HomeMy WebLinkAbout14-0231 Supreme Court of Pennsylvania
Court` Common Pleas
Civil Co ver Sheet For Prothonotary Use Only:
CUM ERLAND„ County Docket No:
J
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other papers as required by law or rules o cour
S Commencement of Action: El Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiff's Name: SANTANDER BANK, N.A. Lead Defendant's Name: ERIC S. MOORE A/K/A ERIC SCOTT
T MOORE
I Are money damages requested. El Yes 0 No Dollar Amount Requested: ❑ within arbitration limits
Q (Check one) outside arbitration limits
N Is this a Class Action Suit? ❑ Yes 0 No Is this an MDJ Appeal? ❑ Yes N No
A Name of Plaintiff /Appellant's Attorney: John Michael Kolesnik, Esq. , Id. No.308877 Phelan Hallinan LLP
❑ Check here if you have no attorney (are a Self- Represented (Pro Se] Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important,
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
❑ Premises Liability ❑ Statutory Appeal: Other
❑ Product Liability (does not
S include mass tort) ❑ Employment Dispute:
❑ Slander/Libel/ Defamation Discrimination
E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board
C ❑ Other:
T
I MASS TORT ❑ Other:
0 ❑ Asbestos
N ❑ Tobacco
❑ Toxic Tort - DES
❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration
$ ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
E Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
• Dental ❑ Partition ❑ Replevin
• Legal ❑ Quiet Title ❑ Other:
• Medical ❑ Other:
❑ Other Professional:
Pa.R.C.P. 205.5 Updated 01/01/2011
f J 7
41, -g y
�up��RL 4�
PHELAN HALLINAN, LLP
John Michael Kolesnik, Esq., Id. No.308877
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza ATTORNEY FOR PLAINTIFF
Philadelphia, PA 19103
John.Kolesnik@phelanhallinan.com
215 -563 -7000
SANTANDER BANK, N.A.
824 NORTH MARKET STREET, SUITE 100 COURT OF COMMON PLEAS
WILMINGTON, DE 19801
CIVIL DIVISION
Plaintiff
V. TERM
�V l
ERIC S. MOORE A/K/A ERIC SCOTT MOORE NO. ( H
390 NOLAN ROAD
MOUNT UNION, PA 17066 -2012 CUMBERLAND COUNTY
KRISTINA M. MOORE A/K/A K MOORE A/K/A
KRISTIN A. MARIE MOORE
390 NOLAN ROAD
MOUNT UNION, PA 17066 -2012
GLENN C. PARSONS
600 MOUNT ROCK ROAD
CARLISLE, PA 17015 -7427
Defendants
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
6 4 1
File #: 934297 C r �� a �v
1. Plaintiff is
SANTANDER BANK, N.A.
824 NORTH MARKET STREET, SUITE 100
WILMINGTON, DE 19801
2. The name(s) and last known address(es) of the Defendant(s) are:
ERIC S. MOORE A/K/A ERIC SCOTT MOORE
390 NOLAN ROAD
MOUNT UNION, PA 17066 -2012
KRISTINA M. MOORE A/K/A K MOORE A/K/A KRISTINA MARIE MOORE
390 NOLAN ROAD
MOUNT UNION, PA 17066 -2012
GLENN C. PARSONS
600 MOUNT ROCK ROAD
CARLISLE, PA 17015 -7427
who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 05/16/2005 ERIC S. MOORE, KRISTINA M. MOORE, and GLENN C.
PARSONS made, executed and delivered a mortgage upon the premises hereinafter
described to SOVEREIGN BANK, which mortgage is recorded in the Office of the
Recorder of Deeds of CUMBERLAND County, in Book 1907, Page 3821.The mortgage
and assignment(s), if any, are matters of public record and are incorporated herein by
reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its
obligations to attach documents to pleadings if those documents are of public record. Said
mortgage was modified as set forth in the modification agreement effective 01/01/2011.
4. Sovereign Bank is now known as Santander Bank, N.A.
5. The premises subject to said mortgage is described as attached.
File #: 934297
6. The mortgage is in default because monthly payments of principal and interest upon
said mortgage due 06/01/2013 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.
7. The following amounts are due on the mortgage as of 10/23/2013:
Principal Balance $197,376.85
Interest $1,876.03
05/01/2013 through 10/23/2013
Late Charges $810.94
Property Inspections $113.85
Escrow Deficit $2,058.78
TOTAL $202,236.45
8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in
2008, and/or Notice of Default as required by the mortgage document, as applicable, have
been sent to the Defendant(s).
File #: 934297
Y
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$202,236.45, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
PHEL HALLINAN, LLP
�
By:
Jo ichael Kolesnik, Esq., Id. No.308877
ttorney for Plaintiff
File #: 934297
M w
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or tract of land situate in the Township of Penn, County of
Cumberland and State of Pennsylvania, designated as Lot'13' as shown on Subdivision Plan
entitled'Final Subdivision Plan for Edgewood Estates' prepared by Eric L. Diffenbaugh,
Professional Land Surveyor, dated November 29, 2001, which plan has been approved by the
appropriate municipal authorities as a final Subdivision Plan, and which is recorded in the Office
of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 85, Page 33,
and is bounded and described as follows:
BEGINNING at a set railroad spike in the centerline of an 18 -foot paved cartway on Mt. Rock
Road and common corner of Lot Nos. 13 and 14; thence along the common boundary line of Lot
No. 13 and Lot No. 14, North 57 degrees 00 minutes 00 seconds West, 407.76 feet to a set iron
pin at corner of Lot No. 13, Lot No. 14 and Lot No. 12; thence along common boundary line of
Lot No. 12 and Lot No. 13, North 28 degrees 41 minutes 06 seconds East, 182.48 feet to a point
in the centerline of U.S. Route 11 (Ritner Highway); thence through the centerline of U.S. Route
11 (Ritner Highway), North 68 degrees 53 minutes 20 seconds East, 35 feet to a point; thence
continuing along same, North 71 degrees 16 minutes 52 seconds East, 661.50 feet to a point at
the corner of Lot No. 13 in the centerline of a 21 -foot paved cartway and an 18 -foot paved
cartway on Mt. Rock Road; thence along the centerline of an 18 -foot paved cartway on Mt. Rock
Road, South 32 degrees 15 minutes 26 seconds West, 141.50 feet to a set railroad spike; thence
continuing along same, South 34 degrees 2 minutes 55 seconds West, 500 feet to an existing
railroad spike; thence continuing along same, South 34 degrees 2 minutes 00 seconds West,
70.74 feet to an existing railroad spike; thence continuing along same, South 33 degrees 48'
minutes 15 seconds West, 17.45 feet to a set railroad spike, the point and place of BEGINNING.
PROPERTY ADDRESS: 600 MOUNT ROCK ROAD, CARLISLE, PA 17015 -7427
PARCEL #31 -09- 0521 -057.
File #: 934297
VERIFICATION
1AD'A , hereby states that he /she is Advn w i of SANTANDER
BANK, N.A., Plaintiff in this matter, that he /she is authorized to make this Verification, and
verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true
and correct to the best of his/her information 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: d-
Name.
Title: f
SANTANDER BANK, N.A.
File #: 934297
Name: MOORE
File #: 934297
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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BEABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249 -3166
(800) 990 -9108
File #: 934297
FORM 1 r�
C) xa f
IN THE COURT OF COMMON — S� ~
(,
SANTANDER BANK, N.A. OF CUMBERLAND COUNTY, PENIIVA
Plaintiff(s) "* ';Q C.3
vs.
ERIC S. MOORE A/K/A ERIC SCOTT MOORE Z cl�
KRISTINA M. MOORE A /K/A K MOORE A /K/A Z
KRISTINA MARIE MOORE
GLENN C. PARSONS �'
Defendant 3
' J
s) Civil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foeclosure action, you may be able to
participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference.
First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 2439400
extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you.
Once you have been appointed a legal representative, you must promptly meet with that legal representative within
twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all
requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal
representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the
service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attemptto work out reasonable arrangements with your
lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a
conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal
representative. However, you must provide your lawyer with all requested financial information so that a loan resolution
proposal can be prepared on your behalf. If you and your hwyer complete a financial worksheet in the format attached
hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed
within sixty (60) days of the service upon you of the foreclosure complaint. Ifyou do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable
arguments with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully sub ' d:
Date
ohn Michael Kolesnik, Esq., Id.
No.308877
Attorney for Plaintiff
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to determine
possible options while working with your counseling agency. Please provide the following information to
the best of your knowledge:
CUSTOM ER/PRI MARY APPLICANT
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
CO-BORROWER
Mailing Address:
City: State: Zip
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
• Is the loan in Bankruptcy? Yes ❑ No ❑
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model Year:
Amount owed: Value:
Automobile #2 : Model: Year:
Amount owed: Value:
Other transportation (automobiles, boats, motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1. Monthly Gross Monthly Net
2. Monthly Gross Monthly Net
3. Monthly Gross Monthly Net
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 Mortgage Utilities
Car Payment(s) ) Condo/Neigh. Fees
Auto Insurance Med. not covered
Auto fuel/repairs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Mone
Da /Child Care /Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency: Counselor:
Phone (Office): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)
assistance?
Yes R No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender and lender's loan servicing
company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTHORIZATION
I /We, , authorize the above named
to use /refer this information to my lender /servicer for the sole purpose of evaluating my
financial situation for possible mortgage options. I /We understand that I /we am /are under no obligation to
use the counseling services provided by the above named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and lender's
counsel:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation (hardship
letter)
6. Listing agreement (if property is currently on the market)
•
•
PHELAN HALLINAN,LLP 20i JAN 30 All 10' I49
Jonathan Lobb,Esq.,'Id.No.312174 • •
1617 JFK Boulevard, Suite 1400 CUMBERLAi'ID COUNTY
One Penn Ccnter Plaza PENNSYLVANIA
•
Philadelphia,PA 19103 • •
Jonathan.Lobb @phelanhallinan.com
215-563-7000 . . • • _
SANTANDER BANK, N.A. • . . : •COURT OF COMMON PLEAS •
• Plaintiff
• : CIVIL DIVISION
vs.
: CUMBERLAND COUNTY
ERIC S. MOORE A/K/A ERIC SCOTT : No. 14-231-CIVIL
MOORE
KRISTINA M. MOORE A/K/A K MOORE :
A/K/A KRISTINA MARIE MOORE
GLENN C. PARSONS
Defendants
PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
•
Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above
captioned matter.
PHELAN HALLINA/ LP •
By:
Jon. an Lobb, Esq., Id. No.312174
A torney for Plaintiff
Date: //2- // '
/nru, Svc Dept.
File#934297
"Ctlitl //T75J
724- r"&)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson PRO .,4r r r
Sheriff
.'"' of rttr�t?r y1,
Jody S Smith `� 7014 FEB 28 f'il 3°
Chief Deputy
W Stewart CUMBERLAND COUNTY
Solicitor PENNSYLVANIA
Santander Bank, N.A.
Case Number
vs.
Eric Moore(et al.) 2014-231
SHERIFF'S RETURN OF SERVICE
01/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Kristina Moore, but was unable to locate the Defendant in the
Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Mifflin, Pennsylvania to serve the within
Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure
according to law.
01/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Kristina Moore, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Huntingdon, Pennsylvania to serve the
within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage
Foreclosure according to law.
01/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Eric Moore, but was unable to locate the Defendant in the Sheriffs
bailiwick. The Sheriff therefore deputizes the Sheriff of Mifflin, Pennsylvania to serve the within Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according
to law.
01/10/2014 03:22 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Glenn C Parson, but was unable to locate the
Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 600
Mount Rock Road, Penn Township, Carilsle, PA 17015.
01/13/2014 01:56 PM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Kristina Moore, but was unable to locate the Defendant
in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage
Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as Not Found"at 600 Mount
Rock Road, Penn Township, Carlisle, PA 17015. Deputies were advised by a neighbor that the defendant
has not lived here for approximately two years.
01/14/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Eric Moore, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion
Program and Complaint in Mortgage Foreclosure as"Not Found"at 600 Mt. Rock Road, Penn Township,
Carlisle, PA 17015. Deputies were advised by a neighbor that the defendant is not currently residing at
this address but does stop by from time to time.
01/23/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in
Mortgage Foreclosure returned by the Sheriff of Huntingdon County,the within named Defendant Kristina
Moore, not found. William G. Walters, Sheriff, Return of Service attached to and made part of the within
record.
02/06/2014 01:50 PM -The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint
in Mortgage Foreclosure served by the Sheriff of Mifflin County upon Kristina Moore, personally, at 390
Nola Road, Mount Union, PA 17066. Christopher S. Shade, Sheriff, Return of Service attached to and
made part of the within record.
e'ff Tel•OSC`,�....
02/06/2014 01:50 PM -The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint
in Mortgage Foreclosure returned by the Sheriff of Mifflin County,the within named Defendant Eric
Moore, not found. Christopher S. Shade, Sheriff, Return of Service attached to and made part of the
within record.
SHERIFF COST: $104.78 SO ANSWERS,
February 19, 2014 RONNR ANDERSON, SHERIFF
Dui:Sheit�:"?eleeseft.;...,.
i-,-
,, ` 1` SHERIFF' S OFFICE
d ,4GDptiri
r ' -',�` t HUNTINGDON COUNTY, PENNSYLVANIA
1 ;� f t. �
j • T: °AfT84 /;� •• K .
. = �. 241 Mifflin Street
.''� .>,SyERI���` '' Huntingdon, PA 16652
p Telephone: 814-643-0880
`o;/ William G.Walters,Sheriff
Santander Bank, N. A.
No. 231 Term:2014
Vs.
Kristina Moore
21574 Parsons Farm Road
Blairs Mills, PA 17213
Now, this 23rd day of January , 2014 , I am unable to locate the within named
defendant, Kristina Moore , within my bailiwick, return this
Notice of Residential Mortgage Foreclosure Diversion Program,Notice and Complaint in Mortgage Foreclosure
"NOT FOUND." Reason unable to serve: defendant is believed to be living at
390 Nolan Road, Mount Union, PA 17066 (Mifflin Co.)
•
So Answers, ,yam
d9 /a
Sworn and subscribed to William G. Walters, Sheriff
before me this =(1
day of ..Q,,,bvtA t _ i Cm--ec 2.-------
20 (� , A.D. eputy Nicole A. Lippmann
Chief Deputy/Deputy
Costs:
Pr. •e•e i4 •o a u. c
COMMO � TH Of PENH;,, Rec. & Doc. $9.00
NOTARIAL SE i M �i Return Not Found $5.00
Tammy S.Foor,Notary Nt.'s, 1 Mileage/Postage $12.10
Huntingon Bore,Huntingdon County.ggs Surcharge ---
My commission ex'ties October 26.2:)i 4
- !
Affidavit $5.00
Miscellaneous ---
Total Costs $31.10 Paid
SHERIFF'S OFFICE OF MIFFLIN COUNTY
Christopher S.Shade Daniel Z.Searer, Esq
Sheriff Solicitor
4 1►
Laurie J. Kozak
Chief Deputy
Santander Bank, N.A.
vs. Case Number
Eric S. Moore(et al.) 2014-231
SHERIFF'S RETURN OF SERVICE
02/06/2014 01:50 PM-Deputy James Drayer, being duly sworn according to law, deposes and says, an attempt to
serve the Complaint in Mortgage Foreclosure(CIMF)upon Eric S. Moore, Defendant was unsuccessful.
Complaint in Mortgage Foreclosure(CIMF) returned Not Found.
I was advised that Subject, Eric S. Moore, current address is 600 Mount Rock Road, Carlisle, Pa. 17015
JAME DRAYER, DEPUTY
02/06/2014 01:50 PM-Deputy James Drayer, being duly sworn according to law, deposes and says,the Complaint in
Mortgage Foreclosure(CIMF)was served upon Kristina M Moore at 390 Nolan Drive, Mount Union, PA
17066 by handing a true and attested copy to the Defendant and made known the contents thereof.
9JAME DRAYER, DEPUTY
SHERIFF COST: $60.95 SO ANSWERS,
g4iL(147‘1004,
February 06, 2014 CHRISTOPHER S. SHADE, SHERIFF
NOTARY
Affirmed and subscribed to before me this
6TH day of FEBRUARY , 2014 , •
Plaintiff Attorney:Phelan Hallinan, LLP, One Penn Center, Suite 1400, P*.-s
(Ci i;ou tyx f... , t;a '"w'N1 L:RH OF ..N7LVANIA
5.unOf T..eesoft Inc
PATRICIA A.WILSON,Notary Public
lewistnwn Boro,Mifflin County
My Commission Expires March 31,2015
PHELAN HALLINAN, LLP
John Michael Kolesnik, Esq., Id. No.308877
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
John.Kolesnik@phelanhallinan.com
215 -563 -7000
SANTANDER BANK, N.A.
Plaintiff
vs.
f41lfAR 10 MI 9:39
CUMBERLAND COUNTY
PENNSYLVANIA
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: CUMBERLAND COUNTY
ERIC S. MOORE A/K/A ERIC SCOTT :
MOORE
KRISTINA M. MOORE A/K/A K MOORE :
A/K/A KRISTINA MARIE MOORE
GLENN C. PARSONS
Defendants
No. 14- 231 -CIVIL
PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above
captioned matter.
Date:
3/7//
/nru, Svc Dept.
File# 934297
By:
PHEL
AN, LLP
Jo Michael Kolesnik, Esq., Id. No.308877
torney for Plaintiff
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
f �[' i�'`? 1 1 F, t c'
Santander Bank, N.A.
vs.
Eric Moore (et al.)
Case Number
2014 -231
SHERIFF'S RETURN OF SERVICE
03/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Eric Moore, but was unable to locate the Defendant in the Sheriffs
bailiwick. The Sheriff therefore deputizes the Sheriff of Huntingdon, Pennsylvania to serve the within
Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure
according to law.
03/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Glenn C Parson, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Huntingdon, Pennsylvania to serve the
within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage
Foreclosure according to law.
03/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Glenn C Parson, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Mifflin, Pennsylvania to serve the within
Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure
according to law.
03/13/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in
Mortgage Foreclosure returned by the Sheriff of Mifflin County, the within named Defendant Glenn C
Parson, not found. Christopher S. Shade, Sheriff, Return of Service attached to and made part of the
within record.
03/18/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in
Mortgage Foreclosure served by the Sheriff of Huntingdon County upon Penny Parson, wife of defendant,
who accepted for Glenn C Parson, at 21574 Parsons Farms Road, Blairs Mills, PA 17213. William G.
Walters, Sheriff, Return of Service attached to and made part of the within record.
03/18/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in
Mortgage Foreclosure returned by the Sheriff of Huntingdon County, the within named Defendant Eric
Moore, not found. William G. Walters, Sheriff, Return of Service attached to and made part of the within
record.
`Per Huntingdon Sheriffs Office, defendant's address is 600 Mt. Rock Rock Road, Carlisle, but per
Cumberland County Sheriff's Return dated 1/14/14 the defendant no longer resides at this address but
does stop by from time to time.
SHERIFF COST: $78.00 SO ANSWERS,
April 07, 2014 RONNY R ANDERSON, SHERIFF
;oun &,iie 5., riff, Te eoso,.
Santander Bank, N. A.
SHERIFF'S OFFICE
HUNTINGDON COUNTY, PENNSYLVANIA
Vs.
Eric Moore
21574 Parsons Farm Road
Blairs Mills, PA 17213
241 Mifflin Street
Huntingdon, PA 16652
Telephone: 814 -643 -0880
William G. Walters, Sheriff
No. 231 Term: 2014
Now, this 18th day of March , 2014 , I am unable to locate the within named
defendant, Eric Moore
, within my bailiwick, return this
Notice and Complaint in Mortgage Foreclosure
"NOT FOUND." Reason unable to serve: defendants address is 600 Mt. Rock Road,
Carlisle, PA 17013
Sworn and subscribed to
before me this ary
day of
20
ono
COMMONWEAL
NOTARIAL SEAL
Tammy S. Foor, Notary Public
Huntingon Boro, Huntingdon County
My commission ex ires October 26, 2014
So Answers,
William G Walters_ Sheriff
eputy Rocco Panosetti, Jr.
Chief Deputy /Deputy
Costs:
Rec. & Doc.
Return Not Found
Mileage /Postage
Surcharge
Affidavit
Miscellaneous
Total Costs
See
First
Entry
See First Entry Paid
Santander Bank, N. A.
SHERIFF'S OFFICE
HUNTINGDON COUNTY, PENNSYLVANIA
Vs.
Glenn C. Parson
21574 Parsons Farm Road
Blairs Mills, PA 17213
241 Mifflin Street
Huntingdon, PA 16652
Telephone: 814 -643 -0880
William G. Walters, Sheriff
No. 231
Term: 2014
Now, this 18th day of March , 2014 , at 1012 HOURS I served the within
Notice and Complaint in Mortgage Foreclosure upon
Glenn C. Parson at
21574 Parsons Farm Road, Blairs Mills, PA 17213
by handing to Penny Parson, wife
one
true and correct copy /copies of the within Notice and Complaint in Mortgage
Foreclosure and made known to Penny Parson
the contents thereof. 1
Sworn and subscribed to
before me this
day of
20, (y D.
P
-:
CONIIv10
.;n
NOTARIAL SEAL
Tammy S. Foor, Notary Public
Huntingon Boro, Huntingdon County
My commission ex ires October 26, 2014
So Answers,
William G. Walters, Sheri f
eputy Ro 'co Panose
Chief Deputy /Deputy
Costs:
Rec. & Doc.
Service
Mileage /Postage $41.80
Surcharge
Affidavit $10.00
Miscellaneous
$9.00
$15.00
Total Costs $75.80 Paid
Christopher S. Shade
Sheriff
Laurie J. Kozak
Chief Deputy
SHERIFF'S OFFICE OF MIFFLIN COUNTY
Daniel Z. Searer, Esq
Solicitor
Santander Bank, N.A.
vs.
Glenn C Parson
Case Number
2014-231
03/13/2014
03/13/2014
SHERIFF'S RETURN OF SERVICE
01:55 PM - Deputy James Drayer, being duly sworn according to law, deposes and says, that service was
attempted to the Defendant, to wit: Glenn C Parson at 390 Nolan Drive, Mount Union, PA 17066. The
Defendant was found to have moved. Address being 21574 Parsons Farm Road, Blairs Mills PA 17213.
01:55 PM - Deputy James Drayer, being duly sworn according to law, deposes and says, an attempt to
serve the Complaint in Mortgage Foreclosure (CIMF) upon Glenn C Parson, Defendant was
unsuccessful. Complaint in Mortgage Foreclosure (CIMF) returned Not Found.
JAMES DRAYER, DEPUTY
SHERIFF COST: $59.21 SO ANSWERS,
March 13, 2014 CHRISTOPHER S. SHADE, SHERIFF
Affirmed and subscribed to before me this
13TH day of MARCH
Plaintiff Attorney: Phelan Hallinan, LLP, 1617 JFK Boulevard, Suite 1400, One Perth lazaO , Philadelphia, PA 19153
A TR PENNSYLVANIA
NOTARIAL SEAL
PATRICIA A. WILSON, Notary PubliC
Lewistown Bow, Mifflin County
My Commission Expires March 31, 2015
NOTARY
2014
(c)CountySuite Sheriff: Teleosoft, Inc
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
;11/20TECOTAi:
20114 APR 16 Af1 10: 06
Attorney For Plaintiff
moCUMBERLAND COUNTY
PENNSYLVANIA
SANTANDER BANK, N.A.
Plaintiff
v.
ERIC S. MOORE
A/K/A ERIC SCOTT MOORE
KRISTINA M. MOORE
A/K/A K MOORE
A/K/A KRISTINA MARIE MOORE
GLENN C. PARSONS
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 14-231-CIVIL
PRAECIPE
TO THE PROTHONOTARY:
Z Please withdraw, the complaint and mark the action Discontinued and Ended without prejudice.
Please mark the above referenced case Settled, Discontinued and Ended.
E Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
0 Please mark the in rem judgment Satisfied and the action Discontinued and Ended.
1-1 Please Vacate the Judgment entered.
Date: (411S 14
PH # 934297
PHELAN HALL AN, LLP
By:
Chrisovalante P. Fliakos, Esq., Id. No.94620
Attorney for Plaintiff
Attorney For Plaintiff
SANTANDER BANK, N.A.
Plaintiff
v.
ERIC S. MOORE
A/K/A ERIC SCOTT MOORE
KRISTINA M. MOORE
A/K/A K MOORE
A/K/A KRISTINA MARIE MOORE
GLENN C. PARSONS
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 14-231-CIVIL
CERTIFICATION OF SERVICE
I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by
regular mail to the person(s) on the date listed below:
ERIC S. MOORE
A/K/A ERIC SCOTT MOORE
21574 PARSONS FARMS RD
BLAIRS MILLS, PA 17213-9456
KRISTINA M. MOORE
A/K/A K MOORE
A/K/A KRISTINA MARIE MOORE
390 NOLAN ROAD
MOUNT UNION, PA 17066-2012
GLENN C. PARSONS
390 NOLAN RD
MOUNT UNION, PA 17066-2012
Date: 44/15
PHELAN HALLINAN.
By:
Chrisovalante P. Fliakos, Esq., Id. No.94620
Attorney for Plaintiff