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Home My WebLink About07-4765GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF CITIFINANCIAL SERVICES, INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 Plaintiff vs. SUSAN M. HARPSTER Mortgagor and Real Owner 806 16th Street New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Defendant Term COY No. a7' l/710.5~ 1 NOTICE CIVIL ArtC~TION~A~C?RT~Ar~~ You have been sued in court. If you wish to defend against the cl~~P-s's~el"fom~ the following pages, you must take action within twenty (20) days after the Complaint and notice aze 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 maybe entered against you by the Court without further notice for any money claim in the Complaint of 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 5ET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDE~SE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTEDI RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARR DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, 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 PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THI5 FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TQ COLLECT Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(c~goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Nulmber of 55239FC. Para information en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is CITIFINANCIAL SERVICES, INC., 1111 Northpoint Drive, Building 4, Suite 100 Coppell, TX 75019. 2. The names and addresses of the Defendant is SUSAN M. HARPSTER, 806 16th Street, New Cumberland, PA 17070, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On November 28, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to CITIFINANCIAL SERVICES, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1975, Page 5047. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are. matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule o£ Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for April 10, 2007 and each month thereafter and by the terms the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$125,314.39 Interest from 03/10/2007 through 08/31/2007 at 10.5000% .....................$6,272.70 Per Diem interest rate at $36.05 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$6,265.72 Late Charges from 04/10/2007 to 08/31/2007 .............................................$:573.14 Monthly late charge amount at $114.63 Costs of suit and Title Search ......................................................................$900.00 Appraisal ......................................................................................................$225.00 $139,550.95 7. If the Mortgage is reinstated prior to a Sheriff s Sale, the Attorney's Fees set forth above maybe less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excels of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" juldgment) against the Defendant in this Action but reserves its right to bring a separate Action to esti~blish that right, if such right exists. If Defendant has received a discharge of their personal liability in; a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant 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 through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. 10. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $139,550.95, together with interest at the rate of $36.05, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: t ~ - ' ~ ~I'`-~=- Cam. D CK McCAFFERTY & McKEEVER BY: 70SEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Frankie Ward, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: ~ ~' ~~ ~ ~ #2000510257153 -SUSAN M. HARPSTER E~Fii6itA Finiti Settlement, LLC .0(:` . TITLE SEARCH REPORT f 111111 Order N :6278075 EXHIBIT A ALL THAT CERTAIN PARCEL OF LAND IN BOROUGH OF NEW CUMBERUWD ,CUMBERLAND COUNTY, COMMONWEALTH OF PA, AS MORE FULLY DESCRIBED IN BOOK 126 PAGE 881 IDN 28-23-0543-559, BEING KNOWN AND DESIGNATED AS LOT N0.9 PLAN OF LOT$ LAID OUT BY ELMER E. ZIMMERMAN, FILED IN PLAN BOOK 2 AT PACE 20,AND MORE PARTICULARLY DESCRIBED AS A METES AND BOUNDS PROPERTY. BEING THE SAME PROPERTY CONVEYED BY FEE SIMPLE DEEQ FROM ROMAINE E, VALPE, EXECUTRIX OF THE LAST WILLAND TESTAMENT OF RUTH E. DONICKER, DECEASED TO SUSAN M. HARPSTER WA , DATED 08H0/1995 RECORDED ON 08J18/1995 IN BOOK 126PAG~ 861 IN CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PA. c~eneraeed: »n5noo6s:5aa~ Pepe 7as E~Fii6it ~ 38-0041-0204594 REPRESENTATION OF PRINTED DOCUMENT 7107 8381 6540 0508 1657 11110 000005 SUSAN M HARPSTER 806 16TH STREET NEW CUMBERLAND PA 17070 RE: CitiFinancial Loan#: 38-0041-0204594 Property Address: 806 16TH STREET NEW CUMBERLAND PA 17070 ACT 91 NOTICE DATE OF NOTICE: June 17, 2007 TAKE ACTION TO SAVE YOUR HOME FROIV~ FORECLOSURE The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to help to save vour home. Thts Notice exnlams how the nroeram works when you meet with 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 any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de soma importancia, pues afecta su derechb a continuar viviendo en su casa. Si no comprende el contenido de esta notification ! obtenga una traduccion immediatamente llamanda esta agenda (Pennsylvania Housing Figance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prt#stamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program"', el coal puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: CITIFINANCIAL SERVICES, INC. 1VALLEY STREET CARLISLE PA 17013 INTERNET REPRINT n,e,oo emu.. ~a.~ ~ ~ i i~ i ov-~ ooy. ~ 38-0041-0204594 REPRESENTATION OF PRINTED DOCUMENT Date: June 17, 2007 Homeowners Name: SUSAN M HARPSTER Property Address: 806 16TH STREET NEW CUMBERLAND PA 17070 Loan Account No.: 38-0041-0204594 Lender/Servicer: CITIFINANCIAL SERVICES, INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE 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. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO C LURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with Otte of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone {cumbers of designated consumer credit counselin a encies for the coup to which the roe is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise youur lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the ttature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a INTERNET REPRINT A78701 38-0041-0204594 REPRESENTATION OF PRINTED DOCUMENT complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 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 yon can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brinc it up to date). NATURE OF THE DEFAULT -The Mortgage debt held by the above lender on your property located at: 806 16TH STREET, NEW CUMBERLAND PA 17070 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments (including late charges) from 04/10/07 through present. (b) Other charges; Escrow, Inspections, NSF Check (c) TOTAL AMOUNT OF (a) and (b) REQUIRED AS OF THIS DATE $3660.76 HOW TO CURE THE DEFAULT - You may cure the default withinTHIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS 53660.76 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 or money order made payable and send to CITIFINANCIAL SERVICES, INC.,1 VALLEY STREET,CARLISLE PA 17013 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its riehts to accelerate the morteaee debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your morteaeed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings aze started against INTERNET REPRINT n~aroz 38-0041-0204594 REPRESENTATION OF PRINTED DOCUMENT you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which max also include other reasonable costs. If you cure the default within the THIRTY (301 DAY nerinA_ vnu will not h OTHER LENDERREMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, ou still have the right to cure the default and prevent the sale at anv time up to one hour before the Sheri~f's Sale You may do so by pavin¢ the total amount then east due, plus anv late or other charges then .due reasonable attomev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing anv other reauirements under the mort~,aee. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately four (4) to six (61 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CITIFINANCIAL SERVICES, INC. Address: 1 VALLEY STREET CARLISLE PA 17013 Phone Number: 717-249-9566 Contact Person: BRANCH MANAGER EFFECT OF SHERIFF'S SALE -You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges :and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. INTERNET REPRINT 818703 38-0041-0204594 REPRESENTATION OF PRINTED DOCUMENT YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. If you are represented by an Attorney, please refer this letter to such Attorney and provide us with such Attorney's name, address and telephone number. To the extent your obligations have been discharged, or are sulhject to an automatic stay of bankruptcy order under Title 11 of the U~Iited States Code, this notice is for compliance and informational purposes only and does not constitute a demand for payment or any attempt to collect any such obligation. INTERNET REPRINT A187oa 38-0041-0204594 REPRESENTATION OF PRINTED DOCUMENT PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INC. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLTI'AN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 INTERNET REPRINT n~niz ~~ °~ ~, r-? C~ c.~ Cyr __, ..~.,.A i' .~-- ', ~,.._~ (s~ ~ _. x' ". : C 7 . r ..~fE~ , .Y ~__ , ~ .,,.. SHERIFF'S RETURN - REGULAR CASE NO: 2007-04765 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL SERVICES INC VS HARPSTER SUSAN M MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE HARPSTER SUSAN M was served upon DEFENDANT the at 1525:00 HOURS, on the 16th day of August 2007 at 806 16TH STREET NEW CUMBERLAND, PA 17070 by handing to SUSAN HARPSTER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 16.32 Affidavit .00 Surcharge 10.00 .00 $~,~, ~~~~ ~ 4 4 . 3 2 Sworn and Subscibed to before me this day So Answers:''ff~~ I %~ R. Thomas Kline 08/20/2007 GOLDBECK MCCAFFERTY MCKEE R By: Deputy Sheriff of A.D. • ' GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 Attorney for Plaintiff CITIFINANCIAL SERVICES, INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 Plaintiff vs. SUSAN M. HARPSTER 806 16th Street New Cumberland, PA 17070 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Docket No. 07-4765 CNIL PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. JOSEPH A. GOLDBECK, JR., ESQUIRE ~ c°~ ~~.- .w :~r~ ~ r-- !"7-, ~.r ~, ..., .: , ..... ,,'t -`1 ~ f