HomeMy WebLinkAbout01-7250 FX
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Steven K. Eisenberg, Esquire
Attorney ill No.. 75736
530 W. Street Road, Suite 200
Warminster, Pennsylvania 18974
Telephone: (215) 675-4211
Aristar Mortgage
P.O, Box 4365
Woodland Hills, California 91365
Plaintiff
vs.
Dale L. Scott
11 Texaco Road
Mechanicburg, P A 17050
and
Carta Scott
11 Texaco Road
Mechanicsburg, P A 17050
Oefendant(s)
"NOTICE
"You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must tal<e
action within (20) days after this COtn\llaint and notice are
served by entering a written aJlPl'llf8ll"C personally or by
attorney and tiling in writing with the court your defenses
or objections to the claims set forth against yon. You are
warned that if you filii to do so the case may proceed
without further notice for lUly money claimed in the
COtn\llaint or for any other claim or reliefrequested by the
plaintilf. You may lose money or property or other
rights important to you.
"YOU SHOULD TAKE THIS PAPER TO YOUR
LAWYERATONCE. IFYOUDONaIHAVE
A LAWYER OR CANNOT AFFORD ONE. GO TO OR
TELEPHONE THE OFFICE SET FOR1'H BEWW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CU1I\berlanq Bar Association
LAWYER REFERRAL SERVICE
Two Liberty Avenue
Carlisle,l>ennsylvania 17013
7172493166
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Attorney for Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: Cumberland County, Pennsylvania
; NO. 01- 7:2S6
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: CIVIL ACTION
: ACTION FOR BREACH OF CONTRACT
: COMPLAINT - CIVIL ACTION
; NOTICE TO DEFEND
"A VISO
"Le ban demandado a usted en la corte. Si usted quiere defence
se de estas demands expuestas en !as paginas siguientes. Usted
tiene vente (20) <lias, de plazo at par\ir de la fecha de la demanda
y la notification haec faita asentar lJIIll comparencia escrita 0 en
persona 0 con un abogado y en1regar a la corte en forma escrita
sus defensas 0 sus omeciOlWs a las demandas en contra de su
persona. Se avisado que si usted no se defiende, la corte tomara
medidas y puede continuar la de manda en contra suya sin previa
aviso 0 notification. Ade mas a corte puede decidir a Javor del
demandante y requiere que usted clllllllla con todas !as provisiones
Provisiones de esta demanda. Usted paede perder dinero 0 sus
propiedades u otros derechos importantes para usted.
"LLEVEESTA DEMANDA A UN ABOGAOO INMEDIATAMENTE.
SI NO T1ENE ABOGAOO 0 Sl NO TIENE EL DINERO SUFlCIENTE
DE PAGAR TAL SERVlCIO, VAYAEN PERSONA 0 LLAMEPOR
TELEFONO ALA OFlCINA CUY ADlRECCtON SE ENCUENTRA
ESCRlTA ABAJO PARAAVEIUGUAR OONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Associacion De Licendiados De ClUl)berland
SERVlCIO DE REFENCIA E INFORMACION LEGAL
Two Liberty Avenue
Carlisle, Pennsylvania 17013
7172493166
~
Steven K. Eisenberg, Esquire
Attorney IO No.. 75736
530 W. Street Road, Suite 200
Warminster, Pennsylvania 18974
Telephone: (215) 675-4211
Aristlr Mortgage
P.O. Box 4365
Woodland Hills, California 91365
Plaintiff
VS.
Dale L, Scott
11 Texaco Rood
Mechanicburg, PA 17050
and
Carla Scott
11 Texaco Road
Mechanicsburg, P A 17050
Defendant(s)
"NOTICE
"You have been sued in court. Jf you wish to defeIid against
the claims set forth in the following pages, you must take
action wit!jin (20) days after this complaint and notice lll'e
served by entering a written appearance personally or by
attorney and fiJing in writing with the <:ourt your defenses
or objections to the claims set forth against you. You are
warned that if you fuil to do so the case may proceed
without further notice for any money claimed in the
complaint or fur any other claim or relief requested by the
plaintiff. You may lose money or property or other
rights important to you.
"YOU SHOULD TAKE TillS PAPER TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE TIlE OFFtCE SET roRTH IlELOW TO
PlNDotrr WHERE YOU CAN GET LEGAL HELP.
Cmuberland Blll' Association
LAWYER REFERRAL SERVICE
Two Liberty Avenue
Carlisle, Pennsylvania 17013
7172493166
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Attorney fur Plaintiff
: IN THE COt)RT OF COMMON PLEAS OF
: Cumberland Connty, Pennsylvania
: NO.
: CIVIL ACTION
: ACTION FOR BREACH OF CONTRACT
: COMPLAINT - CIVIL ACTION
: NOTICE TO DEFEND
"AVlSO
"Le ban deman<ll\do a usted en la corte. Si usted quiere defence
se de estas demands expuestas en las paginas siguientes. Usted
tiene vente (20) dias, de plazo a1 partir de la fecha de la demanda
y la notification hace faita asentar una comparencia escrita 0 en
persona 0 con un abogado y entregar a la corte en fonna escrita
sus defensas 0 sus objeciones a las demandas en contra de su
persona Se avisado que si usted no se defiende, Ia corte tomara
medidas y puede continuar Ia de manda en contta suya sin previo
aviso 0 notification. Ade mas a corte puede decidir a fuvor del
demandante y requiere que usted cumpla con todas !as provisiones
Provisiones de esta demanda Usted puede perder dinero 0 sus
propiedades u otros derechos importantes para usted.
"LLEVE ESTA DEMANDA A UN ABOOADO INMEDlATAMENrn.
S1 NG TIENE ABOOAOO 0 S1 NO TIENE EL DINERO SUFIcIENTE
DEPAGAR TALSERVIC10, VAYAENPERSONAOLLAMEPOR
rnLEFONO ALAOFICINACUY ADIRECCION SE ENCUENTRA
EBCRIT A ABA.lO PARA A VERlGUAR DONDE BE PUEDE
CONSEOUIR ASISTENCIA LEGAL
Associacion De Ucendiados De Cumberland
SERVICIO DE REFIlNCIA E INFORMA.CION LEGAL
Two Liberty Avenue
Carlisle. Pennsylvania 17013
7172493166
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Steven K. Eisenberg, Esquire
The Law Offices of Steven K. Eisenberg
Attorney ill No. 75736
530 W. Street Road, Suite 200
Warminster, Pennsylvania 18974
Telephone: (215) 675-4211
Attorney for Plaintiff
Aristar Mortgage
P.O. Box 4365
Woodland Hills, California 91365
: IN THE COURT OF COMMON PLEAS OF
: Cumberland County, Pennsylvania
: NO, 01- 7;J.rSD ~ T.u.-
Plaintiff
: CIVIL ACTION
vs.
Dale L. Scott
11 Texaco Road
MechanicbUl'g, PA 17050
: ACTION FOR BREACH OF CONTRACT
and
Carla Scott
11 Texaco Road
Mechanicsburg, P A 17050
Defendant(s)
CQl\lPLAIN'J
Plaintiff, Aristar Mortgage, by and through its attorneys, The Law Offices of Steven K.
Eisenberg, submits the within Complaint against the above-captioned Defendants, and in support
thereof, respectfully aVllrs the following:
1. Plaintiff, Aristar Mortgage (hereinafter referred to as "Aristar"), is a <;orporation, with a
place of business located at P.O. Box 4365, Woodland Hills, California 91365.
2. Defendant, Dale L. Scott (hereinafter referred to as the "Defendants"), is an adult
individual residing at 11 Texaco Road, Mechanicburg, P A 17050.
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3. Defendant, Carla Scott (hereinafter ( collectively) referred to as the "Defendants"), is an
adult individual residing at 11 Texaco Road, Mechanicsburg, P A 17050.
4. This action is an attempt to collect the debt averred herein and any infonuation obtained
in this matter will be used for that purpose.
S . You must file a response to this Complaint within the time provided by the rules of
court, However, you have thirty (30) days to dispute the debt in writing to the undersigned counsel for
Aristar.
6. If you do not dispute the debt averred herein, or any portion thereof, in writing, within
thirty (30) days, the debt will be assumed to be valid. If you notifY the undersigned counsel for Aristar
in writing of some dispute as to the validity of this debt, in whole or in part, within the thirty (30) day
period, counsel will provide you with a copy of documentation verifYing the debt necessary beyond the
exhibits to this Complaint, if any. Also, upon written notice to counsel requesting such advice, counsel
will provide you with the name of the original creditor with whom you incurred this debt.
BREACH OF CONTRACT
7. Paragraphs 1 through 6 above are reaverred and incorporated herein by reference as if
set forth at length,
8. Defendants entered into a Contract to borrow funds (hereinafter referred to as the
"Contract") on or about 5/25/2000, wherein Aristar (and/or its predecllssor in interest) agreed to
provide financing, a loan, to Defendants subject to the terms and conditions COlltained in ~ Contract,
which Contract was assigned per its terms and delivered to Aristar with notice to Defendants. A copy
of the Contract is attached as Exhibit "~' and is incorporated herein by reference as if set out at length.
9, Under the tenus of the Contract Aristar agreed to finance, provide the loan, and
Defendants agreed to pay Aristat the principal amount of $24,600,00, plus interest at the rate of 13.40
percent annually (and other conditional charges).
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10, In accordance with the Contract, Defendants agreed to pay Aristar payments 0[$295.25
per month for a period of240 months, commencing on 7/1/2000 and continuing thereafter each month
the same day of the month until the entire indebtedness to Aristar is paid in full.
11. Defend~ts became in default under the Contract when they failed to make payment
when due on or about 6/11200 1. Defendants remain in default under the Contract, which default
permits Aristar to accelerate the balance due under the Contract.
12, Defendants were notified by written notice dated that they were in default of the
Contract because of their failure to make payments when due under the Contract. True and a correct
copies of the Notice of Default are attached as Exhibit "B" and are incorporated herein. by reference as
if fully set forth.
13. Despite such notice and demands by Aristar for payment, Defendants did not, and have
not cured the foregoing default, and have neglected and refused to honor the terms and conditions of
said Contrllct and have failed, refused or neglected to make payment to Aristar of the sum justly due
Aristar. The outstanding principal balance is $24,579.45,
14. In accordance with the Contract and applicable law, there is interest due at the rate of
13.40 percent per annum from6/i!200t to the date of this suit in the amount of$2,191.71. In addition
there are late charges accrued and charged to the date of this suit are $206.71.
15. reserved
16. All credits due, ifany, to Defendants have been given to himlher.
17. The balance due from Defendants to Aristar under the Contract as of the date of
commencement of this suit is $26,977.87 and interest continues to accrue on that debt at the rate of
13.40 percent per annum as set forth in the Contract.
18. Although demand of the sum justly due Aristar has been frequently made, Defendants
have neglected, failed and refused to make payment thereof.
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WHEREFORE, Plaintiff, Aristar Mortgage, demands judgment against Defendants Dale L
Scott and Carla Scott, jointly and severally, in the sum of$26,977.87 plus any and all additional
interest, attorney's fees and costs.
Count II - Unjust Enrichment
19. Plaintiff hereby incorporates by reference paragraphs 1 through 18 above as though set
forth at length herein.
20. Defendant(s) received the use and benefit of the loan as set forth above.
21. Defendant(s) accepted the funds.
22. Defendant(s) received the funds from Plaintiff knowing that they were receiving a
benefit.
23. Defendant(s) have been unjustly enriched at the expense of Plaintiff and Plaintiff is
entitled to recover the amounts that it (or its predecessor) has expended.
WHEREFORE, Plaintiff, Aristar Mortgage, demands judgment against Defendants Dale L
Scott and Carla Scott, jointly and severally, in the sum of$26,977.87 plus any and all additional
interest, attorney's fees and costs.
Respectfully submitted,
By /f~
,...-/Stefen K. Eisenberg, Esquire
~ Attorneys for Plaintiff,
Aristar Mortgage
DATED: Friday, December 28,2001
70010003/W.1OO-1OO
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Exhibit
"A"
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SECONDARY MORTGAGE LOAN NOTE
This agreement is snbject to the provisions of the Secondary Mortgage Loan Act
May 25, 2000
ID.te]
Camp Hill
[CityJ
Pennsylvania
(State]
11 Texaco Road, Mechanicsburg, PA 17055
(Property Address]
1. BORROWER'S PROMISE TO PAY
In return for a loan that I bave received, I promise to pay U.S. $ 24,600.00
"principal"), plus interes~ to the order of the Lender. The Lender is Aames Funding
Loan
(this amonnt is called
Corporation,DBA Aarnes Horne
. I understand
that the Lender may transfer this Note. Tbe Lender or anyone who takes this Note by transfer and who is entitled to receive
payments under this Note is called the "Note HoJder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly rate
of 13 .400 %.
The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of
this Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by makiug payments every month.
I will make my monthly payments on the 1st day of each month beginning on July 1st ,
2000 . I will make these payments every month until I have paid all of the principal and interest and any other charges
described below that I may owe under this Note.My monthly payments will be applied to interest before principal. If, on
June 1, 2 02 0 , I still owe amounts under this Note, I will pay those amounts in full on that date,
which is called the "Maturity Date."
I will make my monthly payments at
90071
(B) Amount of Monthly Payments
My monthly payment will be in the amount of U.S. $ 295.25
4. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of principal at any time before they are due. A payment of principal only is known as a
"prepayment" When I make a prepayment, I will tell the Note Holder in writing that I am doing so.
, I may make a full prepaym'ent or panial prepayments without paying any prepayment charge. The Note Holder will use all of
my prepayments to reduce the amount of principal that I owe nnder this Note. If I make a partial prepayment, there will be no
changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes.
5. LOAN CHARGES
This Note shall be governed by the laws of the State of Pennsylvania. If a law, which applies to this loan and which sets
mllJcimum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with
this loan exceed the permitted limits, then: (i) any such loan charge shall be reduced by the amount necessary to reduce the charge
IOthe permitted limit; arid (ii) any sums already collected .from me which exceeded permitted limits will.pe refunded to me. The
Note Holder may choose 10 make wis refund by redueing the principal I owe under this Note or by making"a direct payment to me.
If a refund reduces principal, the reduction will be treated as a panial prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after
the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 10 . 000 % of
my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment.
(B) Default
If I do not pay the full amount of each monthly payment on the date it is due, I will be in default.
350 South Grand Avenue, 47th Floor, Los Angeles, CA
or at a different place if required by the Note Holder.
PENNSYLVANIA fiXED RATE NOTE. Single Family
(,. DOC #: 503721 APPL # I 0007826931 ~a9E11 QI2
lJG:-AX5RPA (9105}.04 ELECTRONIC LASER FPRMS,/NC. . (800)327-0545
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(C) Notice of Default
If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a
certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the
mterest that I owe on that amount That date must be at least 30 days after the date on which the notice is delivered or mailed to me.
(D) No Waiver by Note Holder
Even if, at a time when. I am in default, the Note Holder does not require me to pay immediately in full as described above
the Note Holder will still have the right to do so if I am in default at a later time. '
(E) Payment of Note Holder's Costs and Expenses
If the Note lIolder has required me to pay immediately in full as described above, the Note Holder will have the right to be
paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those
expenses include, for example, reasonable attorneys' fees.
7. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by
delivering it or by mailing it by flIst class mail to me at the Property Address above or at a different address if I give the Note
Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by mailing it by flIst class mail to the Note
Holder at the address stated in Section 3(A) above or at a different address if I am given a notice ,of that different address.
8; OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this
!\!ote, including the promise to pay the full amount owed. Any person who is a guarantor, sur~ty or endorser of this Note is also
obligated to do these things. Any person who taIces over these obligations, including the Obligations of a guarantor, surety or
endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Flolder may enforce its riglits under
this Note against eljCh person individually or against all of us together. This means that anyone of us may be required to pay all of
the amounts owed under this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor.
"Presentment" means the right to require the Note Holder to demand payment of amounts dne. "Notice of dishonor" means the right
to require the Note Holder to give notice to other persons that amounts due have not been paid.
10. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the
Note Holder under this Note, a Mortgage, Deed of Trust or Security Deed (the "Security Instrument"), dated the same date as this
Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note.
That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all
amounts I owe under this Note. Some of those conditions are described as follows:
Transfer .o(tbe Property or a Beneficial Interest in Borrower. If all or any part of the Property or any
interest in it is Sold or transferred (or if a beneficial interest in Borrower is sold ortraIisferred and Borrower is
not a natural}lCrson), without Lender's prior written consent, Lender may, at its option, require immediate
payment in full of all sums secured by this Security Instrument However, this option ,shall not be exercised by
Lender if exercise is prohibited by federal law as of the date of this Security Instrument
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide
a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay
all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this
period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand
on Borrower. ~,
WITNESS TIffi HAND(S) AND SEAL(S) OF TIffi UNDERSIGNED.
JJ~ R ~ (Seal) Cb~ ofuL
Scott L. Dale:' .' -Borrower Carla R. Dale
SSN: 211-58-5313 SSN: 159-56-1137
(Seal)
~BorTower
(Seal)
-Borrower
(Seal)
-Borrower
SSN:
SSN:
[Sign Original Only]
fit DOC #:503722 APPL #:0001826931
.AX5RPA (91051.04
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Exhibit
"B"
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MICHAEL $. POLK
SPENCER P. SCHEER
DEAN R, PROBER
DA YID E. PINCH
MICHAEL D. IMFELD
MARK DOMEYER
LEE $. RAPHAEL
VICTOR CAPONPON
NORMAN D. SHAW
SHARON L. MASON
KAREN A. ROMAGNANO
NATALIE A, PANOSSIAN
Scott Dale
Carla Dale.
11 Texaco Road
Mechanicsburg, PA 17050
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POLK, SCHEER & PROBER
A LAW CORPORATION
6400 CANOGA AVENUE, SUITE 350
NORTHERN CALIFORNIA
WOODLAND HILLS, CALlFORNIA 91367
P.O, BOX 4365
145 NORTH REDWOOD DRIVE, SUITE 200
SAN RAFAEL, CALIFORNIA 94903
(415) 491-8900
FAX (415) 491-8910
WOODLAND HILLS, CALIFORNIA 91365
(818) 227-0100
FAX: (818) 227-0101
EMAIL: USER@PSPLAW1.COM
NATIONWIDE BANKRUPTCY
REPRESENTATION
November 7, 2001
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Re: Aristar Loan No. CA048 ,00058388
Dear Mr. and Mrs. Dale:
I have been retained for the purposes of collecting on above-referenced loan, secured by your
residence. There currently is due appwximately$I,771.50 plus late charges - as your loan is only
paid through 511101.
Please call me to discuss yourifltentions as soon as possible.
MSP:mz
enclosure
cc: Miranda Sievert
Very truly yours,
Michael S. Polk
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SPECIAL NOTICE
THE FOLLOWING NOTICE IS GIVEN TO YOU IN THE EVENT THAT
THE FEDERAL FAIR DEBT COLLECTIONS ACT APPLIES TO THIS
COMMUNICATION.
The following statement provides you with notice of certain rights which you may have
by law. Nothing in this statement modifies or chanGes the hearing date or response time
specified in the attached documents or your need to take legal action to protect your rights in
this matter. No provision of the following statement modifies or removes your need to comply
with local rules concerning the attached documents.
CONSUMER DISCLOSURE
This communication is made in an attempt to collect on a debt or judgment and any information"
obtained will be used for that purpose. Please be advised that if you notify ARISTAR MORTGAGE
COMP AL'N attorneys in writing witllln 30 days that all or a part of your obligation or judgment to
ARISTAR MORTGAGE COMPAl'N is disputed, then ARISTAR MORTGAGE COMPANY attorneys
will mail to you a written verification ofthe obligations or judgment and the amountsowed to ARISTAR
MORTGAGE COMPANY. In addition and upon your written request within 30 days, I will provide you
with the name and address ofthe original creditor, if different from the current creditor.
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VERIFICATION
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(Name), verify that I am IJ fIo; "'\ (Title) for
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thorized to make this Verification on its behalf and further that the
Aristar Mortgage and as such, am
facts set forth in the foregoing document are true and oorrect to the best of my knowledge, information, and
belief
This verification is made suQiect to the penalties of 18 PaC. SA S 4904 relating to unsworn
falsification to authorities.
By:
Dated: /tj'Lr/ttt
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-07250 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ARISTAR MORTGAGE
VS
SCOTT DALE L ET AL
BRYAN WARD
, Sheriff or Deputy Sheriff of
Cumberland County,pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
SCOTT DALE L
the
DEFENDANT
, at 1502:00 HOURS, on the 2nd day of January
2002
at 11 TEXACO ROAD
MECHANICSBURG, PA 17050
by handing to
DALE SCOTT
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
5.85
.00
10.00
.00
33.85
~~~J
R. Thomas Kline
01/03/2002
STEVEN EISENBERG
Sworn and Subscribed to before By:
me this ~~ day of
-4, U.AA.f] JJn1)..... A. D .
(\ "I a.~ ~
~~~othonotaryJ
-
-
SHERIFF'S RETURN - REGULAR
.
.
CASE NO: 2001-07250 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ARISTAR MORTGAGE
VS
SCOTT DALE L ET AL
BRYAN WARD
"
,
."~~,~~".' ""'-'flliiei!~liiil~'~c,,"
,
:",,,,"~,,"~.
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
SCOTT CARLA
was served upon
the
DEFENDANT
, at 1502:00 HOURS, on the 2nd day of January ,2002
at 11 TEXACO ROAD
MECHANICSBURG, PA 17050
DALE SCOTT
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
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
Sworn and Subscribed to before
lW
me this '? ~ day of
~ Q~ A.D
p:fothonotary r~
So Answers:
r~~
R. Thomas Kline
01/03/2002
STEVEN EISENBERG
By: ~ ~ J
/Dep~riff ~