HomeMy WebLinkAbout09-5885IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY MORTGAGE, A
DIVISION OF NATIONAL CITY BANK,
CIVIL DIVISION
NO. Cq - 5885 o'-'icre-'rm
Plaintiff,
VS.
CHRISTOPHER A. TASSIN,
COMPLAINT IN MORTGAGE
FORECLOSURE
Defendant. Code -MORTGAGE; FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party.
Louis P. Vitti, Esquire
Supreme Court #01072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF
NATIONAL CITY BANK, )
Plaintiff, ) NO:
VS. )
CHRISTOPHER A. TASSIN, )
Defendant. )
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 THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR
DEFENSES AND 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
SHOULD 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.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR
NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT IN MORTGAGE FORECLOSURE
AND NOW, comes the Plaintiff by its attorneys, Louis P. Vitti and Associates, P.C. and Louis P.
Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141 through 1150, for
its Complaint in Mortgage Foreclosure, sets forth the following:
1. The Plaintiff is a corporation duly authorized to conduct business within the laws of the
Commonwealth of Pennsylvania, having a principal place of business located at 3232 Newmark Drive,
Miamisburg, OH 45342.
2. The Defendant is an individual with a last known mailing address of 622 North Pitt Street,
Carlisle, PA 17013. The property address is 622 North Pitt Street, Carlisle, PA 17013 and is the subject
of this action.
3. On the 23rd day of February, 2006, in consideration of a loan of Ninety One Thousand
Three Hundred Fifty and 00/100 ($91,350.00) Dollars made by National City Mortgage a division of
National City bank of Indiana, to Defendant, the said Defendant executed and delivered to National City
Mortgage a division of National City Bank of Indiana, a "Note" secured by a Mortgage with the Defendant
as mortgagor and National City Mortgage a division of National City Bank of Indiana, as mortgagee, which
mortgage was recorded on the 24th day of February, 2006, in the Office of the Recorder of Deeds of
Cumberland County, in Mortgage Book Volume 1941, page 2280. The said mortgage is incorporated herein
by reference thereto as though the same were set forth fully at length.
4. The premises secured by the mortgage are:
SEE EXHIBIT "A "ATTACHED HERETO.
5. Said mortgage provides, inter alia:
"that when as soon as the principal debt secured shall becorne due and payable, or in
case default shall be made in the payment of any installment of principal and interest, or any
monthly payment, keeping and performance by the mortgagor of any of the terms, conditions
or covenants of the mortgage or note, it shall be lawful for mortgagee to bring an Action of
Mortgage Foreclosure, or other proceedings upon the mortgage, of principal debt, interest
and all other recoverable sums, together with attorney's fees."
6. Since September 1, 2007, the mortgage has been in default by reason, inter alia, of the
failure of the mortgagor to make payments provided for in the said mortgage (including principal and
interest) and, under the terms of the mortgage, the entire principal sum is, due and payable.
7. In accordance with the appropriate Pennsylvania Acts of Assembly and the Pennsylvania
Rules of Civil Procedure, the mortgagor has been advised in writing of the mortgagees intention to foreclose.
The appropriate time period has elapsed since the Notice of Intention to Foreclose has been served upon the
mortgagor.
8. The amount due on said mortgage is itemized on the attached schedule.
9. Pursuant to Pennsylvania Rules of Civil Procedure 1144 the Plaintiff releases from
liability for the debt secured by the mortgage any mortgagor, personal representative, heir or devisee of the
mortgagor who is not a real owner of the property as evidenced by the last recorded deed of record at the
time of filing this complaint.
WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 1147(6), Plaintiff
demands judgment for the amount due of One Hundred Sixteen Thousand Three Hundred Sixty Two and
37/100 Dollars ($116,362.37) with interest and costs.
Respectfully submitted,
LOUIS P. VITTI & ASSOC., P.C.
BY `
4AAttoommeyVffor . il Esquire
Plaintiff
Tassin
SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE
Unpaid Principal Balance 89,740.42
Interest ( 6.0000% from 08/01/07 through 8/31/2009 11,226.16
)
(Plus $14.7518 per day after 8/31/2009
Late charges througl 8/25/2009
0 months @ 30.88
Accumulated beforehand 813.56
(Plus $30.88 on the 17th day of each month after 8/25/2009 )
Attorney's fee 4,487.02
Escrow deficit 10,095.21
(This figure includes projected additional charges that may be incurred by the
Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of
the sheriffs sale)
BALANCE DUE 116,362.37
¦
Date. 21222008 •
Order number: 000029665
Re: Christopher A. Tassin 622 NORTH PITT STREET
CARLISLE, PA 17013
CUMBERLAND County
ZXHIBIT 'A'
ALL THOSE TWO CERTAIN tracts of land with the improvements thereon
erected situate in the Fifth Ward of the Borough of Carlisle, County of
Cumberland and State of Pennsylvania.
TRACT NO. 1
Bounded on the North by Tract No. 2, hereinafter described; on the East
by North Pitt Street; on the South by a 16 foot alley; and on the West
by a 16-foot alley. Containing 25 feet in front on said North Pitt
Street and extending at an even width 179 feet in depth to the
aforesaid alley.
TRACT NO. 2
Bounded on the East by North Pitt Street; on the South by Tract No. 1,
above described, on the West by a 16 foot alley; and on the North by
lot now or formerly of Newton N.R. Myers. Containing 6 .feet in front
on said North Pitt Street and extending at an even width 179 feet in
depth to the aforesaid alley.
BEING improved with a two and one-half story frame dwelling house known
as No. 622 North Pitt Street.
EMBIT a A -- •
Time: 9:50:42 AM
94 t PG2290
Page: 6oi6 BK 1
Order Number 000029865
VERIFICATION
AND NOW Louis P. Vitti verifies that the statements made in this Complaint are true and
correct to the best of his knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the
verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is
submitted by counsel having sufficient knowledge, information and belief based upon the information
provided him by the Plaintiff.
A??" I I J"-,
Loui P. vitiu
Dated: 8/25/2009
0 iL? 7i @r T} "r < r kq 1
2 D9 AUG 2? R": ! ? 2- 3
$'18.50 Pp ATr4
Co M05
p 2a9ggb
Sheriffs Office of Cumberland County
R Thomas Kline
Sheri
Ronny R Anderson r
Chief Deputy C. , 2 u
Jody S Smith
Civil Process Sergeant OFriC ETHE ?gERIFF
Edward L Schorpp t
Solicitor
National City Mortgage Company Case Number
vs.
Christopher A. Tassin 2009-5885
SHERIFF'S RETURN OF SERVICE
09/01/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Christopher A. Tassin, but was unable to locate him in
his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the
defendant Christopher A. Tassin. The residene is visibly vacant, and the neighbor stated the defendant
has moved over a year ago. An exact address is not available.
SHERIFF COST: $38.40
SO ANSWERS,
September 02, 2009 R THOMAS KLINE, SHERIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY MORTGAGE, CIVIL DIVISION
A DIVISION OF NATIONAL CITY BANK
NO.09-5885 Civil Term
Plaintiff,
MOTION FOR SPECIAL
Vs.
SERVICE
CHRISTOPHER A. TASSIN
Defendants. Code - MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti & Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
412-281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, )
A DIVISION OF NATIONAL CITY BANK)
No. 09-5885 Civil Term
Plaintiff, )
VS. )
CHRISTOPHER A. TASSIN )
Defendants. )
NOTICE OF PRESENTATION
TO: Christopher A. Tassin
622 North Pitt Street
Carlisle, PA 17013
Take notice that the within Motion for Special Service pursuant to Rule 430 of the
Pennsylvania Rules of Civil Procedure will be presented before Motions Judge, Cumberland County,
Pennsylvania, as unopposed unless a responsive pleading is filed.
VITTI AND VITTI AND ASSOCIATES, P.C.
BY:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, )
A DIVISION OF NATIONAL CITY BANK)
Plaintiff, )No. 09-5885 Civil Term
VS. )
)
CHRISTOPHER A. TASSIN
Defendants. )
CERTIFICATE OF SERVICE
I, Louis P. Vitti, hereby certify that on the 23rd day of October, 2009, a true and correct copy
of the within Motion for Special Service was served upon the following by Regular U.S. Mail:
Christopher A. Tassin
622 North Pitt Street
Carlisle, PA 17013
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §
4904, relating to unworn falsification to authorities.
BY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, )
A DIVISION OF NATIONAL CITY BANK)
Plaintiff, )No. 09-5885 Civil Term
VS. )
CHRISTOPHER A. TASSIN
)
Defendants. )
MOTION FOR SPECIAL SERVICE PURSUANT TO RULE 430
AND THE PENNSYLVANIA RULES OF
CIVIL PROCEDURE 400, ET SEQ.
NOW comes the Plaintiff by and through their attorneys, Louis P. Vitti & Associates, P.C.
and Louis P. Vitti, Esquire, and files this motion requesting this Honorable Court permit servier
pursuant to Pennsylvania Rules of Civil Procedure 400, et seq., and particularly Rule 430 whereof
the following is a statement:
Plaintiff did file a Complaint at the above-captioned number in mortgage foreclosure
2. The property address is 622 North Pitt Street, Carlisle, PA 17013, and is the subject
of this action.
3. The Sheriff did attempt to make service but has been unable to serve the Defendants,
Christopher A. Tassin because the residence is visibly vacant, and the neighbor stated flee defendant
has moved over a year ago. See Exhibit "A".
4. The Postmaster of Carlisle, PA 1701 states that the Defendant isnot known at address
given. See Exhibit "B".
An investigation report completed by Plaintiffs counsel shows Defendant's last know
address as 622 North Pitt Street, Carlise, PA 17013.
6. Efforts to effectuate service by the Sheriff have met without success and service has
been frustrated requiring presentation of this Motion.
WHEREFORE, Plaintiff prays this Honorable Court enter an Order permitting service by
posting the property by the Sheriff.
Respectfully submitted,
VITTI AND VITTI AND ASSOCIATES, P.C.
BY:
orney for Plaintiff
ID 01072
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
Sheriffs Office of Cumberland County
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
National City Mortgage Company Case Number
vs.
Christopher A. Tassin 2009-5885
SHERIFF'S RETURN OF SERVICE
09/0112009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Christopher A. Tassin, but was unable to locate him in
his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the
defendant Christopher A. Tassin. The residene is visibly vacant, and the neighbor stated the defendant
has moved over a year ago. An exact address is not available.
SHERIFF COST: $38.40 SO ANSWERS,
September 02, 2009 R THOMAS KLINE, SHERIFF
XHIM " „'
VITTI and VITTI and ASSOCIATES, P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
PHONE: (412) 281-17251 FAX: (412) 281-3810
DATE: September 11, 2009
POSTMASTER OF CARLISLE
CARLISLE PA 17013
Request for Change of Address or Boxholder
Information Needed for Service of Legal Process
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: CHRISTOPHER A. TASSIN
Address: 622 NORTH PITT ST. CARLISLE PA 17013
NOTE: The name and last known address are required for change of address information. The name, if known, and post office box
address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for
providing chance of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and correspondina Administrative
Support Manual 352.44a and b.
1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a
corporation acting pro se must cite statute): N/A
3. The names of all known parties to the litigation:_ NATIONAL CITY MORTGAGE CO
4. The court in which the case has been or will be heard: CCP CUMBERLAND County. Pa
5. The docket or other identifying number if one has been issued: 09-5885 CIVIL TERM
6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE
OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES
INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE
THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service of legal
process in connection with actual or prospective litigation.
is P. Vitti, Esquire
916 Fifth Avenue
Pittsburgh, PA 15219
FOR POST OFFICE USE ONLY
NEW ADDRESS or BOXHOLDER'S NAME AND STREET ADDRESS
Address:
City, State, ZIP:
? No change of address order on file Not known at address given
? Moved, left no forwarding address ? No such address
POSTMARK
? Good as addressed - still receives mail at this address
exie T "a2
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF
NATIONAL CITY BANK
VS.
CHRISTOPHER A. TASSIN
PLAINTIFF
DEFENDANT
NO. 09-5885 CIVIL TERM
INVESTIGATION AFFIDAVIT PURSUANT TO PA.R.C.P. NO. 430
Four Star Investigation sets forth the following:
1. Affiant and/or its agents have conducted an investigation to determine the
whereabouts of the Defendant(s), CHRISTOPHER A. TASSIN, by making inquiries of or
examining the following:
a. Local telephone directory assistance has the following information:
?1 ??1oa7, f-Q- 7A -;C;2 -? i AT 6.2 :2-
b. Local voter registration office shows the property address is:
h- 4 l c72n.??"1 a 4 (A JLAD,1,r
C. Department of Transportation - shows that the last known
address for the Defendant(s) is/are:
acKURj K .,C"
...._.._
d. Other (please explain):
- ?. SSG e g&L /e ?r 0:5i's T ssm AT 16a;R N, Pj-'r s >'
I/i
2. Notwithstanding the investigation as set forth in this Affidavit, Affiant and/or its
agents have not been able to locate the whereabouts of said Defendant(s) as shown above
and by the attached exhibits.
We verify that the statements made in this Affidavit are true and correct to the best
of our knowledge, information and belief. We understand that false statements are made
subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to
authorities.
FOUR STAR INVESTIGATION
BY: 'adz?
In es ' ator
Commonwealth of Pennsylvania
SS.
County of Allegheny :
On this the !_to
- day of , 2009, before me the undersigned
officer, personally appeared the Affiant, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument and acknowledged that he
executed the same for the purposes therein contained.
In Witness Whereof, I hereunto set my hand and official seal.
NOTARY PUBLIC
I.)EC6W/ 01r- AD ? ,VCS
VERIFICATION
NOW Louis P. Vitti verifies that the statements made in this Motion are true and correct
to the best of his knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the Court and tle
verification cannot be obtained within the time allowed for the filing of this pleading, the pleading
is submitted by counsel having sufficient knowledge, information and belief based upon the
information provided him by the Plaintiff.
BY
Dated: October 26, 2009
2099 OCT 23 P.1 i ! : C' 3
r ti ;'; ?y irk
S
OCT 2 s Zoos 6.1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, )
A DIVISION OF NATIONAL CITY BANK)
Plaintiff, )No. 09-5885 Civil Term
vs. )
CHRISTOPHER A. TASSIN )
Defendants. )
ORDER OF COURT
...r3
cn
th
NOW, this day of 0(6,4 , 2008, it appearing to the Court
that the Sheriff has been frustrated in service of process, it is Ordered, Adjudged and Decreed that
service of the Complaint and all subsequent documents upon all Defendants be accomplished by by
posting the property by the Sheriff in order to effect compliance with Rule 400, et seq. and Rule
3129.1, et seq.
BY THE COURT:
lqc? J.
- ',;FE
RLED
OF THF
?
2009 NOV -6 PM 12= 05
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY MORTGAGE, A
DIVISION OF NATIONAL CITY BANK,
Plaintiff,
vs.
CHRISTOPHER A. TASSIN,
Defendant.
CIVIL DIVISION
NO. 09-5885 CIVIL TERM
PRAECIPE TO
REINSTATE COMPLAINT
MORTGAGE FORECLOSURE
Filed on behalf of Plaintiff
Counsel of record for this party:
Louis P. Vitti, Esquire
PA I.D. #01072
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGGAE, A. )
DIVISION OF NATIONAL CITY BANK, )
) NO. 09-5885 CIVIL TERM
Plaintiff, )
Vs )
CHRISTOPHER A. TASSIN, )
Defendant. )
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY OF CUMBERLAND CPUNTY
Please reinstate the complaint in the above-captioned case
Respectfully submitted,
Vitti and Vitti and Associates P.C.
BY:
Lotus P. Vitti, Esquire
DATE: November 12, 2009
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
4
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Edward L Schorpp
Solicitor
National City Mortgage Company
Case Number
vs.
Christopher A. Tassin 2009-5885
SHERIFF'S RETURN OF SERVICE
11/18/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Christopher A. Tassin, but was unable to locate him in
his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the
defendant Christopher A. Tassin. Request for service at 622 North Pitt Street Carlisle, PA 17013 remains
vacant.
SHERIFF COST: $38.40
November 18, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
iC) Cour'; Si;itB 5he'!?f. Tell^,.50fl. II?C
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2010 J~Pd I I PM i2~ G 9
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY MORTGAGE, A CIVIL DIVISION
DIVISION OF NATIONAL CITY BANK,
NO. 09-5885 Civil Term
PRAECIPE FOR DEFAULT
Plaintiff, JUDGMENT, CERTIFICATION OF
MAILING AND AFFIDAVIT OF NON-
MILITARY SERVICE
vs.
CHRISTOPHER A. TASSIN,
Defendant.
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
p~Y~
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti and Vitti and Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
~I~•00 Po PYT~/
~ a3lo 086
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL
CITY BANK,
Plaintiff, NO: 09-5885 Civil Term
vs
CHRISTOPHER A. TASSIN,
Defendant.
PRAECIPE FOR DEFAULT JUDGMENT
AND ASSESSMENT OF DAMAGES
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Enter judgment in Default of an Answer in the amount of $118,235.84, in favor of
the National City Mortgage, et al, Plaintiff in the above-captioned action, against the Defendants,
Christopher A. Tassin and assess Plaintiffs damages as follows and/or as calculated in the
Complaint:
Unpaid Principal Balance $89,740.42
Interest from 08/01/07-01/OS/10 13,099.63
(Plus $19.4360 per day after O1/OS/10)
Late charges (Plus $30.88 per
month from 08/25/09-06/02/10 $277.92) 813.56
Attorney's fee 4,487.02
Escrow Deficit 10,095.21
(Plus any additional charges that may be
incurred by the Plaintiff and transmitted
to the sheriff as charges on the writ prior
to the date of the sheriff s sale)
Total Amount Due $118.235.84
The real estate, which is the subject matter of the Complaint, is situate in Fifth Ward,
Boro of Carlisle, Cty of Cumberland & Cmwlth of PA. HET a dwg k/a 622 North Pitt Street,
Carlisle, PA 17013. Parcel No. 06-20-1798-034.
Louis P. Vitti, Esquire
Attorney for the Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL
CITY BANK,
Plaintiff, NO: 09-5885 Civil Term
vs
CHRISTOPHER A. TASSIN,
Defendant.
CERTIFICATION OF MAILING
I, Louis P. Vitti, do hereby certify that a Notice of Intention to Take Judgment was mailed to the
Defendant(s), in the above-captioned case on December 23, 2009, giving ten (10) day notice that judgment
would be entered should no action be taken.
VITTI AND VITTI AND ASSOCIATES, P.C.
BY:
Louis P. Vitti, Esquire
Attorney for Plaintiff
SWORN to and subscribed
before me this 5th day
of January, 2010.
iJOTf~,RiAL ~t:Hl
~j/ SHERRY L HOUSE
Notary Publdc
Notary Public , CITY OF PITTSBURGH, ALLEGHENY COUNT!
My Commission Expires May ~ 5, 201 ~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK,
vs
CHRISTOPHER A. TASSIN,
TO: Christopher A. Tassin
622 North Pitt Street
Carlisle, PA 17013
Plaintiff,
Defendant.
IMPORTANT NOTICE
Date of Notice: December 23, 2009
No. 09-5885 Civil Term
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 YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
LOUIS`P,.VITTI & ASSOCIATES, P.C.
-~ ~~ f )
BY ..,,o.' ,~~,
',$~~Louis P. Vitti, Esquire ~-~
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
** THIS FIItM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN 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.**
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
COMMONWEALTH OF PENNSYLVANIA, SS:
COUNTY OF ALLEGHENY
BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire, who,
being duly sworn according to law, deposes and says that he is advised and believes that
DEFENDANT(S) is/are not presently in the active military service of the United States of America
and not members of the Army of the United States, United States Navy, the Marine Corps, or the
Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with
the Army or Navy; nor engaged in any active military service or duty with any military or naval units
covered by the Service Members Civil Relief Act of 2004 and designated therein as military service,
and to the best of this affiant's knowledge is/are not enlisted in military service covered by said act,
and that the averments herein set forth, insofar as they are within his knowledge, are correct, and
true; and insofar as they are based on information received from others, are true and correct as he
verily believes. In the alternative, should the defendant(s) be currently serving in the military the
Service Members Relief Act does not apply as the mortgage in question did not originate before the
period of the Service Members military service and is secured by a mortgage pursuant to 50 U.S.C.
App §533 formerly cited as 50 U.S.C. App §532 (a)(1)(2).
This Affidavit is made under the provisions of the Service Members Civil Relief Act of 2004.
-- - - - --~,~%iaGU- .
Louis P. Vitti, Esquire
SWORN to and subscribed
before me this 5th day
of January, 2OlO. NOTARIAL SEAL
SHERRY L HOUSE
Notary Publlc
CITY OF PITTSBURGH, ALLEGHENY COUNTY
My Commission Expires May 15, 20T 1
Notary Public
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY MORTGAGE, A CIVIL DIVISION
DIVISION OF NATIONAL CITY BANK,
NO. 09-5885 Civil Term
PRAECIPE FOR WRIT OF
Plaintiff, EXECUTION AND AFFIDAVIT OF
LAST KNOWN ADDRESS
vs.
CHRISTOPHER A. TASSIN,
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Defendant.
Counsel of record for this
party:
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti and Vitti and Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL
CITY BANK,
Plaintiff, NO: 09-5885 Civil Term
vs
CHRISTOPHER A. TASSIN,
Defendant.
PRAECIPE FOR WRIT OF
EXECUTION IN MORTGAGE FORECLOSURE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the
above-captioned matter as follows:
Amount Due $118,235.84
Interest 01106110-06/02/10 2.857.10
Total X121.092.94
The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate
in:
Fifth Ward, Boro of Carlisle, Cty of Cumberland & Cmwlth of PA. HET a dwg k1a 622 North Pitt Street,
Carlisle, PA 17013. Parcel No. 06-20-1798-034.
Louis P. Vitti, Esquire
Attorney for Plaintiff
. f ..-~
IN THE ~~OURT 0~' COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
~_ _ CIVIL DIVISION ._-. _ --- - _ _ _ .. -
PRAECZPE FOR WRIT OF E:CECIJTION
~1ATIONAL CITY MORTGAGE, A DNISION OF NATIONAL ~ ) Confessed 3udgrrent
CITY BANK,
Plaintiff, ( ) Other
vs
File Na. dq_ 5~8s- ~ v, I Tom.
CHRISTOPHER A. TASSIN, .
Arrnun t Due '~//~; a7~' . ~'fL
Atty's CoRm
Costs
TO THE PRO'IHONO'TARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail
installment sale, contract, or account based on a confession of judgment, but if it does,
it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
a~ ed; and for real pro~oerty pursuant to Act 5 of 1974 as amended_
Issue writ of execution in the above m=_tter to the Sheriff of ~ y f jf~„~/
County, for debt, interest and costs upon the followin described ro
nj g perty of the
!ic Fanriant / e 1 LJ! d/J n n ,n ~ n ~ 1.y., s A_ _ _~ ~. ,•. _ ,~/ n,.. .. ~. _ ~_ _l
PRAECIPE E•UR ATTACf~iT EXEC'UI'I~V
Issue writ of attachment to the Sheriff of County, for debt,
interest and costs, as above, directing attact~.ment against the above-n~3 g~ishes(s) for
the following property (if real estate, supply six copies of the description; supply four
espies of lengthy personalty list) - .
:.nd all other property of the defendant(s) in the possession, custody or control of the
paid garnishee (s) .
(Indicate) Index this writ against the garnishee(s) as a.~.s pendens against
-eat estate of the defendant(s) described in the attached exhibit.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DNISION
NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL
CITY BANK,
Plaintiff, NO: 09-5885 Civil Term
vs
CHRISTOPHER A. TASSIN,
Defendant.
LEGAL DESCRIPTION
ALL those two certain tracts of land with the improvements thereon erected situate in the Fifth Ward of
the Borough of Carlisle, County of Cumberland and State of Pennsylvania.
TRACT NO. 1:
BOUNDED on the North by Tract No. 2, hereinafter described; on the East by North Pitt Street; on the
South by a 16 foot alley; and on the West by a 16 foot alley. Containing 25 feet in frant on said North Pitt
Street and extending at an even width 179 feet in depth to the aforesaid alley.
TRACT N0.2:
BOUNDED on the East by North Pitt Street; on the South by Tract No. 1, above described, on the West
by a 16 foot alley; and on the North by lot now or formerly of Newton N.R. Myers. Containing 6 feet in
front on said North Pitt Street and extending at an even width 179 feet in depth to the aforesaid alley.
HAVING erected thereon a dwelling known as 622 North Pitt Street, Carlisle, PA 17013.
PARCEL NO. 06-20-1798-034.
BEING the same premises which Leonard R. McKee, Sr. and Bonnie F. McKee, husband and wife, by
Deed dated 10/30/200 and recorded 10/31/2002 in the Recorder's Office of Cumberland County,
Pennsylvania, Deed Book Volume 254, Page 1553, granted and conveyed unto Christopher A. Tassin.
FfLED~-~rrlC~
cJ~ ~!~ ~~ ~TF~'C~~'~1TARY
2010 JAi~ i i PPS i2= I 0
~3xtn~d At
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL
CITY BANK,
Plaintiff, NO: 09-5885 Civil Term
vs
CHRISTOPHER A. TASSIN,
Defendant.
AFFIDAVIT
I, Louis P. Vitti, do hereby swear that, to the best of rimy knowledge, information and belief,
the Defendants}, is/are the owners of the real property on which the Plaintiff seeks to execute . That the
Defendants' last known address is 622 North Pitt Street, Carlisle, PA 17013.
Louis P. Vitti, Esquire
SWORN TO and subscribed
before me this 5th day of
January, 2010.
otarv Public /
,.J NOTARIAL SEAL
SHERRY l HOUSE
Notary Public
CITY OF PITTSBURGH, ALLEG NENY COUNTY
My Commission Expires May 15, 2011
1~ 1~'~J~'ARY
ZO10 J~l~ 1 I PM 12= .:0
CUArlj ~ .. ~ -. ~ ,
r~~~f~k`J r ~~r1i~+'?,~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL
CITY BANK,
Plaintiff, NO: 09-5885 Civil Term
vs
CHRISTOPHER A. TASSIN,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
National City Mortgage, et al, Plaintiff in the above action, sets forth as of the date the Praecipe for the
Writ of Execution was filed the following information concerning the real property located at 622 North
Pitt Street, Carlisle, PA 17013.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Christopher A. Tassin 622 North Pitt Street
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 above.
3. Name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Name:
Beneficial Consumer Discount Company
Beneficial Consumer Discount Company
c/o Chromulak & Associates, LLC
Address (Please indicate if this
cannot be reasonably ascertained)
2700 Sanders Road
Prospect Heights, IL 60070
375 Southpointe Blvd, 4th Floor
Cannonsburg, PA 15317
4. Name and address of the last recorded holder of every mortgage of record:
Name
First Indiana Bank, NA
Citifinancial Mortgage Company, Inc
Address (Please indicate if this
cannot be reasonably ascertained)
135 North Pennsylvania Street
Philadelphia, PA 46204
1111 Northpoint Drive, Bldg 4
Suite 100
Coppell, TX 75019
5. Name and address of every other person who has any record lien on the property:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
6. Name and address of every other person who has any record interest in or record lien on the
property and whose interest may be affected by the sale:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
Tax Collector of Carlisle Borough
c/o Darlene Moyer
Borough of Carlisle
Water & Sewage Dept.
Commonwealth of PA -DPW
Clerk of Courts
Criminal/Civil Division
P.O. Box 128
Carlisle, PA 17013
53 West South Street
Carlisle, PA 17013
P.O. Box 8016
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
Tax Claim Bureau of Cumberland County
Cumberland County Courthouse
Court of Common Pleas of
Cumberland County
Domestic Relations Division
PA Dept. of Sheriff Sales
Bureau of Compliance
Tenant/Occupant
One Courthouse Square
Carlisle, PA 17013
P.O. Box 320
Carlisle, PA 17013
Dept. #281230
Harrisburg, PA 17128-1230
622 North Pitt Street
Carlisle, PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
January 5.2010
Date
SWORN TO and subscribed
before me this 5th day
of January, 2010.
Public
~- NOTARIAL SEAL I
SHERRY L HOUSE
Notary Public
CITY OF PITTSBURGH, ALLEGHENY COUNT
My Commission Expires May 15, 2011
V
Louis P. Vitti, Esquire
Attorney for Plaintiff
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL
CITY BANK,
Plaintiff, NO: 09-5885 Civil Term
vs
CHRISTOPHER A. TASSIN,
Defendant.
AFFIDAVIT
I, Louis P. Vitti, hereby certify that as representative of National City Mortgage, et al, am familiar
with the above-captioned case and various servicing activities related thereto and that the provisions of
the laws of the Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with
in the above-captioned case.
Louis P. Vitti, Esquire
Attorney for Plaintiff
SWORN to and subscribed
before me this 5th day
of January, 2010.
Notary
NOTARIAL SEAL
SHERRY L HOUSE
Notary PubllC
CITY OF PITTSBURGH, ALLEGHENY COUNTY
My Commission Expfr~e MaY 15, 2011
NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
TO: Christopher A. Tassin
622 North Pitt Street
Carlisle, PA 17013
AND: ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in Cumberland County Courthouse on June 2, 2010 at 10:00 A.M., the
following described real estate, of which Christopher A. Tassin are owners or reputed owners:
Fifth Ward, Boro of Carlisle, Cty of Cumberland & Cmwlth of PA. HET a dwg k/a 622 North Pitt Street,
Carlisle, PA 17013. Parcel No. 06-20-1798-034.
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of
National City Mortgage, et al vs. Christopher A. Tassin at 09-5885 in the amount of $118,235.84.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal rights to prevent your property from
being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights
you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
You may have legal rights to prevent the Sheriff s Sale and the loss of your property. In order to
exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice
to Defend, you may have the right to have the judgment opened in you promptly file a petition with the
Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the
judgment is opened, the Sheriff s Sale would ordinarily be delayed pending a trial of the issue of whether
the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid return
of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days
after service or in certain other events. To exercise this right, you would have to file a petition to strike
the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriff s
Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or
equitable right.
You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly
inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a
petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The
Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date
when the Schedule of Distribution is filed in the Office of the Sheriff.
Louis P. Vitti, Esquire
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
** THIS FIItM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN 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.**
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-5885 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NATIONAL CITY MORTGAGE, a Division of
NATIONAL CITY BANK, Plaintiff (s)
From CHRISTOPHER A. TASSIN
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $118,235.84
Interest from 1/6/10 to 6/2/10 -- $2,857.10
L.L. $.50
Atty's Comm
Atty Paid $245.20
Plaintiff Paid
Date: 1/11/10
(Seal)
Due Prothy $2.00
Other Costs
David D. Buell, Pr thonotary
By:
Deputy
REQUESTING PARTY:
Name: LOUIS P. VITTI, ESQUIRE
Address: VITTI AND VITTI AND ASSOC., PC
916 FIFTH AVENUE
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone : 412-281-1725
Supreme Court ID No. 01072
1=1Li ,
-(E
2010 ~'
i~~~~~
~,~~
MBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 09-5885 Civil Term
AFFIDAVIT OF SERVICE
Filed on behalf of
Plaintiff
Counsel of record for this
p~Y~
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Vitti and Vitti and Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
N
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1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL
CITY BANK,
Plaintiff, NO: 09-5885 Civil Term
vs
CHRISTOPHER A. TASSIN,
Defendant.
AFFIDAVIT OF SERVICE
I, Louis P. Vitti, do hereby certify that a Notice of Sale was mailed and served upon the
defendant and all lien holders by Certificate of Mailing for service in the above-captioned case
on January 15, 2010 and February 12, 2010, advising them of the Sheriff s sale of the property at
622 North Pitt Street, Carlisle, PA 17013, on June 2, 2010.
VITTI AND VITTI AND ASSOCIATES, P.C.
/ ~ .
B ~ ~ - ~ ./ ,
Louis P. Vitti
SWORN to and subscribed
before me this 13th day
of May, 2010.
Notary Publi~
NOTARIAL SEAL
SHERRY L HOUSE
Notary Public
CITY OF PITTSBURGH, ALLEGHENY COUNTY
r~ny Commission Expires May 15, 2011
U. S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Vitti and Vitti and Associates P.C.
916 Fifth Avenue. Pittsburgh, PA 15219 !
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One piece of ordinary mail adtlressetl to: I
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Tenant/Occupant ~
;
622 North Pitt Street
Carlisle
PA 17013 ¢'r;
, ~ •
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
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Receivetl From: , ~, •,.~ .~°""
Vitti and Vitti and Associates P.C. r
~
916 Fifth Avenue. Pittsburgh. PA 15219 A. ,
One piece of ordinary mail atltlressetl to: A
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PA Dept
of Sheriff Sales `• ~ i
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Bureau of Compliance '
Dept. #281230
Harrisburg, PA 17128-1230
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MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
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916 Fifth Avenue. Pittsburgh. PA 15219 ~
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One piece of ordinary mail addressed to: ~ ~,!^4~
Court of Common Pleas of Cumberland C
Domestic Relations Division c~'; ;.4 3
P.O. Box 320 ~ ~--
Carlisle, PA 17013
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MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
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916 Fifth Avenue. Pittsburgh. PA 15219 ~'
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One piece of ordinary mail addressed to'
~
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Tax Claim Bureau of Cumberland Co t~
- -
Cumberland County Courthouse '`'-, -r,._.-- ~~
One Courthouse Square ~il~ r I c
Carlisle, PA 17013
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916 Fifth Avenue. Pittsburgh. PA 15219
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One piece of ordinary mail adtlressetl to: :+.
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One Courthouse Square ~t;
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916 Fifth Avenue. Pittsburgh. PA 15219 r ~•
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Received From: 1
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916 Fifth Avenue. Pittsburgh. PA 15219 ,
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One piece of ordinary mail addressetl to: I
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Water & Sewage Dept. r, ~.~~
53 West South Street ~`-'
Carlisle, PA 17013
rs rorm sei i, .lanuary zuui
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PROVIDE FOR INSURANCE-POSTMASTER
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916 Fifth Avenue. Pittsburgh. PA 15219 ~ ~ i
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One piece of ordinary mail atltlressed to: ~1,
Tax Collector of Carlisle Borough
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Carlisle, PA 17013
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Vitti and Vitti and Associates P.C. ~ V
916 Fifth Avenue. Pittsburgh. PA 15219 C
~ :~
One piece of ordinary mail addressed to: :/. !` -oe..
Citifinancial Mortgage Company
Inc. ~ ~ ~ w"'N ''_
,
1111 Northpoint Drive Bldg 4 \~ ;
~~
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Suite 100 •;
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Coppell, TX 75019
rs rorm see i, January zuui
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received Fram:
Vitti and Vitti and Associates P.C. .~~
916 Fifth Avenue. Pittsburgh, PA 15219 ~ ~
.~
One piece ofordinary mail atldressetl to: :..
First Indiana Bank, AI-Pr~~.( A ~"
135 North Pennsylvania Street
I
Philadelphia, PA 46204 ~~~
ra rorm stsT i, uanuary zuu~
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAV BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Receivetl From:
Vitti and Vitti and Associates. P.C. -x-
916 Fifth Avenue. Pittsburgh. PA 15219 ~ t~
One piece of Ordinary mail addressetl to: y.
Beneficial Consumer Discount Company ~ -~~
c/o Chromulak & Associates, LLC
~
375 Southpointe Blvd, 4th Floor ~
Cannonsburg, PA 15317 ~
~~.,,,
r~ roan oaT r, January zuu-t
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
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Vitti and Vitti and Associates P
C ""
.
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916 Fifth Avenue. Pittsburgh. PA 15219 t'~~
One piece of ordinary mail addressed to:
b
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onsumer Discount Company
2700 Sanders Road
~
Prospect Heights, IL 60070 ~'^.,.,:'~
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$1.150
US POSTAGE
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Receivetl From:
Vitti and Vitti and Associates. P.C.
916 Fifth Avenue. Pittsburs~h. PA 15219 ---
One piece of ortlinary mail atltlressed to:
Christopher A. Tassin ~ r ~~ ~~ ~
~ • ~'
622 North Pitt Street
~ ~
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Carlisle, PA 17013 •~~~'~~0~~-
PS Form 3817, January 2001
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U. S. POSTAL SERVICE CERTIFICATE OF MAILING
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PROVIDE FOR INSURANCE-POSTMASTER
Receivetl From:
Vifti and Vitti and Associates. P.C.
916 Fifth Avenue. Pittsburgh, PA 15219
One piece of ordinary mail atltlressed to:
Tax Collector of Carlisle Borough
c/o Darlene Moyer
P.O. Box 128
Carlisle, PA 17013
Form 3817, January 2001
$1.15a
US POSTAG
FIRST-CLA
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson • ..
~
F1!_r ~_
~ r,~
Sheriff
tigtl'~ 0t ~IE~~1p4/ ~'"= T~'=~ r;` ; ~_,~Y
Jody S Smith
Chief Deputy ~~~
~~~
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Richard W Stewart "~''~°
CUr
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Solicitor c~tc~c~ ~~~~µe~l~~ v
, _. ~,
.,;~~.=t~J
National City Mortgage Company
vs.
Christopher A. Tassin
Case Number
2009-5885
SHERIFF'S RETURN OF SERVICE
03/30/2010 06:31 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on 3/30/10
at 1831 hours, he/she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in
the above entitled action, upon the property of Christopher A. Tassin, located at, 622 North Pitt Street,
Carlisle, Cumberland County, Pennsylvania according to law.
03/30/2010 06:31 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on 3/30/10
at 1831 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above
entitled action, upon the within named defendant, to wit: Christopher Tassin by posting property located at
622 North Pitt Street, Carlisle, pursuant to Court Order.
06/30/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice
had been given according to law, he exposed the within described premises at public venue or outcry at
the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 2, 2010 at 10:00 o'clock A.M. He
sold the same for the sum of $1.00 to Attorney Louis P. Vitti, on behalf of PNC Mortgage, A Division of
PNC Bank, N.A., et. al., 3232 Newark Drive, Miamisburg, OH 45342, being the buyer in this execution,
paid to Sheriff Ronny R. Anderson, the sum of $ 884.92
SHERIFF COST: $884.92
June 30, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
a ~a ter. ~ _
sra ~.
~~ 7~os~~
~ a~ts~~ ~
(o) CountySuite Sheriff. T'eleosoft, Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY MORTGAGE, A CIVIL DIVISION
DIVISION OF NATIONAL CITY BANK,
NO. 09-5885 Civil Term
AFFIDAVIT OF SERVICE
vs:
Plaintiff,
Filed on behalf of
Plaintiff
Counsel of record for this
CHRISTOPHER A. TASSIN, party:
Louis P. Vitti, Esquire
PA I.D. #3810
Defendant. Supreme Court #01072
Vitti and Vitti and Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412} 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL
CITY BANK,
Plaintiff, NO: 09-5885 Civil Term
vs
CHRISTOPHER A. TASSIN,
Defendant.
AFFIDAVIT OF SERVICE
I, Louis P. Vitti, do hereby certify that a Notice of Sale was mailed and served upon the
defendant and all lien holders by Certificate of Mailing for service in the above-captioned case
on January 15, 2010 and February 12, 2010, advising them of the Sheriff s sale of the property at
622 North Pitt Street, Carlisle, PA 17013, on June 2, 2010.
VITTI AND VITTI AND ASSOCIATES, P.C.
Louis P. Vitti
SWORN to and subscribed
before me this 13th day
of May, 2010.
Notary Publi~
NOTARIAL SEAL
SHERRY L HOUSE
Notary Public
CITY OF PITTSBURGH, ALLEGHENY COUNTY
My Commission Expires May 15, 2011
M
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622 North Pitt Street ~ *~~
Carlisle, PA 17013
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PA Dept. of Sheriff Sales P'/y ~
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Bureau of Compliance
Dept. #281230
Harrisburg, PA 17128-1230
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P.O. Box 320 ~- ~
Carlisle, PA 17013
PS Form 3817, January 2001
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Clerk of Courts ~ ~
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One Courthouse Square ~~;~~ ~ ~\~
Carlisle, PA 17013
PS Form 3817, January 2001
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERPUITIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMMSTER
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V' n Vi n oci P.C. ~ A
916 Fifth Avenue. Pittsburgh. PA 15219 ty'
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One piece of ordinary mail addressed to:
Q~L. +' A
Commonwealth of PA -DPW "~
P.O. Box 8016 k~
Harrisburg, PA 17105 d!~r" 5 ' '
.15 g
15219
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PS Form 3817, January 2001
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
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Vitti nd Vitti and ci P.C. ~
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916 Fifth Avenue. Pittsburgh. PA 15219 t ~'
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One piece of ordinary mail addressed lo: ~ t v'
Borough of Carlisle ~
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Water & Sewage Dept. ,~,,
15a
>TAGE
LASS
J61721
15219
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PS Form 3817, January 2001
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Vitt- nd Vi i and sociates P.G. ?~ ~
916 Fifth Avenue. Pittsbumh. PA 15219 ;, ~ `,
One piece of ordinary mail addressed to: Q,_
Tax Collector of Carlisle Borough ~~
a '
c/o Darlene Moyer ,~'~~
P.O. Box 128 'mot '' ~ ' ~
Carlisle, PA 17013
.150
15219
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PS Form 3817, January 2001
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING ~ ~~~
MAY BE USED FO DOMESTIC AND INTERNATIONAL MAIL, DOES NOT 1.15 g
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FIRST-CLASS
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m 15219
Vi i an V - nd Ass cia P.C. ~Vt o
916 Fifth Avenue. Pittsburgh. PA 15219 q ~• "' '~
.. ~~_ _ •-
One pace of odinary mail addressed to: '/. ._ ___ _ _ -~.~..
Citifinancial Mortgage Company, Ina ~ ~. "~ ~ •'-
1111 Northpoint Drive, Bldg 4 ~ ~
Suite 100 ~~~~; ~ ~ '
Coppell, TX 75019
PS Fonn 3817, January 2001
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER r `
• 15 O
POSTAGE
FIRST-CLASS
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Vitti and Vi n is P.C.
916 Fifth Avenue. Pittsburgh. PA 15219 .r"
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First Indiana Bank
-~~~ A- ' ~
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135 North Pennsylvania Street
~ ~
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Philadelphia, PA 46204
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PS Form 3817, January 2001
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAYBE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received Fmm: -
Vitla and Vitti and Associates. P.C.
916 Fifth Avenue. Pittsburgh. PA 15219
One piece of odinary mail addressed to: L,
Beneficial Consumer Discount Company '11t
c/o Chromulak & Associates, LLC
375 Southpointe Blvd, 4th Floor
Cannonsburg, PA 15317
PS Form 3817, January 2001
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Receivetl From:
916 Fifth Avenue. Pittsburgh. PA 15219
One piece of ordinary mail addressed to:
Beneficial Consumer Discount Company
2700 Sanders Road
Prospect Heights, IL 60070
.15 0
S POSTAGE
FIRST-CLASS
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916 Fifth Avenue. Pittsburgh. PA 15219 -----., ~ p ~
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one pace or ordinary mail addressed a: , ~ NC _.... _. _.. -.....
•~' -1
Christopher A. Tassin
622 North Pitt Street 'tc.. ~~
Carlisle, PA 17013 ~.~yr~sy
January 2001
slh.tassin.6.2.10
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U. S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTFJ2
Receivetl From:
Vitti and Vitti and Associates. P.C.
916 Fifth Avenue. Pittsburgh. PA 15219
Ooe Oleoe of aMirlary meG etldresse0 to:
Tax Collector of Carlisle Borough
c/o Darlene Moyer
P.O. Box 128
Carlisle, PA 17013
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND, LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
April 16, April 23, and Apri130, 2010
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
~-
' a Marie Coyne, ' or
SWORN TO AND SUBSCRIBED before me this
30 day of April, 2010
~~
Notary
NOTARIAL SEAL
DEBORAH A COLUNS
Not•ry Public
ARUSLE BOROU~iF1, CUNIBERLANO COUNTY
My Commatbn Expint Apr 2B, 2014
w:it lls. 90Of-fill Ci~it
National City Mortgage Company
a division of National City Bank
vs.
Christopher A. Tessin
Atty: Louis P. Vitti
ALL those two certain tracts of
land with the improvements thereon
erected situate in the Fifth Ward of
the Borough of Carlisle, County of
Cumberland and State of Pennsyl-
vania.
TRACT NO. 1:
BOUNDED on the North by Tract
No. 2, hereinafter described; on the
East by North Pitt Street; on the
South by a 16 foot alley; and on the
West by a 16 foot alley. Containing 25
feet in front on said North Pitt Streit
and extending at an even width 179
feet in depth to the aforesaid alley.
TRACT NO. 2:
BOUNDED on the East by North
Pitt Street; on the South by Tract No.
1, above described, on the West by
a 16 foot alley; and on the North by
lot now or formerly of Newton N.R.
Myers. Containing 6 feet in front on
said North Fitt Street and extending
at an even width 179 feet in depth to
the aforesaid alley.
HAVING erected thereon a dwell-
ing known as 622 North Pitt Street,
Carlisle, PA 17013.
PARCEL NO. 06-20-1798-034.
BEING the same premises which
Leonard R. McKee, Sr. and Bonnie
F. McKee, husband and wife, by
Deed dated 10/30/200 and recorded
10/31 /2002 in the Recorder's Office
of Cumberland County, Pennsylva-
nia, Deed Book Volume 254, Page
1553, granted and conveyed unto
Christopher A. Tessin.
a f? ~
Lawwwaw~....rw+.i.w.ae+:.sv.:,»,-',,:.ww~.,. .oe.. „~. ,-..
- The Patriot-News Co.
2020 Technology Pkwy
Suite~300 -
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
~he~latriot News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is
interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time,
place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verity this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
04116/10
of May, 2010 A.D.
coMMONweaLTH of PENNSnvlwra
NotaAal seat
5hertte L tOsner, Notary Punk
Lower Paxton TVvp., DauphM County
Commlastp~ Nov. 26, 2011
Member, PennsyNaMa A~sodatlon of Notaries
'~,..
f /,
04123110
04/30/10
MMIt Mor, ~dp~~Mi t~itM'tp~n
•+r~ItWlw~l d M q!y Aairik
vs.
AILS, thee, twe cdtaia keels of land with the
im~,venr.~.thaeon seeded stuate,in the
FifH.oCtheBarough•ofCadisle, County of
C~nnBalaud end State of Pmmsylvania.
ZRACTN0:1:'
BUCINb®:`on the'North by 1YaCt No, 2,
heranefta~ Acscribed q® the East by North Pitt
Street; on fire Sotuh by a Y6 foot alley; and on
the test by a 36 foot alley. Containing 25 fed
in fromoa said North Pitt ~eetaod eatendiag e<
an ev~m Width 179 feet is depth to tlrZ Aforesaid
a~Y•' ,
TRAC'1`N0.2
BBIINDED on the Bast by.i9arth Pitt Street;
on the Sontli by Tract No. 3, abovg described,
0o the ~4st by a 16 foW,altey;;aa<l on the Ni-rth
by lot now or fo~maly.of.Newton N.R. Myers..
Containing bfxt is fromonSaidNorthPitt Street
and extending at'an even width 319~fea in depth
to the aforesaid alley.
HA~iG erected thereon a dwelling known as
622 North Pitt Street, Catli~k, PA`17013.
PARCEGNO: (16-2t}~1798-034.:.,
BEING: t~ same premises which I:sonard R.
McIFee, Sr.-4nd .Bonnie F. lnt~iitee, httsband
and wife, by i~ dated 1Ot38l200 and-
recorded 10/31/200'L iat the per's Office of
Cumber.C~pr,Fta~gdvaariq i4aad Book
Vt>~ ~+ k333, gtiaatsti ad txu~syed
assn t~ristopber k'lLpin.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
} SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which PNC MTG is the grantee the same having been sold to said grantee on the
2ND day of JUNE A.D., 2010, under and by virtue of a writ Execution issued on the 1ST day of JAN,
A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 5885, at
the suit of NATIONAL CITY MTG against CHRISTOPHER A TASSIN is duly recorded as Instrument
Number 201018384.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this ~ day of
A.D. ~--~
Necorder of Deeds, Axrbedar~d Cauniy, Cerliste, PA
MY Commission Expires the Frst Monday of Jan. 2014