HomeMy WebLinkAbout99-06857Zs
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FEDERMAN AND PHELAN
By: FRANK FEDERb1AN, ESQUIRE
IDENTIFICA'T'ION NO. 12348
'I'WO 111-NN CENTER PLAZA, SUITE 900
Ill IILADELPIIIA, PA 19102
(215) 563-7000
LIQUIDATION PROPFRTIES,INC.
505 SOUTH MAIN STREET, SUITF 6000
ORANGE, CA 9286S
Plaintiff
V.
IRENE It. VAUGIIN
28 VAUGIIN ROAD
NEWVILLE, PA 17241
Defendant(s)
ATl'ORNEY POR PLAIN HIT
COURT OF COMMON I'Llit\S
CIVIL DIVISION
TERM
No. elel - 6, 57 Glee
CUMBERLAND COUNTY
CIVII. ACTION - LA\\'
R'1'GAG1: IY)RFCLOSIiRI?
?I0
NOTICE
PLEASE BE ADYISFI)T AT'TIIIS FIRM Is,\oEu-r(*OI.IXC'I'OIt A'fI'F.?I VI'ING "r0 COLLECT' A D MIT. ANY
INFORMATION ItF.C4:1Yfal \\11.1. BE CSED FOILTHAT PURPOSE. II' YOC IIAVi; i'Kf:\'IOl'SIA' ItF.C'4;1VFU,\
DISCILU(GE IN HANKRIT r('Y AND] IIIS I)EII I' \\',\S NOT HF.AFFIRMED.1 115 COlut"S"OSIIhN('f- IS NOT,\SII
SIIOULD NOT BE ('ONS"1'It4F.I1'rO IIF. ,\N 1''FO COLLF.CF A DEBT BUT ONLY k.NFDItCI:mr.,,-' OF A
LIEN AGAINST I'ItOI'f:lt'I'\'.
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 F.lil 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 SI IOULD TAKE TIIIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO'r
IIAVE A LAWYER OR CANNOT AFFORD ONE, GO'ro OR TELEPI IONS THE OFFICE
SET FORTII BELOW TO FIND OUT \\'IIERE YOU CAN GET LEGAL I IELI'.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE. PA 17013
(717) 249-3166
Plaintiff is
LIQUIDATION PROPI:RTIES,INC.
505 SOUTH MAIN STREET, SUITE 6000
ORANGE, CA 92868
2. The name(s) and last known address(es) of the Defendant(s) arc:
IRENE It. VAUGI IN
28 VAUGIIN ROAD
NEWVILLE, PA 17241
who is/arc the mortgagor(s) and real o xner(s) of the property hereinafter described
3. On 3/18/98 mortgagor made, executed and delivered a mortgage upon the premises
hereinafter described to AMERIQUEST MORTGAGE COMPANY which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 1440, Page 925. PLAIN'rIPP is now the legal owner of the mortgage and is in the
process of formalizing an assignment of same.
4. The premises subject to said mortgage is described as attached.
5. "file mortgage is in default because monthly payments of principal and interest upon said
mortgage clue 5/1/99 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith. A copy of such notice is attached as Exhibits "A."
acffi
6. The following amounts are due on the mortgage:
Principal Balance 5123,642.00
Interest 7,716.54
411/99 through 11/1/99
(Per Dient 536.06)
Attorney's Fees 4,000.00
Cuuudative Late Charges 476.76
3/I8/98 to 11/1/99
Cost of suit and Title Search 550.00
Subtotal 136,355.60
Escrow
Credit 550.00
Deficit 0.00
Subtotal (550.00)
'raw. 5135,535.60
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
Sheriffs Sale. Ville Nlortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
S. This action (foes not come wider Act 6 of 1974 because the original mortgage amount
exceeds 550,000.
9. This action does not come under Act 91 of 1953 because the mortgaged premises
is not the principle residence of this Defendant.
10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
(1977), Defendant(s) may dispute the validity ol'the debt or any portion thereof'.
If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading,
Counsel for Plaintiff will obtain and provide Defendant(s) with written
verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if
requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff
will send Defendant(s) the name and address of the original creditor if different
from above.
WI IEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the SUIT! of
S 135,535.60, together with interest from I I/1/99 at the rate of 536.06 per diem to the (fate of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
/s/ Frank Federman
FRANK FEDERNIAN, ESQUIRE
Attorney f'or Plaintiff
FEDERiMAN AND PHELAN
Suite 900
Two Penn Center Pl .za
Philadelphia, PA 19102-1797
215-241-1711
Fax: 215-568-7617
Representing Lenders in
Pennsylvania and New Jersey
September 23, 1999
Irene R. Vaughn Irene R. Vaughn
360 Running Pump Road 28 Vaughn Road
Nevrville, PA 17241 Newville, PA 17241
Re: Premises: 360 Running Pump Road - Newville, PA 17241
Loan No.: 0004911806
NOTICE OF INTENTION TO FORECLOSE
We represent Ameriquest Mortgage Co., the holder of the
Mortgage on the above-referenced premises, who hereby advises that
it will 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.
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM
YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED
A DISCHARGE IN BP.NKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.
You may dispute the validity of the debt or any portion
thereof. If you do so in writing within thirty (30) days of
receipt of this letter, this firm will obtain and provide you with
written verification thereof; otherwise, the debt will be assumed
to be valid. Likewise, you may reauest the name and address of the
original creditor if different from above.
The total delinquency, including late and other charges is
$5,206.69 for the months of 5/1/99 through 9/1/99. 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 (30) 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.
;
X&I: to
lr` TA
To avoid the acceleration of your mortgage and subsequent
foreclosure action, the delincn:ency mentioned above and any accrual
thereto must be paid by CERTIFIED CHECK OR MONEY ORDER and received
in our offices at Suite 900, Two Penn Center Plaza, Philadelphia,
PA 19102, in or before thirty (30) days from the date of this
letter. Please call (215) 241-1711 f .
or t:e exact amount required.
You have the right to reinstate your mortgage r
acceleration by fulfilling the conditions stated agage
pertaining to such reinyour statement. You may call our office to
discuss these conditions.
Any future negotiations attempting to reinstate your loan or
acceptance of any payment less than the full amount due shall not
constitute a waiver by the mortgage holder of the acceleration
unless agreed to in wri_ing by the mortgage holder.
You have the right to assert in the foreclosure proceedings
the non-existence of a default or any other defense to acceleration
and foreclosure.
very truly yours,
F EDEPhAL01 AN?Dl PHELAN
By:
Frank Federman
FF:11
CC: Ameriquest Mortgage Co. (CA)
Attn:James Brownell Loan No.: 0004911806
?t:ilr.:;;f•j?
4 !T
=7?
ALL THAT CERTAIN property in the Township dated 3/2 and appearing of Hopewell, County of Cumberland, and
ID #
Commonwealth of Pennsylvania, Parcel d 11-09-0509-030, being more fully described in Deed
among the land records of the County and State set Forth above, in
Book 102, , page 1108.
AND as more fully described as follows:
ALL THAT CERTAIN tract of land, together with improvements erected thereon known as 360
Running Pump Road, situate in the Tuwnship of Hopewell, in the County of Cumberland,
Commonwealth of Pennsylvania, bounded and described as follows:
BEGINNING at an iron pin in a public road at corner of land now or formerly of Alfred W. Bitner,
formerly part of this same farm; thence with the said public road, North eighty-five (85) degrees
twenty-five (25) minutes East, seventy and eight-tenths (70.8) perches to a stake in the road at
corner of land now or formerly of Evans W. Bitner, also formerly part of this same farm; thence
with said land, North seventy-four (74) degrees fifty-five (55) minute East, forty-eight and four-
tenths (48.4) perches to a post on line of land formerly of Hugh B. McCune and now or formerly of
William P. Tiller; thence with said land, South forty-five and twenty-five hundredths (45.25)
degrees East two hundred two (202) perches to a stone in a run or a drain; thence South forty-two
(42) degrees west, forty-one and eight-tenths (41.8) perches to a post, formerly a black oak tree;
thence South seventy-three (73) degrees West, ninety-two (92) perches to a post; thence by land
formerly of Joseph Whistler, later John Booz, now or formerly of Charles Hassler, North sixty-two
(62) degrees West, one hundred fifty-three and two-tenths (153.2) perches to a stake in the public
road; thence with said road, North thirty-seven and five-tenths (37.5) degrees East, eighteen (18)
perches to a point in the said road; thence by same, North twenty and five-tenths (20.5) degrees
East, fifty-nine and eight-tenths (59.8) perches to an iron pin in the center of the Newburg Road, the
place of BEGINNING.
¦ i,
CONTAINING one hundred fifty-three (153) acres and thirteen (13) perches.
EXCEPTING THEREFROM the following tracts of land:
1. Three and three-fourths (34) acres, more or less, conveyed by W.H. Vaun, single man, to
Howard G. Vann and Irene R. Vaun, his wife, by deed dated August 11, 1951, and recorded
in the Cumberland County Recorder's Office in Deed Book "H", Volume 19, page 393.
Also being the same which Howard G. Vaughn and Irene R. Vaughn, his wife, by their deed
dated May 28, 1971, and recorded in Cumberland County Deed Book "C", Volume 24, at
page 503, conveyed to Howard L. Vaughn and Connie L. Vaughn.
2. Three acres conveyed to William E. Cramer, Jr., dated July 26, 1961, and recorded in
Cumberland County Deed Book "G", Volume 20, at page 693.
3. Three and seventy-nine hundredths (3.79) acres conveyed to William J. Burchfield and
Josephine L. Burchfield, his wife, dated December 18, 1971, and recorded in Cumberland
County Deed Book "K", Volume 24, at page 921.
4. One and seven hundred twenty-one thousandths (1.721) acres conveyed to Hugh E. Beam
and Marguerite D. Beam, his wife, dated May 23, 1974, and recorded in Cumberland
County Deed Book "S", Volume 25, at page 83.
5. Two (2) acres conveyed to Richard C. Aby and Alice A. Aby, his wife, dated August 7,
1974, and recorded in Cumberland County Deed Book "S", Volume 25, at page 823.
6. Lot in Hopewell Township conveyed to William E. Cramer, Jr., dated July 8, 1977, and
recorded in Cumberland County Deed Book "H", Volume 27, at page 338.
7. Five and four hundred ninety-three thousandths (5,493) acres conveyed to Roger L. Vaughn,
dated October 11, 1982, and recorded in Cumberland County Deed Book "Z", Volume 29,
at page 293.
8. Lot 9 conveyed to Amos K. King and ivlalinda E. King recorded June 3, 1996 in
Cumberland County Deed Book 140, page 343.
BEING Tax Parcel n 11-09-0509-030.
360 RUNNING PUMP ROAD
7 -
FEDERMAN & PRELAN
VERTFTCATION
!W James Brownell hereby states that he/she is Foreclosure specialist
of Ameriquest mortgage servicing
I'
agent for Plaintiff in this matter, that he/she 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/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: I I IE: l-7 y
!s
<Jam s Brownel
For
closure Specialist
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06857 P
COUNTYCOMMONWEAOFLCUMBERLANDTH OF
LIQUIDATION PROPERTIES INC
VS.
VAUGHN IRENE R
Sheriff or Deputy Sheriff of
BRIAN BARRICK
CUMBERLAND County, Pennsylvania, who being duly sworn according
was served
to law, says, the within COMPLAINT - MORT FORE the
upon VAUGHN IRENE R of December
defendant, at 18:05 HOURS, on the 7th day
1999 at 350 RUNNING PUMP ROAD CUMBERLAND
NEPIVILLE, PA 17241
County, Pennsylvania, by handing to IRENE R. VAUGHN
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.
So answers:
Sheriff' s Costs: 18,00
Docketing 10.54
Service .00 nevi
Affidavit 8.00 R-'inomas ine,
Surcharge
FEDERMAN &,
:r4 1
2/09/1999 PHEL. I
by /r ` rm'
epu-y erl -
sworr. and subscribed to before me
this 13 tr.. day of Q-1 I.. -
49 >_ci"0 A.D.
cz ro ?l t t,o
-?`-rtnofio rye
IN THE COURTOF COMMON PLEAS OF CUMBERLAND COUNTY,
COMMONWEAL'm OF PENNSYLVANIA
LIQUIDATION PROPERTIES, INC.,
Plaintiff,
COURT OE COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
IRENE It. VAUGHN,
Defendant
NO. 99-6857-CIVIL
NO'rICG TO PLEAD
TO: Liquidation Properties, Inc.
You are hereby notified to File a written response to the attached Preliminary Objections
of the Defendant. Irene R. Vaughn, within twenty (20) days from service hereofor a
judgement may be entered against you. /
r'
A.
Attorney for Irene R.
MARK. WEIGLE AND PI!1tKIN5 - ATTORNEYS AT LAW - 126 EAST' KING STREET - 5HIPPEN5DURG, PA 17257 1307
IN TIiF, COURT OF COMMON PLEIAS OF CII,\II3I;RLAi\'U COUNTY,
COMMONWEAL 1l OF PENNSVLVANIA
LIQUIDATION PROPERTIES. IN('.,
Plainlil'r,
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
V.
IRENE R. VAUGHN
NO. 99-6357-C 11'1 L
DFFENDANf'S PRI'sLUMINARV OlUrCTIONS TO PLAIN'TIFF'S
COMPLAINT
The defendant. Ircnc R. Vaughn, b' her undersigned Iegal counsel, Jerry A. Weigle,
Esquire, preliminarily objects to plaintill-S complaint pursuant to Pa R.C.P. 1023 (a)(1)
as follows:
PRL'•I.li`91NAR1' OI3.16C'I'ION RAISING LACK OI' SU13.IECf MA,i-r R
.JURISDICTION
I. The defendant. Irene R. Vaughn, resides at 160 Running Pump Road, Newvillc,
Pennsylvania 17241, and said location is the principal owner occupied residence
orthe defendant.
2. The plaintirf initiated this mortgage foreclosure action by filing a complaint in
this Court on or shout November 12. 1999.
3. In paragraph nine (9) orsaicl complaint, plaintilThas alleged that this action does
not come tinder Act 91 of 1983 hccause the mortgaged premises is not the
principal residence orthe defendant.
4. The mortgaged premises is and has been the principal residence of the defendant.
and this action does come under Act 91 ol'1983 (35 P.S. § 1680. 401 c et seq), the
I Ionic Owner's Emergency Assistance Act of 1983, as amended.
5. The plaintifi'has tailed to provide to the defendant the proper notice required
under said Act 91 of 1983.
6. Because the plaintill, failed to comply with the notice requirements orsaid Act 91
of 1983, this Court is deprival orthe requisitc_jurisdiction over the subject matter
ol'this mortgage Ihreclosure action.
7. Accordingly, the delendanl asserts that this Court lacksjurisdiction over the
subject matter of this action and preliminarily ohjccis to this complaint pursuant
to I'a R.C.P. 1028 (a)(I I.
MA K, V:IIGLI. AND P1.IIN IY; - AI TLIP"1. P`. AI I•:'.? - 1 tY. 1-A',I KI G SI MCCI 'AI PPL SBL) (i, PA 1]09]-1107
WHEREFORE, the defendant respectfully requests that this mortgage foreclosure action
be dismissed.
Respectfully submitted
WEIGLE, PERKINS AND ASSOCIATES-
1
13
- t -r .
Jerry A. Weigle, Esquire
Attorney I.D. #01624
Attorney Rrr Derenclanl
126 East King Street
Shippensburg, PA 17257-1397
(717)332-7388
N nHK. %Vf'(.L.r ANO PENNINS - AI fOHNI VS At I.AW - 1 -6 1ASI KING SIHLrt - "III P'[N"IRG. PA 1]2571]97
VERIFICATION
We veril'v that the statements made in the loregoing pleading are true and correct. We
understand that false statements herein are made subject to the penalties of IS Ila. C.S.
4904. relating to unsworn falsification to authorities. \ p
Irene R. Vaughn
:rosephit • Burchfield, Attomcy-in-Iuict for
Irene R. Vaughn
MARK. wniou_ AND P[HKCC; - AT I014PJEYS AT LAW . IzG Tina KING srurrt - 9jP,,CN5BURG., vn 172.7.1 397
miz
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
COiNIMONWEALTI I OF PENNSYLVANIA
LIQUIDATION PROPERTIES, INC., : COURT OF COMMON PLEAS
Plaintiff, : CIVIL DIVISION
: CUMBERLAND COUNTY
v.
IRENE 11. VAUGHN,
Defendant
AFFIDAVIT OF SERVICE
COMMONWEAL II OF PENNSYLVANIA
COUNTY OF CUMBERLAND
1
Rhonda R. Wolford, being duly sworn according to law, deposes and says that on
January 13. 2000, she served true and attested copies of Defendant's Preliminary
Objections to Plaintiff-s Complaint with Notice to Plead attached, upon Frank Federman,
Esquire, Attorney for Plaintiff. by mailing the same postage paid, certified mail, return
receipt requested. at Shippensburg. Pennsylvania, addressed as follows:
Sworn to and subscribed before
, .. .
NO. 99-6857-CIVIL
Frank Federman, Esquire
Fcdemmin and Phelan
"fwo Penn Center Plaza, Suite 900
Philadelphia. PA 19102-1799
Rhonda R. Wolford
000e
f
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSIIURG. PA 17257.1397
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
COMMONWEALTH OF PENNSYLVANIA
LIQUIDATION PROPERTIES, INC., : COURT OF COMMON PLEAS
Plaintiff, : CIVIL DIVISION
: CUMBERLAND COUNTY
V.
IRENE 11. VAUGHN,
Defendant
NO. 99-6857-CIVIL
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sent la arman anG rneluu
Frank Federman, Esquir
Senet and NO
Two Penn Center Plaza
P O, State and LIP Code Ul e
Philadel hia PA 19102-1
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MARK, WEIGLE AND PE11I15 - ATTORNEVS AT LAW - 126 EAST KING STREET - SIIIPPENSDURG, PA 17257-1397
FEDERMAN AND I'IIELAN
I3Y: 17R:?N1< 1717.DI?R\IAN, 17.SQUIRI.
Identification No. 17248
"1'no Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
Liquidation Properties, lnc.
Vs.
Irene R. Yauf;lan
Attornev for Plaintiff
COURT O17 C0NUNlON PLEAS
CUMBERLAND COUNTY
NO. 99-0857-CIVIL
CERTIFICA"1'E 017 SERVICE.
I hereby certify that it copy of the Praccipe to Discontinue Foreclosure Action was served
upon counsel for the Defendant's counsel by first class mail, postage prepaid, at the address and on
the date listed below:
Jerry A. Weigle, Esquire
126 East King Street
Shippcnsburg,13A 17257-1397
FL•DERNIAN AND P1IELAN
DATE:
Frank Federman, Esquirc/J13S
Attorney 1'or Plaintiff
FEDERMAN AND PIIELAN
BY: FRANK FEDERnIAN, ESQUIRr.
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
Liquidation Properties, Inc.
Vs.
Irene R. Vaughn
Attorney for Plaintiff
COURT' OF COMkNlON PLEAS
CUMBERf.AND COUNTY
NO. 99-6857-CIV11.
PRAECIPE'CO DISCONTINUE FORECLOSURE ACTION
TO THE PROTHONOTARY:
Please mark this case discontinued without prejudice.
FEDERMAN AND PI [ELAN
DATE:-41 ( BY:_
Pr tk Pcdcrman,lsquirc/J[3S
Attorney for Plainti IT
IN THE COURT OF COMMON PLEAS OF C1JIMBERLAND COUNTY, CONIMONNEALTH
OF PENNSYLVANIA
LIQUIDA'T'ION PROPERTIES, INC.,
Plaintiff,
IRENE R. VAUGHN,
Defendant
COURT OF COMNION PLEAS
CIVIL DIVISION
CUMBERLAND COUN-rY
NO.99-6857-CIVIL
AFFIDAVIT or SERVICE
COMMONNEALT1I OF PENNSYLVANIA
COUNTY 017 CUMBERLAND
Rhonda Nolfortl, being duly sworn according to law, deposes and says that on July 19, 2000. she
served a true and attested copy of Preliminary Objections with a Notice to Plead upon the Plaintiff,
Liquidation Properties. Inc.. by mailing the same to Plaintiffs Counsel postage paid, certified mail,
addressee only, and return receipt requested, at Shippensburg. Pennsylvania, addressed as lollows:
Frank Federman, Esquire
Federman and Phelan
Two Penn Center Plaza
Suite 900
Philadelphia. PA 19102 /
Rhonda \Nolfortl c/?"
r
I
1.
Sworn to anti subscribed More
me this clay of . 2000.
PJnutrv ' hG••
Noladal s ,a'
Patricia L.Tome. Notary Public
Shippun3bur9 Boro. Cumberland Counry
My Commission Expires June 7.2004
WEIGLE. PUMNS c. ASSOCIATES - AT TOPNrYS AT LAW - 6'f PAST ranG STHCrT - SIIIFPCr:9nUHG. PA 17297-1397
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH
OF PENNSYLVANIA
LIQUIDATION PROPERTIES, INC.,
Plaintiff,
V.
IRENE R. VAUGHN,
Defendant
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