HomeMy WebLinkAbout00-05091SHERIFF'S RETURN - REGULAR
CASE NO: 2000-05091 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK ET AL
VS
WOGAN BETH A ET AL
BRIAN BARRICK Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT- MORT FORE was served upon
RITE AID CORPORATION
the
DEFENDANT
, at 0016:00 HOURS, on the 26th day of July , 2000
at 30 HUNTER LANE
CAMP HILL, PA 17011
HEATHER WITMAN (LEGAL
by handing to
SECRETARY
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 6.00
Service 9.30
Affidavit .00
Surcharge 10.00
.00
25.30
Sworn and Subscribed to before
me this ?AA- day of
-2 opt) A. D.
a, Od
r thonotary
So Answers:
R. ''Thomas Kline
07/27/2000
FEDERMAN & PHELAANN
By: Deputy Sheriff
U,
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-05091 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK ET AL
VS
WOGAN BETH A ET AL
KELL
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
WOGAN DAVID A the
DEFENDANT , at 0019:20 HOURS, on the 24th day of July 2000
at 96 COLD SPRING ROAD
CARLISLE, PA 17013 by handing to
BETH WOGAN (WIFE)
a true and attested copy of COMPLAINT - MORT FORE together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this /.ar day of
pvr7 A.D.
thonotary
So A?nswEers :
R. Thomas Kline
07/27/2000
FEDERMAN & PHELAN
By : '7? (1 I? S1'1 ? &L
Deputy Sheriff
/.
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-05091 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK ET AL
VS
WOGAN BETH A ET AL
DAWN KELL
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
WOGAN BETH A the
DEFENDANT
, at 0019:20 HOURS, on the 24th day of July , 2000
at 96 COLD SPRING ROAD
CARLISLE, PA 17013
BETH WOGAN
by handing to
a true and attested copy of COMPLAINT - MORT FORE
NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 4.34
Affidavit .00
Surcharge 10.00
.00
32.34
Sworn and Subscribed to before
me this 144L day of
a A.D.
iothonotary
So AnswEwers :
R. Thomas Kline
07/27/2000
FEDERMAN & PHELAN
By: lo0.. i a
Deputy Sheriff
FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215 563-7000
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
LASALLE NATIONAL BANK,
AS TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED 2/1/99,
SERIES 1999-1
ONE RAMLAND ROAD
ORANGEBURG, NY 10962
V.
Plaintiff
TERM
BETH A. WOGAN
DAVID A. WOGAN
96 COLD SPRING ROAD
CARLISLE, PA 17013
Defendant(s)
NO.00-504/ I.I000?
CUMBERLAND COUNTY
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, 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. **
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.
Loan 8:80(530494
r
Plaintiff is
LASALLE NATIONAL BANK,
AS TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED 2/1/99,
SERIES 1999-1
ONE RAMLAND ROAD
ORANGEBURG, NY 10962
2. The name(s) and last known address(es) of the Defendant(s) are:
BETH A. WOGAN
DAVID A. WOGAN
96 COLD SPRING ROAD
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 1/27/99 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to ALLIANCE FUNDING COMPANY, A DIVISION OF
SUPERIOR BANK, FSB which mortgage is recorded in the Office of the Recorder of
CUMBERLAND County, in Mortgage Book No. 1520, Page 173. By Assignment of
Mortgage recorded 6/9/00 the mortgage was assigned to PLAINTIFF which Assignment
is recorded in Assignment of Mortgage Book No. 646, Page 122.
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 10/1/99 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 $31,373.60
Interest 1,844.37
9/1/99 through 511100
(Per Diem $7.59)
Attorney's Fees 800.00
Cumulative Late Charges 87.71
1/27/99 to 511100
Cost of Suit and Title Search 550.00
Subtotal 34,655.68
Escrow
Credit 0.00
Deficit 0.00
Subtotal 0.00
TOTAL $34,655.68
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.
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 either:
(i.) Defendant(s) have failed to meet 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 "A"; or
(ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$34,655.68, together with interest from 5%1/00 at the rate of $7.59 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/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
DATE: June 14, 2000 FORECLOSURE
TO: Beth A. Wogan David A. Wogan
96 Cold Spring Road 96 Cold Spring Road
Carlisle, PA 17013 Carlisle, PA 17013
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU INAN 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 ENFORCEMENT OF A LIEN AGAINST PROPERTY.
LA NOTIFICACION EN ADJUNTO ES DE SUMA 1MPORTANCIA, PUEDE AFECTA SU DERECHO
A CONTINUAR 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 PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): Beth A. Wogan and David A. Wogan
PROPERTY ADDRESS: 96 Cold Spring Road - Carlisle, PA 17013
LOAN ACCT. NO.: 801530494
ORIGINAL LENDER: Alliance Funding Company, A Division of Superior Bank, FSB
CURRENT LENDER/SERVICER: Superior Bank, Servicing Division
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save
your home. This Notice explains how the program works.
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.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
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 consumer credit counseling agencies listed at the
of your intentions.
necessary to schedule one face-to-face meeting. Advise your lender immediately
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in a default for the reasons set forth
later in this Notice (see following pages for specific information about the nature 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 complete
application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-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 24MEDIATELY 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
PURPOSE 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.)
'lit 4I1 • ,r't,
HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up 'o date)
NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located
at: 96 Cold Spring Road - Carlisle, PA 17013 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: Start/End: 10/1/99 thru 6/1/00 at $250.63 per month.
Monthly Payments Plus Late Charges Accrued $2,434.09
NSF: $0.00
Inspections: $120.00
Other: $100.00
(Suspense): $109.60
Total amount to cure default $2,544.49
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable): N/A
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 $2,544.49,
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 sent to: FEDERMAN AND PHELAN, Suite 900,Two Penn
Center Plaza, Philadelphia, PA 19102, attention: Reinstatement Department.
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter. (Do not use if not applicable.) N/A.
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 rights to accelerate the mortgage debt. The 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 tender also intends to instruct its attorney to start legal action to
foreclosure upon your mortgage property_
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage 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 begins 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 are started against 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 to the lender, which may also include other reasonable
'.6d13. La yVLL a V :LLG uI.LUUaI .yluLLa uLG Li14\? L \JVJ ?rt1 UGIIVLL. YULL .V u1 uVL VG IGqLLll G4 .V 114y
attorney's fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
within the THIRTY (30) DAY
have not cured the default
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 mortgage property could be held would be approximately SLY (6) MONTHS from the date of
this Notice. A notice of the actual date of the Sheriffs 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 be by contacting the lender.
HOW TO CONTACT THE LENDER: Attorney Representing Lender:
FEDERMAN AND PHELAN
Suite 900, Two Penn Center Plaza, Philadelphia, PA 19102
Phone : (215) 563-7000 Fax Number: (215) 563-5534
Contact Person: Phyllis Levin, Reinstatement Department
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriffs 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 or_X_may not (CHECK ONE) sell or transfer
your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost are paid prior to or at the sale and that the other requirements
of the mortgage are satisfied.
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 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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
very uuly yours,
FEDERMAN AND PHELAN
Cc: Superior Bank, Servicing Division
Attn: Keith Fitzgerald Account No.: 801530494
Mailed by 1" Class mail and by certified Mail No: P-974-911-062,061
L- An i I
Pennsylvania Housing Finance Agency
Homeowner's Emergency Mortgage Assistance Program
Consumer Credit Counseling Agencies
(Rev. 5/99)
L3'toming-Clinton Counties
Commission For Community Acti6a ($irp)
2138 Lincoln Streec
P. 0.Rot1328
(570WB))3326-0 8 PA 11703
FAX (570)322-2197
CCCS of Northeastern PA
201 Basin Street
W"llarISPorr, P417703
)
FA.'Y(570) 23-x-626
CLIlYTON COU Tor
CCCS ofYorthesatern Py
1631 S Atherton St
Suite 100
I680I
(814) 238-3668
FAX (814) 238-3669
COLUMBIA COUNTY
CCCS of Northeastern Pennavivania
31 W. Market Street 1400 Abington Executive Par's
FOB LL? Suite 1
Wilkes-Barre, PA 18102 Clarks Summitt P.A. 18411
(570) 821-0837 or(800)922-9537 (570)587.9163 or (800) 922-9537
FAX (57o) 821-1785 FAX (570) 587-9134!9135
Commission on Economics Opportunity of L=erne County
163 Amber Lane
Wilkes-Barre, P-4.18702
(570) 8264510 or (800) 822-0359
FAX (570) 829-1665--CALL BEFORZ KL=G
(570) 4554994 HAZELTON
FAX (570) 455-5631-CALL BEFORE FA=G
(370) 836-4090 TUNKHANNOCK
Booker T. Washington Center
1720 Holland Street
Pais, P416503
(814) 453-5744
FAX (814) 453-5749
John F Kennedy Center, Inc.
2021 East 20th Street
Ere, P.6,16510
(814) 898-0400
FAX (814) 898-1243
CRAWFORD COUNTY
Greater Erie Community Aeon Committee
18 West 9th Street
Erie, P.416501
(814) 4594581
FAX (814) 456-0161
Shenango Valley Urban League, Inc
601 Indiana Avenue
Farrell, PA 16121
(412) 981-5310
CUYIBERIA2NI), COUNTY
CCCS of Western Pennsylvania, Inc. Financial Counseling Services of F:-snIrlm
2000 Linglesmwn Road 31 West 3rd Street
Harrisburg, P317102 Waynesboro, PS 17268
(717) 541-1757 (717) 762-3285
Urban League of Metropolitan Har.'sbur;
N. 6th Street
Harrisburg, PS 17101
(717) 234-5925
F4X (717) 234-9459
Community Action Comm of the Capital Region
1514 Derry Street
Harrisburg, PA 17104
(717) 232.9757
FAX (717) 2342227
YWCA of. Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FA.Y (717) 731-9589
Adams County Housing Auchor'ty
139-143 Carlisle St
Gettysburg, Rk 17325
(717)334.1518
F4X (717) 334-8325
P£NNSYLYANIA BULLETIN, VOL. 29, NO. 23, JUNE 5, 1999 C-XHiBi 1 .A
r
ALL that certain tract of land situate in the'fownship of Dickinson, Cumberland
•j County, Pennsylvania, bounded and described as follows:
BEGINNING at a point on the Cold Springs Road at the line of land now or formerly
of Charles B. and Cora M. Hamtan; thence northwardly along the Cola Springs
Road, 119 feet, more or less, to a stake at the line of land now or formerly of Arthur
W. Shmmon and wife; thence westwardly along the Shannon land, 365 feet, more or
less, to a stake at ilia line of land now or formerly of George Bear; thence
9 southwardly along the Bear land, 1 15 fact, more or less, to the line of land of ilia
1 aforesaid Harmans; thanca eastwardly along the Barman land, 345 feet, more or less,
to the Placc of Beginning; being improved with a dwelling house.
TOOSTHL•R with the right to the use of the well oo the Shannon land as provided
in the decd from the aforesaid Vaughns Lo Arthur W. Shannon and wilb.
premises: 96 Cold Spring Road
i
VERIFICATION
KEITH FITZGERALD hereby states that he is FORECLOSURE MANAGER of SUPERIOR
BANK, FSB mortgage servicing agent for Plaintiff in this matter, that he 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 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: I-/-7-®O
C
?c
n
C?
t,.
CD
CD
Lss._
(-1
'too
FEDERMAN AND PHELAN, LLP
By-. Frank Federman, Esquire I.D. No. 12248
Lawrence T. Phelan, Esquire I.D. No. 32227
'Francis S. Hallinan, Esquire I.D. No. 62695
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
LASALLE NATIONAL BANK, AS TRUSTEE
UNDER THE POOLING AND SERVICING
AGREEMENT DATED 02/01/99, SERIES 1999-1
Attorney for Plaintiff
Plaintiff Court of Common Pleas
CUMBERLAND County
Vs. No. 00-5091-CIVIL
BETH A. WOGAN
DAVID A.WOGAN
Defendant(s)
PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PREJUDICE,
AND DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark
this case discontinued and ended, upon payment of your costs only.
Date
Frank Federman, Esquire
Lawrence T. Phelan, Esquire
Francis S. Hallinan, Esquire
Attorneys for Plaintiff
„m?i?;,nfrrrau '
i r C:? n
_
e r', C
T? C
Ul