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Home My WebLink About01-3098 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 A TIORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION FLEET MORTGAGE CORPORATION FIKIA FLEET REAL ESTATE FUNDING CORPORATION 11200 WEST PARKLAND AVENUE MILWAUKEE, WI 53224 Plaintiff TERM NO. 01 - .30r;; Cui ('-r~ CUMBERLAND COUNTY v. WILLIAM H. DEVORE, JR. DONNA M. DEVORE 199 RIDGE HILL ROAD MECHAN1CSBURG, PA. 17055 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE ..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 ajudgment 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 HA VB 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 ": 71843403 1. Plaintiff is FLEET MORTGAGE CORPORATION F/KJA FLEET REAL ESTATE FUNDING CORPORATION 11200 WEST PARKLAND AVENUE MILWAUKEE, WI 53224 2. The name(s) and last known address(es) of the Defendant(s) are: WILLIAM H. DEVORE, JR. DONNA M. DEVORE 199 RIDGE HILL ROAD MECHANICSBURG, PA. 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 1219/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to AFFINITY NATIONAL MORTGAGE which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1187, Page 333. By Assignment of Mortgage recorded 2/2196 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 513, Page 1146. 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 2/110 I and each month thereafter are due and unpaid, and by the tenns 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 Interest 1/1/01 through 5/1/01 (Per Diem $19.89) Attorney's Fees Cumulative Late Charges 1219/93 to 511101 Cost of Suit and Title Search Subtotal $116,142.81 2,406.69 4,000.00 239.26 550.00 $123.338.76 Escrow Credit Deficit Subtotal 0.00 0.00 $ 0.00 TOTAL $123,338.76 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. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. 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." 10. 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 Plaintiffs 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 $123,338.76, together with interest from 511101 at the rate of$19.89 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. 13~~ FRANK FEDERMAN, ESQUIRE Attorney for Plainti ff APRIL 05, 2001 \\1LLlAM H DEVORE JR. 199 RIDGE HILL RD MECHANICSBURG PA 17055-??oo RE: ACCOUNT # 0071843403 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortJllllle on vour homc is in default. and the lender intends to foreclose. Specific information about the nature of thc default is provided in the attached pajleS. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save vour home. This notice explains how the PI'ORI'am works. To see if HEMAP can help. YOU must MEET WITH A COl"SUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when YOU meet with the CounselinJ1: AllCIlcv. The name, address and phone number of the Consumer Credit CounselinlZ AlZet1cv servinlZ your County are listed at the end of his notice. If yOU have any Questions, you may ca11 the Pennsylvania Housina Finance AllCIlcv toU free at 1-800-342-2397. (Persons with impaired hearinl! can ca11 (717) 780-1869). This Notice contains important legal information. If you have any questions, reprcsaltatives 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 association may be able to help you find a lawyer. LA NOTIFICACION EN AOJUNTO ES DE SUM A IMPORTANCIA, PUES AFECfA SU DERECHO A CONTINUAR VlVlENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDlTAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINAl'iCE AGENCY) SIN CARGOS AL NUMERO MENCONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWENER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR SU HIPOTECA. HOMEOWNER'S NAME(S): WILLIAM H DEVORE JR. DONNA M DEVORE PROPERTY ADDRESS: 199 RIDGE Hll.L ROAD MECHANlCSBURG PA 17055 0071843403 LOAN ACCT. NUMBER: ORIGINAL LENDER: CURRENT LENDER/SERVICER: GF. ACQL1SmON Fleet Mortgage Corp €.y...~\e\1 ".. APRR. 05, 2801 DONNA M DEVORE 199 RIDGE HR.L RD MECHAl\lCSBURG P A 17055-??oo RE: ACCOUNT # 0071843403 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortR8.Re 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 (HEMAP) may be able to help to save your home. This notice explains how the proltl'3m worlcs. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the CounselinR AlZeIlcv. The name. address and phone number of the Consumer Credit CounselinR AJ1,eIlcv servinR your County are listed at the end of his notice. If yOU have any Questions. you may call the Pennsylvania Housinl! Finance Al!encv toll free at 1-800-342-2397. (Persons with impaired hearinl! can call (7\7) 780-1869). This Notice COIltains important legal infonnation. 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 association may be able to help you find a lawyer. LA NOTlFICAClON EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECfA SU DERECHO A CONTINUAR VIVIEN DO E'" SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'" OBTENGA U1'iA TRADUCCION INMEDlTAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAM A LLAMADO "HOMEOWENER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL Cl:AL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR SU HIPOTECA. HOMEOWNER'S NAME(S): WR.UAM H DEVORE JR. DONNA M DEVORE PROPERTY ADDRESS: 199 RIDGE HILL ROAD MECHA. "ICSBL'RG 0071843403 PA 17055 LOAN ACCT. NUMBER: ORIGINAL LENDER: CURRENT LENDER/SERVICER: GE ACQUISITION e.1-\,\'\3\\ ~ Fleet 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 TI1E HOMEOWNER'S EMERGEi\CY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"'), YOI! MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTA~CE: IF YOUR DEFAULT HAS BEEN CAUSED B\' CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASOi\ABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINAi""CE AGENCY. TEMPORARY STAY OF FORECLOSURE. Under the Act, you are entided 10 a temporary stay oCCoreclosure on your mortgage Cor lhirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one oC the consumer credit counseling agencies Dsted at the end oC this Notice. THIS MEETING MUST OCCUR WlTHI1\' THE NEXT ~30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORI'GAGI; UP T DAlE. TH~ PARI OFTHIS NOIICt;CALLED NHOW 10 CURt. YOLiR MORIGAGE DEfAULI".I::XPLAINS HOW 10 BRI;"II(j YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENOES-Ifyou meet with one oCthe consumer credit counseling agencies DSled at the end oC this notice, the lender may NO I take action against you Cor thirty (30) days after the date of this meeting. The names, addresses, and telephone numbers of desianated consumer credit counselirur .Rendes for the countv in which me Dropertv is located are set forth at the end of this Notice. It is only necessary to schedule one face.to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE. Your mortgage is in default for the reasons set forth later in this Notice (see follOWIng pages for speCIfic information about the nature or your default). If you have tried and are unable to resolve this problem with the lender. you have the right to apply for tinancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Mortgage Assistance Program Application with one or the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseDng 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 thirt). (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 LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION. Available funds for emergency mortgage assistance are very limited. They will be disbursed by lIle Agency under the eli8'bility 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 lime. no foreclosure proceedings will be pursued against you. if you have met the time requirements set forth above. You will be notified direcdy by the Pennsylvania Housing Finance Agency of its decision of your appDcation. . NOTE: IF YOl: ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN AITEMPT TO COLLECT THE DEBT (If yo. .... filed banllrup\q', you ... still .pply for Em........,. Mort.... Assist......) HOW TO Ct:RE YOUR MORTGAGE DEFAULT <Drin!!: it UP to date). NATURE OF THE DEFAUL T- The MORTGAGE debt held by the above lender on your property located at: 199 RIDGE HILL ROAD MECHANlCSBURG PA 17055 IS SERIOlJSL Y I!\' DEFAULT BECAUSE: Financial Difficullies e.~\-\\e\' ~ A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS Cor the rollowing months and the rollowing amounts are now past due: Monthly I n'!allments: 02/01/0 1 03/01/01 0"/01/01 Other charges (explain:"il.emize): Late Charges: $ $ $ 79".28 79".28 79" 28 Uncollected Fees: Uncollecled late charges Less Credits 02/01/01 03/01/01 $ $ 39.71 ~Q 71 $ $ $ .00 119 13 .00 TOTAL AMOUNT PAST DUE: 5 2581. 39 B. YOU HAVE fAilED TO TAKE THE fOLLOWING ACfION (No. applIcable): HOW TO CURE THE DEFAULT- You may cure the deraul. within THIRTY (30) DAYS or the date or this notice BV PAVING THE rr>~AtH1.~g:iNJ':;~~W~oEMl~r~~~~~I\~E~H~~~~~i~ ~30) DN~M8D'. ~~~~~~:u~~~~Z~~:''i,~~~~~,~,~~ check. certified check. or money order made payable and sent to: FI.,.,t Mortgage Corp Allention: Cashiering P.O. Box 3147 Milwauk.,." \\1 53201-3147 You can cure any other default by taking the followmg action wlttun THIRTY (30) DA YS of the dale of this letter: (Not applicable): IF YOU DO NOT CURE THE DEFAULT- ICyou do not cure the deFault within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its fl S to accelerate the mort a e debt. This means that the entire outstanding balance of this debt will- e cons. ered ue imme lately. an you may ose the chance to pay the morlgage in monthly inslallmenlS. IF Full paymenl of the lolal amounl pasl due is noL made within THIRTY (30) DAYS. the lender also inlends 10 instruCI its allorneys to starllegal aclion to foreclose upon .our mortl!':atze aropertv. . IF THE MORTGAGE IS FORECLOSED UPON. The mortgaged property will be .old by the SherifTto pay off the mortgage debt. If the lender reFers your case to lIS allorneys, bUI you cure the delinquency beFore the lender begins legal proceedings againsl you, you will still be required 10 pay the reasonable allorney's Fees thaI were actually incurred. up 10 550.00. However. iF legal proceedings are Slarted againsl you, you will have to pay aU reasonable allorney's Cees aCblally incurred by the lender even iF they exceed 550.00. Any attorney's Fees will be added 10 the amount you owe the lender, which may also include other reasonable coslS. If you eure the default within the THIRTV (30) DA V period. yoU will not be required to ..... attorney's fees. OTHER LENDER REMEDlES- The lender may also sue you personally For the unpaid principal balance and all other sums due under the morlgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- ICyou have nol cured the default within the THIRTY (30) DA Y period and Coreclosure proceedings have begun, you may sliU have the rlRhllo cure the deFaul1 and prevenlthe sale al any time up to one hour before the Sherilrs Sale. You ma do so b a in the 10lal amount then asl due. Ius an late or other cI1ar then due. reasonable attomey's fees and costs connec1.ed with the foreclosure sale and any other cosls connecled with the SheriJT"s Sale as sp . led in writina bv the lender and by Derformina any other requirements under the mortaaae. Curing your default in the manner set forth in thIS notiee WIll restore your mortgage to the same positIon as If you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated thaI the earliest dale tha. such a Sherifrs Sale oCthe mortgage property could be held would be approXImately 9 months from the date or this Notiee. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may fmd out at any lime exactly what the required payment or action will be by contacting the lender. HOW TO CO:";TACf THE LENDER: Name of I.ender: Address: Fleet Mortgage Corp 1'.0. Hox 100500 Florence, SC 2950 I ~SOO 800-254-3677 84.1-673-4533 <:ollection Department E.~",,\a'1 A "hone :"liumber: Fax "umber: Contact Person: EFFECTS OF SHERIFF'S SALE.. You should realize tha' a Sherifl"s Sale will end your ownership or the mortgage property and your right to occupy IL II you conunue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your rurnistungs and other be1ongin&s could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You ma10r X may not sell or ..ansrer your home to a buyer or ..ansferee who WW assume the mortgage QeDt. proVlC1ed that all the outstandllll payments, charges, and attorney's fees and costs are paid prtor to or at the lale. and that the other requiremenu of the mortgage are salisfied. 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 PAYOFF THIS DEBT. . TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACfING O!'/ YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THE 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 A"Y OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SI;CH ACfIO!'/ BY THE LE~DER. . TO SEEK PROTECfION UNDER THE FEDERAL BANKRt:PTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE AITACHED Applicable Law requires us to inform you that, under these circumstances, we are acting as a debt collector, we are attempting to collect a debl, and any information will be used for that purpose. €.~",,\a\"'{ ~ PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8100) CLINTON COUNTY Lycominl-ClinmR Counties Commision for Community Action (STEP) 2131 Lincoln S..... P,O. Box 1321 Williomspon. PA 17703 (S70) 326-0517 FAX (S70) 322-2\97 CCCS ofNonhe....m PA 20 I Basin S...., Williomsport, PA 17703 (570) 323-6627 FAX (S70) 323-6626 31 W,Markc:ISIreOt POB 1127 Wilkes-Barre. PA 11702 (S70) 121-0137 or (100) 922-9537 FAX (S70) 121-1715 COLUMBIA COUNTY Commission on Economics Opportunity of Luzemc County 163 Amber Lan. Wilkes.Barre. PA 11702 (S70) S26-05 10 or (100) 122-0359 FAX (S70) 129-1665-{CIlI Belixe FaxinBl (S70) 455-1994 Hozeltown FAX (570) 455.563 I-{CIlI Belixe FaxinBl (S70) 136-lO9O Tunkhonnoclc Booker T. WashingtOn Center 1720 Holland CenlCl' Eri., PA 16503 (1\4)453-5744 FAX (114) S749 John F. Kennedv Center, Inc. 2021 East 20'" Street E"., PA 16510 (114) 19100400 F.~(114)191-1243 CCCS of Weslml PcMsyl.ania, Inc. 2000 Linsleslown Road Horrisburs. PA 17102 (717) 541-1757 Urban L..... ofM.lnlpClliWl Harrisburg N. 6. Stre., Horrisburg, PA 17101 (717) 234.5925 FAX (717) 234-9459 COlM1unity Action Comm of the Capital Region 1514 Derry Suee, HarrisbWJ, PA 17104 (717)232-9757 FAX(717)234-2227 CRAWFORD COUNT.... CUMBERLAND COUNTY CCCS ofNonheaslml PA 163 \ Sourh Arhenon SI., Sui.. \00 S.... Colle... PA 1610\ (114) 231-3661 FAX (114) 231.3669 1"00 Abingmn Executive Park Suite I Clarl" SummlL PA 11411 (570) 517.9163 or (100) 922.9537 FAX (S70) 517.9134.9135 Gre3lCr Ene CommuniE)' Action Comminee 11 Wes' 9. Slm:l Eri.. PA 16501 (114) 459-1511 FAX (114) 456-0161 Shooan.. VIlIey Urban Leagu.. Inc. 60 I lndiana Avenue Farrell, PA 16121 (412) 911-5310 Financial Counseling Services of Franklin 3 I Wesl 3~ S...., Waynesboro, PA 17261 (7\7) 762-3215 YWCA of Carlisi. 301 "G'"SIreOt Carlisi.. PA 17013 I (717)243-3111 FAX(717)7JI-9519 Adams County HoUSinl Aurhority 139.143 Carlisi. SL GcllysbWJ, PA 17325 (7\1) 334-1511 FAX 334-1326 PENNSYLVAl\l1A BULLETIN. VOL:I9, NO. 23, JUNE 5.1999 e.~\,\\af\ p.. ALL _ cmmuR ~ .... ~ of lazld -.1.__ 1ft _ 'ramIoh1p of SUver Spri,ng, 0:.: 4.,i or - ..... IZ"1anc! and a......._ --''t:h o~ P8'D'ISylvClia. IIIrZ'e p.ft.1cu1az'1y ~ ~.l and "-cz,1,bea _ .fol.1cN&, om W.:l.t:.1 ...........DlG _ . poJ.nt 1ft _ -._ of pubUa _p Read T00577, Icnawn .. 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Lat:a Jllca. 2 _ 1, JIIart:b ""ent:y-1Iix 1261 d .~U8 fit,.... 1151 _ _, . d1aunce of tOO>r hundred .,.,. _ e.igtlt:y-1:hI:ee _I>urlazedttla 1401.83) t!_ to . po1ft,. 1ft t:be cen10er of Ridge Hill Read (Too!!77) t!1ra" _.U..'II..s above. ti1ence alClnll _ cen~ u... ot! salcl JUdge Hill Read, _ 81~ (63) ~._.... f~1_ 1451 _ _, . distanee of ........_~ f~ 11401 teet to . point: 1ft t:tIa ._ .,. t:tIa dividi.ngl.ine _ _' Lat:a _. 2 """ 3 .. .-.. an _ ~f1:ez lIl8nt:1aned Plan of LobI, _ point: _ p1aoe of BIlGl:DlNDOG. I~ <>no .nd twO _ ~1x _~ (1.296) of an ___ of land. I IIEDlG ~ lb. 2 .. .-.. an . 8Ubdi.v1_ p1aD of 1I1-.s W, ..-.....-.. as _ by JolvI C. k"11had: sun.y:l.ne and Mapp1ng _.1 10>aI:1es W. Junk1nS, 1l8g1_ ~) and., JB4 1ft _ Office of the - "'- of Deeds 1ft ...., f.... n ~ .lazld ~Y. I'eIlnaylV1Ulia, 1ft Plan _ 23, 1'_ lB. ImVDG --.. _ . brido ...., a1animm1 _ 1:ype ao, '''"'9' _. 8EDOG _ __ pnad._ wh1c:h ftank M. 1I1c:h ...., Mazy Z- _. hill _. granted and _.~ 'Co 1a.111_ R. DeVc:lc1I. i1~. and DcnnII M. ElIIVc:IEe.. hill wife. ~...___ ~. PIlEMISES OR: 199 JUDGE HILL IIOAD VERIFICATION GAIL H. FINK. hereby states that she is VICE PRESIDENT of FLEET MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she 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 her knowledge, infonnation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 5/1 7 fO} GAl 1-) " (') .... ", ~ C' ~ ~ ~ <" ""':::' 0 ..t." . '. ~ " Of C5 ~'.. i ". 8 a (. r;:; . . d r- " - ~ g ~ ., ...., - t I .- . .. ~ .. " ~ ~ ..-, (0" ". '-l ~ -', .. ~ ~t SHERIFF'S RETURN - REGULAR CASE NO: 2001-03098 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FLEET MORTGAGE CORP ET AL VS DEVORE WILLIAM H JR ET AL RICHARD E. SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DEVORE JR WILLIAM H the DEFENDANT , at 1920:00 HOURS, on the 4th day of June , 2001 at 199 RIDGE HILL ROAD MECHANICSBURG, PA 17055 by handing to DONNA DEVORE WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.72 .00 10.00 .00 31.72 So Answe7~}-//' ~ r; ~.. - "c -r -P'br ~ R. Thomas Kline 06/07/2001 FEDERMAN & Sworn and Subscribed to before By: me this .It.!:!- day of \ L :U-O/ A.D. , (,\ ~, 0 n"",~., ~ ...... t'E;othonotary I'r! SHERIFF'S RETURN - REGULAR CASE NO: 2001-03098 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FLEET MORTGAGE CORP ET AL VS DEVORE WILLIAM H JR ET AL RICHARD E. SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DEVORE DONNA M the DEFENDANT , at 1920:00 HOURS, on the 4th day of June , 2001 at 199 RIDGE HILL ROAD MECHANICSBURG, PA 17055 by handing to DONNA DEVORE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers'",? tIP ~ -~4.;"~.~...,,,.,.:~ .~ T' .... .... ~ .. .-.---- R. Thomas Kline 06/07/2001 FEDERMAN & Sworn and Subscribed to before By: me this ;1t. ~ day of t j~~ L- V '. (----nt.L- t2 'In,,,;.. ~ ~ rothonotary ~7J/ A.D. FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia. PA 19103-1814 i2151 563-7000 FLEET MORTGAGE CORPORATION, FIK/A FLEET REAL ESTATE FUNDING CORPORATION 11200 WEST PARKLAND AVENUE MILWAUKEE, WI 53224 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION : 01- '20fiY : NO. OI~CIVIL VI. WILLIAM H. DEVORE, JR. DONNA M. DEVORE 199 RIDGE HILL ROAD MECHANICSBURG, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against WILLIAM H. DEVORE. JR. and DONNA M. DEVORE, Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest SII/Ol TO 7/11101 5123,338.76 $1,432.08 TOTAL 5124,770.84 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. CI1tlA1f 4P~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE DEREBY ASSESSED AS INDICATED. ~ DATE:.JrJ...y /~ ::u'JOJ fJM~' J 7? _ PRO ~OT **THIS FIRM IS A DEBT COLLEcrOR AlTEMPTING TO COLLEcr A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIns DEBT WAS NOT REAFFIRMED. THIS CORRESPONDENCE IS NOT AND SHOlILD NOT BE CONSTRlJED TO BE AN ATIEMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF FLEET MORTGAGE CORPORATION, F/K/A FLEET REAL EASTATE FUNDING CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. WILLIAM H. DEVORE, JR. DONNA M. DEVORE NO. 01-3098 CIVIL TERM Defendant(s) TO: WILLIAM H. DEVORE, JR. 199 RIDGE HILL ROAD MECHANICSBURG,PA 17055 DATE OF NOTICE: JUNE 26. 2001 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 AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN . Frank Federman, Esquire Identification No. 1224B One Penn Center Plaza at Suburban Station, suite 1400 philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF FLEET MORTGAGE CORPORATION, F/K/A FLEET REAL EASTATE FUNDING CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION plaintiff CUMBERLAND COUNTY vs. :NO.01-309B CIVIL TERM WILLIAM H. DEVORE, JR. DONNA M. DEVORE Defendant TO: DONNA M. DEVORE 199 RIDGE HILL ROAD MECHANICSBURG,PA 17055 DATE OF NOTICE: JUNE 26. 2001 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 AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman,Esquire Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Ooe Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff FLEET MORTGAGE CORPORATION, F/KlA FLEET REAL ESTATE FUNDING CORPORATION : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION :JO'If : NO. OI-)4II)9-CIVlL vs. WILLIAM H. DEVORE, JR. DONNA M. DEVORE VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on infonnation and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant WILLIAM H. DEVORE, JR. is over 18 years ofage and resides at 199 RIDGE HILL ROAD, MECHANICSBURG, PA 17055. (c) that defendant DONNA M. DEVORE is over 18 years of age, and resides at 199 RIDGE HILL ROAD, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~( ~ch./I/YJ~ FRANK FEDERMAN Attorney for Plaintiff (Rule of Civil Procedure No. 236 - Revised) FLEET MORTGAGE CORPORATION, FIKIA FLEET REAL ESTATE FUNDING CORPORATION : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. OI-3089-CIVIL WILLIAM H. DEVORE, JR. DONNA M. DEVORE Notice is given that a Judgment in the aboye captioned matter has been entered against you on JULY /7 .iMI. :lCOI. .' _ i\y /1,,-'. 8. .~.RA;y. JDEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUlRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR A TIEMPTlNG TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A'ITEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ~ if- i ~. ~ ~ "'- ~! ! ~ ~ "" ~ .... .f"' ~:.;. . ... . ~.. --. .. ... '" -< Co... _.~ PHELAN HALLINAN & SCHMEIG, LLP By: DANIEL G. SCHMIEG, ESQUIRE IDENTIFICATION NO. 62205 ONE PENN CENTER AT SUBURBAN STATION PHILADELPHIA, PA 19103 (215) 563-7000 FLEET MORTGAGE CORPORATION ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION v. WILLIAM H. DEVORE DONNA M. DEVORE NO. 01-3098-CIVIL CUMBERLAND COUNTY PRAECIPE TO V ACA TE JUDGMENT AND MARK THE ACTION DISCONTINUED AND ENDED WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly vacate the Judgment, which was entered on or about 7111/01 in the amount of, relative to the instant matter. j)~ G .2r~~/ Daniel G. Schmieg, Esquire Ii April12,2005 )t~ -<: -:-J c~~ leE -;." :-;j ;;~!~1 - ...D ~. " _.,,~~ _J