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FEDERMAN AND PHELAN
By: FRANK FEDERMAN. ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000
STANDARD FEDERAL BANK
2600 WEST BIG BEAVER ROAD
TROY, MICHIGAN 48084
V.
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
FSi&air
NO. C1?t '3S9U
CUMBERLAND COUNTY
NEIL M. BOYD
JILL H. BOYD
205 NORTH 25TH STREET
CAMP HILL, PA 17011
Defendant(s)
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
You have been stied 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.
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 LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE. PA 17013
(717) 249-3166
I . Plaintiff is
STANDARD FEDERAL BANK
2600 WEST BIG BEAVER ROAD
TROY, MICHIGAN 48084
2. The name(s)and last known address(es) of the Defendant(s) are:
NEIL M. BOYD
JILL H. BOYD
205 NORTH 25TH STREET
CAMP HILL, PA 17011
who is/are the mortgagor(s) and real o%vncr(s) of the property hereinafter described.
3. On 1/3/96 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to FIRST UNITED MORTGAGE SERVICES, INC. which
mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in
Mortgage Book No. 1298, Page 865. By Assignment of Mortgage dated recorded 1/5/96
the mortgage Nvas assigned to PLAINTIFF which Assignment is recorded in Miscellaneous
Book No. 511, Page 818.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 3/l/99 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. A copy of such
notice is attached hereto as Exhibit "A".
6. The following amounts are due on the mortgage:
Principal Balance
Interest $140,002.05
2/1/99 through 6/1/99 3,508.72
(Per Diem $28.76)
Attorney's Fees
Cumulative Lite Charges 7,000.00
1/3/96 to 6/1/99 100.90
Cost of Suit and Title Search
Subtotal 550.00
151,161.67
Escrow
Credit
Deficit 42.20
Subtotal 0.00
42.20
TOTAL $151,119.47
The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs
Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be
charged.
8. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
0 J Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a
true and correct copy of which is attached hereto as Exhibit "B"; or
60 Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
(1977). Defendant(s) ina dispute the validity of the debt or any portion thereof.
If Dclcndant(s) do so in writing within thirty (30) days of receipt of this pleading,
Counsel four Plaintiffwill obtain and provide Defendant(s) with written verification
thcrcol; otherwise, the debt will be assumed to be valid. Likewise, if requested
within thirty (30) days of receipt or this pleading, Counsel for Plaintiff will send
Defendant(s) the name and address of the original creditor if different from above.
WHEREF01M, PLAINTIFF demands in in am Judgment against the Defendant(s) in the sum of
$151,119.47, together with interest I}om 6/1/99 at the rate of $28,76 per diem to the date of
Judgment, and other costs ;in(] charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
/s/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
Notice of Intent
Foreclose/Accelerate CertNied and Regular Mail
Standard Federal Bank
Member ABN AMRO Group
2800 West Big Beaver Road
Troy, Michigan 48084
800!783-7788
May 3, 1999
Neil M Boyd
205 N 25th St
Camp Hill PA 17011 36!1
Borrower(s) Neil M Boyd
Jill H Boyd
Loan Number: 0209592282 Loan Type: Conventional
Property Address: 205 N 25th St
Camp Hill PA 17011
According to our records, payments on the above referenced
loan are in default. You are hereby advised that Standard
Federal Bank may accelerate your mortgage (demand payment
in full) and pursue the foreclosure remedies permitted by
the mortgage unless your loan delinquencies are cured as
provided below.
You may dispute the validity of the debt, or any portion
thereof. If you do so in writing within thirty (30) days
of the date of this letter, we will provide you with written
verification; otherwise, the debt will be assumed to be valid.
Likewise, if requested in writing within thirty (30) days of
the date of thi letter, we will send you the name and address
the original creditor if different from Standard Federal Bank.
The total delinquency, including late and other charges, is
$3,919.82 for payments due on 03-01-99 through 05-01-99.
Your failure to pay the delinquent amount, plus any additional
monthly payment and late and other charges (including any accrued
interest) that may come due within the next thirty days, will
result in the acceleration of all sums due under your mortgage.
After acceleration occurs, a foreclosure action, or any other
remedy permitted by your mortgage, may be instituted.
To avoid this acceleration of your mortgage and subsequent
foreclosure action, the delinquency mentioned above, and any
accrual thereto, must be paid by CERTIFIED CHECK, CASHIER'S
CHECK, MONEY ORDER OR CASH and RECEIVED in our office at
2600 West Big Beaver Road, Troy, Michigan 98089, Attention:
LN294414-9111 EXHIBITA
Notice of Intent t..
Foreclose/Accelerate cawed and Regular Mail
Bundard Federal Bonk
Member ABN AMRO Oroup
2600 Wed Big Beaver Road
Troy, Mlcbipan 48084
600782-1786
May 3, 1999
Jill H Boyd
205 N 25th St
Camp Hill PA 17011 3611
Borrower(s) Neil M Boyd
Jill H Boyd
Loan Number: 0209592282 Loan Type: Conventional
Property Address: 205 N 25th St.
Camp Hill PA 17011
According to our records, payments on the above referenced
loan are in default. You are hereby advised that Standard
Federal Bank may accelerate your mortgage (demand paypment
in full) and pursue the foreclosure remedies permitted by
the mortgage unless your loan delinquencies are cured as
provided below.
You may dispute the validity of the debt, or any portion
thereof. If you do so in writing within thirty (30) days
of the date of this letter, we will provide you with written
verification; otherwise, the debt will be assumed to be valid.
Likewise, if requested in writing within thirty (30) days of
the date of thi letter, we will send you the name and address
the original creditor if different from Standard Federal Bank.
The total delinquency, including late and other charges, is
$3,919.82 for payments due on 03-01-99 through 05-01-99.
Your failure to pay the delinquent amount, plus any additional
monthly payment and late and other charges (including any accrued
interest) that may come due within the next thirty days, will
result in the acceleration of all sums due under your mortgage.
After acceleration occurs, a foreclosure action, or any other
remedy permitted by your mortgage, may be instituted.
To avoid this aceleration of your mortgage and subsequent
foreclosure action, the delinquency mentioned above, and any
accrual thereto, must be paid by CERTIFIED CHECK, CASHIER'S
CHECK, MONEY ORDER OR CASH and RECEIVED in our office at
2600 West Big Beaver Road, Troy, Michigan 48084, Attention:
1x2944(4.98) G.J1HIBITA
Act 91 Notice
Standard Federal Bank
Member ABN AMRO Group
2600 West Big Beaver Road
Troy, Michigan 48084
eow466-3000 May 3, 1999
Neil M Boyd
205 N 25th St
Camp Hill PA 17011 3611
Loan Number: 0209592282
Amount Due: $3,919.82
Property: 205 N 25th St, Camp Hill PA 17011
Certified and Regular Mail
ACT 91 NOTICE
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 AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
The names and telephone numbers of our representatives are listed below. Correspondence may be
directed to them at Standard Federal Bank, Attention: Loss Mitigation Department 4th Floor, 2401 West Big
Beaver Road, Troy, MI 48084.
Mrs. H. S. Obremski Ext. 24125 Mr. W. R. Handley Ext. 24103
Ms. J. A. Mandziara Ext. 24112 Mr. K. A. Griffin Ext. 22636
You may be eligible for financial assistance that will prevent foreclosure of your mortgage if you comply
with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). 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, you may qualify for emergency, temporary assistance.
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 Standard Federal, 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 must occur in the next thirty (30) days.
If you attend a face-to-face meeting with Standard Federal, 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 names and addresses of designated consumer credit counseling
agencies are shown on the enclosed list. It is only necessary to schedule one face-to-face meeting. You
should advise Standard Federal immediately of your intentions.
Your mortgage is in default because you have failed to promptly pay installments of principal and interest,
as required, for a period of at least sixty (60) days. The total amount of your delinquency is indicated
above and is itemized on the enclosed Late Notice.
(over, please)
LN2957(10.98) EXHIBIT B
Act 91 Notice Certified and Regular Mall
Standard Federal Bank
Member ABN AMRO Group
2600 West BIG Beaver Road
Troy, Michigan 48084
800/466.3000
May 3, 1999
Jill H Boyd
205 N 25th St
Camp Hill PA 17011 3611
Loan Number: 0209592282
Amount Due: $3,919.82
Property: 205 N 25th St, Camp Hill PA 17011
ACT 91 NOTICE
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 AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
The names and telephone numbers of our representatives are listed below. Correspondence may be
directed to them at Standard Federal Bank, Attention: Loss Mitigation Department 4th Floor, 2401 West Big
Beaver Road, Troy, MI 48084.
Mrs. H. S. Cibremski Ext. 24125 Mr. W. R. Handley Ext. 24103
MS. J. A. Mandziara Ext 24112 Mr. K A Griffin Ext 22636
You may be eligible for financial assistance that will prevent foreclosure of your mortgage if you comply
with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). 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, you may qualify for emergency, temporary assistance.
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 Standard Federal, 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 must occur in the next thirty (30) days.
If you attend a face-to-face meeting with Standard Federal, 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 names and addresses of designated consumer credit counseling
agencies are shown on the enclosed list. It is only necessary to schedule one face-to-face meeting. You
should advise Standard Federal immediately of your intentions.
Your mortgage is in default because you have failed to promptly pay installments of principal and interest,
as required, for a period of at least sixty (60) days. The total amount of your delinquency is indicated
above and is itemized on the enclosed Late Notice.
(over, please)
1N2957(10•98) j_,^?H?LJ1T b
1995 WJD-APPSD"D HOUSING CODN519LING A=NCIaB
IN PZMSYLVANIA
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21 North From about PhaWalpNa, PA1D108 patients
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Harrisburg PA 17103 Telophowic(21W4463137er ?Ithbargh PA 16230
Tabun nE(717)236-9540 4464192 TWphows:(412)9165291
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3671 cream Covet Ew Pittsburgh PA 15222 Phg d"*Io PA 19123
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Tahphone: (SID) 691-4011 Am bar County Cow4nul6y
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TNaphant 1412) 361.6900 316Ewet Hnbam Avenue
WaeMngbenlGracac Calvrruntly Washington PA 15301
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Vault, PA 72401 BookorT. Washington. Ma P.O. as 100
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1209 Fenayhu ks Avenue W. Action Agency 116 East Norwegian about
P.O. Moe 547 309 Ohio street Pottsville PA 17201.2921
Warren. PA 16365 Sharon, PA 16146 Telephanr (717) 022.1996
Telephone 1614) 725.2400 Telephone. (412) 342.6222
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commission of Eeoaomlo 5011ndlann Avenue 137 Nora 6aaon Avenue
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Telplonc (717) 026-0610 Center For Independent Living His Community Devebpment
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SERVICE All Reedingand 7110 Penn Avenue 2013-2017 Centre Avenue
Berke County Pittsburgh PA 16200 Pittsburgh PA 15219
Mara Catnmen@y Action Telephone: (412) 371.7700 Telephone: (412) 766.1320
Prognun
247 North F6M about
2( THAT CERTAIN tract or parcel of land and premise:, shuttle,1?(4 pnd being in the
Borough of Camp Hill in the County of
Cumberland and Commonwealth of Pennsylvania, more particttlurl,? defcrlbed psfollows:
BEGINNING at the corner formed by the intersection of the,porthern
line of Logan Street with the eastern line of Twenty-fifth Street,
formerly Locust Stroet; thence in a northerly direction along the eastern
line of Twenty-fifth StreeL ninety (90) feet to a point,on the line
of lands now or formerly of Walter F. Deissler and Sylvia G.'Deissler,
his wife; thence in an easterly direction along said line;one hundred
forty (140) feet to St. John's Ailey; thence in a southerly direction
along St. John's Alley ninety (90) feet to Logan Street; thence in
a westerly direction along the northern line of Logan Street one hundred
forty (140) feet to the point or place of BEGINNING.
BEING portions of Lots Nos. 1, 2, 3, 4, 5, 6, and 7, Section "E", on
the Plan of Lots known as Plan No. 2, First Addition to the Borough
of Camp Hill, laid out and adopted by Arthur B. Rupley,and Caleb B.
Brinton, said Plan being recorded in the Cumberland County Recorder's
Office in Plan Book No. 1, Page 5.
HAVING THEREON erected a brick and stucco dwelling house, knuwn as
No. 205 North Twenty-fifth Street, Camp Hill, Pennsylvania.
BEING the same premises which Kenneth R. MacDonald, Jr.., Executor
of the Last Will and Testament of Wilma MacDonald, by Deed dated
December 21, 1994 and recorded December 27, 1994 in the. office of
the Recorder 'of Deeds in and for Cumberland County, Pennsylvania,
in Deed Book 116, Page 848, granted and conveyed unto John Dunkle,
Nancy M. Hall, Charles Myers and Doris Myers, his wife, Grantors herein.
VERIFICATION
David S. Snow hereby states that he is a Vice President of Standard Federal
Bank, mortgage servicing agent for Plaintiff in this matter, that he is
authorized to take this Verification, and that the statements made in the
foregoing Civil Action in Mortgage Foreclosure are true and correct to the
best of his knowledge, information and belief. The undersigned understands
that this statement is made subject to the penalties of 18 Pa. Sec. 4904
relating to unsworn falsification to authorities.
David S. Snow Vice President
DATE: In Z I 01
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03890 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
STANDARD FEDERAL BANK
VS.
BOYD NEIL M ET AL
BRAIN BARRICK , 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 BOYD NEIL M the
defendant, at 14:06 HOURS, on the 28th day of June
1999 at 205 NORTH 25TH ST
CAMP HILL, PA 17011 CUMBERLAND
County, Pennsylvania, by handing to NEIL BOYD
a true and attested copy of the NOTICE AND COMPLAINT IN
together with MORTGAGE FORECLOSURE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 9.30
Affidavit .00
Surcharge 8.00 RTI s it t ,j t1 ri -
$35?.30-FEDERMAN & PHELAN
06/29/1999
by
pu y Snerir
Sworn and subscribed to before me
this :W9 day of
19 99 A. D.
rotnonooary
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03890 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
STANDARD FEDERAL BANK
VS.
BOYD NEIL M ET AL
BRIAN BARRICK , 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 BOYD JILL H
the
defendant, at 14:06 HOURS, on the 28th day of June
1999 at 205 NORTH 25TH ST
CAMP HILL, PA 17011 CUMBERLAND
County, Pennsylvania, by handing to NEIL BOYD (HUSBAND)
a true and attested copy of the NOTICE AND COMPLAINT IN
together with MORTGAGE FORECLOSURE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 6.00
Service .00 ''
Affidavit .00
Surcharge 8.00 l??ffo l?l' ,
-06/29 1999 PHELAN
i /? `
J? /f
by U?
epu y ?h?
Sworn and subscribed to before me
this ,1Q IP-- day of 2
19 X991 A.D.
0
FEDERMAN AND PHELAN
BY: FRANK FEDERMAN, ESQUIRE
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215)563-7000
Attorney for Plaintiff
STANDARD FEDERAL BANK
Plaintiff
VS.
NEIL M. BOYD
JILL H. BOYD
Defendants
. COURT OF COMMON PLEAS
. CIVIL DIVISION
. Cumberland County
No. 99-3890 CIVIL
PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly reinstate the Civil Action in Mortgage Foreclosure with
reference to the above captioned matter.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
Date: July 15, 1999
7
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03890 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
STANDARD FEDERAL BANK
VS.
BOYD NEIL M ET AL
DAVID MCKINNEY Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within REINSTATED NOTICE AND CIVIL was served
upon BOYD JILL H
the
defendant, at 18:32 HOURS, on the 21st day of July
1999 at 1437 APPLE CIRCLE # 189
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to JILL H BOYD
a true and attested copy of the REINSTATED NOTICE AND CIVIL
together with ACTION IN MORTGAGE FORECLOSURE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answer
Docketing 18.00
Service 8.68
Affidavit .00Q
Surcharge 8.00 R7h`omas ine, e i
$3 68-'FEDERrN & PHELAN
07/23/1999
by
S i
Sworn and subscribed-to before me
this 3.1,( day of
19 q A.D.?
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ocnonotary