HomeMy WebLinkAbout14-0813 Supreme Court�of Pennsylvania
Courkb Comm Pleas
For Prothonotary Use Only:
CXV>!l; Cove B eet
CUMBC AS i -'r ' Coun Docket No:
?
The information collected on this form is used solely for court administration purposes. This form does not
supplement or rep lace the filing and service ofpleadings or other a ers as requiredby law or rules o court.
S Commencement of Action:
Complaint ❑ Writ of Summons ❑ Petition
E+ ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiff's Name: CITIMORTGAGE, INC. Lead Defendant's Name: RICHARD J. NAZAY, JR A /K/A
T RICHARD J. NAZAY
I Are money damages requested? ❑ Yes Z No Dollar Amount Requested: ❑ within arbitration limits
0 (Check one) outside arbitration limits
N Is this a Class Action Suit? ❑ Yes Z No Is this an MDJ Appeal? ❑ Yes Z No
A Name of Plaintiff/Appellant's Attorney: John D. Krohn, Esq., Id. No.312244, 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
B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
Z 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
04
tIIERLAN
PEN piSYLVA CO ' U NTY
N
PHELAN HALLINAN, LLP
John D. Krohn, Esq., Id. No.312244
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza ATTORNEY FOR PLAINTIFF
Philadelphia, PA 19103
john.krohn@phelanhallinan.com
215 -563 -7000
CITIMORTGAGE, INC.
1000 TECHNOLOGY DRIVE COURT OF COMMON PLEAS
OTALLON, MO 63368
CIVIL DIVISION
Plaintiff
V. TERM
RICHARD J. NAZAY, JR A/K/A RICHARD J. NAZAY NO.
24 COLD SPRINGS ROAD
CARLISLE, PA 17015 -7600 CUMBERLAND COUNTY
RUTH C. NAZAY
24 COLD SPRINGS ROAD
CARLISLE, PA 17015 -7600
Defendants
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 939897
C 3� aa9
1. Plaintiff is
CITIMORTGAGE, INC.
1000 TECHNOLOGY DRIVE
OTALLON, MO 63368
2. The name(s) and last known address(es) of the Defendant(s) are:
RICHARD J. NAZAY, JR A/KJA RICHARD J. NAZAY
24 COLD SPRINGS ROAD
CARLISLE, PA 17015 -7600
RUTH C. NAZAY
24 COLD SPRINGS ROAD
CARLISLE, PA 17015 -7600
who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 05/23/2003 RICHARD J. NAZAY, JR and RUTH C. NAZAY made, executed and
delivered a mortgage upon the premises hereinafter described to MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR SUPERIOR
HOME MORTGAGE CORPORATION, which mortgage is recorded in the Office of the
Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1815, Page 2156. By
Assignment of Mortgage recorded 11/19/2013 the mortgage was assigned to PLAINTIFF,
which Assignment is recorded in Assignment of Mortgage Instrument No.
201337166.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.
4, The premises subject to said mortgage is described as attached.
Fite t 939897
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 09/01/2013 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.
6. The following amounts are due on the mortgage as of 01/06/2014:
Principal Balance $141,364.32
Interest 08/01/2013 through 01/06/2014 $3,194.02
Accumulated Late Charge Balance $0.00
Less Escrow Balance 888.62
TOTAL $143,864.08
7.1 Plaintiff is not seeking a judgment of personal liability (or an in person am 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.
8. 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 Defendants) on the date(s) set forth thereon, and the temporary stay as
provided by said notice has terminated because Defendant(s) has/have failed to meet with
the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied
assistance by the Pennsylvania Housing Finance Agency.
Fife #: 939897
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$143,864.08, 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.
PHELAN HALLINAN, LLP
By:
John D. Kro , Esq., Id. No.312244
Attorney forfPlaintiff
File #: 939897
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County,
Pennsylvania, bounded and described as follows:
BEGINNING at a point on the western dedicated right of way line of Cold Spring Road
(T -356) at the dividing line between lots 14 and 5 on the hereinafter mentioned subdivision plan;
thence along said dividing line by a curve to the right with a radius of 23 1.3 5 feet an arc distance
of 120.91 feet; thence along same South 76 degrees 49 minutes 30 seconds West 543.14 feet to a
point; thence along same North 16 degrees. 40 minutes 25 seconds West 37.90 feet to a point;
thence along lands now or formerly of Lester Eser North 16 degrees 40 minutes 25 seconds West
335.47 feet to a point; thence along the dividing line between Lots 5 and 7 on said plan North 77
degrees 41 minutes 20 seconds East 352.11 feet to a point; thence along the dividing line
between Lots 5 and 6 on said plan South 12 degrees 18 minutes 40 seconds East 150.00 feet to a
point; thence along same North 77 degrees 41 minutes 20 seconds East 315.40 feet to a point;
thence along the western dedicated right of way line of Cold Spring Road by a curve to the left
with a radius of 395.00 an arc distance of 150.00 feet to a point, the Place of BEGINNING.
CONTAINING 3.827 acres, exclusive of the dedicated right -of -way of Cold Spring Road
as described on the hereinabove mentioned subdivision plan.
BEING further described as Lot No. 5 of the Final Plan of Major Subdivision for Cold
Springs Meadows prepared by Rodney Lee Decker, R.S. dated June 5, 1989 and recorded in
Cumberland County Plan Book 59, Page 128.
File fit: 939897
BEING THE SAME PREMISES which Steven J. Harman, by his Deed dated March 6, 1998 and
recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in
Deed Book 173, page 422, granted and conveyed unto Richard J. Nazay and Ruth C. Nazay,
husband and wife, Grantors herein.
PROPERTY ADDRESS: 24 COLD SPRINGS ROAD, CARLISLE, PA 17015 -7600
PARCEL #08 -12- 0338 -083
File #: 939897
VERIFICATION
Heather Minear, hereby states that she is Vice President - Document Control of,
CITIMORTGAGE, INC., Plaintiff in this matter and is authorized to make this Verification. The
statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and
correct to the best of my information and belief.
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904
relating to unsworn falsification to authorities.
AFFIANT:
By: _
Print:
Title : * esidolt n )Yn
employed by CitiMortgagle, Inc.
Plaintiff: &VI
Date:
File #: 939897
Name: NAZAY
Attorney File No.: 939897
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 BE ABLE.
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 #: 939897
FORM 1
IN THE COURT OF COMMON PLEAS
CITIMORTGAGE, INC. OF CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
vs.
RICHARD J. NAZAY, JR A/K/A RICHARD J.
NAZAY `
RUTH C. NAZAY
Defendant(s) i I ' U Civil rri - n -'
NOTICE OF RESIDENTIAL MORTGAGE FORECLQSUfE c.,;
DIVERSION PROGRAM
:r_ CD
You have been served with a foreclosure complaint that could cause you to lose your home. Y
If you own and live in the residential property which is the subject of this foreclosure action, yoavna} -lie alk 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 Cout 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 attempt to work out reasonable arrangenents 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 lawyer complete a financial woksheet 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. If you do so and a conciliation onference 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 submitted:
Date John D. Krohn, Esq., Id.
No.312244
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, motorc cje 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 nd 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 ❑ 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)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson w, - i 0.
Sheriff
Jody S Smith ''°� t iarai��f4rfi/ HE i iC i i1 �
Chief Deputy - 2n1 if FEB 28 Pti 3: d
Richard W Stewart
Solicitor ,r. . r ;:� �
PENNSYLVANIA
Citimortgage Inc.
vs. Case Number
Richard J Nazay(et al.) 2014-813
SHERIFF'S RETURN OF SERVICE
02/19/2014 11:52 AM- Deputy Shawn Harrison, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally" handing a true copy to a person representing themselves to :e the D: - •ant, to wit:
Richard J Nazay at Manor Care, 940 Walnut Bottom Road, South Middl=ill p - isle, PA 17015. As
per defendant the residence at 24 Cold Springs Road, Carlisle, PA 1701 - :c:
!
SH' HAR'i N, DEP TY
02/21/2014 08:09 PM- Deputy Shawn Harrison, being duly sworn according to law, served the re. -sted Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in M. •age Fo -closure by
"personally" handing a true copy to a person representing themselves to •- - D: end,nt, to wit: Ruth C
Nazay at 33 Country View Est, Upper Frankford, Newville, PA 17241.
lir
SH' N HARRI •', . i Y
SHERIFF COST: $71.58 SO ANSWERS,
February 25, 2014 RONIR ANDERSON, SHERIFF
PHELAN HALLINAN, LLP
Emily M. Phelan. Esq., Id. No.315250
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
emily.phelan@phelanhallinan.com
215-563-7000
CITIMORTGAGE, INC.
VS.
RICHARD J. NAZAY, JR A/K/A
RICHARD J. NAZAY
RUTH C. NAZAY
)1.
11TE PRO T A
Attorney for Plaintiff
20iii APR 21 A11101 I 8
CUMBERLAND COUNT
FINNS YL VA Ni A
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: No. 14-813 CIVIL
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against RICHARD J. NAZAY, JR
A/K/A RICHARD J. NAZAY and RUTH C. NAZAY, Defendants 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
TOTAL
$143,864.08
$143,864.08
I hereby certify that (1) the Defendants' last known addresses are 940 WALNUT
BOTTOM ROAD, CARLISLE, PA 17015-6926, 24 COLD SPRINGS ROAD, CARLISLE, PA
17015-7600, and 33 COUNTRY VIEW ESTATE, NEWVILLE, P1 41, and hat notice
has been given 'n accorda ce with Rule Pa.R.C.P 237.1.
Date
DAMAGES ARE HEREBY ASSESSED AS INDICATED...
4,D tt'k
DATE: (.4
PH 8 939897
PROTHONOTARY
aI
939 gPI C112?/c7
_47436 LIU LP
PHELAN HALLINAN, LLP
Emily M. Phelan, Esq., Id. No.315250
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
emily.phelan@phelanhallinan.com
215 -563 -7000
Attorney for Plaintiff
CITIMORTGAGE, INC. : CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
vs.
: CIVIL DIVISION
RICHARD J. NAZAY, JR A/K/A
RICHARD J. NAZAY : No. 14 -813 CIVIL
RUTH C. NAZAY
AFFIDAVIT OF NON - MILITARY SERVICE
The undersigned attorney hereby verifies that he /she is the attorney for the
Plaintiff in the above - captioned matter, and that on information and belief, he /she has knowledge
of the following facts, to wit:
(a) that the defendants RICHARD J. NAZAY, JR A /K/A RICHARD J. NAZAY
and RUTH C. NAZAY are not in the Military or Naval Service of the United States or its Allies,
or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended.
(b) that defendant RICHARD J. NAZAY, JR A/K/A RICHARD J. NAZAY is
over 18 years of age and the last known addresses of the defendant are 940 WALNUT BOTTOM
ROAD, CARLISLE, PA 17015 -6926 and 24 COLD SPRINGS ROAD, CARLISLE, PA 17015-
7600.
(c) that defendant RUTH C. NAZAY is over 18 years of age and the last known
addresses of the defendant are 33 COUNTRY VIEW ESTATE, NEWVILLE, PA 17241 and 24
COLD SPRINGS ROAD, CARLISLE, PA 17015 -7600.
This statement is made subject to the pena ties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date
Phel " allinan, LLP
Emily M. Phelan, Esq., Id. No.315250
Attorney for Plaintiff
PHELAN HALLINAN, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza, Philadelphia, PA 19103
215 -563 -7000
939897
Department of Defense Manpower Data Center
Results as of : Apr-17-2014 12:06:24 AM
SCRA 3.0
Status Report
Pursuant to Servicemembers Civil Relief Act
Last Name: NAZAy
First Name: RUTH
Middle Name: C
Active Duty Status As Of: Apr-17-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
, NA
No
NA
This response reflects the individuals active duty status based on the Active Duty Status Date
- Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
. • NA
No
NA
This re posse reflects where the individual lefl active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Ner Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA •
No
NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
yA
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
Department of Defense Manpower Data Center
Results as of : Apr -17 -2014 12:06:17 AM
SCRA 3.0
Status Report
Pursuant to Servicemembers Civil. Relief Act.
Last Name: NAZAY
First Name: RICHARD
Middle Name: J
Active Duty Status As Of: Apr -17 -2014
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No "
NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Stud Date
Active Duty End Date
Status
Service Component
NA
- NA
No
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His /Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA
No
NA
This response reflects whether the individual or his/her unit has received early -notification fo report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status dale as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely- Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
Department of Defense Manpower Data Center
Results as of : Apr-17-2014 12:53:32 AM
SCRA 3.0
Status Report
Pursuant to Service meI Civil. ReIiefAct.
Last Name: NAZAY
First Name: RICHARD
Middle Name: J
Active Duty Status As Of: Apr -17 -2014
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
Ni, '
NA
This response reflects the individuals' active duty, status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
. -No
NA
This response reflects where the individual left active' duty status within 367 days preceding the Active Duty Status Date
The Member or His /Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA
No
NA
This response reflects whether the individual or his /her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely- Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
(Rule of Civil Procedure No. 236) - Revised
CITIMORTGAGE, INC. CUMBERLAND COUNTY
vs. : COURT OF COMMON PLEAS
RICHARD J. NAZAY, JR A/K/A
RICHARD J. NAZAY : CIVIL DIVISION
RUTH C. NAZAY
: No. 14-813 CIVIL
against you on
Notice is given that a Judgment in the above captioned matter has been entered
qz
If you have any questions concerning this matter please contact:
Phelan Hallinan, LLP
Emily M. Phelan, Esq., Id. No.315250
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
** 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, THIS IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
939897
CITIMORTGAGE, INC.
Plaintiff
V.
RICHARD J. NAZAY, JR A/K/A RICHARD J.,
NAZAY
RUTH C. NAZAY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 14-813 CIVIL
CUMBERLAND COUNTY
Defendant(s)
TO: RICHARD J. NAZAY, JR
A/K/A RICHARD J. NAZAY
940 WALNUT BOTTOM ROAD
CARLISLE, PA 17015-6926
DATE OF NOTICE: ... g y
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 TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN 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 PAPER 'FO 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 BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE,
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
By:
PH # 939897
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(7)7) 249-3166
Jo an Lobb, Esq., Id. No.312174
Attorney for Plaintiff
Phelan H.allinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
CITIMORTGAGE. INC.
Plaintiff
RICHARD J. NAZAY, JR A/K/A RICHARD J.
NAZAY
RUTH C. NAZAY
Defendant(s)
TO: RICHARD J. NAZAY, JR
A/K/A RICHARD J. NAZAY
24 COLD SPRINGS ROAD
CARLISLE, PA 17015-7600
DATE OF NOTICE: Li qfiy
COURT OF COMMON PLEAS
CIVIL DIVISION
NO, 14-813 CIVIL
CUMBERLAND COUNTY
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 TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN 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 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 BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
By:
PH # 939897
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Jona Lobh, s )., Id. No.3 12174
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
CITIMORTGAGE, INC,
Plaintiff
V.
RICHARD I. NAZAY, JR A/K/A RICHARD I.
NAZAY
RUTH C. NAZAY
Defendant(s)
TO: RUTH C. NAZAY
33 COUNTRY VIEW ESTATE
NEWVILLE, PA 17241
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 14-813 CIVIL
CUMBERLAND COUNTY
DATE OF NOTICE: q It( ft y
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 TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN 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 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 BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
By:
PH # 939897
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
,r( .1 an Lobb, Esq., Id. No.312174
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
CITIMORTGAGE, INC.
Plaintiff
V.
RICHARD J. NAZAY, JR A/K/A RICHARD J.
NAZAY
RUTH C. NAZAY
Defendant(s)
TO: RUTH C. NAZAY
24 COLD SPRINGS ROAD
CARLISLE, PA 17015-7600
DATE OF NOTICE: (1
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 14-813 CIVIL
CUMBERLAND COUNTY
THIS FIRM IS A DEBT COLLECTOR AI TEMPTING 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 TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN 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 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 BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
By
P1-I# 939897
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Joi Ian Lobb.; Esq., Id. No.312174
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103