HomeMy WebLinkAbout01-2123 FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD
SUITE 1400
PHILADELPHIA, PA 19103-1814
~000
COURT OF COMMON PLEAS
MANUFACTURERS AND CIVIL DIVISION
TRADERS TRUST COMPANY
ONE FOUNTAIN PLAZA
BUFFALO, NY 14203
Plaintiff TERM
V.
DALE L. CROMER CUMBERLAND COUNTY
TAMMY L. CROMER
448 NORTH PITT STREET
CARLISLE, PA 17013
Defendant(s)
N__OTICE
**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.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Loan ti' 9787037
1. Plaintiff is
MANUFACTURERS AND
TRADERS TRUST COMPANY
ONE FOUNTAIN PLAZA
BUFFALO, NY 14203
2. The name(s) and last known address(es) of the Defendant(s) are:
DALE L. CROMER
TAMMY L. CROMER
448 NORTH PITT STREET
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 10/30/89 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to FARMERS TRUST COMPANY which mortgage is recorded in
the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 957, Page
312. PLAINTIFF is now the legal owner of the mortgage and is in the process of
formalizing an assignment of same.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 4/1/00 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 $19,005.19
Interest 1,730.92
3/1/00 through 4/1/01
(Per Diem $4.36)
Attorney's Fees 800.00
Cumulative Late Charges 143.76
10/30/89 to 4/I/01
Cost of Suit and Title Search 550.00
Subtotal $22~229.87
Escrow
Credit 0.00
Deficit 0.00
Subtotal $ 0.00
TOTAL $22,229.87
7. 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
Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. 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
$22,229.87, together with interest from 4/~0-~at the rate of $4.36 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' January 11, 2001 FORECLOSURE
TO'
Dale L. Cromer Tammy L. Cromer
448 N. Pitt Street 448 N. Pitt Street
Carlisle, PA 17013 Carlisle, PA 17013
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
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 MORTGAGE ASSISTANCE PROGRAM ~ be able to help to save
your home. This Notice explains how the program works
To see if HEMAP can hel o~st MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when you meet the
Counseling Agency.
The name, address and~ .number of Consumer Credit Counseli~n. cies ~ Coun_,W_0~
listed at thc end of this Notice. ~ h-~ve a--'~--~ue~ o'-~-~ma' call the P-~n~ Finance.
Ager:.cv 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 ADJ~JNTO 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 "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): Dale L. Cromer and Tammy L. Cromer
PROPERTY ADDRESS' 448 N. Pitt Street, Carlisle, PA 17013
LOAN ACCT. NO.: 9787037
ORIGINAL LENDER: Farmers Trust Company
CURRENT LENDER/SERVICER: M&T Mortgage Corp.
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 (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
end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO
NOT APPLY FOR ~MERGENCY 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.
CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit
counselin a~ncies listed at the end of this notice the lender ma~z NOT take action a ainst ou for thirty
30L~Q)_~.vs after the date of this meeting:. The names~_addresses and telephone numbers~ated
consumer credit counseling_ggencies for the county in w~S located are set forth at the end
of this Notice. It is only necessaq.' to schedule one face-to-face meeting. Advise your lender immediately
of your intentions.
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 IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
EXHII T A
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.)
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: 448 N. Pitt Street, 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: 4/1/00 thru 1/1/01 at $239.60 per month.
Monthly Payments Plus Late Charges Accrued $2,407.98
NSF: $0.00
In:pections: $0.00
Other: $0.00
(Suspense): $0.00
Total amount to cure default $2,407.98
B. YOU i-IAVE 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
th.;s notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,407.98,
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, L.L.P., One Penn
Center at Suburban Station, Suite 1400, 1617 John F. Kennedy Boulevard, Philadelphia, PA 19103-
1814,, Attention:Payoffs/Reinstatements 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. 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 attorney to start legal action to
foreclose upon your mortgage properts_'.
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 ,viii still be required to pay the reasonable attorney's
tees 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 exceec[ $50.00.
Any attorney's fees will be added to the amount you owe 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 tees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
F. XHI ff A
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 SheriWs Sale. You may do so
by paying the total amount then pa_st 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 mortgage 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 wh~t the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER: FEDERMAN AND PHELAN, L.L.P.
One Penn Center at Suburban Station, Suite 1400
1617 .John F. Kennedy Boulevard, Philadelphia, PA 19103
Tel:(215) 241-1711
Attention' Phyllis Levin, Payoffs/Reinstatements Dept.
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 SheriWs
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 truly yours,
FEDERMAN AND PHELAN, L.L.P.
Attn: Carmen Otero Account No.' 9787037
Mailed by Ist Class mail/Certificate of Mailing and Certified Mail No: 7106 4575 1294 1900
'7673. 7666
PENNS~VANIA HOUSING FINANCE AGENCY
HOMEOWNER,S EMERGENCY ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
(REV. 3/00)
CLINTON COUNTY
Lycoming-Clin~n Counties Conunision for -- --
Community Action (STEP) CCCS of Northeastern PA
2138 Linco{n Street P.O. Box 1328 1631 South Atherton St., Suite I00
Williamsport, PA ! 7703 State Co{lege, PA 16801
(570) 326-0587 FAX (570) 322-2197 (814) 238-3668 FAX (8!4) ~8-3669
CCCS of Northeastern PA
.' 201 Basin Street
Wiiliamsport, PA 17703
(570) 323-6627 FAX (570) 323-6626
31 W. Market Street COLUMBIA cOUNTY
POB 1127 ~ 1400 Abington Executive Park
Wilkes-Barre, PA 18702 Suite 1
(570) 821-0837 or (800) 922-9537 Clarks Summit, PA 18411
FAX (570) 821-1785 (570) 587-9163 or (800) 922-95.37
FAX (570) 587-9134-9135
Commission on Economics Opportunity of Luzeme County
163 Amber Lane
Wilkes-Barre, PA 18702
(570) 326-0510 or (gOO) 322-0359
FAX (570) ~29-1665--(Call Before Faxmg)
(570) 4554994 Hazeltown
FAX (570) 455-563 i---(Ca/I Before Faxing)
(570) 836-4090 Tunk. h~ock
· Booker T. Washington Center C~RAWFORD CO~
1720 Holland Center Greater Erie Community Action Committee
Erie, PA 16503 18 West 9' Street
(814) 453-574.4 FAX (814) 5749 Erie, PA 16501
(gl4) 4594581 FAX (814) 4564161
John F. Kennedy Center,
2021 East 20'~ Street Shenango Valley Urban League, Inc.
Erie, PA 16510 601 Indiana Avenue
(814) 898-0400 Farrell, PA 16121
FAX (814) 898-1243 (412) 981-5310
CCCS of Western Pennsylvania, Inc. -C--UMBERL,*~NrD COUNTY
2000 Linglestown Road - Financial Counseling Services ofl:'ranklin
Harrisburg, PA 17102 31 West 3~ Street"
(717) 541-1757 Waynesboro, PA 17268
(717) 762-3285
Urban League of Metropolitan Harrisburg
N. 6* Street YWCA of Carlisle
Harrisburg, PA 17101 301 "G" Street
(717) 234-5925 FAX (717) 234-9459 Carlisle, PA 17013
(717) 243-381g FA.X (717~'"731-9589
Community. Action Corem of the Capital Region
1514 Deny. Street Adams County Housing Authority
Hamsburg, PA 17104 139-143 Carlisle St.
(717) 232-9757 FAX (717) 23,4-222.7 Gettysburg, PA 17325
(717) 334-151g FAX 334-8326
PENNSYLVANIA BULLETIN, VOL 29, NO. 23, JUNE 5, 1999
ALL THAT CERTAIN lot or piece of land situate in the Fifth Ward of the
Borough of Carlisle, Cumberland County, Pennsylvania, bounded and
described in accordance with a survey and plan thereof made by Gerri=
J. )etz, Registered Surveyor, dated September 22, 1971, as follows:
BEGINNING at a point on the West side of North ~itt Street, said point
being 108.6 feet South of the Southwest corner of North Pitt Street
and "A" Street; thence along =he West si~e of Nor=h Pitt Street South
10 degrees 30 minutes West 30 feet to a corner of premises now or
formerly of Ralph McKee; thence along said premises and passing
through the center of a pa=tition wall North 79 degrees '30 minutes
west 165 feet to a point om the East side of a 15 foot alley; thence
along said alley North 10 degrees 30 minutes East 30 feet to a corner
of land now or formerly of Charles C. Yinger; thence along said land
Sou=h 79 degrees 30 minutes ~.ast 165 feet to the point and place of
BEGINNING.
HAVING thereon erected a two story frame dwelling house, known and
numbered as 448 North Pitt Str'eet, Carlisle.
BEING the same premises which Harry R. Poper and Carolyn L. Poper (now
known as Carolyn L. Olsen} by their deed dated June llth, 1986 and
recorded in the Office of the Recorder of Deeds in and for Cumberland
County at Book D, Vol. 32, Page 357, granted and conveyed unto Glenn
E. Hockenberry, Grantor herein.__ ~ _ .
P~SES' 448 NORTH PII'[
VERIFICATION
· . DENNIS GAWRON hereby states that he is BANKING OFFICER of MANUFACTURERS &
TRADERS MORTGAGE CORPORATION 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.
..
.
SHERIFF'S RETURN - REGULAR
CASE NO' 2001-02123 P
COMMONWEALTH OF PENNSYLVANIA'
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUS
VS
CROMER DALE L ET AL
SHANNON M. SUNDAY , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
CROMER DALE L the
DEFENDANT , at 1930-00 HOURS, on the 17th day of April , 2001
at 448 NORTH PITT STREEET
CARLISLE, PA 17013 by handing to
DALE L CROMER
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs- So Answers-
Docket ing 18.0 0 ~::,,~-*~
Af f i davit .00
Surcharge 10.00 R. Thomas Kline
.00
0 / s/200
FEDER~ & PHEL~
Sworn and Subscribed to before By- ~/~~
me this ~~ day of Deputy Sheriff
......
SHERIFF' S RETURN - REGULAR
CASE NO' 2001-02123 P
COMMONWEALTH OF PENNSYLVANIA'
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUS
VS
CROMER DALE L ET AL
SHANNON M. SUNDAY , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
CROMER TAMMY L the
DEFENDANT , at 1930-00 HOURS, on the 17th day of April , 2001
at 448 NORTH PITT STREET
CARLISLE, PA 17013 by handing to
TAMMY L. CROMER
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs- So Answers-
Docket ing 6.00 ~ ,..~. ~? . ......
· ..., . .. /.......-. · /...:
S e rvi c e 00 -~.~-~ ":'" -: "-': ' .~ ..... ; ~":'~-' ....
Af f i davit .00 "~' '" '"' ~ .......... ~ ..... '" ''~f' ~(''' ....
Surcharge 10. O0 R. Thomas Kline
.00
16.00 04/18/2001
FEDER~ & PHE~
Sworn and Subscribed to before By- ~f~~ ~~
me this ~~'~'~ day of Deputy Sheriff '
ool
FEDERMAN AND PItEL~
By' Frank Federman, Esquire
Atty. I.D. No.' 12248
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000 Attorney for Plaintiff
MANUFACTURERS AND
TRADERS TRUST COMPANY
Plaintiff Court of Common Pleas
CUMBERLAND County
vs. No. 01-2123 CIVIL TERM
DALE L. CROMER
TAMMT L. CROMER
Defendant(s)
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.
'- Frank Federman
Date Attorney for Plaintiff