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Home My WebLink About99-05095Y1 }s tAy N? f'. ^f_ . ,+ra. SFt r r, 46 L'eli 'V z ?i N. eGi?r t l? IO,t V i f C? V rq( ? r ( ' •i'?k h t.. " ,:4re U t?tr U U ?7t QZ 3uN a am wQ a Q V N Z U._ Q p ? y 0 G ?ihFG Rb]L[ Ay M w OiSULtLUOB zl1r?Rilwa6u uIUY ?IS v K?[O '1MO31 31 31g5 ' 1 1Y FEDERMAN AND PHELAN By FRANK FEDERMAN. ESQUIRE IDENTIFICATION NO 12244 TWO PENN CENTER PLAZA. SUITE 900 PHILADELPHIA. PA 19102 (213) 363-7000 MELLON MORTGAGE COMPANY 3100 TRAVIS STREET HOUSTON. TX 77006 V. Pla miff MATTHEW R. LAMAN JENNIFER D. LAMAN 314 WOODLAND AVENUE NEW CUMBERLAND. PA 17070 Dcfcudant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERNI NO Cp- 6C45 CTerM CUMBERLAND COUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been suctl in Court. If you wish to defend against the claims set forth in the follotcing Pages. you must talc action ttithi» mcnq (20) dais alter this Complaint and Notice arc sated, bt entering a teritten appearance pcrsonall> or bN attorney and filing in tcriting tenth the court our defenses or objections to the claims sat forth against coo. You are ttarncd that if you fail to' do so the case stay proceed mil out you and a judgment maN be entered against %ou by the court tvitlwut further notice for any moncc claimed in the Complaint or for any other claim or relief requested by the Plaintiff.. You ntay lose money or proport% 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 CUibIBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE. PA 1701? (717)249-,166 Plaintiff is MELLON MORTGAGE COMPANY 3100 TRAVIS STREET HOUSTON. TX 77000 The name(s) and last Lno%%u address(es) orthc Dutcndant(s) are MATTHEW R. LAMAN JENNIFER D LAMAN 314 WOODLAND AVENUE NEW CUMBERLAND, PA 17070 Who is/are the mortgagor(s) and real o%%mcr(s) of the proper[) hereinafter described On 8/31/93 mortgagor(s) made. esecutcd and delivered a mortgage upon the premises hereinafter described to MCA MORTGAGE CORPORATION which mortgage is recorded in the Officc of ilic Recorder ot'CUMBERLAND COMA, in Mortgage Book No. 1280, Page 248. B) Assignment of Mortgage recorded 2/29/96 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 514. Page 696. The premises subject to said mortgage is described as attached. ?. The mortgage is in detholt because monthh Pacmcnts of principal and interest upon said mortgage due 511199 and each month thereafter are due and unpaid, and b% the terms of said mortgage. upon default M such pegnwmts for a period of Lime month. the entire principal balance and all interest due thuton are collectible torilmith 6. The following amounts arc duc on tile Illollgage Principal Balance $110.837.80 Interest 2.734 02 4/ 1 MI) lh ruugll 8/ 1 /99 (Pcr Diem $22 41) Att nne\'s Fees 4.000,0(1 Cumulative Late Charges 126.00 8/31/95 to x/ I/()[) Cost of Suit and Title Search 550.00 Subtotal 108.247.82 Escro\\ Credit 0.00 Deficit 1.127 43 Subloul 1.127 43 TOTAL $109.375.23 The attorney's foes set forth above aro ill contorinm Md, the Mortgage documents and Pennsylvania La\\. and \viII be collected in the event of a third park purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Salo. reasonable atto' mov'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 Pursuant to the Fair Debt Collection Practices Act. 15 U.S.C. § 1692 of seq. (1977). Dotcndant(s) mad dispute (lie vahdlt\' of the debt or ally portion thereof If Defendant(s) do so in \\ citing mthin thirty (30) days of receipt of this pleading, Counsel for Plaintiff mll obtain and pro%ide Defendant(s) \\ith \vitten verification thereof, otherwise. the debt mll be assumed to be valid LikcmSC. itrequestcd within thirty (30) dams of receipt of this pleading. Counsel for Plaintiff mll solid Defendant(s) the name and address of the original credaur if diffircnt from abo\c. WHEREFORE. PLAINTIFF dcntan IS Ml Ill rem Judgment against the Dulcndant(s) in the suns of $1119.373 25, together \\ 5th interest I}enl 8/ I/99 at the rate of $22 41 per dicul to the date of Judgment. and other costs and Charges collectible Uudcr the 1110tgage and lin the fi icclusurc and Salo of the nmrlgagcd prupcrt\ /s/ Frank Federman FRANK FEDERMAN. ESQUIRE Allornc\ fie' Plaintiff ALL THAT CERTAIN crecc of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to Witt BEGINNING at a point on the northwest corner of Woodland ¦nd River Avenue; thence in a westerly direction along River Avenue, one hundred forty (140) feet to Oak Avenue; thence in a northerly direction along Oak Avenue, fifty (50) feet to the line of Lot No. 24, Block "V" in the hereinafter mentioned Plan; thence in an eastarly direction along said line, one hundred forty (140) feet to Wood- land Avenue; thence in a southerly direction along Woodland Avenue, fifty (50) fee L- to the Place of BEGINNING. BEING Lots Nos. 25 and 26, Block "V", on the Plan of George W. Buttorff's Second Addition to New Cumberland, which Plan is recorded in the Cumberland County Re- corder's Office in Dead Book)J5. Page qqS. BEING known and numbered as 314 Woodland Avenue, New Cumberland, Pennsylvania. BEING TILE SAME PREMISES which Richard 14. Sponaugle and Ann A. Sponaugle, husband and wife, by. their Deed dated May 16, 1968 and recorded May 17, 1968 in the Offica of the Recorder of Deeds in and for Cumberland County in Deed Book T. Vol- ume 22, Page 862, granted and conveyed unto Max E. Schmidt and Muriel M. Schmidt, husband and wife, Grantors herein. VERIFICATION DEBORAH SPRITZER hereby states that he/she is ASSISTANT VICE PRESIDENT of MELLON MORTGAGE COMPANY mortgage servicing agent for Plaintiff in this matter, that he/she is authorised 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/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.B. Sec. 4904 relating to unsworn falsification to authorities. DATE: a0 O(W LLL BIIL v11'?' OIMl1:M1M wl TFl.IVUivW vlvi iltl1?umvv.?dy t.110 1V93111Y151 ttl ti FEDERMAN AND PHELAN By: Frank Federman, Esquire Atty. I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 Mellon Mortgage Company V. Matthew R. Laman Jennifer D. Laman ATTORNEY FOR PLAINTIFF Cumberland County Court of Common Pleas Civil Division No. 99-5095 Civil Team PRAECIPE TO THE PROTHONOTARY: _x_ A. Plaintiff hereby withdraws the complaint filed in this matter. Please mark this case discontinued and ended without prejudice. B. Please mark this case settled, discontinued and ended. Date Frank F erman Attorney for Plainti f SHERIFF'S RETURN - REGULAR CASE NO: 1999-05095 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MELLON MORTGAGE COMPANY VS. LAMAN MATTHEW R ET AL KATHY CLARKS , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LAMAN JENNIFER D the defendant, at 20:12 HOURS, on the 25th day of August 1999 at 314 WOODLAND AVENUE NEW CUMBERLAND, PA 17070 ,CUMBERLAND County, Pennsylvania, by handing to JENNIFER LAMAN a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So ans r Docketing .00 Service 9.30 Affidavit .00 Surcharge 8.00 omas ine, eri $2J.30FEDER & PHELAN 09/23 1999 by pu y 5 e i Sworn and subscribed to before me this 2- day of .u?../„ 19_99; A.D. l r/ 4 Tro 1,04.11 ar SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-05095 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MELLON MORTGAGE COMPANY VS. LAMAN MATTHEW R ET AL R. Thomas Kline Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: LAMAN MATTHEW R but was unable to locate Him in his bailiwick. He therefore returns the COMPLATNTT - Mnnm .,'-- NOT FOUND _ as to the within named defendant R IN D Sheriff's Costs. Docketing 18.00 So answe s: Service Not Found Return 10.54 5.00 Surcharge 8.00 omas ine, eri $4=7574' FEDERMAN & PHELAN 09/23/1999 Sworn and subscribed to before me this -?3AA day of 19 91 A.D. ?.![ ?C4 /LQ/zr5 i ro no a y L' ?;:FF lit' _ f hl '99 buc 23 3 50 ie?° cc r;,i,?; ?,IIiA PC aoeouc rw rH ?? olsotn noe v, ?.aw.winn. in ) i 3(tl61 Z0b ?GLLO 'lM1b FEDERNIAN AND PHELAN By FRANK FEDERiNIAN. ESQUIRE IDENTIFICATION NO. 12244 TWO PENN CENTER PLAZA. SUITE 9n0 PHILADELPHIA. PA 19102 (2151 563.7000 MELLON MORTGAGE COMPANY 3100 TRAVIS STREET HOUSTON. TX 77006 V. PIamUff MATTHEW R. LAMAN JENNIFER D. LAMAN 314 WOODLAND AVENUE NEW CUMBERLAND. PA 17070 DcfondantCsl ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM No C",_ 5095 (,' 1. s7-errr CUMBERLAND COUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have boon sued in Court. If y uu gush to defend against the claims set forth in the following Pages. you must tale action mthm t enq (20) days after this Complaint and Notice are scr%ed, b entering a watcn appearance persunally or b.x attorney and filing in wiling %%ith the court your defenses or objections to the claims sot turth against coo You are earned that if you fail to do so the case ntay proceed ?? ithout 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 ina% lose monc% or property or other rights important to coo. 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) 244-3166 We hereby certtly the ?n+lthln to be a true grid correct copy of the Oil81nal filed of record "EDERMAN AND PHELAN TRUE (,Op' FPCm RECORD la T;;S:!rtc?y>:3rw,f, I i+re cnin sot my hang i:i,cr ?t t:d-ll;4e, Pa. s_. c7fc! cay ut., - --?? I ntNary Plaintiff is MELLON MORTGAGE COMPANY 3100 TRAVIS STREET HOUSTON. TX 77006 The name(s) and last knomo address(vs) orthe Dctcndant(s) are MATTHEW R. LAMAN JENNIFER D. LAMAN 314 WOODLAND AVENUE NEW CUMBERLAND, PA 17070 who is/are the mortgagor(s) and read ok%ncr(s) of the property hereinafter described. On 8/31/95 mortgagor(s) made. eUcutW and delivered a mortgage upon the premises herenafter described to MCA MORTGAGE CORPORATION \%hich mortgage is recorded in the Office of the Recorder of CUMBERLAND Count, in Mortgage Book No. 1280. Page 248. B% Assignment of Mortgage recorded 2/29/96 the mortgage «as assigned to PLAINTIFF Much Assignment is recorded in Assignment of Mortgage Book No. 514. Page 696 The premises subject to said mortgage is described as attached i. The mortgage ism default because nwnthh payments of principal and interest upon said mortgage due 5/1/99 and each month thereafter arc due and unpaid. and by the terms of said mortgage. upon default in such pay mcnts for a period of one month, the entire principal balance and all interest due thereon arc collectible fortim ith The following atuuunts arc due on the mortgage Principal Balance $100.S3 7 Sq Inlcresi 1 734 02 411/ov iluuugh . (Per Dion $22 4 1 ) Atturnc)'s Fees Cunudatnvc Laic Charges 4.000(g) R/31/93 to 8/Img 126.00 Cost of Sort and Tide Search Subtotal i>0 00 Iu8,247.82 Escrow Credit Deficit 11.00 5ubwtnl 1.127 43 1.127 43 TOTAL S109.373 25 The attorney's fees set forth abuve are tit conPornuq w nh the Mortgage documents and Pennsylvania Laa. and Mill be collected in the event of a third pam purchaser at SheritT's Sale. If the Mortgage is reinstated prior to the Sale. reasonable attornc)'s fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $311.1100 oo 9 Pursuant to the Fair Debt Collection Practices Act. 11 U.S.C. ` 1692 et seq. (1977). Defendant(s) maN dispute the ulidity of the debt or any portion thereof. If Defendant(s) do so in writing w thin thirty (30) days of receipt of this pleading, Counsel for Plaintiff mll obtain and provide Defcndant(s) with written verification thereof. othemue. the debt mll be assumed to be valid Likumsc. if requested mthin thirty (30) digs of receipt of this plcadmg. Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if'difteicm fium above. WHEREFORE. PLAINTIFF demands all gl rem Judgment against the Defendant(s) in the stint of $109.371 23. together mill interest fium 8/ I rn) ai ills rate of x12 41 pcr dorm to the date of Judgment. and other costs and charges collectible under the nun'tgage and 1.01 the tbreCIOSUIV and sale of the mortgaged propcrn s/ Frank Federman FRANK FEDERMAN. ESQUIRE llorncv for Plaintiff ALL THAT CERTAIN tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly boundad and deacrIbed as follows, to wit: DEGINNING at a point on the northwest corner of Woodland ¦nd River Avenues; thence in a westerly direction along River Avenue, one hundred forty (140) feet to Oak Avenue; thence in a northerly direction along Oak Avenue, fifty (50) feet to the line of Lot No. 24, Dlock "V" in the hereinafter mentioned Plan; thence in an masterly direction along said line, one hundred forty (140) feet to Wood- land Avenue; thence in a southerly direction along Woodland Avenue, fifty (30) feet to the Flees of BEGINNING. BEING Lots Nos. 25 and 26, Block "V", on the Plan of George W. Buttorff's Second Addition to New Cumberland, which Plan is recorded in the Cumberland County Re- corder's Office in Dead Book1J5, Page 498. BEING known and numbered as 314 Woodland Avenue, New Cumberland, Pennsylvania. BEING THE SAME PREMISES which Richard W. Sponaugle and Ann A. Sponeugle, husbund and wife, by, their Deed dated May 16, 1968 and recorded May 17, 1968 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book T. Vol- ume 22, Page 862, granted and conveyed unto Max E. Schmidt and Muriel M. Schmidt, husband and wife, Grantors herein. VERIFICATInN DEBORAH SPRITZER hereby states that be/she is ASSISTANT VICE PRESIDENT of MELLON MORTGAGE COMPANY mortgage servicing agent for Plaintiff in this matter, that he/she is authorised 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/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: a O