HomeMy WebLinkAbout01-2504C. WILLIAM FAHNESTOCI~, gR., and : IN THE COURT OF COMMON PLEAS OF
ELAINE L. FAHNESTOCK, his wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs, :
: CIVIL ACTION o LAW
v. : NO. ~1 - ~ CIVIL TERM
ALLIANCE MORTGAGE COMPANY, :: Defendant.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend agains! the claims set forth in the
following pages, you must take action within ~venty (20) days after this complaint, order and
notice are served, by en~ring a written appearance personally or by attorney and filing in writing
with the court your defenses or objections to the claims sc~ 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 fu~her money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other fights important to you.
, IS PAPER TO YOUR LAWYER AT ONCE. IF YOU
U SHOULD TAKE TH . TO OR TELEPHONE
YO AFFORD ONE, GO
DO NOT HAVE A OR O OUT WHE YOU CAN GET LEGAL
THE OFFICE SET Fo~ ~ H BELOW T-- __N
HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) ?,49-3166
Americans with Disabilities
Act of 1990
The Cou~ of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
to disabled individuals having business before the court, please contact our
accommodations available least 72 hours prior to any hearing or business before the court.
office. All arransements must be made at
You must attend the scheduled conference or heating.
C. WILLIAM FAHNESTOCK, JR., and : IN THE COURT OF COMMON PLEAS OF
ELAINE L. FAHNESTOCK, his wife, : CUMBERLAND COUNTY, PENNSYLVANIA
plaintiffs, :
: CIVIL ACTION - LAW
;
¥o
: NO. Ol- .2 ~'o¥ CIVILTERM
ALLIANCE MORTGAGE COMPANY, :
Defendlmt. :
COMPLAINT TO COMPEL
SATISFACTION OF MORTGAGE
AND NOW, this 27th day of April, 2000, come the Plaintiffs C. WILLIAM
FAHNESTOCK, JR, and ELAINE L. FAHNESTOCK, his wife, by and through their
attorneys, Irwin, McKnight & Hughes, and make the following Complaint against the Defendant,
ALLIANCE MORTGAGE COMPANY, averring as follows:
Plaintiffs, C. William Fahnestock, Jr. and Elaine L. Fahnest~ck, his wife, are adult
individuals currently residing at 37 Woodcrest Drive, Carlisle, Cumberland County,
Pennsylvania, 17013.
Defendant, Alliance Mortgage Company, is a corporation existing under thc laws of
Florida, with its principal address at 8100 Nations Way, Jacksonville, Florida 32256.
Plaintiffs are now and for many years past have been the lawful owners and in possession
of their personal residence known and numbered as 37 Woodcrest Drive, Carlisle, Cumberland
County, Pennsylvania, 17013 (hereinafter referred to as the "Property").
The Property was granted and conveyed by Guy H. Foster and Alverta M. Foster, his
wife, to Plaintiffs by Deed dated October 13, 1977, and recorded in the Office of the Recorder of
Deeds for Cumberland County in Deed Book "L", Volume 27, Page 811. A true and correct
copy of said Deed is attached hereto and incorporated herein as Exhibit "A."
On or about September 29, 1978, Plaintiffs executed a Mortgage securing an interest
against the Property in the amount of $51,000.00 in favor of the Carlisle Building and Loan
Association of Carlisle, Pennsylvania, which mortgage is recorded in the Office of the Recorder
of Deeds for Cumberland County in Mortgage Book 650, Page 357. A true and correct copy of
said Mortgage is attached hereto and incorporated herein as Exhibit "B."
On or about December 3, 1999, the Mortgage was assigned flora Harris Savings Bank to
Defendant, Alliance Mortgage Company, and recorded in the Office of the Recorder of Deeds
for Cumberland County in Miscellaneous Book 632, Page 337. A U'ue and correct copy of the
Assignment of Mortgage is attached hereto and incorporated herein as Exhibit "C."
On or about July 13, 2000, Plaintiffs received a Payoff Statement from Defendant
indicating that the total remaining amount due under said Mortgage was $252.16, which amount
included interest to August 1, 2000. A true and correct copy of said Payoff Statement is attached
hereto and incorporated herein as Exhibit "D."
On or about July 24, 2000, pursuant to the Payoff Statement from Defendant, Plaintiffs
remitted payment in full in the amount of $252.16 to Defendant. A true and correct copy of the
Remittance Statement and check in the amount of $252.16 paid by Plaintiffs as final payment is
attached hereto and incorporated herein as Exhibit "E."
Plaintiffs have therefore paid end Defendant has received all sums due and owing to
Defendant pursuant to the Mortgage attached hereto as Exhibit "B" and assigned to Defendant
pursuant to Exhibit "C."
10.
By and through its actions, Defendant, Alliance Mortgage Company, promised to satisfy
the mortgage of record at the time of final payment.
11.
Since July of 2000, when Plaintiffs remitted full and final payment to Defendant,
Plaintiffs have repeatedly requested Defendant to satisfy said Mortgage. A hue end correct copy
of the most recent correspondence, dated February 9, 2001, and sent to Defendant by counsel for
Plaintiffs requesting satisfaction of the Mortgage, is attached hereto and incorporated herein as
Exhibit "F."
12.
Defendant has refused to satisfy the Mortgage of record and continues to refuse to do so
despite repeated requests by Plaintiffs.
13.
Pennsylvania law requires that a satisfaction piece be issued within forty-five (45) days
after a mortgagor has sent full payment due and owing under a mortgage and has requested that
the mortgage be satisfied. 21 P.S. §§ 681-682.
14.
Defendant has failed to mark the mortgage satisfied in the Office of Recorder of Deeds
for Cumberland County, Pennsylvania within forty-five (45) days of the receipt of full payment
and request by the Plaintiff for satisfaction, as required by Pennsylvania law.
15.
Under Pennsylvania law, statutory fines for neglect may be imposed where there is
failure to satisfy a mortgage within forty-five (45) days of the request following full payment of
all sums due and owing. 21 P.S. § 682.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court order that the
mortgage be marked satisfied of record. Plaintiff also respectfully requests that this Honorable
Court award any and such other further relief as this Court shall deem fair, just, and proper.
Respectfully Submitted,
IRWIN, McKNIOHT & HUOHES
Supreme Court I.D. No. 06282
Douglas G. Miller, Esquire
Supreme ~ourt I.D. ~o. ~776
60 West Pomi~et Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Attorneys for Plaintiffs
Date: April ~, 2001
VERIFICATION
The foregoing Complaint is based upon information which has been gathered by our
counsel and ourselves in the preparation of this action. We have read the statements made in this
document and they are ~ue and correct to the best of our knowledge, information and belief. We
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unswom falsification to authorities.
ELAINE I.. FAHNESTOCK
Date: April 27 , 2001
EXHIBIT "A"
13th ~ o! October
e/~~s~&~ and seventy-seven (1977). ~Aeymr
GUY B. FOSTER and ALVBRTA M. FOSTER, his wife, of
Penasboro To~nship, Cumberland County, Pennsylvan~a~
and CLAIR'~t.FAI~ESTOCB~and ~LA~t~B L. FAltNESTOCR, his Wife, of
Scrough of Neuville, Cumberlsnd vounty, Pennsylvania,
· "? ........ ('~ , .00) ........... ' ........
A~ t~c certain ~oC of gr~nd s~tuate ~n West Pen~boro
T~s~p, C~rhnd C~ncy, Pennsylvania, ~o~ Particularly
b~nded and described aa
BEGI~I~ aC a point on the n~he~ l~ne of ~oodcresC
~l~ on ~he d~v~d~ l~ne beC~en Lots Nos. 3 ~ ~ on the
~fCer mnCloned p~n o~ loCsj Chance by the nxche~
line o~ Woodcrest Dr~ve South 72 ~sree8 30 minutes 22 seco~8
WeaC ~ ~eeh Co a poinCi thence by a cu~e Co ~he T~ShC connecc~
~ nor~rn line o~ Woodc~sC DF~ w~ch the easCe~ line o~
Road, ~vi~ a radius o~ 23.00 ~eeC an arc le~Ch o~ 39.27teC and
chord le~ch o~ 33.36 ~ee~ on a chord b~r~ o~ North ~2 des~ees
09 ~nuCes 38 seconds WeoC Co · po~u~; thence al~ ~he Eas~e~ ".
l~ne o~ MI~ R~d~ North ~7 des~ees 09 m~nuCes 38 seconds West
233.~4teC ~oa point aC lands n~ or ~o~erly o~ C~r~e8 F. Nelson;
Chance by landb n~ or ~o~rly o~ Charles F. Nelson, North 70 desree8
~ ~nuCes 09 seconds East I~0.1~ fee~ ~o a point on the d~vidl~'
l~ne bergen ~cs Nos. 3 and ~ on Che herei~her mentioned Plan
Lots; ~hence by 8a~d d~v~d~ l~ne, S~Ch ~7 desrees 09 ~nuCes 38
seconds East 263.2G ~ee~ to a point on ~he northern ~ne o~ ~oodccesC
Dr~ve, .c~ place o~
BErG Loc No. 3 o~ Section "C' o~ Phn o~ ~ ~ as
~bd~v~s~on f~ ~y H. Foacer~ vhich Plan la recorded In C~berhnd
C~nCy ~an Book 29, ~ge 60.
B~I~ a of a larser tract of hnd v~h ~Ty C.
he~r8 ~ deadened OcCo~r 2~, 19~ end ~ourded ~n the O~ce
o~ cb Recorder o~ Deeds la and ~ ~berhnd County, Pennaylvanh,
in Deed Book "p", Vol. 12, pass ~ Startled end co~e~d ~o ~y
Foster, one o~ the ~an~ors here~n.
~e ab~ co--yale ~8 mdc under and subject co the
~ldl~ and uae ~esc~lct~ons:
lj All lo~e s~ll be used ~ res~dent~l ~oses Only.
2~ No d~ellir~ shall be erected upon n lot vhlch shall ~ost
lees than $30,000°00, besed upon COBS O£ n~ter~al and labor aa o~
Ja~ry) 1977.
3. NO l~s~ock o~ any k~ mt~le, sheep, ~gs, goats o~ '
horses and no p~lc~ o~ any kind ~hll be ~pC upon Chase loC8
A. No b~eed~z~ and ~reining ko.els ~or dogs or ocher an~ls
8~I1 be ~pC o~ minCal~d up~ C~ae 1oC8. ''
5. No ~e~o~a~y livid' s~c~u~a, including ~rallere or mbile
h~a, s~ll be b~il~' 9r mln~at~d upon ~hese
6. No mdu~r h~s s~ll be ~l~ or m~n~al~d upon ~hese
7. No au~b~le. Ju~ards order Cmrcial bu~id~s s~ll
be erected or m~nca~ed up~ C~se lot8.
8. aes~dence v~th~n a ~ra~e or ~t~lld~8 upon those lots
~s )roh~b~ted. .
9. Any dvelll~ t~t ho been started to ha erected ~sC
c~l~d vithin a periofl o~ one year and us un~nished
a~ per,tied Co stand a~t~r sa~d per~od. '
10. So ~ell~M, ~nclud~n; the p~ch, shell be erected closer
t~n ~10 ~C ~=~ Ch center line o~ any P~llc rMd or Street.
1~. ElectrLc service ~or tha pr~Lse8 e~ll be supplied onl7 by
the understand d~strLbut~on sysco.
..... S~BJ~. to a 9en~sy~ven~ Power & L~ht Co,any right-of-way
recorde~ in C~erla~d C~Aty Nlscellaneou8 Record Book 230,
962, et al.
T hereby certL£y the precise ~esLdence end
complete
post ££Lce edclress o~ tb~ wLth~n nmnd Grentees
October 13 , 1977 ~ '~--'~ ~ · I
Ce~f~ o! CL~£RLAAqD
~ ~' ~ 13th ~ e/ ' October
G~ H. ~ER and ~R~A
EXHIBIT "B"
,.d ~ ~,~ ~.,~ .................. ~? ""~ .o/zoo ......... '"
~ , .. e~ ~ the ~rlffa~ .
~-- _~. if ~r ~r
8~ZNNZ~ a~ a Point on the ~o~
d~v~d~g Z~e beCueefl hevn ueu and desovlbed
39.2~ : ..o~ R~d ~_:~,e~n Zlne o~ ~o~"c~ ~henee b --. ~ de~ee8
BOok 2o - ""E ~' POeCe~ ..~. ~ ~1~ o~ Lo~.~,~ae P~aoe oE B~;~-- ·
3U~ ~", VoZ. 27e ~' .fie Recovde~
--- uo ce~caln h;,~.~age 811. - ~- ueeds ~oP P.:~' ~[h. 1977
............ ~o~ (;517 r~E 357
~ m' hemHt(ler itllc]~d . t, and · Ic..~ ~ ~ itoflll a__ _ ~. pi ib?&.~.
..............................................................
EW3tlBIT "C"
P.O"_~:!','.. _',-i!~ }!.ER
C U~f,~ ER LMm'!) COUtlTY-pA
'99D£C 3 ,q/1 9 39
ooum~ Cr..r~BES.r..,AND
NL~C~L ~. CARLISLE
~ ~. 6033
PROPERTy ~D~gag: 37 ~DCRE~T ~R ~RLISLE PA 17013-~482
Said ~ ~e duly ~ ~ t~ ~gth ~y oE gE~E~ 19 78
~ or ~C ~. ~ty, tn ~ 650
a~c of FI~-ONE THOUS~ and NO 100 .....
~s~l, 000. O0
J~ES820.S. 00084
Bgo;,[ 632 ~c[ 337
EXHIBIT "D"
MORTGAGECOMPANY
Clair W Fahnestock
37 Woodcrest Dr
Carlisle, PA 17013
RE: Loan No. 006033
Loan Type: Conventional
Mortgagor(s): Clair W Fahnestock
~"'-~'~= P~ 1';'3!3
AMouNT NECESSARy TO PAY LOAN IN FULL ON OR BEFORE Au st 01 2000
These figures include interest To August 01, 2000.
This loan is due for the August 01, 2000 payment.
The CUrrent unpaid principal balance is:
Interest at 7.62500% $ 250.57
- - - TOTAL AMOUNT TO PAY LO~ IN FULL .... 1.59
* 252.16
Funds received after August 01, 2000 will require an additional
$.05 interest per Day.
INSTRUCTiONs
~ QUOTE AMOUNT: IS SUBJECT TO CHA~GE WITHOUT NOTICE DUE TO TRANSACTIoNs
ON OR AFTER THE DATE OF T~IS QUOTE. IT IS YOUR RESPONSIBILITY TO VERIFY
THE AMOUNTS ON THIS STATEMENT PRIOR TO CLOSING AND VERIFy THE PROPERTy
ADDRESS IS THE ONE YOU REQUESTED. WE SUGGEST YOU CALL (800) 669-9721 FOR
OBTAIN A VERBAL UPDATH PRIOR TO SENDING THH PAYOFF CHECK.
These figures are subject to final verification by the Noteholder.
PA'tOFF unpaid i e,ns ti
~ ~ £ wlll be deducted from any available escrow fund-
be adjusted if any Pa}~ent previously received is rejected by the
institution Upon which it was dra~. If funds received are not
sufficient to pay the loan in full, we will attempt to contact you once
verbally. If the necessary funds are not received within 24 hours, we
will return your remittance and you will he liable for any additional
interest due.
continue~ next Page . . .
PAOE 2, ~ ~. 006033
MORTGAGE COMPANy
~. ESCROW: ~LI~CE MOR~AGE COMP~ WILL COSINE TO ~AY ESCRO~D ITEMS
~IL T~IS ~ IS PAID IN ~LL. ~y remainin~ escrow balance will be
refunded within 30 days of payoff. To avoid delays ~n receipt of your
refund, ~lease notify us of any address chan~e on the attached fo~.
4. PA~ENTS: Issuance of this statement does NOT suspend the contractual
retirement to make mortgage pa~ents when due. A late Charge of
$ ~2.8~ %:ii! be a~scs~ed ~5 days -~ w
and must be added to the payoff total if received after that time.
If we currently draft your monthly mortgage pa~ent you ~ST have
this process stopped. Please notify Customer Se~ice by callin~
(800) 669-9721 no later than the 18th of the month Drior to payoff.
5. REMITT~CE OF PAYOFF: PERSONAL ~ECKS ~E NOT ACCEPTED FOR PAYOFF.
Interest continues to accrue until the date the payoff ~s RECEI~D by
Alliance Mortgage. There are 2 options for remittin~ the payoff funds:
TO ~IL ~S: Forward to one of the followin~ addresses:
OVE~I~T DELI~Ry:
RE~ ~IL:
Alliance Mortgage Company Alliance Mortgage Co~any
Attn: Payoff Department Attn: Payoff Department
8100 Nations Way P.O. Box 44040
Jacksonville, FL 32256
Jacksonville, FL 32232
TO WIRE ~S: First Union National Bank of Florida
(wires only, Jacksonville, Florida
no deposits) ~A No. 063000021
Account No. 2112639030984
Alliance Sor~a~e Pa)'ment Ciearin~ Account
Reference: Payoff Loan 006033, Clair W Fa~es~ock
The wire transf
er ~ST have the Alliance Mcr
~o~tgag~r's name to process the funds. W~ m-~a~ ~?~n numar and
· acer =nan 2:00 p.m. EST. =-.-~- - ... . ........ c=lve =he ~unds no
be processe~ ,,.+~ ~ =m,u~ zecel.ea after 2:00 p.m. wil~ ~-
~= - - -..~ u~e next business dau a.~ .~..~= . . - ~ ,,uu
u~rougn that day. If we ar .... =~ = .~ .... ~uuau include interest
t you call us at (800) 669-9721 the ..... e~s owed. We recommend~
payoff. Please forward -~' . _ ~o~owxng business day to confi~
refunds immedlatelv wit~n~nz~etlon for documents and escrow -'"
~ ~',= auuacne~ form.
A
$10.00 FEE WILL BE C~
W~ERE APPLI~LE. ~ ~u~ ~C, DUPL~TE ,TATEM~ PRODUCED,
EXHIBIT "E"
)
""" COPy
Alliance. ,-,,, E ,oR ,o,,, ,,o. oo,o,, -
MORTGAGE COMPANY ~ .......
PAYOff 0UOTL'D ~uly 13, 2000 ~ O~ August 01, 2000
PLEASE COMPLETE THE FOLLOWING'AND FORWARD WITH PAYOFF FUNDS:
(if wiring funds please fax to (904) 281-6115)
A~ount q~/oted
$ 252.16
If Variance (List Reason
)
(i.e. additional fees, interest due)
Total Amount Remitted
2. ESCROW/REFUNDADDRESS:
The address on record to forward escrow refunds and year end reporting
information is as follows; if this is changing please list the new
address:
NEW ADDRESS (if applicable): ADDREss ON RECORD
Clair W Fahnestock
Carlisle, PA 17013-9482
New Phone No. (_ )
ES:
3. DOCUMENT ADDRESS:
Name/Address to forward documents, if other than above:
Name/Company:
attn:
Street:
City, State, Zip:
4. DOCD-MEI~T RECORDING & LEGAL INFORMATION:
To expedite the release process, p/ease provide the following:
- Copy of the recorded instrument
OR
Copy of schedule "A" or B of the title policy INCLUDING RECORDING DATE,
INSTRUMENT NUMBER OR BOOK AND PAGE, ORIGIN-ALMORTGAGEE OR BENEFICIARY
AND TRUSTEE IF APPLICABLE.
Completed bY/Title:
XF002/JB1
Please return completed form to:
Alliance Mortgage Company, P.O. Box 44040, Jacksonville, FL 32232
EXHIBIT "F"
LAW OFFICES
IRWIN McKNIGHT & HUGHES "
WEST PO4IFRET PROFESSION, aL BUll,DING
RC, GER a. IRi~'l.¥ 60 tVEST POt14FRET STREET
M.4/?Cb'$.t. McKHIGIfT. #1 CARl. ISLE. PENNSYI V,4NIA 17013.3222
February 9, 2001
Alliance Mortgage Company %
ATTENTION: PAY-OFF DEPARTMENT cc,
P. O. Box 44040Jacksonville, Florida 37232 ..r..
Re: CLAIR W. FAHNESTOCK %
37 WOODCREST DR_WE, CARLISLE
TO ~rHOM IT MAY CONCERN:
Please be advised that I represent Mr. Clair Ix,.'. Fahnestock.
According to the attached papers (copy A, copy B, copy C) he pa/d-off your loan on
August I. 2000. - .
As of February 9, 2001, the Mortgage has not been satisfied in the Cumberland Count,,.
Courthouse despite repeated requests from him for you to do so. -
Pennsylvania law requires a sads£aetion · ·
when_ a mortgagor has sent t _:_ piece.to be issued within fortv- -
sat, stied. 2.1 P.S. § 68I. Be,,otnhde-a.-p,-pr-°.P"a~ sumfl oz money requesting that'afive_ ?5) days
In accordance with Pennsylvania [aw, we request that this mortgage (see copy attached)
be satisfied immediately. Failure
in legal action, as provided above, to satisfy this mortgage before the end of February may result
or action through the Pennsylvania Department of"Banl~ing.
Sincerely yours,
IRWIN, McKNIGHT & HUGHES
RBl,%arn Roger B. Irwin
Enc/
cc~ Hr. Tom Bream
~aypoin~ Bank
235 N. 2nd St
Harrisburg, PA 17101
Hr. Clair ~. Fahnestock
37 goodcresc Dr
Carlisle, PA 17013
C. WILLIAM FAHNESTOCK, JR. and : IN THE COURT OF COMMON PLEAS OF
ELAINE L. F~nNESTOCK, his wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs, :
: CIVIL ACTION - LAW
V,
: NO. 01-2~04 CIVIL TERM
~I.I.IANCE MORTGAGE COMPANY, :
Defendant. :
AFFIDAVIT OF SERVICE OF
COMPLAINT TO COMPEL
SATISFACTION OF MORTGAGE
COMMONWEALTH OF PENNSYLVANIA :
: SS:
COUNTY OF CUMBERLAND :
NOW, Douglas G. Miller, Esquire, being duly sworn according to law, does depose and state:
I. That he is a compe~em adult and atWmey for the Plaintiff~, C. William Fahnes~ock, .Ir. and Elaine
L. Fahnestock, in the above-captioned action.
2. That a certified copy of the Complaint ~o Compel Satisfaction of Mortgage was served upon
Defendant, Alliance Mortgage Company, on May 3, 2001, by certified mail, addressed to it at 8100 Nations
Way, Jacksonville, Florida 32256, Return Receipt No. 7099 3400 0018 4997 1223.
3. That the said receipt for certified mail is signed and altached hereto and made a part hereof.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unswom
falsification to authorities
Date: May 7, 2001 DOU ~R,
Supreme Court I.D. No. 83776
Attorney for Pbintiffs,
C. Winism Falmestock, Jr. and
Einine L. Fahnestock
r.,i
· Complete items 1.2. and 3. AJso Complete
Item 4 if Res[flct~l Dellv~y
· I:~nt your name and address on the reveme
~o that we can return the card to you.
· Attach this can:l to the back of the mai/piece,
~or on the front if space Permits. ~ Agent
' adcbe~ dfffomnt frem item 17
~[~A~C~ ~0~.~.~ C~j~i~ If YES, enter de#ve~ address below: ~i' No
8100 RATZONs VAT
· ]AC~Ioln~M.E ~ 32256
~B Cerlified Mail I'1 Express Mail
I-I Regfate~cl i Retum Receipt for MemhandMe
L3 C.O.D.
P8 Fom~ 3811. Ju~y ~ Dom,,~ R,tum R~:,~
C. WILLIAM FAHNESTOCK, JR., and : IN THE COURT OF COMMON PLEAS OF
ELAINE L. FAHNESTOCK, his wife,
i CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs,
: CIVIL ACTION. LAW
¥.
;
ALLIANCE MORTGAGE COMPANY, ~ No. 2001 - 2504 CIVIL TERM
Defendant. :
P~RAECIPE TO SE3~FLE_ AND DISCONTINUE
TO CURTIS R. LONG, PROTHONOTARY:
Please mark the above-captioned case settled and discontinued and mark any judgment
related thereto as paid in full and satisfied and issue evidence of the same to the undersigned.
Respectfully submitted,
IRWIN, MeKNIGHT & HUGHES
Date: May 31, 2001 By: ~
Supreme Court ID #83776
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Attorney for Plaintiffs