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HomeMy WebLinkAbout08-0340PHELAN HALLINAN & SCHMIEG, LLP FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 MICHELE M. BRADFORD, ESQ., Id. No. 69849 SHEETAL R. SHAH-JANI, ESQ., Id. No. 81760 JUDITH T. ROMANO, ESQ., Id. No. 58745 JENINE R. DAVEY, ESQ., Id. No. 87077 MICHAEL E. CARLETON, ESQ., Id. No. 203009 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 169184 THE BANK OF NEW YORK TRUST COMPANY, NA, AS SUCCESSOR-IN-INTEREST TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, F/K/A JPMORGAN CHASE BANK, AS TRUSTEE- SURF-BC2 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081-2226 Plaintiff V. CYNTHIA L. FISHER 116 WILLIS ROAD NEWVILLE, PA 17241 Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 0% - 30 Civit TerM CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 169184 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File #: 169184 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 File #: 169184 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 ENFORCE A LIEN ON REAL ESTATE. File #: 169184 1. Plaintiff is THE BANK OF NEW YORK TRUST COMPANY, NA, AS SUCCESSOR-IN-INTEREST TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, F/K/A JPMORGAN CHASE BANK, AS TRUSTEE- SURF-BC2 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081-2226 2. The name(s) and last known address(es) of the Defendant(s) are: CYNTHIA L. FISHER 116 WILLIS ROAD NEWVILLE, PA 17241 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 01/15/2004 mortgagor(s) made, executed, and delivered a mortgage upon the premises hereinafter described to WILMINGTON FINANCE, A DIVISION OF AIG FEDERAL SAVINGS BANK which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book: 1851, Page: 3949. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File #: 169184 5 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/01/2007 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. The following amounts are due on the mortgage: Principal Balance $107,150.92 Interest $3,822.00 08/01/2007 through 01/15/2008 (Per Diem $22.75) Attorney's Fees $1,250.00 Cumulative Late Charges $192.12 01/15/2004 to 01/15/2008 Cost of Suit and Title Search 550.00 Subtotal $112,965.04 Escrow Credit ($698.63) Deficit $0.00 Subtotal 698.63 TOTAL $112,266.41 7 If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be 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 reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. File #: 169184 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 9. 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. File #: 169184 10. 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 $112,266.41, together with interest from 01/15/2008 at the rate of $22.75 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. PHELAN HALLINAN & SCHMIEG, LLP By: D ` S ? FRANCIS S. 14ALLINWS ESQUIRE DANIEL G. SCHMIEG, ESQUIRE MICHELE M. BRADFORD, ESQUIRE SHEETAL R. SHAH-JANI, ESQUIRE JUDITH T. ROMANO, ESQUIRE JENINE R. DAVEY, ESQUIRE MICHAEL E. CARLETON, ESQUIRE Attorneys for Plaintiff File #: 169184 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected, situate in North Newton Township, Cumberland County, Pennsylvania, more fully bounded and described as follows: BEGINNING at a nail in the center line of T-305, also known as Willis Road; thence along the dividing line between Lots Nos. 8 and 7, North 45 degrees East, 300.00 feet to an iron pin; thence by the lands now or formerly of Katherine W. MaCoy, North 45 degrees West, 150.00 feet to an iron pin; thence by lands now or formerly of Katherine W. MaCoy, South 45 degrees West, 300.00 feet to a nail in the center line of T-305, thence along said centerline South 45 degrees East, 150.00 feet to a nail in the center line T-305. the Place of BEGINNING. BEING known as Lot No. 8 on the Subdivision Plan for Stonecrest Development, which plan is recorded in Cumberland County Plan Book 51, Page 46. SUBJECT, NEVERTHELESS, to restrictions and conditions as recorded in Cumberland County Miscellaneous Book 331, Page 450. PARCEL NO: 30-10-0618-002A File #: 169184 VERIFICATION I hereby state that I am the attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unworn falsifications.to authorities. Attorney for Plaintiff$? DATE: t 0 ? L ? J ,J J V .? C7 ; .p C7 c- a t l I C SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-00340 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK TRUST CO VS FISHER CYNTHIA L R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: but was unable to locate Her deputized the sheriff of BEDFORD serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On February 20th , 2008 , this office was in receipt of t attached return from BEDFORD Sheriff's Costs: So answ ?r?"? Docketing 6.00 Out of County 9.00 Surcharge 10.00 R. Thomas Kline Dep Bedford County 49.80 Sheriff of Cumberland County Postage .97 75.77 ? 9' 9., 02/20/2008 PHELAN HALLINAN SCHMIEG Sworn and subscribe to before me this day of in his bailiwick. He therefore A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-00340 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK TRUST CO VS FISHER CYNTHIA L GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE FISHER CYNTHIA L was served upon the DEFENDANT , at 2008:00 HOURS, on the 14th day of February-, 2008 at 116 WILLIS RD NEWVILLE, PA 17241-9452 by handing to 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: So Answers: Docketing 18.00 Service 26.88 Affidavit 00 Surcharge 10.00 R. Thomas Kline n 00 54.88 02/20/2008 PHELAN HALLINAN SCHMIEG Sworn and Subscibed to By: before me this day Deputy She f of A.D. KA 0 -F nEk U EA In The Court of Common Pleas of Cumberland County, Pennsylvania The Bank of New York Trust Company, NA vs. Cynthia L. Fisher No. 08-340 civil Now, January 28, 2008. , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Bedford deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service ved the Now, jr-hruprq I , 20AL, at o'clock M. ser1} within upon at by handing to a and made known to copy of the original the contents thereof. w a 5 ?.o kd ?-ha-? 5??u I i Uf.S Ln '( urnbt r la nd COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cynthia J. Kendall, Notary ftlic Bedford Twp., Bedford Cw* W Commission Expires July 12, 2009 Member, Pennsylvania Association of Notaries Sworn and subscribed pefore me this day of / r , 20 1 So answers, COSTS \j SERVICE MILEAGE AFFIDAVIT ?D FHELAN HALLINAN & SCHMIEG, LLP By: Francis S. Hallinan, Esquire IDENTIFICATION NO. 62695 1617 JFK Boulevard, Suite 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF THE BANK OF NEW YORK TRUST CUMBERLAND County COMPANY, NA, AS SUCCESSOR-IN- INTEREST TO JPMORGAN CHASE Court of Common Pleas BANK, NATIONAL ASSOCIATION, F/K/A JPMORGAN CHASE BANK, AS CIVIL DIVISION TRUSTEE-SURF-BC2 NO. 08-340-CIVIL TERM Plaintiff File: 169184 Vs. LOAN # 14164445 CYNTHIA L. FISHER Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. x Francis S. Hallinan, Esquire Attorney for Plaintiff Dated: 3/14/08 co VERIFICATION oenise Bailey hereby states that he/she is Assistant Sea+etary of LITTON LOAN SERVICING, LP, SERVICING AGENT FOR THE BANK OF NEW YORK TRUST COMPANY, NA, AS SUCCESSOR-IN-INTEREST TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, F/K/A JPMORGAN CHASE BANK, AS TRUSTEE- SURF-BC2, servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: DATE: Title: Ash SOUG" Ulm Loge SOM" LP Aftmy In FAd Company: LITTON LOAN SERVICING, LP, SERVICING AGENT FOR THE BANK OF NEW YORK TRUST COMPANY, NA, AS SUCCESSOR-IN-INTEREST TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, F/K/A JPMORGAN CHASE BANK, AS TRUSTEE- SURF-BC2 Loan:14164445 File #: 169184 ve" going(; gJWi3hea"nO U 1=1 #0 Is iWA PHELAN HALLINAN & SCHMIEG, LLP By: Francis S. Hallinan, Esquire IDENTIFICATION NO. 62695 1617 JFK Boulevard, Suite 1400 PHILADELPHIA, PA 19103 (215) 563-7000 THE BANK OF NEW YORK TRUST COMPANY, NA, AS SUCCESSOR-IN- INTEREST TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, F/K/A JPMORGAN CHASE BANK, AS TRUSTEE-SURF-BC2 Plaintiff Vs. CYNTHIA L. FISHER Defendant(s) ATTORNEY FOR PLAINTIFF CUMBERLAND County Court of Common Pleas CIVIL DIVISION NO. 08-340-CIVIL TERM File: 169184 LOAN # 14164445 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to Substitute Verification was sent via first class mail to the following on the date indicated below: CYNTHIA L. FISHER 116 WILLIS ROAD NEWVILLE, PA 17241 r? Francis S. Hallinan, Esquire Attorney for Plaintiff Dated: 3/14/08 Phelan Hallinan & Schmieg, LLP By: Daniel G. Schmieg, Esquire Identification No. 62205 One Penn Center Plaza 1617 JFK Boulevard, Ste. 1400 Philadelphia, PA 19103 (215) 320-0007 THE BANK OF NEW YORK TRUST COMPANY, NA AS SUCCESSOR-IN- INTEREST TO JPMORGAN CHASE BANK VS. CYNTHIA L. FISHER 116 WILLIS ROAD NEWVILLE, PA 17241 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 08-340-CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against CYNTHIA L. FISHER. 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 - 01/16/2008 -10/16/2008 TOTAL $112,266.41 $6,256.25 $118,522.66 I hereby certify that (1) the addresses of the Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237. 1, copy attached n Daniel G. Sc Attorney for DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: / a8 PHS# 169184 PRO PR THY 4 Phelan Hallinan & Schmieg, LLP By: Daniel G. Schmieg, Esquire Identification No. 62205 One Penn Center Plaza 1617 JFK Boulevard, Ste. 1400 Philadelphia, PA 19103 (215) 320-0007 THE BANK OF NEW YORK TRUST COMPANY, NA AS SUCCESSOR-IN- INTEREST TO JPMORGAN CHASE BANK VS. CYNTHIA L. FISHER Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 08-340-CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE Daniel G. Schmieg, Esquire, 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/are 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 CYNTHIA L. FISHER is over 18 years of age and resides at 116 WILLIS ROAD, NEWVILLE, PA 17241. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Daniel G. Schmieg, &re Attorney for Plainti PHELAN HALLINAN & SCHMIEG, LLP By: LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215 563-7000 THE BANK OF NEW YORK TRUST COMPANY, NA, AS SUCCESSOR-IN-INTEREST TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, F/KIA JPMORGAN CHASE BANK, AS TRUSTEE- SURF-BC2 Plaintiff V. CYNTHIA L. FISHER Defendant(s) TO: CYNTHIA L. FISHER 116 WILLIS ROAD NEWVILLE, PA 17241 DATE OF NOTICE: October 1, 2008 91 wn Cui'1' FILL 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 PROPERTY. IMPORTANT NOTICE You are in default because you have failed to 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 _ 17) 249-3166 SON RICCO Legal Assistant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISON NO. 08-340-CIVIL TERM CUMBERLAND COUNTY PHS # 169184 F' J r ? t'3 c? ? f C C • .q. (Rule of Civil Procedure No. 236) - Revised THE BANK OF NEW YORK TRUST CUMBERLAND COUNTY COMPANY, NA AS SUCCESSOR-IN- INTEREST TO JPMORGAN CHASE COURT OF COMMON PLEAS BANK VS. CYNTHIA L. FISHER 116 WILLIS ROAD NEWVILLE, PA 17241 : CIVIL DIVISION : NO. 08-340-CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on -{- 2008. By: BEP`b" - If you have any questions concerning this Daniel G. Scfimieg, E q ire Attorney or Party Fili 1617 JFK Boulevard, Ste. 1400 Philadelphia, PA 19103 (215) 563-7000 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PRE VIO USL Y RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECTA DEBT, BUT ONL Y ENFOR CEMENT OFA LIEN AGAINST PROPERTY. ** g , ?*:;