HomeMy WebLinkAbout99-05507
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GOLDBECK MCCAFFERTY & MCKEEVER
3Y: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
Plaintiff
VS.
RALPH S. SCARPELLI AND
JANE A. SCARPELLI
(Mortgagor(s) and Real Owner(s))
411 Sharon Avenue
Mechanicsburg, PA 17055
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
qq-
CIVIL ACTION: MORTGAGE
FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
N O T I C E
You have been sued in court. If you wish to Re-.3 gainat 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 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 TARE 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.
Court Administrator
Cumberland County Courthouse. Carlisle, PA
(717) 240-6200
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V I S 0
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS. ES
A13SOLUTAKENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIM DESPUES DE HER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO DUE USTED, 0 SU ABOCADO, 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 PROSEOUIR CON EL PROCEED SIN SU PARTICIPACION.
ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DE:ANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS
LAS PROVISIONES OE ESTA DEMANDA. MR RA20N DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD
U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A ON ABOGADO NA4EDIATAMENTE.
SI NO CONOCE A UN ASOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS),
215-238-6300.
Court Administrator
Cumberland County Courthouse, Carlisle, PA
(717) 240-6200
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is COLUMBIA NATIONAL INC., 7142 Columbia
Gateway Drive, Columbia, MD 21046-2132.
2. The name(s) and address(es) of the Defendant(s) is/are
RALPH S. SCARPELLI, 411 Sharon Avenue, Mechanicsburg, PA 17055 and
JANE A. SCARPELLI, 411 Sharon Avenue, Mechanicsburg, PA 17055, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On March 27, 1997, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
COLUMBIA NATIONAL INC., which mortgage is recorded in the Office of
the Recorder of Deeds of Cumberland County in Mortgage Book 1372,
Page 498. The mortgage has not been assigned. These documents are
matters of public record and are incorporated herein by reference
in accordance with Pennsylvania Rule of Civil Procedure 1019(g).
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 May 1, 1999, 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.
The following amounts are due on the mortgage:
Principal Balance
interest from 4/ 1/99
through 8/31/99 at 7.500%
Per diem interest rate at $29.00
Attorney's Fee at 5%
of Principal Balance
Late Charges 5/ 1/99- 8/31/99
Monthly late charge amount at $66.74
Costs of suit and Title Search
Escrow Balance Deficit
Monthly Escrow amount $328.61
$ 141,143.99
4,408.00
7,057.20
266.96
560.00
$ 153,436.15
1,167.71
$ 154,603.86
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. A Notice of Homeowners' Emergency Mortgage Assistance Act
of 1983 has been sent to the Defendant(s) by regular mail in
accordance with Act 91 of 1983 of the Commonwealth of Pennsylvania
on the date set forth in the true and correct copy of such notice
attached hereto as Exhibit "A". The date of the postmark on the
Notice was the same as the date of the Notice. The Defendant(s)
has/have not had the required face to face meeting within the
required time and Plaintiff has no knowledge of any such meeting
being requested by the Defendant(s) through the Plaintiff, the
Pennsylvania Housing Finance Agency, or any appropriate Consumer
Credit Counseling Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $154,603.86, together with interest at the rate of
$29.00, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises.
By:
GOLDBECK 4A. F McKEEVER
BY: Joseph Goldbe Jr., Esq.
Attorney for Plaintif
VERIFICATION
I, , as the representative of the
Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
Date: .n • 9.1 JA20
#2733482 - SCARPELLI,RALPH S.
EXHIBIT "A"
ALL THAT CERTAIN piece or parcel of land situate in the Borough of
Mechanicsburg, County of Cumberland and State of Pennsylvania,
bounded and described as follows, to wit:
BEGINNING at a point on the northern line of Sharon Avenue, said
point being at the dividing line between Lots No. 171 and 172 on
the hereinafter mentioned Plan of Lots; thence along said dividing
line North 25 degrees 09 minutes West, one hundred ten (110) feet
to a point; thence North 64 degrees 51 minutes East, eighty (80)
feet to a point at the dividing line between Lots Noe. 172 and 173
on said Plan; thence along said dividing line South 25 degrees 09
minutes East, one hundred ten (110) feet to a point on the northern
line of Sharon Avenue; thence continuing along the northern line of
Sharon Avenue, South 64 degrees 51 minutes West, eighty (80) feet
to a point, the place of BEGINNING.
BRING Lot No. 172 on Final Plan No. 10, Plot "B" of Heritage
Acres, said Plan being recorded in the Cumberland County Recorder's
Office in Plan Book 29, Page 120.
BRING the same premises which Edward A. Loscher and Kathleen W.
Loscher, husband and wife, granted and conveyed to Ralph S.
Scarpelli and Jane A. Scarpelli, husband and wife, Borrowers
herein.
Pennsylvania Ss
of Cumberland of ppeas
in the office for the recording
eood .72/ACE 504
June 25, 1999
COLUMBIA NATIONAL
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EX H I ?irwcYPLEASEAREADSNOTICE. PROGRAM
n YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
Ralph Scarpelli
411 Sharon Ave.
Mechanicsburg, PA 17055
Re: Columbia National No. 3229437
411 Sharon Ave.
Mechanicsbu, PA 17055
Dear Borrower:
You may be eligible for financial assistance that will
prevent 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 asaistance if you 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 ALL OF
THE NOTICE. IT CONTAINS AN EXPLANATION OF YOUR RIGHTS.
Under the Act, you are entitled to a tempory stay of
foreclosure on you mortgage for thirty (30) day from the
date of the notice. During that time, you must arrange and
attend a "fact-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 ourt a repayment plan, or to otherwise
settle you delinquency. This meeting must occur in the
next (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) day after the
Z 571 020 851
Us Po" Service
Receipt for CetllNd Mail
No I mnce Cowwo Pmdda
Do u for IM?m anY MY see re
71.2 Crwe,A3 D-•:
PO Bo. 3050
date of this meeting. The name, address and telephone
number of our representative is:
Gary B. Masseaux
ASSISTANT VICE PRESIDENT
Columbia National, Incorporated
7142 Columbia Gateway Drive
Columbia, Maryland 21046
(800)444-7963 EXT 2446
(410)872-2446
The names and addressee of designated consumer credit
counseling agencies are shown on the attached sheet. It is
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 2,770.18. That sum
includes the following:
PAYMENTS $2,669.56
NSF FEES $.00
LATES $100.62
OTHER FEES $.00
LESS FUNDS ON-HAND $.00
TOTAL
$2,770.18
Your mortgage is also in default for the following
reasons: n/a
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 Homeowner's
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 filed or postmarked, within thirty
(30) days of your face-face meeting.
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.
IT IS EXTREMELY IMPORTANT THAT YOUR APPLICATION IS ACCURATE
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 proceedings 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, P.O. Box 15530, Harrisburg,
Pennsylvania 17105. Telephone No. (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 Foreclosure". 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.
Sinc rely,
Gary B. M sseaux
ASSIST VICE PRESIDENT
Enclosures
COPIES VIA FIRST CLASS MAIL, COPIES TO THE PROPERTY &
MAILING ADDRESSES
APPENDIX A
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
The Commonwealth of Pennsylvannia's
Homeowner's Emergency Mortgage Assistance
Program
may be able to help you.
Read the attached notice to find out how the
program works.
If you need more information call the Pennsylvania
Housing Finance agency at 1 (800) 342-2397
LANOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO
COMPRENDE EL CONTENIDO DE ESTA NOTIFCACION OBTENGA UNA
TRADUCCION INMEDIATAMENTE LLAMANDO 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.
- .EXHIBIT A
June 25, 1999
COLUMBIA NATIONAL
Incorporafcd
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
C WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
N HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
Jane Scarpelli
411 Sharon Ave.O
Mechanicsburg, PA 17055
Re: Columbia National No. 3229437
411 Sharon Ave.
Mechanicsbu, PA 17055
Dear Borrower:
Z 571 020 852
us Postal Service
Receipt for CwdW Mail
No Insurance Coverepe PtoYtled.
Do t use for I enrW W IW t*ArWM
You may be eligible for financial assistance that will
prevent foreclosure on your mortgage if you comply with the
provisions of the Homeowners' Emergency Mortgage Assistance
Act of 2.983 (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 ALL OF
THE NOTICE. IT CONTAINS AN EXPLANATION OF YOUR RIGHTS.
Under the Act, you are entit:ed to a tempory stay of
foreclosure on you mortgage for thirty (30) days from the
data of the notice. Durinc that t±me, you must arrange a:4
attend a "fact-to-face" meeting with a representativ of
this lender, or with a designated consumer credit
counseling agency. The purpose of this meeting is to
attempt to work ourt a repaym=ent clan, or to otherwise
settle you delinquency. This meeeting must occur in the
next (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
PO 9: - 3050
Ca-.",t MD 2tD=c
I, Q
date of this meeting. The name, address and telephone
number of our representative is:
Gary B. Masseaux
ASSISTANT VICE PRESIDENT
Columbia National, Incorporated
7142 Columbia Gateway Drive
Columbia, Maryland 21046
(800)444-7963 EXT 2446
(410)872-2446
The names and addresses of designated consumer credit
counseling agencies and shown on the attached sheet. It is
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 2,770.18. That sum
includes the following:
PAYMENTS $2,669.56
NSF FEES $.00
LATES $100.62
OTHER FEES $.00
LESS FUNDS ON-HAND $.00
TOTAL $2,770.18
Your mortgage is also in default for the following
reasons: n/a
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 Homeowner's
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 filed or postmarked, within thirty
(30) days of your face-face meeting.
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.
IT IS EXTREMELY IMPORTANT THAT YOUR APPLICATION IS ACCURATE
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 proceedings 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, P.O. Box 15530, Harrisburg,
Pennsylvania 17105. Telephone No. (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 Foreclosure". 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.
Sinc rely,
Gary B. sseaux
ASSISTANT VICE PRESIDENT
Enclosures
COPIES VIA FIRST CLASS MAIL, COPIES TO THE PROPERTY &
MAILING ADDRESSES
APPENDIX A
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
The Commonwealth of Pennsylvannia's
Homeowner's Emergency Mortgage Assistance
Program
may be able to help you.
Read the attached notice to find out how the
program works
If you need more information call the Pennsylvania
Housing Finance agency at 1 (800) 342-2397
LANOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO
COMPRENDE EL CONTENIDO DE ESTA NOTIFCACION OBTENGA UNA
TRADUCCION INMEDIATAMENTE LLAMANDO 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.
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
Plaintiff
VS.
RALPH S. SCARPELLI AND JANE A.
SCARPELLI (Mortgagor(s) and
Record owner(s))
411 Sharon Avenue
Mechanicsburg, PA 17055
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-5507 CIVIL
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned
matter.
GOLDBECK 71"tMCKEEVIIR
BY:
Joseph A. Goldbeck, Jr.
Pw-0288
Qa?
? CO
wi,3 6;
C}
L,
c? j
SHERIFF'S RETURN - NOT FOUND
i.;
CASE?IO: 1999-05507 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLUMBIA NATIONAL INC
VS.
SCARPELLI RALPH S 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: SCARPELLI RALPH S
but was unable to locate Him in his bailiwick. He therefore returns
the COMPLAINT - MORT FORE
NOTICE
NOT FOUND as to the within named defendant
SCARPELLI RALPH S
INFORMED ATTY THAT DEFT. NOW LIVES OUT OF COUNTY,
NEVER RECEIVED ADDL FUNDS TO DEPUTIZE.
Sheriff's Costs: So answe
Docketing 18.00
Service 6.20
Not Found Return 5.00
Surcharge 8.00 II omas ine, eri
$T 10/DB?CK, MCCAFFERTY,MCKEEVER 1999
Sworn and subscribed to before me
this L t? day of &L„,..G..-_
19A.D.
1 ?'
??
ro ono ary
+` SHERIFF'S RETURN - NOT FOUND
CAS9-RO : 1999-05507 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLUMBIA NATIONAL INC
VS.
SCARPELLI RALPH S 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: SCARPELLI JANE A
but was unable to locate Her in his bailiwick. He therefore returns
the COMPLAINT - MORT FORE
NOT FOUND , as to the within named defendant
SCARPELLI JANE A
INFORMED ATTY THAT DEFT. NOW RESIDES OUT OF COUNTY
NEVER RECEIVED ADDL FUNDS TO DEPUITZE.
Sheriff's Costs: So answer_
Docketing 6.00
Not Found Return 5.00 r
Affidavit .00 irfz,
Surcharge 8.00 Inoma3 A 1 t- - --
$TPr.= 1OLDB$CK, MCCAFFERTY, MCKEEVER
99
Sworn and subscribed to before me
this (.t day of kltl?
19'99_ A. D.
?-Pr0 ono?Yy
b SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1999-05507 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLUMBIA NATIONAL INC
VS.
SCARPELLI RALPH S 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: SCARPELLI JANE A
but was unable to locate Her in his bailiwick. He therefore
deputized the sheriff of BLAIR County, Pennsylvania.
to serve the within COMPLAINT - MORT FORE
On December 6th, 1999 , this office was in receipt of
the attached return from BLAIR County, Pennsylvania.
Sheriff's Costs: So answe
Docketing 6.00
Out of County .00
Surcharge 8.00 nomas K in eri
0 1O/06/CK9 MCCAFFERTY, MCKEEVER
2199
Sworn and subscribed to before me
this //t' day of
1V J&P-J A. D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1999-05507 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLUMBIA NATIONAL INC
VS.
SCARPELLI RALPH S 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: SCARPELLI RALPH S
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of BLAIR County, Pennsylvania.
to serve the within COMPLAINT - MORT FORE
On December 6th, 1999 , this office was in receipt of
the attached return from BLAIR County, Pennsylvania.
Sheriff's Costs: So answ
Docketing 18.00
Out of County 9.00
Surcharge 8.00
DEP. BLAIR COUNTY 40.00 II?
$1bOU 1O/06/ $CK, MCCAFFERTY, MCKEEVER 1999
Sworn and subscribed to before me
this "-- day of
1* ;i vzo A.D.
/ rrocnonocary
In The Court of Common Pleas of Cumberland County, Pennsylvania
Columbia National, Inc.
VS.
Ralph S. Scarpelli, et. al.
Serve: Jane A. Scarpelli No. 99-5507 Civil
Now, 11/17/99 19_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Blair County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
upon
at
by handing to _
a
and made known to
So answers,
the contents thereof.
Sheriff of
COSTS
Sworn and subscribed before SERVICE
me this _ day of , 19 MILEAGE-
AFFIDAVIT
19_, at o'clock M. served the
copy of the original
Counry, PA
In The Court of Common Pleas of Cumberland County, Pennsylvania
Columbia National Inc.
VS.
Ralph S. Scarpelli, et. al.
Serve: Ralph S. Scarpelli No. 99-5507 Civil
Now, 11 / 17 / 9 9 , 19__, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Blair County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
?a?Z14 2
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
upon
at
by handing to
a
and made known to
So answers,
Sheriff of
Sworn and subscribed before
me this _ day of , 19
copy of the original
COSTS
SERVICE _
MILEAGE _
AFFIDAVIT
19_, at o'clock M. served the
the contents thereof.
PA
i DATE RECEIVED ,
DATE PROCESSED
`til SHERIFF'S DEPARTMENT
lr BLAIR COUNTY, PENNSYLVANIA
COURTHOUSE, HOLLIDAYSBURG, PA. 16648
SHERIFF SERVICE INSTRUCTIONS: a
PROCESS RECEIPT, and AFFIDAVIT OF RETURN Print legibly, insuring readability of all copies.
y
art ppplas. scab ENV. a
-/
1. PLAINTIFF I S Do not detACFI
2. COURT NUMBER
?1 Nr. R - 99- ssD? aT
x DEFFMrwvT r.9 r C:,
SERVE 9 s. NAME OF INDIVIDUAL. COMPANY. CORPORATION, ETC.. TO SERVILE OR DESCRIPTION OF PROPERTY TO BE L , ATTACHED OR SOLD.
_ ?.1 S SC4rev /
6. ADDRESS ISVeet or RFD, Apartment No_ City, Boro, Two.. Slate and ZIP Cade) /?,,
AT of/L/ S e.n '?' n' >Or:wc P4 19
7. INDICATE UNUSUAL SERVICE: PERSONAL PERSON IN CHARGE LJDEP TIZE UCERT MAIL REGISTERED MAIL
?POSTED OTHF
NOW, 19_, I, SHERIFF OF BLAIR , COUNTY, PA., do hereby deputize the Sheriff of to execute
to law. This deputation being made at the request andtrisk of the pla nrtif Writ and make return thereof according
B. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SFRVICF- SHERIFF OF BLAIR COUN y
NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon W attaching any property under within win
may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the pert of
such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before Sheriffs' sale thereof.
9 SI ATURE o` ` ATTORNEY of other ORIGIN'TO?equesting service on behalf or: 10. TELEPHONE NUMBER t 1. DATE
"i.^q...v n%_;*
j ?PLAINTIFF
SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE
12 1 acknowledge receipt of the writ SIGNATUR (honied BCSC Deputy or Clerk and Title 13. Dale Recei pcI 1d. EapimllnNHa Ins
or complaint as indicated above. 1 I I a, 15i 7 HI
15. 1 hereby CERTIFY and RETURN that I have personally sewee, ?have serves arson in charge, ? have legal evidence of service as shown in Remarkst n reverse)
?nave prates the above described property with the writ or complaint described on the intlividual, company, corporation. att.. at the address shown above Oran the a indlviduM,
company, corporation. etc , at the address inserted below by hand inglor Posting a TRUE and ATTESTED COPY Ihamol.
Is, ? 1 hereby certify and return a NOT FOUND because I am unable to locale the individual. company, corporation. eta., named above. (See remarks below)
12 NAme and idle of individual served 18. A person of suitable age and discr;=
Ihenresidieg in adeleFdant'susual Pace Read
of abode. ?
19. Address of where served (complete only it different than shown above) (Street or RFD, Apdrimenl Nn , City. Bore. Ter, 20. Dale oI SSNIce 21, Time
Slate and ZIP Code)
SPr? tVVi-99 20730
_. __._ ._..__ ...r. ..a. nna noes wP• ml.
I I d5 19130 PAG d'ti? (Z
23. Advance Costs ?n 25. 26 22. Total LpeH 2@-BBBF9eEgR D
ISO.W/"'I 91t :mil 3GOL) 1J:t ylx? ?Yoni IInDJ -711 L/
30 REMARKS 13 AFFIRMED anddss iInssc?n/o d?/I to fore ma Ines _.?/,'s
day 01?-,/ a'U5.114 1 19 -/ 9
or
Feh. 3,
I ACKNOWLEDGE RECEIPT 6i0-TAk"sNtkfff1 '
OF AUTHORIZED ISSUING AUTHORITY AND TITLE.
s DATE RECEIVED DATE PROCESSED
V so SHERIFF'S DEPARTMENT
BLAIR COUNTY, PENNSYLVANIA
COURTHOUSE, HOLLIDAYSBURG, PA. 16648
INSTRUCTIONS: L• Z
SHERIFF SERVICE Print legibly, insuring readability of all copies.
PROCESS RECEIPT, and AFFIDAVIT OF RETURN Do not detach any copies. Bcsb ENV.e
1. PLAINTIFF I B 1 2. COURT NUMBER
CD I? k 99- SSU C? 7
3. DEFENDANT I S 1 4. TYPE OF WRIT O COMP INT
w i0.S(. 6'/-( di.?js..rc-
SERVE 5. E OF INDIVIDUAL. COMPANY. C PORA N. ETC.. TO SERVICE On DESCRIPTION OF PROPERTY TO BE E ED. ATTACHED OR SOLD.
A Scan o Il:
B. A DRESS Iseeel A, RFD, Apenmant P0 , City. Boca. Two .Blare and 21P Code) ?eil 44
[]POSTED []OTHER
7. NDICATE SL
UNUSUAL SERVICE: a. ERSO AL PERSON IIN CHA GE DE TIZE []CERT. MAIL ?REGISTERED MAIL
NOW, 19I, SHERIFF OF BLAIR , COUNTY, PA., do hereby deputize the Sheriff of
County to execute this Writ and make return thereof according
to law. This deputation being made at the request and risk of the plaintiff.
SHERIFF OF BLAIR COUNTY
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE:
NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN -- Any deputy sheriff levying upon or attaching any property under within will
may leave same without a watchman, in custody of whomever is found in possession, alter notifying Person of levy or attachment, without liability on the part of
such deputy Or the sheriff 10 any plaintiff herein for any loss, destruction or removal of any such property before sheriffs' sale thereof.
LEPHONE NUMBER 11. DATE
9 SIGNATURE of ATTORNEY or other ORIGINATOR requesting service an behalf al: -71071E
[]PLAINTIFF
tl []DEFENDANT
SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE
I .acknowledge receipt of the writ / SIGNATURE of Authorized 9CSO Deputy or Clark and Title 13. Data Received 14. EapinlroNHearing date
t2. or complaint as indicated above. Z.? 1
IS. 1 hereby CERTIFY and RETURN that I have personally served, []have served person m charge. ? have legal evidence of service As shown in "R imarka" (an reversal
[]nave posted In. above described prorSeny with the writ or complaint described on She individual. company, cpraoralion, eta. at the address shown some or on the individual,
company. corooratmn. rim , at the address inserted below by hand inglor Posting a TRUE and ATTESTED COPY thereof.
,? .._- __....? ------ , -.- ._ ....,..,...w. ..a...,n,.., .nmmn., enrnnrebnn. etc . named above. (So. remarks below)
.... u......... I ..,.,..,-.._._._..... .._
re. A perwn of suitable age and dicarehorl
Read Ofdef'-"
17 Name and title of inmwdual served ncidug mO deleldanfs uwalpMU
1
bo
f de
?
Vag a
0
.
a
o
19 Address Of where served (Complate only it different than shown above) (Strom a, RFD, Apanmanl Ni, . City, Bar., Twp.. 20. Dale OI Service 21. Time
Slate and ZIP Code)
l?'??t °?9
2030
sawn
ATTEMPTS
22 Dale Miles D.P. Int. Dole Data Must, Oep. Int. Dale Mlles Dap. Sol. Date Mlles pap. Ina.
. 1
I I,-Vi 9W rm .1
27. Advance Costs 1 7
22, 25. 26
27, Total Costs
e. COST DUE OR REFUND
2
80. REMARKS
SO
AFFIRMED and suhsc1b0d to before me this
By
19 9
anal Seal
n NOfAfV P
IBialr County
xDiras Feb. 3. 7703 10
or
SHERIFF Of
MY COMMISSION EXPIRES - grI 5 y]
I ACKNOWLEDGE REC T F g? ' HERS E Uhf l
OF AUTHORIZED ISSUING AUTHORITY AND TITLE.
GOLDBECK, MCCAFFERTY & MCKEEVER
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
BY: MICHAEL T. MCKEEVER, ESQUIRE
Attorney I.D. #56129
Attorney for Plaintiff
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
V8.
RALPH S. SCARPELLI AND JANE A
SCARPELLI (Mortgagor(s))
411 Sharon Avenue
Mechanicsburg, PA 17055
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Term
No. 99-5507 CIVIL
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Settled, Discontinued and Ended
upon payment of your costs only.
;RJR., ESQUIRE
tSl
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