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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12245 Al" 1'ORNBY FOR PLAINTIFF
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000 COURT OF COMMON PLEAS
CIVIL DIVISION
PNC BANK, N. A.,
S/B/M TO THE FIRST BANK AND TRUST COMPANY
539 SOUTH FOURTH AVENUE
LOUISVILLE, KY 40202
TERM
V.
Plaintiff
RALPH CHARLES CRONE
SANDRA L. CRONE
1311 OLD WILLOW MILL ROAD
MECHANICSBURG, PA 17055
Cti?
Defendant(s)
NO. -1q /`7S
CUMBERLAND COUNTY
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
mi...
PLEASE DE ADVISED TIIAT TIIIS FIRM IS A DEBT COLLEC OR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSF. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND
SHOULD NOT RE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OFA
LIEN AGAINST PROPERTY.
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.
YOU SHOULD TAKE THIS PAPER '1'O YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORT] I BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Ulan N: 0000 7 07 3 17
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
I`:
1. Plaintiff is
PNC BANK, N. A.,
S/B/M TO THE PIRS'I' HANK ANi) TRUST COMPANY
539 SOUTH POURTII AVENUE
LOUISVILLE, KY 40202
2. The name(s) and last known address(es) of the Defendant(s) are:
RALPH CHARLES CRONE
SANDRA L. CRONE
1311 OLD WILLOW MILL ROAD
MECHANICSBURG, I'A 17055
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 3/30/92 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to 1'LAIN'rIPP which mortgage is recorded in the Office of the
Recorder of CUMBERLAND County, in Mortgage Book No. 1059, Page 645.
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 7/3/99 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 Exhibit "A."
6. The following amounts are due on the mortgage:
Principal Balance $86,612.21
Interest 3,225.36
6/3/99 through 11/1/99
(Per Diem $21.36)
Attorney's Pees 4,000.00
Cumulative Late Charges 205.60
3/30/92 to 11/1/99
Cost of Suit and'rillc Search 550.00
Subtotal 94,593.17
Escrow
Credit 0.00
Deficit 0.00
Subtotal 0.00
TOTAL $94,593.17
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.
8. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because 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 "A."
10. Pursuant to the Pair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
(1977), Defendant(s) may dispute the validity of 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.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$94,593.17, together with interest from l 1/l/99 at the rate of $21.36 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
/s/ P 6 erman
PRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
ZZ119
BS211-Clst
October 08, 1999
Ralph Charles Crone
1311 Old Willow Mill Rd
Mechancisburg PA 17055
RE: LOAN NUMBER: 0000707317
PROPERTY ADDRESS M1311 Old Willow echancisburg PAM d
17055
Current Servicer: PNC Mortage
539 S 4th Avenue
Louisville, KY 40202
AGENCY ACTION -- Available funds for emergency mortgage assistance are
very limited. They will be disbursed by the Agency under the eligibility
criteria established by the Act. The Pennsylvania Housing Finance Agency
has sixty (60) days to make a decision after it receives your
application. During that 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 the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE
DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage
Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on
your property located at: 1311 OOldsWill w Mill Rd
Mechanci PA 17055
IS SERIOUSLY IN DEFAULT because:
As of 10-04-99 YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the
following months and the following amounts are past due:
Payments from 07-03-99 through 10-04-99 822 42
* PAYMENT AMOUNT
* PAYMENTS NOW DUE 4
* LATE CHARGES 164.48
* RETURN CHECK CHARGE .00
* OTHER FEES 15.70
* LESS UNAPPLIED FUNDS .00
TOTAL AMOUNT PAST DUE: 3,499.71
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30)
DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO
THE LENDER, WHICH IS $ 3,499.71, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
m„ter 1" made either by cash, cashier's check, certified check
ve
ZZ119*
BS212-C2nd
October 08, 1999
Sandra L Crone RE: LOAN NUMBER: 0000707317
1311 Old Willow Mill Rd PROPERTY ADDRESS: 1311 Old Willow Mill Rd
Mechancisburg PA 17055 Mechancisburg PA 17055
Current Servicer: PNC Mortage
539 S 4th Avenue
Louisville, KY 40202
AGENCY ACTION -- Available funds for emergency mortgage assistance are
very limited. They will be disbursed by the Agency under the eligibility
criteria established by the Act. The Pennsylvania Housing Finance Agency
has sixty (60) days to make a decision after it receives your
application. During that 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 the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE
DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage
Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date)
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on
your property located at: 1311 Old Willow Mill Rd
Mechancisburg PA 17055
IS SERIOUSLY IN DEFAULT because:
As of 10-04-99 YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the
following months and the following amounts are past due:
Payments from 07-03-99 through 10-04-99
* PAYMENT AMOUNT 822.42
* PAYMENTS NOW DUE 4
* LATE CHARGES 164.48
* RETURN CHECK CHARGE .00
* OTHER FEES 15.70
* LESS UNAPPLIED FUNDS .00
TOTAL AMOUNT PAST DUE: 3,499.71
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30)
DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO
THE LENDER, WHICH IS $ 3,499.71, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cash cashier's check certified check
money order made payable and sent to PNC Mortggage Corp of America
ATTN. Cash Services_Dept, 75 .N Fairway Drive Vernon Hills IL 60061
ryHiBlT Pa`
APPENDIX A
ACT 91 NOTICE
TAKE ACTION TO SAYE
YOUR ROME FROM
FORECLOSURE
Fhis is an ancia? nuucc -• - _ _
i ecirtc•information about the nature of the default is rovided in the attached pages.
your home This Notice explains how the program works.
the Counseling Agency.
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA . UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA 'HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PRA UN PRESTAMO POR EL PROGRAMA
STANCE
RTGAGE AS
EMERGENCY
ER'
LLAMADO "HO
PROG PUEDE SALVARnSU CASA DEL PERD DA DELODERECHO A RED MIR SU H PORTECA.L CUAL
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
BLE FORE ERGENCY MORTGAGE ASSMORTGAGE ISTANCE: ASSISTANCE
IF YOU PROV
EMERGENCY CT OF 983 (TPLY HE "AICT"), YOU MAYI BE IONS
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
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Pennsylvania Housing Finance Agency
Homeowner's Emergency Mortgage Assistance Program
Consumer Credit Counseling Agencies
(Rev. 5/99)
Lycoraing-Clinton Counties
Commission For Communicy Actioa(STEP)
2138 Lincoln Street
P. 0. Box 1328
Willfamspor PA 17703
(570) 326-0587
FACC (570) 322.2197
CCCS of Yar-'seaste= PA
201 Basin Street
MiiMunsporr, P.% 17703
(570)323.6627
FA.X (570) 323-6626
COLU14BL1 COL NTY
CLL`fTON COMNTY
CCCS of Northeastern PA
1631 S Atherton St
Suite 100
State College, PA 16801
(814) 238.3668
F.4.X (814) 238-3669
CCCS of Northeastern Pennsvlvanin
1400 %hingtou Execrative Par's
31 W. Market Steer Suite 1
POB 112, Clarks Summit. PA 18411
Wilkes-Bare. PA 18702 (570) 537.9163 or (800) 922-9537
(570) 821-0837 or (800) 922-9535 FAX (570) 587.91349135
F-%-%(570) 821-1785 of Lu=erne Couarr
Commission an Economics Opponanic/
163 Amber Lane
Wilkes-Bare. PA 18702
(570) 826-0510 or (800) 822 BEFORE F:,G
FAX (570) 829-1665--CALL
(570) 455-4994 F=AZE LTON
FAX (570) 455-5631-,CALL BEFORE FAXL' G
(570) 836.4090 TU':ri+:ri-%NNOCE 'I'Y
BooknrT. Washington- Center
MO Holland Sc_eet
Erie, PA 16503
(814) 453-574-4
F.i X (814) 453-5749
John F. Kennedy Center, Inc.
2021 East 20th Street
Erie, PA 16510
(814) 898-04C0
FAX (814) 898-1243
CCCS of W??a? Fe a Ylvul-Ina
2000 Ling.
Harrsbur3, PA 17102
(717) 541-1757
Urban League of Nlet-opalitaa Karriburd
N. fit's Sleet
F.arrisburg, P.A. 17101
(717) 234-5925
F4.X (717) 234-9459
CRAWFORA COUN
Greater Ere Can:aunic! Ac=on Committee
18 West 9th Street
Frie, PA 16501
(814) 459-4581
FAX (814) 456-0161
She-ago ValleY Urban League, Inc
601 Indiana Avenue
Farrell. PA 161°1
(412) 981.3310
CUMBEpJ A D7 COUNTY
Financial Counseling Services of ?"anklin
31 West 3rd Street
Waynesboro, PA 17268
(717) 762.3285
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
F.AX (717) 731-9539
Cottsmunit, Ac=on Comm of the Capital Region
1514 De try Sr-eec
Harrisburg. PA 17104
232-9-5-1
FAX (717) 234-2227,
EX^/?
HIBIT As
Adams County Housing Nuthoric/
139-143 Carlisle St
Gettysburg, PA 17325
(717) 334-1518
FAR (717) 334-8325
PENNSYLVANIA BULLETIN, VOL. 29, NO. 2], JUNE 5, 1999
ALL that certain lot at ground situate in Silver Spring
Township, Cumberland County, Pennsylvania, being Lot No. 5 on a
Subdivision Plan prepared for Georgetta M. Crone by Whittock and
Hartman, Registered Engineers, and recorded in the Office of the
Recorder of Deeds for Cumberland County in Plan Hook 60, Pago 130,
bounded and described as follows:
BEGINNING at a point on the Western side of Old Willow Mill
Road, as it appears on said Plan, which point is also on the dividing
line between Lots Nos. 4 and 5 on said Plan; thence along said dividing
line, North 79 degrees 25 minutes West 402.72 foot to a point: thence
continuing along said dividing line, North 2 degrees 42 minutes 40
seconds East 316.86 feet to a point on line of land now or formerly of
Ernest Clawscr, sr., and Nall L. Clawser, his wife: thence along said
line of Clawsor, South 89 degrees 17 minutes 40 seconds West 370.03
feet to a point in line of land now or formerly of. David Thumma Heirs;
thence along said land of Thumma flair=, South 8 degrees 6 minutes 'Nest
407.76 feet to a point in line of property now or formerly of Jay H.
Smith: thence along said land of Smith, North 82 dagreca 43 minutes
East 301.05 feet to a point: thence continuing along said lard of
Smith, South 79 degrees 25 minutes East 490.25 foot to a point on the
Western right-of-way lino of Old Willow Mill Road: thence along said
Western right-o£-way line, North 21 degrees 45 minutes 20 seconds East
a distance of 75 feet to a point on the dividing line between Lots
Nos. 4 and 5 of said Plan, the Place of BEGINNING.
CONTAINING 177,817.94 square feet, 4.0821 acres. Together With
the right to use a 25 foot wide right-of-way across the Northern
portion of Lot No. 4, the center line of which continues along the
dividing line between Lots Nos. 2 and 4 and Lots Nos. 2 and 3 on the
Subdivision Plan to the western side of Old Willow Mill Road.
PREMISES: 1311 OLD WILLOW MILL.
VERIFICATION
'rERESA SW ITZER hereby states that she is SECOND VICE-PRESIDENT of PNC
MORTGAGE CORP. OF AMERICA mortgage servicing agent for Plaintiff in this matter, that
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 her lcttowledge, information
and belief. The undersigned understands that this statement is made subject to the penalties of 1S
Pa. C.S. Sec. 4904 relating to unswom falsification to authorities.
?L I
DATE:y
TERESA SWITZER
2nd VICE PRESIDENT
FEDERMAN AND PHELAN
BY: Lisa D. Blankenburg, Esq.
Atty. I.D. 478020
Ste. 900/Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
PNC BANK, N.A.,
S/B/M TO FIRST BANK AND TRUST COMPANY
VS.
RALPH CHARLES CRONE
SANDRA L. CRONE
CERTIFICATION
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND County
No. 99-7175-CIVIL
I, LISA D. BLANKENBURG, ESQUIRE, hereby certify that a copy
of the motion for Alternate Service has been sent to the
individual(s) as indicated below by first class mail, postage
prepaid, on the date listed below.
RALPH CHARLES CRONE
1311 OLD MILLOW MILL
MECHANICSBURG, PA 17055
SANDRA L. CRONE
1311 OLD MILLOW MILL
MECHANICSBURG, PA 17055
The undersigned understands that this statement is made
subject to the penalties of 18 PA C.S. 4904 relating to unsworn
falsification to authorities.
Lisa D. a t nburg, Esquire
Federman and Phelan
Date: December 20, 1999
FEDERMAN AND PHELAN
BY: Lisa D. Blankenburg, Esq.
Atty. I.D. 1178020
Ste. 900/Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
PNC BANK, N.A.,
S/B/M TO FIRST BANK AND TRUST COMPANY
VS.
RALPH CHARLES CRONE
SANDRA L. CRONE
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
No. 99-7175-CIVIL
ORDER
AND NOW, this 7 day of 7C«"-ttc 1999, upon
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is-30.99
R 93
consideration of Plaintiff's Motion and the Affidavit of Good Faith
Investigation attached thereto, it is hereby ORDERED that Plaintiff
may obtain service of the complaint on the above captioned
Defendant(s), SANDRA L. CRONE, by mailing a true and correct copy
of the Complaint by certified mail and regular mail to the
defendant's last known address and to the mortgaged premise $?{ at
1311 OLD WILLQW MILL, MECHIkNICSBURG, PA 174r5.5 11 1 ?`tG21
t?tti C? ?,loc?lZ-n L.-T. v?d in a news?o PppUU t clz
Service of the aforementioned mAilings is effective upon the
date of mailing and is to be done by Plaintiff's attorney, who will
file with the Prothonotary's office an Affidavit as to the mailing.
BY THE COURT:
FEDERMAN AND PHELAN
BY: Lisa D. Blankenburg, Esq.
Atty. I.D. #78020
Ste. 900/Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
PNC BANK, N.A.,
S/B/M TO FIRST BANK AND TRUST COMPANY
VS.
RALPH CHARLES CRONE
SANDRA L. CRONE
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
No. 99-7175-CIVIL
MOTION FOR SERVICE PURSUANT TO
SPECIAL ORDER OF COURT
Plaintiff, by its counsel, Lisa D. Blankenburg, Esquire, moves
this Honorable Court for an Order directing service of the
Complaint upon the above-captioned Defendant (s) by Certified mail
and regular mail to the defendant's last known address, and
mortgaged premises at 1311 OLD WILLOW MILL, MECHANICSBURG, PA 17055
and in support thereof avers the following:
1. Attempts to serve Defendant(s) with complaint have been
unsuccessful, as indicated by the Sheriff's Return of Service by
the Sheriff's Office attached hereto as Exhibit "A".
2. Pursuant to Pennsylvania Rule of Civil Procedure 430,
Plaintiff has made a good faith effort to locate the Defendant(s).
An Affidavit of Good Faith Investigation setting forth the specific
inquiries made and the results therefrom is attached hereto as
exhibit "B".
WHEREFORE, Plaintiff respectfully requests this Honorable
Court enter an Order pursuant to Pennsylvania Rule of Civil
Procedure 430 directing service of the Complaint by certified mail
and regular mail. Y?_?
Lisa la cenburg, Esquire
ATTORNEY FOR PLAINTIFF
FEDERMAN AND PHELAN
BY: Lisa D. Blankenburg, Esq.
Atty. I.D. #78020
Ste. 900/Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
PNC BANK, N.A.,
S/B/M TO FIRST BANK AND TRUST COMPANY
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
VS. No. 99-7175-CIVIL
RALPH CHARLES CRONE
SANDRA L. CRONE
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430(a) specifically
provides:
(a) If service cannot be made under the applicable rule, the
plaintiff may move the Court for a special order directing the
method of service. The Motion shall be accompanied by an Affidavit
stating the nature and extent of the investigation which has been
made to determine the whereabouts of the Defendant (s) and the
reasons why service cannot be made.
Note: A Sheriff's return of "Not Found" or the fact that a
Defendant has moved without leaving a new forwarding address is
insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa.
Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption
mailed to last known address requires a good faith effort to
discover the correct address." Adoption of Walker, 468 Pa. 165, 360
A. 2d 603 (1976).
An illustration of good faith effort to locate the defendant
includes (1) inquires of postal authorities including inquiries
pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2)
inquiries of relatives neighbors, friends and employers of the
Defendant and (3) examinations of local telephone directories,
voter registration records, , local tax records, and motor vehicle
records.
As indicated by the attached Sheriff's Return of Service,
marked hereto as Exhibit "A", the Sheriff has been unable to serve
the Complaint. A good Faith effort to discover the whereabouts of
the Defendant(s) has been made as evidenced by the attached
Affidavit of Good Faith Investigation, marked Exhibit "B".
WHEREFORE, Plaintiff respectfully requests service of the
Complaint by certified mail and regular mail to the defendant's
last known address.
rglly submitted:
Lisa D. Bla enburg, Esquire
Attorney fo Plaintiff
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-07175 P
COMMONKALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NA
VS.
CRONE RALPH CHARLES
EXHIBITA
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: CRONE SANDRA L
but was unable to locate Her in his bailiwick. He therefore returns
the COMPLAINT - MORT FORE
NOTICE
NOT FOUND as to the within named defendant
CRONE SANDRA L
DEFT. NO LONGER RESIDES AT ADDRESS STATED,
LEFT NO FORWARDING WITH THE POST OFFICE.
Sheriff's Costs: So answers:
Docketing 6.00 Not Found Return 5.00
Affidavit .00 %
Surcharge 8.00 R omas ine, eri
$TV-.7U FEDERM1999 PHELAN
Sworn and subscribed to before me
this day of
19 A.D.
Prothonotary
N PLAYERS NATIONAL LOCATOR
AFFIDAVIT OF GOOD FAITH INVESTIGATION
Loan Number: 0000707317
Attorney Firm: TRACK STARS
Case Number:
Subject: RALPH & SANDRA L CRONE
A.K.A.: CHUCK W CRONE
Last Known Address: 1311 OLD WILLOW MILL
MECHANICSBURG,PA 17055
Last Known Number: (717) 766-2594
Michael K Gross, being duly sworn according to law, deposes and says:
1. 1 am employed in the capacity of President for Players National Locator.
2. On 11/16/1999, 1 conducted an investigation into the whereabouts of the above named
defendant(s). The results of my investigation are as follows:
CREDIT INFORMATION -
A. SOCIAL SECURITY NUMBER: 209-52-6366 191-50-2792
B. EMPLOYMENT SEARCH:
Unable to locate a good employer for Ralph and Sandra.
C. INQUIRY OF CREDITORS:
The creditors indicated that Ralph and Sandra are living at 1311 Old Willow Mill, Mechanicsburg,
Pa. 17055 with a home phone number of 717-766.2594.
i
• i
INQUIRY OF TELEPHONE COMPANY -
A. DIRECTORY ASSISTANCE SEARCH:
The home phone number for Ralph and Sandra Crone is 717-766-2594 registered at 1311 Old
Willow Mill Road, Mechanicsburg, Pa. 17055. Called the home number and spoke with their
daughter who confirmed Ralph and Sandra are both living at this address.
INQUIRY OF NEIGHBORS -
NIA
INQUIRY OF POST OFFICE -
A. NATIONAL ADDRESS UPDATE:
As of November 11, 1999 the National Change of Address (NCOA) has no change for Ralph and
Sandra from last known address.
MOTOR VEHICLE REGISTRATION -
A. MOTOR VEHICLE & DMV OFFICE:
The Pennsylvania Department of Drivers Licensing has Ralph and Sandra listed at last known
address.
OTHER INQUIRIES -
A. DEATH RECORDS:
As of November 11, 1999 the Social Security Administration has no death records on file for Ralph
and Sandra L Crone and or a.k.a: s under their social security numbers.
B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.
None Found
C. COUNTY VOTER REGISTRATION:
The Cumberland County Voters Registration Office has Ralph and Sandra listed at last known
address.
ADDITIONAL INFORMATION ON SUBJECT -
A. DATE OF BIRTH:
Ralph 09/11123
Unable to verify Sandra's date of birth.
AFFIANT Michael K Gross :T/?+?
Subscribe nd sworn to before me on 11/16/1999
*YNBOIC
Players National Locator 16201 Westwoods Business Park Drive St. Louis, MO 63021
Phone: (314) 230-9922 Fax: (314) 230-0558
V E R I F I C A T I O N
Lisa D. Blankenburg, Esquire, hereby states that she is the
Attorney for the Plaintiff in this action, that she is authorized
to take this Affidavit, and that the statements made in the
foregoing MOTION FOR SERVICE OF THE COMPLAINT PURSUANT TO SPECIAL
ORDER OF COURT are true and correct to the best of her knowledge,
information and belief.
The undersigned understands that this statement herein is made
subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to
unsworn falsification to authorities.
December 20, 1999
Lisa D. a enburg, Esquire
Attorney for Plaintiff
i,
i>
i
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-07175 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NA
VS.
CRONE RALPH CHARLES
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: CRONE SANDRA L
but was unable to locate Her in his bailiwick. He therefore returns
the COMPLAINT - MORT FORE
NOTICE
NOT FOUND as to the within named defendant
CRONE SANDRA L
DEFT. NO LONGER RESIDES AT ADDRESS STATED,
LEFT NO FORWARDING WITH THE POST OFFICE.
Sheriff's Costs: So answe >
Docketing
Not Found Return 6.00
5.00
Affidavit 00
Surcharge 8.00 R -f I` omit as &.Li S eri
MA
N
$T9-.UU FEDE & PHELAN
?
R
12/0 99
Sworn and subscribed o before me
this /°//7 day of
]M d&(n) A.D.
--Fro - ono ay
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-07175 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NA
VS.
CRONE RALPH CHARLES
CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon CRONE RALPH CHARLES the
defendant, at 14,08 HOURS, on the 1st day of December
1999 at 1311 OLD WILLOW MILL ROAD
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to RALPH C. CRONE
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
S
18.00
6.20
.00
8.00
$32-2U FEDE MA
b
Sworn and subscribed to before me
this day of
19 A. D.
ro ono ary
ti
FEDERMAN AND PHELAN
By: FRANK FEDE•RMAN, ESQUIRE
IDENTIFICATION NO. 12245
TWO PENN CEN'rER PLcNZA. SUITE 900
PIfILADELPHIA,PA 19102
(215) 563-7000
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
PNC BANK, N. A.,
S/B/M TO THE FIRST BANIK AND TRUST COMPANY
539 SOUTH FOURTH AVENUE
LOUISVILLE, KY 40202 TERbt
Plaintiff
V.
NO.
CUMBERLAND COUNTY
RALPH CHARLES CRONE
SANDRA L. CRONE
1311 OLD WILLOW MILL ROAD
MECHANICSBURG, PA 17055
Defendant(s)
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
PLEASE BE ADVISED THAT THIS FIRJ1 IS A DEBT COLLECTORATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCI IARGE IN BAS KRUPTCY AND THIS DEBT WAS NOT REAFFIRMED. THIS CORRESPONDENCE IS NOT AND
DE13T BUT ONLY ENFORCENI ENT OF A
SUOULD NOT BE CONSTRCED TO BE A ATTEMPT TO PRCOLLECT A OPERTY.
LIE
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.
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.
TRUE G OPY FMM MOM
iR ToarroOny whereat, I here urrto w rw mw
CUMBERLAND COUNTY
CTTVIBERLA D COUNTY BAR ASSOCIATION
2 LDBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
We hereby certioy ii-ie
within to be a true and
correct copy of the
original filed of record
FEDERMAN AND PHELAN
Plaintiff is
PNC BANK, N. A.,
S/B/M TO THE FIRST BATIK AND TRUST COMPANY
539 SOUTH FOURTH AVENUE
LOUISVILLE, KY 40202
2. The name(s) and last knoxvn address(es) of the Defendant(s) are:
RALPH CHARLES CRONE
SANDRA L. CRONE
1311 OLD WILLOW MILL ROAD
MECHANICSBURG, PA 17055
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 3/30/92 mortgagor(s) 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 No. 1059, Page 645.
4. The premises subject to said mortgage is described as attached.
The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 7/3/99 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon failure of mortgagor to make such payments alter 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 Exhibit "A."
6. The following amounts are due on the mortgage:
Principal Balance $86,612.21
Interest 3,225.36
6/3/99 through 11/1199
(Per Diem 521.36)
Attorney's Fees 4,000.00
Cumulative Late Charges 205.60
3/30/92 to 11/1/99
Cost of Suit and Title Search 550.00
Subtotal 94,593.17
Escrow
Credit 0.00
Deficit 0.00
Subtotal 0.00
TOTAL S94,593.17
7. The attomey'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. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because 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 "A."
10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
(1977), Defendant(s) may dispute the validity of 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.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
594,593.17, together with interest from 1 I/199 at the rate of $21.36 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
A/ Frank Federman
FRANK FEDEI MAN, ESQUIRE
Attorney for Plaintiff
ZZ119
BS211-Clst
October 08, 1999
Ralph Charles Crone RE: LOAN NUMBER: 0000707317
1311 Old Willow Mill Rd PROPERTY ADDRESS: 1311 Old Willow Mill Rd
Mechancisburg PA 17055 Mechancisburg PA 17055
Current Servicer: PNC Mortage
539 S 4th Avenue
Louisville, KY 40202
AGENCY ACTION -- Available funds for emergency mortgage assistance are
very limited. They will be disbursed by the Agency under the eligibility
criteria established by the Act. The Pennsylvania Housing Finance Agency
has sixty (60) days to make a decision after it receives your
application. During that 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 the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE
DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage
Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on
your property located at: 1311 Old Willow Mill Rd
Mechancisburg PA 17055
IS SERIOUSLY IN DEFAULT because:
As of 10-04-99 YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the
following months and the following amounts are past due:
Payments from 07-03-99 through 10-04-99
* PAYMENT AMOUNT 822.42
* PAYMENTS NOW DUE 4
* LATE CHARGES 164.48
* RETURN CHECK CHARGE .00
* OTHER FEES 15.70
* LESS UNAPPLIED FUNDS .00
TOTAL AMOUNT PAST DUE:
3,499.71
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30)
DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO
THE LENDER, WHICH IS $ 3,499.71, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
HavrA.
ZZ119
BS212-C2nd
October 08, 1999
Sandra L Crone RE: LOAN NUMBER: 0000707317
1311 Old Willow Mill Rd PROPERTY ADDRESS: 1311 Old Willow Mill Rd
Mechancisburg PA 17055 Mechancisburg PA 17055
Current Servicer: PNC Mortage
539 S 4th Avenue
Loui, KY 4002
AGENCY ACTION -- Available funds for emergency mor
tgagelassistance2are
very limited. They will be disbursed by the Agency under the eligibility
criteria established by the Act. The Pennsylvania Housing Finance Agency
has sixty (60) days to make a decision after it receives your
application. During that 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 the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE
DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage
Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it u to date).
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on
your property located at: 1311 Old Willow Mill Rd
Mechancisburg PA 17055
IS SERIOUSLY IN DEFAULT because:
As of 10-04-99 YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the
following months and the following amounts are past due:
Payments from 07-03-99 through 10-04-99
* PAYME
NT AMOUNT 822.42
* PAYMENTS NOW DUE 4
* LATE CHARGES 164.48
* RETURN CHECK CHARGE .00
* OTHER FEES 15.70
* LESS UNAPPLIED FUNDS .00
TOTAL AMOUNT PAST DUE:
3,499.71
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30)
DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO
THE LENDER, WHICH IS $ 3,499.71, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cash cashier's check, certified cheek
mn .i a
!q-XHiB1T A
APPENDIX .A
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HENIAP) may be able to help to save
vour home. This Notice explains how the program works.
_
To see if HEiyfAP can heip VOU must MEET r:1Tn A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with
the Counseline Aeencv.
The name address and phone number of Consumer Credit Counseling Agencies serving your County are
listed at the end of this Notice If van have any questions you may call the Pennsylvania Housing Finance
Agency toll free at 1 800-342-2397 (Persons.ivith impaired hearing can call (71T) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITA.IMENTE LLAMAINDO 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 CURL.
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE ? N-D HELP YOU HAKE FUTURE NIORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
EXHIBIT A
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Pennsylvania Housing Finance Agency
Homeowner's Emergency Mortgage Assistance Program
Consumer Credit Counseling agencies
(Rev. 5199)
Lyeoming-r- -:roc Coucdes
Commission For Comaunir? Action (S'2 r-?)
2138 Unealn Stet
P. 0. Box 1323
Willi- -or- PA 17703
(57o)326-ims7
FAY (570) 32^_-2197
Fa ( _
Commission an Eeococria Oppor..iaie? of Luz erne Couar•
163 Amber Lane
Willtes-Bare. PA 16702
(5-,0)826-)5( O or (500) 322-0359
FAY (570) 329-1665-CALL BF-OR. Fs.?G
(570) 455-4994 r 4Z.LTON
F•?Y (5'0) 455-5'631-CALL B270R. FA?vG
r:-1n a35-4090 TL-' era:. -,4- CK
CLLNTON C0U,% "f
CCCS of Nor-haastern PA
1631 S A er.on St
Suite 100
State College. PA 16EGI
(814) °-384666a
FAX (814) 238.3669
CCCS of Nformheaste z ?A
201 Basin SCeec
Williamsport, PA 17703
(570) 323-662-
FAX (570) 323-a 625
COLUMBIA COL_ T`.'
CCCS of`;or_4eaetern Pennsvivacia
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1400 Abiag'aa ??eraeve ?a:
31 W. Market Sreet
^ Suite 1 is PA 1341'_
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FOB 11
Wiikes-Bare. Pa 15'02 ar
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(570) 53-, .9163 or (800) 922.953'
(570) 821-083' or 1800) 922.953' FAY (570) 58'•913419'_35
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Booker T. Washing-sr. Center
1720 Holland Street
Ere, PA 16503
(814) 453-5744
F.•1:{ (914) 453-5'49
John F. F{ nnedy Center, Inc.
2021 East 20th': Street
Ere, P.A. 16510
(814) 896-04Co
(814) 898-L243
CCCS of Wesre3 ?ennsylvaaia, Inc.
2000 Linglestaarn ?toad
P-,r.-sbur3, PR 1710^_
(71') 541-1757
Urban League of,
N. 6t-4 S=Let
F.ar.'sbu g, PA 17'01
(711) 234-5925
FAX ('17) 234-9459
CRAWFORD CUUNl r
Grearer E^e Cocmuni:/ Aet(or- Coc^i:xe
18 West 9th Steec
F -.-'.e, PA 16501
(814) 459-4581
FAY (814) 456-0151
She,90 IhUe-v Urban League, T=c
601 lndiana Avenue
Farrell. PA 161^1
(412)981.5310
CUV BERL4`iD COLNTY
tt?
F(nancal Counseling Serrices of ?364446
31 West 3rd Street
Waynesboro. P.66 1-,268
(717) 762.3285
Com^u--r,Action Aeon Com-•a of the Capital Region
1514 Derv; Street
Farrsbu-g PA 17104
(717) 232-9757 ?/ D
FAY (717) 224-222" r/?HIBIT A'
YWCA of Carlisle
301 G Street
Carlisle. PA 17013
(717) 243-3818
FAX (717,) 731.9589
le St
SY E3329 ausiag Author-rr
17325
??-(, PENNSYLVANIA SULLE31N, VOt_ 29, NC. 21, JUNE 4 1999
ALL that certain lot of ground situate in silver spring
Township, Cumberland County, Pannsylvania, being Lot No. 5 on n
Subdivision Plan praparsd for Ceo.go =to M. Crone by Whitlock and
Hartman, Reg_starod Engineers, and recorded in the O£fieo of the
Recorder of Deeds for Cumbarland County in Plan Book 60, Pogo 130,
bounded and described as follows:
OEOINNING at a, point on the Wcatern side of Old Willow .1111
Read, as it npooars on said Plan, which point is also on the dividing
line between Lets Nos. 4 and 5 on said Plan; thence along said dividing
line, North 79 degrees 25 Minutes West 402.72 feet to a paint: thoncp
continuing along said dividing line,
scconds East 316 North 2 degrees 43 minutes 40
.86 feet to a paint on line o£ land now or formerly of
Ernes_ C'-awscr, Sr., and Nell L. Clawser, his wife; thence along said
line Of Clawscr, South 89 degrccs 17 minutes 40 scuonds West 370.03
feet to a point in lino Of land now or formerly of David Thumna ffr_irs;
thence along said
407.76 land of Thurna ffoirs, South a degrees 6 minutes west
foot to a Point in line of oraoarty now or formerly Of lay H.
East thence along said land of Smith, North 82 8egrecs 43 minutes
Smistth, , South feet to a point: thence continuing along said land of
79 degrees 25 minutes East 490,25 feet to a Point on the
Western r-.3ht-of-way lino of Old Willow Mill Road; thence a:.Onc7 said
Western right-of-way line, North 21 degrees 45 minutes 20 seconds East
a distance of 75 feet to a point on the dividing line between rats
Nos. 4 and 5 of said Plan, the Place of BEGINNING.
CCNTA1N7NC 177,817.94 snuare foot, 4.0821 acres. Together with
the right to use a 25 foot wide right-of-way across the Northern
portion of Lot No. 4. the center line of which continues along tho
dividing line between Lots Nos. 2 and 4 and Lots Nos. 2 and 3 on the
Subdivision Plan to the Western side of Old Willow Mill Road.
PREMISES: 1311 OLD WILLOW MILL
VERIFICATION
TERESA SWITZER hereby states that she is SECOND VICE-PRESIDENT of PNC
MORTGAGE CORP. OF ANIERICA mortgage servicing agent for Plaintiff in this matter, that
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 her knowledge, information
and belief. The undersigned understands that this statement is made subject to the penalties of IS
Pa. C.S. Sec. 4904 relating to unswom falsification to authorities.
TERESA SWITZER
DATE: I -(I 1 - 't 2nd VICE PRESIDENT
T
J. 1:a
FEDERMAN AND PHELAN
BY: FRANK FEDERMAN, ESQUIRE
Identification No. 12298
Two Penn Center Plaza, Suite 900
Philadelphia, PA 19102
(215) 563-7000
PNC BANK, N.A., S/B/M TO THE
FIRST BANK AND TRUST COMPANY
Plaintiff
VS.
RALPH CHARLES CRONE
SANDRA L. CRONE
Defendants
Attorney for Plaintiff
. COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
No. 99-7175-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, SQUIRE
Attorney for Plaintiff
Date: January 11, 2000
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FEDERMAN AND PHELAN
BY: FRANK FEDERMAN, ESQUIRE
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
PNC BANK, N.A. S B/COb1 O THE
FIRST BANK AND TRUST Plaintiff
Vs.
RALPH CHARLES CRONE
SANDRA L. CRONE
Defendant(s)
Attorney for Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-7175-CIVIL
VERIFICATION
I hereby certify that a true and correct copy of the Civil
Action Complaint in Mortgage Foreclosure in the above captioned
matter was sent by regular and certified mail, return receipt
requested, to the following persons, to SANDRA L. CRONE at 1311
OLD WILLOW MILL ROAD, MECHANICSBURG, PA 17055 on JANUARY 21. 2000,
in accordance with the Order of Court dated DECEMBER 29, 1999.
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.
FRANK FEDERMAN,ESQUIRE
Attorney for Plaintiff
I?
.r
DATE: January 21. 2000
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PROOF OF PUBLICATION
State of Pennsylvania,
County of Cumberland.
Sherry Clifford, Classified Advertising Manager of THE SENTINEL,
of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of
general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th,
1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice
or publication attached hereto is exactly the same as was printed and published in the regular editions and
issues of THE SENTINEL on the following dates, viz
Copy of Notice of Publication
mum P"Au up "
COUNTY, PENNSYLVANIA
L ACTION•LAW
99.7175-CIVIL '
TOTHE:'.,, : , . -
T .COMPANY, Plaintiff
tE and FENDANTS
NOTICE'
RONE AND SANDRA L.rCRONE- - ? ?
ber2g,1999, Plaintiff,
'BANK AND TRUST
d Complaint endorsed
to Court of Common
ylvanla, docketed to
ke to foreclosure Its '
led, 1311 OLD -
TO, PA 17055 where-
Sheriff oC
above referenced
fte of this publication
1101 inE; youmust
by edt. andfile -
i the court: You are
lair proceed without
lose
Ord one. gb to or telophone the
where you can get legal help.
:
ID COUNTYr>-- ".. q
EAR ASSOCIATION -. 1
AVENUE
PA 17013
9.3166
January 21, 2000
Aff iant further deposes that he is not interested in
the subject matter of the aforesaid notice or
advertisement, and that all allegations in the
foregoing statement as to time, place and character
of publication are true.
Jant:I&y 26, 2000
Sworn to and subscribed before me this 26th
day of Jannuaarry? , 2000
Notary Public
Con:,naa:a . B My commission expires:
A19102 - NOTARIAL SEAL
' I SHIRLEY 0. DURNIN. tluiary Public
Carlisle Eoro., Cunha. i:. -,: !'-.,,U
ldyCommilsiJn Exriir?.!;: ••r
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
JANUARY 28, 2000
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that lie is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
28 day of_JANUARY, 2000
rv IARLALSEAL
LOIb E. SNYDER. Nomry Pobk
CadiA, Barn, Ccrnberi,,.J CouMY, PA
My CoV??mi,paa Ez; i'" !.larch S, 2Go 1
41 -
i
NOTICE OF ACTION IN
MORTGAGE FORECLOSURE
In the Court of Common Pleas of
Cumberland County. Pennsylvania
Civil Action-Law
No. 99-7175-Civil
PNC BANK. N.A.. S/B/h1
TO TIIE FIRST BANK AND
TRUST COMPANY.
PLAINTIFF
RALPH CHARLES CRONE and
SANDRA L. CRONE.
DEFENDANTS
NOTICE
TO: RALPI I CHARLES CRONE AND
SANDRA L. CRONE:
You are hereby notified that on No-
vcmbcr 29. 1999. Plaintiff. PNC
BANK. N.A., S/B/M TO THE FIRST
BANK AND TRUST COMPANY. filed a
Mortgage Foreclosure Complaint en-
dorsed with a Notice to Defend,
against you in the Court of Common
Pleas of CUMBERLAND County. Penn-
sylvania, docketed to No. 99-7175-
CML, wherein Plaintiff seeks to fore-
close its mortgage secured on your
property located. 1311 OLD WILLOW
MILL ROAD. MECHANICSBURG. PA
17055 whereupon your property
would be sold by the Sheriff of CUM-
BERLAND County.
You are hereby notified to plead to
the above referenced Complaint on or
before 20 days from the date of this
publication or a Judgment will be
entered against you.
NOTICE
You have been sued In Court. If
you wish to defend. you must enter
a written appearance personally or
by attorney. and file your defenses or
objections In writing with ilia court.
You are warned that if you fall to do
so, the case may proceed without you
andjudgnnent maybe entered against
you without further notice for the
relief requested by the Plaintiff. You
may lose money or property or other
rights Important to you.
You should take this notice 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 hall).
CUMBERLAND COUNTY
CUMBERLAND COUNTY
BAR ASSOCIATION
2 Liberty Avenue
Carlisle. PA 17013
(717) 2493166
FRANK FEDERMAN
FEDERMAN AND PHELAN
Attorneys for Plaintiff
900 Two Penn Center Plam
Philadelphia. PA 19102
(215) 563-7000
Jan. 28
Cumberland Notices
}
h
v.- fJ
FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
Attorney I.D. No. 12248
Suite 900 - Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
Attorney for Plaintiff
PNC BANK, N.A., S/B/M TO FIRST
BANK AND TRUST COMPANY
Vs.
. COURT OF COMMON PLEAS
CIVIL DIVISION
. CUMBERLANDCOUNTY
No. 99-7175-CIVIL
RALPH CHARLES CRONE
SANDRA L. CRONE
AFFIDAVIT OF SERVICE BY
PUBLICATION IN ACCORDANCE WITH COURT ORDER
I hereby certify that service of the Civil Action Complaint
in Mortgage Foreclosure was made in accordance with the attached
Court order dated DECEMBER 29.
By publication as provided
in THE SENTINEL on JANUARY 21
COUNTY LAW JOURNAL on JANUARY
publication is attached hereto.
The undersigned understai
1999 as indicated below:
by Pa. R.C.P. Rule 430(b)in
2000 and in THE CUMBERLAND
28. 2000 Proofs of said
ids that this statement is made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
FRANK FEDERMAN, ESQUIRE
iarV 16, 2000
-_
s _.
•?
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
PNC Bank, N.A. s/b/m to The First Bank
and Trust Company
539 South Fourth Street
Louisville, KY 40202
Plaintiff
Vs.
Ralph Charles Crone
Sandra L. Crone
1311 Old Willow Mill Road
Mechanicsville, PA 17055
Defendant(s)
Attorney for Plaintiff
: Cumberland COUNTY
:COURT OF COMMON PLEAS
: CIVIL DIVISION
NO. 99-7175 Civil
PRAECIPE FOR JUDGMENT FOR FAILURE. TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against Ralph Charles Crone and
Sandra L. Crone, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20
days from service thereof and for foreclosure and sale of the mortgaged premises, and assess
Plaintiffs damages as follows:
As set forth in Complaint
Interest 11/1/99 to 3/3/00
$94,593.17
$2.648.64
TOTAL
$97,241.81
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above,
and (2) notice has been given in accordance with Rule 237.1, copy attached.
Vrl?
F NK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED r DATE: •? d ?Ca PRO PROTHY
••THIS FIRM IS A BF:nT COI.I.F.CTOR Al-FF.NIPTING'ro Ce1.I.F.CrA DEBT AND ANV INFORNIATION OBTAINED WILL BE
tISED FOR TRAT PURPOSE- IF YOU HAVE. PREVIOUSLY RF.CF.IVF:II A UISCIIAHGF IN IL\NERIII'TCY .\ND TIIIS DEBT WAS
NOT REAFFIRNIED. TIIIS CORRESPONUNCF. IS NOT AND SIIOOLD NOT RF_ CONSTRI IED TO [IF, AN ATFF.NI"TO COLLECT
A DEIIT. Illfr ONI.Y EN'F'ORCE V ENT OF A I.IEN AGAINST 1'i((11'Fltf l'. •.
FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
PNC BANK, N.A., S/B/M TO THE
FIRST BANK AND TRUST COMPANY
Plaintiff
VS.
RALPH CHARLES CRONE
SANDRA L. CRONE
Defendant(s)
TO: RALPH CHARLES CRONE
1311 OLD WILLOW MILL ROAD
MECHANICSBURG, PA 17055
DATE OF NOTICE: FEBRUARY 18. 2000
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-7175-CIVIL
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 IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN
AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12245
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
PNC BANK, N.A., S/B/M TO THE
FIRST BANK AND TRUST COMPANY
Plaintiff
VS.
RALPH CHARLES CRONE
SANDRA L. CRONE
Defendant
TO: SANDRA L. CRONE
1311 OLD WILLOW MILL ROAD
MECHANICSBURG, PA 17055
DATE OF NOTICE: FEBRUARY 18, 2000
ATTORNEY FOR PLAINTIFF
COURT OF COHMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-7175-CIVIL
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 BANKRUPTCY, THIS CORRESPONDENCE IS
NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A
DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROEPRTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE. PA 17013
(717)249-3166
Frank Federman, Esquire
Attorney for Plaintiff
FEDERMAN AND PHELAN
BY: Lisa D. Blankenburg, Esa.
Atty. I.D. 478020
Ste. 900/Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
PNC BANK, N.A.,
S/B/M TO FIRST BANK AND TRUST COMPANY
VS.
RALPH CHARLES CRONE
SANDRA L. CRONE
. i.
DECz719 :.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
No. 99-7175-CIVIL
ORDER L1
AND NOW, this day of DecembeR 1999, upon
consideration of Plaintiff's Motion and the Affidavit of Good Faith
Investigation attached thereto, it is hereby ORDERED that Plaintiff
may obtain service of the Complaint on the above captioned
Defendant(s), SANDRA L. CRONE, by mailing a true and correct copy
of the complaint by certified mail and regular mail to the
defendant's last known address and to the mortgaged premises at
ubl?ca?ion
P
_ 1311 OLD WILLOW MILL, MECPAMICSBURG, PA 17055 O-n? by once
In the LljLmoerland. Law Journal and %n a newspapeR o F general. Circt ?4i on 'i n
Service of the aforementioned mailings is effective upon the Ce berla
r
date of mailing and is to be done by Plaintiff's attorney, who will
file with the Prothonotary's office an Affidavit as to the mailing.
BY THE COURT:
J
SFER_C:'S .mac :'ij,:N
CASE N0: 1999-07175 P
COMM(`NWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NA
v5.
CRONE RALPH CHARLES
CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon CRONE RALPH CHARLES the
defendant, at 14:08 HOURS, on the 1st day of December
1999 at 1311 OLD WILLOW MILL ROAD
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to RALPH C. CRONE
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
S
18.00
6.20
.8.00
$32?U---FEDERM1
b
Sworn and subscribed to before me
this day of
19 A.D.
rro nono ary
FEDERMAN and PH ELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000 Attorney f'or Plaintill'
PNC Bank, N.A. s/b/m to The First Bank : Cumberland COUNTV
and Trust Company
Court of Common Pleas
Plaintiff
: CIVIL DIVISION
vs.
Ralph Charles Crone
Sandra L. Crone
Defendant(s)
: NO. 99-7175 Civil
VERIFICATION 017NON-NI11,1TARY SERVICE.
FRANK FEDERMAN, ESQUIRI's, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the
following facts, to wit:
(a) that the defendant(s) is/arc not in the Military or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act
of Congress of 1940, as amended
(b) that defendant Ralph Clutrles Crone is over 18 years of age and resides at 1311
Old Willow Mill Road, Mechanicsville, PA 17055.
(c) that defendant Sandra L, Crone is over 18 years of age, and resides at present
whereabouts unknown.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unswom falsification to authorities.
FRANK FEDERMAN
Attorney for Plaintiff'
(Rule of Civil Procedure No. 236 - Revised)
PNC Bank, N.A. s/b/m to The First Bank : Cumberland COUNTY
and Trust Company
Court of Common Pleas
Plaintiff
CIVIL DIVISION
VS.
Ralph Charles Crone
Sandra L. Crone
Defendant(s)
NO. 99-7175 Civil
Notice is given that a Judgment in the above captioned matter has been entered against you on
March (91" , 2000.
13y DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN, ESQUIRE
Attorney for Filing Party
SUITE 900
TWO PENN CENTER PLAZA
PHILADELPHIA. PA 19102
(215) 563-7000
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORDIATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT
AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
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