HomeMy WebLinkAbout09-3895GOLDAECK McCAFFERTY & McKEEVER
BY" MICHAEL T. MCKEEVER
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(866) 413-2311
WWW.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
CITIMORTGAGE, INC. F/K/A CITICORP TRUST BANK
FSB
1000 Technology Drive
O'Fallon, MO 63304
Plaintiff
VS.
SHARON S. JACOBY
Mortgagor and Record Owner
2 Cedar Avenue
Mechanicsburg, PA 17055
Defendant
Term ?
G 3dy5
No.
CIVIL. ACTION: MORTGAGE
E:_ `"?!SCLf}l9t F
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 the 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 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 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.
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 DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA 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
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
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
THIS FIRM IS A DEBT COLLECTOR AND WE RE AT'T'EMPTING TO COLLECT
A 71TnT
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 may be 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners
in default. Please See the PHFA website h!W://www.phfa.orp-/consumers/homecowners/real.aspx.
5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: ft://www.DhiladelDhiafed.org/foreclosure/
7). 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 homeretentiona,-Roldbecklaw 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 Number of 83578FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is CITIMORTGAGE, INC. F/K/A CITICORP TRUST BANK FSB, 1000 Technology Drive,
O'Fallon, MO 63304.
2. The names and addresses of the Defendant is SHARON S. JACOBY, 2 Cedar Avenue, Mechanicsburg,
PA 17055, who is the mortgagor and record owner of the mortgaged premises hereinafter described.
3. On June 20, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter
described to PNC BANK NA, which mortgage is recorded in the Office of the Recorder of Deeds of
Cumberland County as Book 1956 Page 4651. The mortgage has been assigned to: CITIMORTGAGE,
INC. F/K/A CITICORP TRUST BANK FSB by assignment of Mortgage June 20, 2006 and recorded on
June 30, 2006 as Book 728, page 2370. The Mortgage and assignment(s) are matters of public record
and are incorporated by this reference in accordance with Pennsylvania Rule of 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 fiilly 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 November 27, 2008 and each month thereafter and by the terms of 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 ....................................................................................$52,291.05
Interest from 10/27/2008 through 05/29/2009 at 9.5900% .......................$3,045.78
Per Diem interest rate at $13.74
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph ...................$2,614.55
Costs of suit and Title Search ...................................................................... $900.00
Delinquent Expense Total ............................................................. .$84.00
$58,935.38
7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees 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 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
Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the
Defendant in this Action but reserves its right to bring a separate Action to establish 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.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $58,935.38,
together with interest at the rate of $13.74, 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:
GOLDBECK McCAFFERTY & McKEEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
I,1? 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 unworn falsification to authorities.
Date: 0/0 16q
#83578FC - SHARON S. JACOBY
2 Cedar Avenue Mechanicsburg, PA 17055
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ALL IM QKRTAIR Uottae and Let of Greg" situate io the ?ewahip of
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11214 between Lots Was. 1 and 2. South 27 dagsess 33 tdswtes =ast. o21e
baudi+ed fifty (130) fiat to a lut., thenee a the division line bo-•
evem Loop was. 1 =4 40 on said plan, swflt 31 eme 13 mtnntes
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.loet to a point in the westerly 3Aao o! NWhet Stet extamded (State
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are o a aisle to the left. 1"ok O"d ets?ale lugs a radims of
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4rdar Awnwa•, afbrementionedj theca ato" the soathet;n line of Cedar
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E.Xhibit B
REPRESENTATION OF PRINTED DOCUMENT 0007669028
c ti mortgages
7107 8381 6540 0929 2820
04/10/09 58608 000634
SHARON S JACOBY
2 CEDAR AVE
MECHANICSBURG PA 17055-4701
RE: CitiMortgage Loan #: 0007669028
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in
default, and the lender intends to foreclose. Specific information
about the nature of the default is provided in the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be
able to help to save your home. This Notice explains how the program
works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take
this Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling
Agencies serving your County are listed at the end of this Notice. If
you have any questions, you may call the Pennsylvania Housing Finance
Agency toll free at 1-800-342-2397. (Persons with impaired hearing can
call (717)780-1869).
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.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES 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 "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM"
EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
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CitiMortgage, Inc. does business as Citicorp Mortgage in NM.
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HOMEOWNER'S NAME(S): Sharon S Jacoby
PROPERTY ADDRESS: 2 Cedar Ave
Mechanicsburg,PA 17055
LOAN ACCT. NO.: 0007669028
ORIGINAL LENDER: PNC Bank NA
CURRENT LENDER/SERVICER: CitiMortgage, Inc. is providing this notice
as lender or servicing agent for the lender.
HOMEOWNER'S 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-three (33)
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 end of this Notice. THIS MEETING
MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE.
IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING
YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE
YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
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CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one 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 numbers
of designated consumer credit counseling agencies for the county in
which the property is located are set forth at the end of this Notice.
It is only necessary to schedule one face-to-face meeting. Advise
your 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 nature of your default). 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. To temporarily stop the lender from filing a foreclosure
action, your application MUST be forwarded to PHFA (filed or
postmarked) within thirty (30) days of your face-to-face meeting with
the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A
MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE
OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF
THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM
STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN
THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE".
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME
PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING
A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED
AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
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
proceeding 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 you can still apply for
Emergency Mortgage Assistance.)
CitiMortgage, Inc. does business as Citicorp Mortgage in NM.
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HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date).
NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on
your property located at: 2 Cedar Ave,, Mechanicsburg, PA 17055 IS
SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE
PAYMENTS for the following months and the following amounts are now
past due:
11/27/08 thru 11/27/08 1 @ $583.14/month
O @ $0.00/late charge/month $583.14
12/27/08 thru 03/27/09 4 0 $583.34/month
0 @ $0.00/late charge/month $2,333.36
Previous late charge(s) $0.00
Delinquency Expenses(s)
TOTAL AMOUNT PAST DUE:
$84.00
$3,000.50
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 $3,000.50, PLUS ANY MORTGAGE PAYMENTS, LATE
CHARGES AND DELINQUENCY EXPENSES WHICH BECOME DUE DURING THE THIRTY
(30) DAY PERIOD. Payments must be made either by cashier's check,
certified check or money order made payable and sent to:
CitiMortgage, Inc.
P.O. Box 689196
Des Moines, IA 50368-9196
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. 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 mortgaged
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 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
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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 you owe the lender, which
may also include other reasonable costs. If you cure the default
within the THIRTY (30) DAY period, you will not be required to pay
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.
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, you still have the right to cure the default
and prevent the sale at any time up to one hour before the Sheriff's
Sale. You may do so by paying the total amount then past due, plus
any late or other charges then due, reasonable attorney'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 any other requirements under the mortgage.
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 six (6) 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 be by
contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: CitiMortgage, Inc.
Address: 1000 Technology Drive
O'Fallon, MO 63368-2240
Phone Number: 1-800-723-7906*
Fax Number: 1-636-261-7716
Contact Person: Adam Saab
Email Address: ryan.ollier@citi.com
* Calls are randomly monitored and recorded to ensure quality service.
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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-Please refer to your original loan documents to
determine whether or not you may 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. You may also call the 1-800 Number above to
find out whether your loan is assumable.
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.
Under IRS regulation, we must report any foreclosure to the IRS
on form 1099-A. The foreclosure may result in income tax
consequences to you. Consult the IRS or your tax advisor for
further information.
Enclosure: Consumer Credit Counseling Agencies, including those for
your county.
This is an attempt to collect a debt, and any information obtained
will be used for that purpose.
In the event you are subject to an Automatic Stay issued by a United
States Bankruptcy Court or the referenced debt has been discharged in
Bankruptcy, this communication is not intended to be an attempt to
collect a debt.
090410D0007245
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ol
RLE -OFFICE
OF THEE PRROTe- I"NOTARY
2009 JUN 12 AM 10: 54
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Sheriff s Office of Cumberland County
R Thomas Kline ~;t~~tr c~~ ~~~+~brr}th r.uwa~u,_. ~~~w~YY
Sheriff ~' ~ , ~` Solicitor
~ , ?~,~
Ronny R Anderson "' ~"°~"~ Jody S Smith
Chief Deputy oF~ioE caF P~sE SwERiFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
06/13/2009 01:31 PM -Brian Barrick, Corporal, who being duly sworn according to law, states that on 11une 13, 2009
at 1331 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within
named defendant, to wit: Sharon S. Jacoby, by making known unto himself personally, defendant at 2
Cedar Avenue Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents andat the same
time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $37.00 SO ANSWERS,
June 15, 2009
2009-3895
Citimortgage
v
Sharon Jacoby
~' ~ ~~.
R THOMAS KLINE^, SAHERIFF
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Deputy Sheriff
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GOLDBECK McCAFFERTY & McKEEVER
ATTORNEY FOR PLAINTIFF
BY: Michael T. McKeever
Attorney LD. #56129
Suite 5000 -Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6321
CITIMORTGAGE, INC. F/K/A CITICORP
TRUST BANK FSB
1000 Technology Drive
O'Fallon, MO 63304
Plaintiff
vs.
SHARON S. JACOBY
2 Cedar Avenue
Mechanicsburg, PA 17055
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. X09-3895
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of your costs only.
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Michael T. McKeever, Esquiire
Attorney for Plaintiff
FILED-~
OF ~E ~?''~ i rC~"~t~TARY
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