Loading...
HomeMy WebLinkAbout99-00015 ~. . (e' 4 1 ' _, S ' ,. ~ _~ ~ ~ , ~ ~. ~^'-, - ~J r ~ .V .- ,~ .,y„ ., J ~, ,_ ~,. } ,; ,, ~: , <<, ~ m ~ •, •~ ? ~ Jo y . ~ /~ ^C -._. v ~~~ a ,~ zz T ~K d 2 °' 4 U .tsi 4p~ja v~ p O,Mi i~h ~~~n~ FEDERMAN AND PHELAN By: FRANIK FEDERMAN, ESQUIRE IDENTIFICATION N0. 12248 TWO PENN CENTER PLAZA, SU1TE 900 PHILADELPHIA, PA 19102 12151 56 ~-~ nQ4_~___.- CITICORP MORTGAGE, INC. MAIL STATION 314 P,O, BOX 790014 3T. LOUIS, MO 63179-0014 v. Plaint.ifE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM ~J ~.. 0 N0. ~` ~S 1....L~ CUMBERLAND COUNTY NELSON DAMSCHRODER ETHEL DAMSCHRODER 311 ERFORD ROAD CAMP HILL, PA 17011 Defendant(s) CIVIL ACTION - LAW $1~RTOA(iE FORECL08URE 0 CE THIB I8 AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BF. UBED FOR THAT PURP08E. You have been sued in Court. If you wish to defend against the olaims 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 pe.rsonal.ly or by attorney and fi19.ng 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 olaim 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 TELEFHONE T'!E OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND CUUNTY AAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 1'%013 (717) 249-3166 1. Plaintiff is CITICORP MORTGAGE, TNC. MAIL STATION 314 P.O. BOX 790014 ST. LOUIS, MO 63179-0014 2. The name(s) and last known address(es) of the Defendant(s) are NELSON DAMSCHRODER ETHEL DAMSCHRODF.R 311 ERFORD ROAD CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter. described. 3. On 7/29/AA mort.gagor(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. 912, Page 1170. 4. The premises subject to said mortgage is described as attached. 5. The mortpage is in default hecause monthly payments of principal and interest upon said mortgage due 9/1/9A 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. Tha following amounts are due on the mortgagee Prinoipal Balance $53,053.99 Interest 1,884.14 8/1/98 through 12/1./98 (Per Diem $15.44) Attorney's Fees 2,G52,U0 Cumulative Late Charges 174.21 7/29/sa to 12/1/9a Cast oY suit and Title Search 550.GU Subtotal ~$~_14.34 .Escrow Credit 229.92 Deficit, app Subtotal 22 9.92 T9TAL $58~p8A.~2 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be oolleoted 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, Thia action does not come under Act G of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated beoauae either: (i) Defendant(s) have failed to meat with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit uBn~ or (11) pefendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. ,: lOr Pursuant to the Fair Debt Collection Practices Act, l& U.B.C. S 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 reoeipt 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 h for Plaintiff will Bond Defendant(s) the name and ~ address of the original rreditor if different from ;.' above. WHEREB'ORE, PLAINTIFF demands an ~ rem .judgment against the Defendant(s) in the sum of $58,n84.42, together with intsrest from 12/1/98 at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collect.ibl.e under the mortgage and for the foreclosure and sale of the mortgaged property. /s/dank Federma~ FRANK FEDERt4AN, ESQUIRE Attorney for Plaintiff REs Property; 31.1 Ertord Road Camp Hill, PA 17011••1169 Loan Nei 0009606559 Mortgagee; F.H.L.M.C. Date; 11/03/98 TOs Ethel Damachroder 311 Ertord Rd Camp Hill PA 17011-1168 NOTICE OF INTENTION TO FORECLOSE MORTGAGE under Section 403 of PA Act No, 6 of1974. (READ ALL PAGES OF THIS NOTICE CAREFULLY) Citicorp Mortgage, Inc, is providing this notice as Lender or servicing agent for the tender. The MORTGAGE held by the above name MORTGAGEE (hereinafter we, us, or ours) on your property noted above under REi, I9 IN UEFAULT because you have not made the monthly payments ae noted below under (a), Previous late charges under (b), if any, have also accrued to this date. THE TOTAL AMOUNT NOW REQUIRED TO CURE THIS DEFAULT IS $4,135.84, INCLUDING $116.14 IN LATE C}IARflE9 I9 NOTED BELOW UNDER (c). 1a) 09/01/98 thru it/01/98 3 ® $1,339.90/month 2 ® $58,07/late charge/month $4,135,84 (b) previous late charge(s) $0,00 (c) TOTAL AMOUNT (a)+(b) kEQUIRED AS OF TI•IIS DATE: $4,135.84 You may cure thin default by 12/03/98 (or the next business da}' thereafter if 12/03/98 is a Saturday, Sunday, or Federa]. Holiday) by paying to us the amount under (c) above. Any additional payments and late charges that. fall due during this period must also be paid to bring your loan current, Such payment must be made either by CASH, CASHIER'S CHECK, CERTIFIED CHECK, UR MONEY ORDER made payable to Citicorp Mortgage, Inc „ 15851 Clayton Road, Ballwin, Missouri 63011. If you do nor. cure the default by 12/03/98, are intend to exercise our right to accelerate the mortgage payments. This means that whatever is awed on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made by 12/03/98, we also intend to instruct our attorneys to start a lawsuik to foreclose your mortgaged property, If the mortgage is foreclosed, your mortgage property will be sold by f.he Sheriff to pa}' off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal prooeedings against you, you will still have to pay the reasonable attorney's fees actually incurred up to $50.00. A~ RE: Propsrtyi 311 Erford Road Camp Hill, PA 17011-1168 Loan No: 0,00960b559 Mortgagee: F.H,L.M,C. Data: it/03/98 Ttl~ Nelson Damachroder 311 Erlord Rd Camp Hill PA 17011-1168 NOTICE OF INTENTION TO FORECLOSE MORTOAtlE under Section 403 oP. PA Act No. 6 of 1974, (READ ALL PAtlE9 OF THIS NOTICE CAREFULLY) Citicorp Mortgage, Inc. is providing ttrie notice as Lander or servicing agent for the Lender. The MORTGAOE held by the above name MORTCiACEE (hereinafter we, us, or ours) on your propert}` noted above under RE:, I9 IN DEFAULT because you have not made rite monthly payments as noted below :order (a). Previous lace charges under (b), if any, have also accrued to this date. THE TOTAL AMOUNT NOW REQUIRED TO CURE TNIS DEFAULT IS $4,135.84, INCLUDINtl $l1b.19 IN LATE CHAP.OE9 I9 NOTED BELOW UNDER (cl. (a) 09/01/98 thru 11/01/98 3 O $1,339.90/month 2 ® a"58.07/late charge/month $4,135,84 Ib) Previous late charge(s) .$0,00 (c) TOTAL AMOUR+1` (a)+(b) REQUIREA AS OF PHIS llATE: $4,135.84 You may cure this default by 12/03/98 (or the next business day thereafter if 12/03/98 is a Saturday, Sunday, or Federal Holiday) by paying to us the amount under (c) above. Any additional payments and late charges that fall due during this period must also be paid to bring your loan currant, Such payment muvt be made either by CASH, CAS}TIER'S CHECK, CERTIFIED CHECK, OR MONEY ORDER made payable to Citioorp Mortgage, Inc., 15851 Claykon Road, Eallwin, Missouri 53011. If you do not cure the default by 12/03/98, we intend to exercise our right to accalsrate the mortgage payments. This means rites whatever is owed on the original mortgage amount borrowed will be considered due immediately, and you may loso the chance to pay off the original mortgage in monthly installments, If. full payment of the amo:ant of the default is not made by 12/03/95, we also intend to instruct our attorneys to start a lawsuit to foracloae your mortgaged property. If the mortgage is foreclosed, youx mortgage property will be sold by the Sheriff to pay pff the mortgage debr_, If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable .attorney's fees actually Incurred up to $50.00. EXHIBIT A Page Two 1.1/03/98 0009406559 However, it legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00, Any attorney's tees will be added to whatever you owe us, which may also include our reasonable costa. If you aura the default by 12/03/98, you will not be required to pay attorney's fees. Also, we may sue you personally for the unpaid principal balance, and all other soma due under t:he martgaga. IL you have not cured the default by 12/03/98,and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do eo by paying the total amount of the unpaid monthly payrnanes plus any late charges, charges than dun, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER, A notice of the date of the Sheriff's sale will be sont 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 will be by calling us at the following number: 1-800-374-8814. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property, YOU HAVE THE RIGHT TO SELL TtIE PRUPERI'Y TO OBTAIN MONEYTO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY RAVE THE RIGtIT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES, ATTORNEY'S FEES, AND COSTS ARE PAID PRIOR T0, OR AT THE SALE (AND THAT OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WFU1T CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTYACTING ON YOUR BEHALF. EXHIBITA Page Three 11/03/9A 0009606559 Under IR& regulation, we moat report any Loreelo6ure to the IR9 on form 1089-A. The foreclosure may xeeulp in income tax conrequencee to you. Coneulk the IR8 or your tax advisor for further information. IL your delinquency le a result of a lose of employment income or a reduction in employment income you may ba eligible for homeownership oounseling from one of the Departrnent. of Housing and Urban Development approved homeownership counseling agencies, Please call. us at 1-800-374-8814 Lor information regarding the HUD-approved counseling agency nearest you and/or to discuss the circumstances of the default with one of our loan Counselors. If you cure the default, the mortgage will ba restored Co Che same position ae if no default has occurred. However, you are not entitled to this right to cure your default more than three (31 times in any cnlendar year. EXHI[31TA li/03/98 E1'HEL DAMSCHRODER 311 ERFORD RD CAMP HILL PA 17011-1168 RE: ACCOUNT N. 0004606559 Prom: CITICORP MORTGAGE, INC. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennaylvania'a Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the following notice to Find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at 1(800) 342-2397. La notification en adjunto ea de auma importancia, puss afecta su derecho a continuer viviendo en au Casa. Si no comprande el contenido de Bata noti.ficacion obtenga una traduccion immadiatamente llamanda eats agenda (Pennsylvania Housing Finance Agency) sin cargos al numero mencienado arriba. Puedes aer eligible pare un prestamo por el programs llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salver au case de la perdida del derecho a redimir au hipoteca. ACT' 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE, YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS, You may be eligible for financial assistance that will prevent foreclosure on your mortgage 1E you comply with the provisions of the Homeowners' Emergency Mortgage Aasistanoe Act of 1903 (the "Act°). You may be eligible for emergency temporary assistance if your default hoe been caused by circumstances beyond yqur control, ycu have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finanee Agency. EXHIBIT B ,1 1?./03/98 NELSON DAMSCHRODER 311 ERFORD RD CAMP HILL PA ].701]-1.163 RE: ACCOUNT N: 0009606559 Fromi CITICORP MORTGAGE, INC.. ACT 91 NOTICE TAKE F.CTFON TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works, If you need more information call the Pennsylvania Housing Finance Agency at 1(800) 3h2-2397. La notificacion en adjunto es de sums importancia, puss afecta au derecho a continuer viviendo en su case. Si no comprende el contenido de seta notificacion obtenga una traduccion immediatart:ente llamanda Bata agancia (Pennsylvania Housing Finance Agency) sin cargos al numero mancionado arriba. Puedes ser eligible pare un prestamo per el programs llamado "Homeowner"s Emergency Mortgage Assiistance Program" el cual pueda salver au case de la perdida del derecho a x•edimj•r su hipoteca. ACT 91 NOTICE IMPORTANT: NOTICE OF k16MGOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE F.LIGTBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YUUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. You may be eligi6la for financial assistance that will prevent foreclosure on your mortgage if you comply wikh the provisions of the ' Homeowners' Emergency Mortgage Assistance Act of 1903 (the "Act"), Ycu may he eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by Che Pennsylvania Housing Finance Agency. EX~lB1Te ..,. . Page Two 11/03/98 0009606559 Please read aL7. of this Notice. It oontaine an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage Los thirty (30) days from the date of this Notice. During that limo you must arrange and attend a "fans-to-Lace" meeting with a representative of this lender, or with a designated consumer credit counseling agency, The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency, This meeting must occur in the next thirty (30) days. If. you attend a face-to-face meeting with this lender, or with a consumer credit. counseliny agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of. this meeting. The name, address and the telephone number of our representative iai Citicorp Mortgage, Inc, P.O. BOX 790005, M.S. 305 St. Louis, Missouri 63179-0005 Telephone Number: 1-800-374-8814 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheeC. It is only necessary to schedule one face-to-face meeting, You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days, The total amount of the delinquency is $9,135.84, including $116.14 in late charges. That sum includes the following.: payment(s) due on 09/01/98 Through 11./01/98 each in the amount of $1,339.90 and late charges of $116.19, If you have tried and are unable to resolve this problem at or after. your face-to-face meeting, you have the right to apply for financial assistants from the Homeowners' Emergency Mortgage Assistance Fund, In order to do this, you must fill out, siyn and file a completed Homeowners' Emergency Assistance application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency, The consumer credit counseling agency will. assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be, tiled or postmarked, within thirty (30) days oP your face-to-face meeting. EXHrBiTg Page Three 11/07/98 0009606559 It io exY.remaly important that you file your applicstion promptly, If you do not do ro, or if you do not follow the other time periods set forth in thi^ letter, foreclosure may proceed against your home immediately. Available funds Por emergency mortgage aeeietance are vary limited, Thsy will be dlaburaed by the Agency under the eligibility cri[eria established by the Act, It ie ertx•emely important that your application is accurate and complete in every reepaot. The Pennsylvania Housing Finance Agency has sixty (fio) days tq make a decielon after it receives your application. During that additional tuna, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will ba notified directly by that Agency of its decision on your Application. The Pennsy7.vania Housing Finance Aaeney is located at 2101 North Front Street, P.O. Box 0029, Harrisburg, PA 17105. Telephone No. (717) 700-3000 or 1-800-342-2397 (toll free number). Persona with impaired hearing can call 1-ODD-342-2397. .In addition you may receive another notice from this lender under Act ti of 1974, That notice is called a "Notice of Intention to Foreclosure". You must read both notices, since they both explain riyhts that you now have under Pennsylvania law, However, if you choose to exercise your riyhts described in this notioe, you cannot be foreclosed upon while you are receiving that aeaiatanca. Sincerely, Wayne Flynn Collection Manager Collection Department ' 90110300000034 EXHIBIT B ALL THAT CERTAIN lot or tract of land •ituare in East Pemaeboro Towahip, Cwber- laad County, Coessonweslth of Pennsylvania, mor+ particulArly bounded and d4r aribed a tollove, to vitf BEGINNING at a point un the western right o[ vay 11ne of Eo[ord Road ap the dividing lio• of Lot No. S and Lot No. b{ thence by a[oramentloned right o! vay line South 27 degrees 45 minuus 43 eecondr Eset 80.00 tact to • point on the' dividing line of Lot No. 4 and Loc No. Si thena• by atorementloned dividing 1lma South 62 degrees 14 minutes 17 eecond• Neet 110.Op feat co.e point on line o[' lands nov or Iormerly of Ilomutead Group, Ina tMnc• by ^Iorementlonld lends North 27 degree 43 minutes 43 seconds Naet 80.00 Ceat to a point on the dividing line of Lot No. 5 and Lot No. 6~ thence by sforementloned dividing line North 62 degrees 14 ninueu 17 seconds Eask 110.00 teak to • point being the place of BEGINNING. EEINC Lot No. S u shown on a Final Subdivision Plen of ViaCOrla Olen, Sactioa I, recorded in Plan Book 48, Page 32. IUVING thereon tressed a duelling house known and numbered re 311 Erloed Road, Camp Hill, Pennsylvania. SEING A PART OF THE 9AHE PRF.NISES vhich Joseph T. Simpson, at •l, by O~ed dated July 12, 1985 and recorded August 12, 19BS in the O[fia• of the Recorder o[ Deeds in and for Ctueberlend County in Desd Book K, Volwe 31, Page 368, granted and conveyed unto The Homeeuad Group, Inc., a Panneylvanla corporation, Crantor~ herein. PREMISES HEING: 311 ERFORD ROAD T~~y ,~ pp~, hereh~ etatee tAat he it h//!q'lA1R /ap~1T11f1Y of nisiaats xo~saaoa, =ac. Mstgaq• e.rviriaq agsat ter tlaiatitt !a thi• natter, that he ie rutboriaoa to take tbia vesitloatlos, amp that the •tateasato aad• !a the toreQoiaq oi~ii nation is Mett~age rereeleruro are true aaa eerroet to th• seot o! Ale haarieAge, ialosaatloa aaa belie!. TDe ua4ereigaeQ uaaeretaadr .that thi• otateaost !e aaee eub~eet to the psaalliee of l• ha. C,a. •ee. 1f0~ reiattaq to uaevers taleitieatiea to authorities. _~ ~ ~~ ,. 0086/tt 800 fN ~!01962R 008 ~ rq ryu'n.IXURPII iN141ry N wnWp tl fY1W 'iV03131tl1491tl J FEDERMAN AND PNELAN By: Frank Federman, Esguire Atty. I.D. No. ].2248 ATTORNEY FOR PLAINTIFF .Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 56~-7000 C t Corp Mortgage, Inc. -'~ Cumberland County Court of Common Pleas v' Civi.i Division Neleoh Damschroder and Etherl Damschroder No. 99-15 ]?~$~CIPE TO THE PROTHONOTARY: x_ A. Plaintiff hereby withdraws the complaint filed in this matter. Please mark this case discontinued and ended without prejudice. B. Please mark this case settled, discontinued, and ended. C. Plaintiff hereby vacates the judgment if filed against Defendant(s) in this case. Please mark this case iscontinued and .ended i h pr dice. L ~~,` ~ ~ .Date Frank Federman Attorney fo r Plaintiff ~~ c SHERIFF'S RETURN - REOULAR CAMMSME NOt 1999-00010 P CQUNTYwOFLGUMBERLANDSYLVANIA~ CITIOORP MOj_QAQE INC VS. D MSCH ODER NELSON ET AL TIMOTHY RETT2 Sherif! or Dsputy Sheriff of CUMBERLAND County, Pennrylvania, who being duly sworn according to law, sayr, the within NOTICE ANDSrOMPLAINT IN war reeved upon DAMSGHROD~R N~ ON ~• ~ the defendant, at _ 14121 HOURS, on the l~tt~ dry oY ,~gnurrv 199• •t _ 311 ERFORD ROAD AMP HILL, PA 170++ ,GUMBERLAND County, Pennsylvania, 6y hsnding tc NELSO[~ DAMSCHRODER _ a true and attested oapy of the _NOTICE AND COMPLAINT I~__ together with NORTOA~E FDRECLasuRF and st the same time directing d.~. attention to the aontentr therraf. Sheriff'r Cortez So anew i Dooketing 18, 00 ~/.!~ Affidavit / Suroharge 8, 0 1~'•T +F-omar ne, er ~'~ 03530-'FEDERMAN R PHELAN 01/14/1999 ~` ?>----- by Sworn and rubeor•ibr to before me thir °/ / ~' dry oil 19~'_ A. D. ~-`L RpU y el' r OLnOnOLBry ~.~ °i SHERIFF'S RkTURN - REGULAR CASE N0~ 1999-00013 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Qj,TICORP MORTGAGE ANC VS. DAHSCHRODER NELSOM ET AL TIMOTHY REIT2 ~~, Shrrili or Deputy Sherif! o! CUMBERLAND County, Pennsylvania, who being duly ^worn aooording to law, ^aye, thr within jiQTICE AND COMPLAINT IN _~ wa^ served upon _ DAMSCHRODER ETHE„L_, the defendant, •t ~ 1421 HOURS, en th• ~,h day of ,Irnuarv 19~ of _ 311 ~$FORD ROAD v CAMP HILL, .~4.. 1701j ~ . CUMBERLAND Ccunty, Pennsylvania, by handing to NELSON DAM~,~RODER a true and •tterted copy of the NOTI~,AND COMPLAINT IN Lopether with MORTGAGE P'DRECLOSURE and at the acme time direoting ~{t sttention to the oontente thereo#. Sheri!!'r Coetst Dooketing Service 5.00 So an,eweraa ~/~ ~ Af#idavit. ~ 00 ~ 1~~~{ P Surohargs 8.00 R T ~ oma^ ne er , iZ'~00' ~'EDERMAN 6 PHELAN , 01/14/1999 ~,'% i ~ °~~ , , eP Y er . `~ Sworn and sub~aribgd to befor e me thi• ~ y ~' day o! L1 1,,.~.,~_ -- __ 19~_ A. D. 7 7 ~ ~ . ro onoono ~ ~ a