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Home My WebLink About03-6515FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 PRINCIPAL WHOLESALE MORTGAGE, INC., F/K/A RELIASTAR MORTGAGE CORPORATION 711 HIGH STREET DES MOINES, IA 50392-0780 V. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 63 - G S*Ar GEORGE W.VANASDALAN 6594 CARLISLE PIKE MECHANICSBURG, PA 17055 Defendant(s) CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE 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, GO TO OR TELEPHONE THE OFFICE SET 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 File #: 84731 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: 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. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORECE A LIEN ON REAL ESTATE. File #: 84731 Plaintiff is PRINCIPAL WHOLESALE MORTGAGE, INC., F/K/A RELIASTAR MORTGAGE CORPORATION 711 HIGH STREET DES MOINES, IA 50392-0780 2. The name(s) and last known address(es) of the Defendant(s) are: GEORGE W.VANASDALAN 6594 CARLISLE PIKE MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 05/12/1997 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1381, Page 820. By Assignment of Mortgage recorded 9/15/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 557, Page 162. 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 10/01/2003 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. File #: 84731 6. The following amounts are due on the mortgage: Principal Balance $70,304.62 Interest 1,767.96 09/01/2003 through 12/17/2003 (Per Diem $16.37) Attorney's Fees 1,225.00 Cumulative Late Charges 44.26 05/12/1997 to 12/17/2003 Cost of Suit and Title Search $ 550.00 Subtotal $ 73,891.84 Escrow Credit -430.41 Deficit 0.00 Subtotal $- 430.41 TOTAL $ 73,461.43 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 73,461.43, together with interest from 12/17/2003 at the rate of $16.37 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDERMAN AND PHELAN ?LLP By: s/Francrs . Hall," W. FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 84731 AM R.H&T CMT6W piece ar pwmml oC Lid situate in iht, V;tinga or T3ag"town4 7'owast* or SCver . prin. Concicy OCIZ-vmuaYana, am" wCFavn,*jvanja. pounded and 4noncibed me fouwv v-* 923" p O q4 ^ pei..s es. ttw ZTenFh asaa er i?o Stow 19402wq Wg tft o char VMdgw oCBo9wXU-T6 elbPaeAld, & at Mo wul LamLO !hencenioqg !be imad of the oaid Laesb, iwe Una >?eat nnq now Mankertr along Vaek ALay, +0R9^mre ,=arty. orwafter Roland; thence sewba*A , wam tha Lind ; Muse to the Mcrtbwtrrfda arlbearam nUoued 66*O igI or add state ji6shwow. 35[x ".end jl,. wntbq tall-? t§? the swcaw Qlat9t,Wena. mare or Mom. 1XA.VWC. rltgraon a Cartlsle >Plka ?p, Zr? !.9055 tl r 2c001e9 fnoM 3Warripb,.rf..' CV amwUsW cma MMA4 lr ardc 4 now of Aww" air. llao Lot ?U&t -darver ndahxw^v- pcbaMs.$) L and 4-taoalhs (ea.e) saes w land. now orlha said R41swu' two hundred rott%-eec to tbo pone =4 plena cr DErmtwx"r,,. wM4 - *1n0w form- d+ wwatorvA. cmer{r k:=vea ma m Ctwllele Pi A ISOM? tho saoae .which RUSS=& J. RRExNStEAN and CAB4L ANN WOMMEMAN Gcauced to MUSSIMIL J 3 =NNWAt^W, we WC ehc 4maw,y 31Cr iM dy A=*ir Aeod 4paed Jaaua'y %A "74 A" rwft- ad in tho MMAbe iAnd. Coemkr Broader atDewdr- [Mace in Deed Book "P} Velmpa 2$, F*nv " AND to w klch pntstleea ZkRt4E 8ZcNX4XWAX reteaee& and trar,"ora MW cod AM intcrca4 she MAV ha +U Nwbl Isom Mar aaw'PC. induam but mat: i mited to, leer =xw iaga to 3xu&%= =zNNSMAN. PREMISES BEING: 6594 CARLISLE PIKE. VERIFICATION TRACY MARTIN, hereby states that she is MANAGER OF FORECLOSURE of PRINCIPAL RESIDENTIAL MORTGAGE, INC. 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 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: (G' 3 r) N O n y :-i l'J a PHELAN HALLINAN & SCHMIEG, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id No. One Penn Center at Suburban Station ATTORNEY FOR PLAINTIFF 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 PRINCIPAL WHOLESALE MORTGAGE INC, F/K/A RELIASTAR MORTGAGE CORPORATION, F/K/A WAHSINGTON SQUARE MORTGAGE COMPANY Plaintiff vs GEORGE W. VANASDALAN Defendant TO THE PROTHONOTARY: : I Court of Common Pleas . I Civil Division : CUMBERLANDCounty : I No. 03-6515 PHS# 84731 PRAECIPE Please mark the above referenced case Discontinued and Ended without prejudice. Please mark the above referenced case Settled, Discontinued and Ended. Please mark Judgments satisfied and the Action settled, discontinued and ended. Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. X Please withdraw the complaint and mark the action discontinued and ended without prejudice. ' y Date: October 1 2007 ?e*z? //a/& ?' ? Francis Hallinan Attorney for Plaintiff t+a 71 C- N C-J