MORtGAGE ELECTRONIC REGISTRATION SYStEMS, INC. PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA VS. NO. 01-3337 CIVIL TERM ROBERT E. RIGNEY AND WENDY L. RIGNEY DEFENDANTS CIVIL ACTION - LAW 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: Leon P. Haller ID #15700 Attorney for PI ntiff Purcell, Krug Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: November 13. 2001 "*"" . ,';; 'p;,~'1,~_~.. '",;0'" , - ". .- 'd'~"'7'" c " I:! " " I': I;' c, Ii i'.'.I' t ~' :',il;;; , :0," ~~"~-~~~ 8 0 ~, \.,..' ,,\ :;;;: z -om C) mrn -< " z~' ~i-;~t3 ~.' zr' ~~ ';.+ :-;, ;<C' ::;? ~~:';.~ ~o 7'..,,:D ~ >;C; 58 w ~.ri1 ,~ ~ -I 0 )> :D 0 -< 0)~ __~_o,~'""'". T,~~'!l;w!t'~~~,"Wi11i~~~~~I_~".~