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Home My WebLink About99-03192 ?lu C3 z? Jti t MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Cumberland County Company d/b/a Beneficial Mortgage Court of Common Pleas Company of Pennsylvania 961 Weigel Drive, P.O. Box 8621 Elmhurst, IL 60126 Ellen Deschenes a/k/a Ellen J. Deschenes Number 1600 Orrsbridge Road Enola, PA 17025 CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE AVISO 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 a judgment 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. Le han demandado a usted en to torte. Si usted quiere defenderse de estas demandas ex•puestas an les paginas siguientes, usted tiene veinte (20) dies de plazo at partir de is fecha de is demands y Is notification. Hace felts asentar una eonparencis escrita o an persona o con un abogado y entregar a la torte en forma escrita sus defenses o sus objeciones a las demendas an contra de su persona. Sea avisado qua si usted no se def iende, is torte tomara medides y puede continuer is demands an contra suya sin previo aviso o notification. Adams,. to torte puede decidir a favor del demandante y requiere qua usted cumple con todas ins provisions de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. YOU SHOULD TAKE THIS PAPER 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 HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249.3166 LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NOTIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA 0 L.LAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA10 PAPA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249.3166 MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Cumberland County Company d/b/a Beneficial Mortgage Court of Common Pleas Company of Pennsylvania 961 Weigel Drive, P.O. Box 8621 Elmhurst, IL 60126 V. , Ellen Deschenes a/k/a Ellen J. Deschenes Number 1600 Orrsbridge Road Enola, PA 17025 1. Plaintiff is Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, a corporation duly organized under the laws of Pennsylvania and doing business at the above captioned address. 2. The Defendant is Ellen Deschenes a/k/a Ellen J Deschenes, who is the mortgagor and real owner of the mortgaged property hereinafter described, and her last-known address is 1600 Orrsbridge Road, Enola, PA 17025. 3. On October 9, 1998, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1489, Page 43. 4. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 1600 Orrsbridge Road, Enola, PA 17025. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due November, 1998 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal. balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $68,636.69 Interest 10/1/98 through 5/3/99 $ 5,398.80 (Plus $27.26 per diem thereafter) Attorney's Fee $ 3,431.83 Cost of Suit $ 225.00 Appraisal Fee $ 125.00 Title Search 8 200.00 GRAND TOTAL $78,017.32 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 Sheriff's Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 have been sent to Defendant by certified mail on the date set forth in the true and correct copies of such notices attached hereto as Exhibit "B." WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $78,017.32, together with interest at the rate of $27.26 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgage property. lw TER ENCE J. M E, ESQ IRE Attorney for aintiff VRRTFTCA11W The undersigned, Robert F. Elston, hereby certifies that he is the Foreclosure Specialist of the Plaintiff in the within action, BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA, and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.c.S. 94904 relating to unsworn falsification to authorities. V T U-4,? ROBERT F. ELSTON 85/20/99 8915.07 D5I7C13-> 215 790 1274 RightPAX Page 092 ? d.R.I MORTGAGE 'MIS MOVIDACD, C"CmJ lwo.hi. 09911-.. Jv u( Olfahar. WK., .E3}en De Cepo011,.tEr.{Lu. h"mrkf 01W-WrIE IE, ad CI OtINIIyICIAL CONSUMER UI.Y000NT COMPANY.. MnayM,JC udtMmIup. 10 DENEFICAL CONSUMED 01WOUN( COMPANY, SiVi Denallalef MmStr Cu, of Penxgvmk, r 14narYl.xlil mq.mniw.. hwinYmnlOw axJ phW Mlwinevvw 4910 , CAr33e1!.t31u I..1V1iLLD}1.Hetk!n:Dyburl_._, Ponlnylvuw.. OaaRcl wJIrJ 'Mw.{x{v,.' 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ADDRESS: 1600 OLASIRIDOT LOAD MLA.PA.17021 TAR PMCLL 1Dt I0-11-1719-006 Mu11<ipJ 7h,1 WI ohxt _- WRoV. P.ral ISCnIViw Lair{ Im pnm,m we""J W MwlYx1"w UV . Jra el wtV,ylnl fitly t ImUnW in On WN, bl the R:wJD4 of D.4. III Ihh, CWxlly nl W41 DWt No. pARc .La as Pnpuv aturDMJ A IWI DUE, 0 I( IM, bw 1. C'hvdaJ, III,, Mo1pp 11 nlynl w , poor mmlgrp drnl , IY....,'1aWDJ y Merlyyxh which (riot Immod "rWal p.y.Iarl ora pom"44 Mo 4114 plLx: l ln,JMl a(t Th.1 Prior nW Wga ww ww.Al,d on IV-with dw LoWroarof W Cwmy of fem. gNsN1, u (huh __ , P v TO NAYDAND TO HOLD 14 PWp:nylunby umwd mg mnv rld IaDMWVV=.0 W W IM Dn IAJ Onmtaf MOnlajr,i4 rRa,rtn W 1r.1p1, &Vmr. THIS MORTCIA06 IS MAOO 4,Dlew x114 fd",j eeMRIQV4. 1I111 MMjlhew 1p11: 1. Mangdom w9J m1ha.91 pgwvw.a At Jv:J.N ltc:ao(W mDm 111&I ebllplbal u fI av=Wld 9AIT1. mJ U nG AI 2. Mmplml w01 pay wW Jua All Ulm Ind awrmw,:l kvkdor mnlEf lylW 14 Prupenymvey pro A"dAli"I WiVdV =I,= Dr dW" pvmmw a h4ulppe UNA Myra Wif M pqr uy4l,10t lw40 a plwlJn lwl a OW .wCa111wN,W mq I,' mJW w JW 11.plia hWCw14(IM AM,, IT line w TDW Dr Plym U.MNd y dlk Mrlglp. 1. Mntppw will trop l4 IWp mum All lm rmptny mmmly kourcJ lS,wo An w4 ucb oudI WI k N4 ~M MW VAIA 1e11 mrxim all M4np{w d,D I.Pp", "), Was. it Pxy. P"D1a u Iweypl Y b Norm m S "Dr. 1. AWnp w011wRMreownlii W UO""y urip, muk 4pl:tmwm Jnvimumo, of dl.MpM. rM wU Mamah, tN awW 11 PW w kw uJ rook. EXHIBIT sad Y C wahIAAI DI. Wv ee6C1489mi,IM 05/20/99 09:16:99 DS[7C13-> 215 790 1274 RightFHR Page 003. Ihle wal, "thing Ianin in Ma cONrly whol nanMnl. 714 "Mina NMI, [nMamal ehall Mlyd, and he haada eye aM.aepr owl I'm to. Ihr nA'lactAM Was Cl,C)i adeWrdamm?s ww•mwin, and uudjane sea the Miner Mala wbi Mud, the ddldN deviser wO lnc[W, rM pleat, IM pa L Me rlnduar, and OY uses wr my Bader doll tv applicable M W1 Iaaden• M1raciv of rhil hdnnpp k whim a the Mind ad c daiwo of tk A jnaneM of awn bR heAVOn Mundapn ud Mmlihpr. 14 W ITMess WHCICOy, Mdnppn have dead life Mdnyae, with aaKs) er14a, en the d : AM alal wdlad. cis l alpd dtd lid d In IM P" or.. ?d wweM '` J?.u.J. IsfyA{? ac . wNresse WiMdw COMMONWCALTH Dp PINMYLWNIA 1 J a. ('OtNdTY tly CuaN[Lan/ On Ihle the ?Otih_. dad oC__Wr[dLL? td_9,1_. Edkra nee, CuLW.YInM ?_ Ndrunkd(MY QIQCv PInamdyalPUMN Chen J. ?uehavoo mown In rna (area efdemray pmdq Mae IM per.d rlyM eanap t nbaNNMMvehhla lwnlaaend minwledpN list _lh*pwMrMUma M, IM pvryold lieti1M1,'.••.A?' I / L WITIR73'+I?KM:ir ieil,iN dad did yea adnlnall. ?iL/ 0.V-?Lw01/ •., rr J,/y:???a?"? `;•?r!'t) ??jj ?y ?- - Nney ryNw rdn"ri,i My awinI. Yn. a, IHlapl. a..rrv hawl?., ?w??r ?l art?Iy nod Mutt in WCadyraen aaMwa t tfJO 1 Iyapr mmymna and al11 aMPly wish all federal, Mast, ua loll MnvN lKlY A Ma M IM Mail paddle and aN or Cn pa y. li r wham, old eahhac IN pnpmy Mar 1st lom pleaMa wn or wll a Will to Illept drodiahi y and list pm(ary if ny stir n to Mi by wry pnarxMYWI "Way hcauu of my Ilkpl au( aalvi y ? . 05/20/99 89:17:19 DSI?C13-> 215 790 1274 RiuhtFAX Page 884 1 1 f. H, a CHHTII(ICAT40tl !iTiB!DGNCS G ....._._.» {Y iynY11 of ?.}S''SFieL a PYWYLpol5P48fS4RlyaY. 41D/A .. ...>N4Yf1oSi3 Maslgayi Co: ej'>innY72Ytp1?„ , MuripplY Y411W Y Of f6,3?{0W,,( Mun`( f. dYRAr µ'(III!' IFYI IM atllryGl fYYiyCYfY WUltl 11 a( IIY MouyYYa h .lyP !jk?`fu5? ?Q4 M¢ Yvf<YaYH. PA ?p!x P?vw.urw ? N v?ti. N r, u' z N n$ ? i V Y+ a m? • • ,?. fr1 ?Y Y W.IYIt 1? 011M, •YY wat489P4 4Y5 M , O lx Y Da :I 's is LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 2080 FIRST UNION BUILDING SUITE 600 123 SOUTH BROAD STREET 216 HADDON AVENUE WESTMONT NJO8108 PHILADELPHIA, PENNSYLVANIA 19109 , (609) 8584080 (215) 790.1010 FAX (609) 858.7020 TERRENCE J, McCABE FAX (215) 790.1274 SUITE 5225 500 FIFTH AVENUE NEW YORX.NY 10110 (212)573.1010 FAX (212) 575.2537 February 22, 1999 Ellen J. Deschenes 1600 Orrsbridge Road Enola, PA 17025 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THE COMMONWEALTH OF PENNSYLVANIA'S HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU. READ THE FOLLOWING NOTICE TO FIND OUT HOW THE PROGRAM WORKS. If you need more information, call the Pennsylvania Housing Finance Agency at 1-800-342-2397. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contcnido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE EXHIBIT "B TO: Ellen J. Deschenes FROM: Terrence J. McCabe, Esquire RE: Premises: 1600 Orrsbridge Road, Enola, PA 17025 Account Number: 711714-00-0106523 foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read ali of this 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 a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting mu occur in the npyt (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of the Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania representative is as follows: Margaret Smith Beneficial Consumer Beneficial Mortgage P.O. Box 4153 Discount Company d/b/a Company of Pennsylvania Carol Stream, IL 60197-4153 1-800-958-2540 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest. as required, for a period of at least sixty (60) days. The total amount of the delinquency is $3,748.92. That sum includes the following: principal and interest. N/A. Your mortgage is also in default for the following reasons: If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be i d o It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the agency under the eligibility criteria established by the Act. and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceeding will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105; telephone number (717) 780-3800 or 1-800-342-2397 (toll free number). Persons with impaired hearing can call (717) 780-1869. In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose." You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice you cannot be foreclosed upon while you are receiving that assistance. NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the original creditor. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND D ANY INFORMATION OBTAINED WTL•L BE USED FOR THIS PURPOSE. Very truly yours, TERRENCE J. McCABE TJM/mb PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNERS1 EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, Pa 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, Pa 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, Pa 17101 (717) 234-5925 FAX # (717) 232-4985 YWCA of Carlisle 301 G Street Carlisle, Pa 17013 (717) 243-3818 FAX 0 (717) 243-3948 LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 2080 FIRST UNION BUILDING 173 SOUTH BROAD STREET PHILADELPHIA, PENNSYLVANIA 19109 (215) 7901010 TERRENCE J. McCABE FAR (215) 790.1274 February 22, 1999 Ellen J. Deschenes 1600 Orrsbridge Road Enola, PA 17025 SUITE 600 216 HADDON AVENUE WESTMONT, NJ 08108 (609) 858.7080 FAR (609) 858.7020 SUITE 5225 500 FIFTH AVENUE NEW YORK, NY 10110 (212)575.1010 FAR (212) 575.2537 LENDER: Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania ACCOUNT NUMBER: 711714-00-0106523 REAL ESTATE: 1600 Orrsbridge Road, Enola, PA 17025 Dear Ellen J. Deschenes: The MORTGAGE held by Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania (hereinafter we, us or ours) on your property located at 1600 orrsbridge Road, Enola, PA 17025 IS IN SERIOUS DEFAULT because you have not made the monthly payments of approximately $937.23 for the months of October, 1998 through February, 1999, and/or because of this failure to remit. Late charges, and other charges have also accrued to this date in the amount of $0.00. The total amount now required to cure this default, or in other words get caught up in your payments, as of the date of this letter is $3,748.92. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $3,748.92 plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, I cashier s check, certified check or money order and made to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania P.O. Box 4153 Carol Stream, IL 60197-4153 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, I have been instructed to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. Once this matter is referred to me for suit, but you cure the default before I begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe, which may also include reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to, cure the default and prevent the sale at any time up to one hour before the Sheriff's Foreclosure Sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's Sale could be held would be approximately 5 months. A notice of the date of the Sheriff 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 what the required payment will be by calling the following number: 1-800-958-2540, Ext. . This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's Sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to pay off the mortgage debt, or to borrow money from another lending institution to pay off this debt. (You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale, and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right might exist. You have the right to have this default cured by any third party acting on your behalf. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the original creditor. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE Very truly yours, ?? &ENCE J. M'1 TJM/mb SENT VIA CERTIFIED MAIL NUMBER Z 333 517 525 RETURN RECEIPT REQUESTED D E u N O ¢O ~o w o? ??„$ 5? ? G I yLL ?®IY 7I 8 ? pyfiy$ a ? Cil O lip &I& y .tl m 16 2? '? @ 16 6 .a a Ep Nm_ ? ?3 0 cg ?1 W ? m gN n& ' 88 yJ' JI {? / a T T CC 4 ? RRRRRR 1 ? NC? O p MM g _ a a ? m¢ I n 9.n IM P C 'q NNj 1 'y ?F L 01 ? ? ,y LR ? d 55?? C U ??? xU g25 m ? ? .?C F ?.n ? $ a HIM 2.5H ¢ o b O? G, y 63J OX e o m $ Q? i $p Nm - v ? q cap C ` g • CL ? Si ? N N N V 77 e xrr Nm ? E 3 V V s? = OR z o m N v C _ Z za`o N M a N CD t, co rn O ^ ' ^ LO ta-$ 5 8 Op i m a c a° m M o` Y 3 H 9a E U y tL z 2 a LL m CO IL a IleW olgelunooab jo,.1 as ra °° wi? rn E-000, CV 'EM Pff LL. ??' V? •• m ro ro N U z a) lz q 0) to .C IT N U b O Ul 34 N N •i H A.4 h • u w h N O e b7 I ru a w Ln ;{ Jj ° Igo ??-? m 8 a aF m E?, + N t; xx? a $ ? n 2 V ?. W pp 4 b ? d ?•a ?s0. dy or 3 y a b s a ? W N Fyn 5 ywN 5 Aq Q gb 3 x 40 Cl. rcn (Y v SHERIFF'S RETURN - REGULAR CASE NO: 1999-03192 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS. DESCHENES ELLEN ET AL DAWN KELL , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon DESCHENES ELLEN A/K/A DESCHENES ELLEN J the defendant, at 15:30 HOURS, on the 27th day of May 1999 at 1600 ORRSBRIDGE ROAD ENOLA, PA 17025 CUMBERLAND County, Pennsylvania, by handing to JENNIE KLINGER (ROOMMATE) a true and attested copy of the NOTICE AND COMPLAINT IN together with MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 9.92 ? Affidavit .00 Surcharge 8.00 R.- imas line, S eri S3.9Z-MC?ABE, WEISBERG & CONWAY 05/1999 by ?Ql?'1 d' • f?-e?J? epu y S zllerll L Sworn and subscribed to before me this .7f day of 7h o. 19-9?'_ A.D. ?• ar