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The information collected on this form is used solely for court administration purposes. .This form does not
supplement or replace the filing and service qfpleadings or other papers as required by law or rules of court.
Commencement of Action:
El Complaint M Writ of Summons Petition
S [3Transfer from Another Jurisdiction n Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
T Rose Acceptance, Inc. Colby D. Neil
Are money damages requested? ®Yes 0 No Dollar Amount Requested: [Dwithin arbitration limits
(check one) 13 outside arbitration limits
0
N Is this a Class Action Suit? Yes x No Is this an MDJAppeal? C3 Yes El No
A Name of Plaintiff/Appellant's Attorney: Lois M.Vitti, Esquire PA ID#209865
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 r1_11 Board of Assessment
Motor Vehicle Debt Collection:Other Board of Elections
[_7j Nuisance Dept.of Transportation
n Premises Liability H Statutory Appeal:Other
S E3 Product Liability(does not include [3
E mass tort) Employment Dispute:
Slander/Libel/Defamation Discrimination
C El Other: Employment Dispute: Other Zoning Board
T Other:
I Other:
O MASS TORT
Asbestos
N Tobacco
Toxic Tort-DES
E] Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
E3 Toxic Waste 0 Ejectment M Common Law/Statutory Arbitration
n Other: 13 Eminent Domain/Condemnation 0 Declaratory Judgment
B Ground Rent [] Mandamus
Landlord/Tenant Dispute n Non-Domestic Relations
Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY Mortgage Foreclosure:Commercial 13 Quo Warranto
El Dental Partition 13 Replevin
n Legal Quiet Title Other:
rl Medical Other:
Other Professional:
Updated 11112011
• L
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Rose Acceptance, Inc., CIVIL DIVISION - L
No. ) L�_ a gi Lo
011u)(
Plaintiff, COMPLAINT IN MORTGAGE
FORECLOSURE
VS. MORTGAGE FORECLOSURE
Colby D. Neil and Cynthia E. Neil, Filed on behalf of Plaintiff
Defendants. Counsel of record for this party:
Lois M. Vitti, Esquire
TODEFENDANT(S): PA I.D. #209865
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT
IN MORTGAGE FORECLOSURE WITHIN TWENTY (20) DAYS FROM
SERVICE HEREOF ORA DEFAULT]UDGMENTMAYBE ENTERED AGAINST Vitti &Vitti &Associates, P.C.
YOU. 215 Fourth Avenue
By: /S/ &.4 M. Vitti Pittsburgh, PA 15222
Attorney for Plaintiff (412) 281-1725
t
C 7-
fTl
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i.
CD
Rose Acceptance, Inc., IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff, CIVIL ACTION - LAW
Vs.
No.
Colby D. Neil and Cynthia E. Neil,
Defendants.
COMPLAINT IN MORTGAGE FORECLOSURE
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 THE
ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND
OWECTIONS 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
]UDGMENT MAY BE ENTERED AGAINST YOU BYTHE 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
SHOULD NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
(717) 249-3166
Rose Acceptance, Inc., IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff, CIVIL ACTION - LAW
vs.
No.
Colby D. Neil and Cynthia E. Neil,
Defendants.
COMPLAINT IN MORTGAGE FORECLOSURE
NOW, comes the Plaintiff by its attorneys, Vitti &Vitti &Associates, P.C. and Lois M.
Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141
through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following:
1. The Plaintiff is a corporation having a principal place of business located at 241
EAST SAGINAW, PO BOX 980, EAST LANSING, MI 48826. Plaintiff is the holder of the
mortgage and is seeking enforcement of the mortgage through foreclosure.
2. The Defendant(s) is/are individuals who resides at 306 Walnut Street,
Shippensburg, PA 17257. The property address is 306 Walnut Street, Shippensburg, PA
17257 and is the subject of this action.
3. On the 1st day of March, 2006, in consideration of a loan of Thirty Thousand
and 00/100 ($30,000.00) Dollars made by John 0. Gossert, III and Sandra E. Gossert to
Defendants, the said Defendants executed and delivered to John 0. Gossert, III and
Sandra E. Gossert a "Note" secured by a Mortgage with the Defendants as mortgagors and
John 0. Gossert, III and Sandra E. Gossert, as mortgagee, which mortgage was recorded
on the 3rd day of March, 2006, in the Office of the Recorder of Deeds of Cumberland
County, at Book No. 1942 Page No. 1125. The said mortgage is incorporated
herein by reference thereto as though the same were set forth fully at length.
4. The premises secured by the mortgage are:
SEE EXHIBIT 'A"ATTACHED HERETO.
5. On the 7t" day of February, 2008, John 0. Gossert, III and Sandra E. Gossert,
assigned to First National Acceptance Company,the said mortgage, that assignment being
recorded in the Recorder's Office of Cumberland County on the 2nd day of April, 2008, at
Instrument No. 200810323. The said assignment is incorporated herein by reference.
6. Subsequently, First National Acceptance Company, assigned to Plaintiff, Rose
Acceptance, Inc., .the said mortgage, that assignment being recorded in the Recorder's
Office of Cumberland County on the 23rd day of April, 2014, at Instrument No. 201408159.
The said assignment is incorporated herein by reference.
7. The mortgage provides that, in the event of default in the payment of one or
more installments,the holder may accelerate the entire indebtedness and foreclose the
mortgage by judicial proceeding, in which event the holder is also entitled to collect the
expenses — including attorneys' fees — thereby incurred.
8. Since October 1, 2013, the mortgage has been in default by reason, inter alia,
of the failure of the mortgagor(s) to make payments provided for in the said mortgage
(including principal and interest) and, under the terms of the mortgage,the entire principal
sum is due and payable.
9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of
Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in
1998, and/or Notice of Default as required by the mortgage document, as applicable, have
been sent to the Defendant(s) on the date set forth thereon, and the temporary stay as
provided the 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.
10. The amount due on said mortgage is itemized on the attached schedule.
11. Pursuant to Pennsylvania Rule of Civil Procedure 1144, the Plaintiff releases
from liability for the debt secured by the mortgage any mortgagor, personal representative,
heir or devisee of the mortgagor who is not a real owner of the property at the time of the
filing of this Complaint.
WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 1147(6),
Plaintiff demands judgment for the amount due of Thirty Thousand Seven Hundred Twenty
Seven and 28/100 ($30,727.28) with interest and costs.
Respectfully su itted,
VFM SOCIATES, P.C.
BY:
Lois M. itt, Esquire
Attor ey for Plaintiff
SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE
Unpaid Principal Balance 24,335.46
Interest @ 7.0000% from 09/01/13 through 4/30/2014 1,124.76
(Plus $4.6671 per day after 4/30/2014 )
Late charges through 4/15/2014
0 months @ 35.00
Accumulated beforehand 875.00
(Plus $35.00 on the 17th day of each month after 4/15/2014 )
Attorney's fee 1,216.77
Escrow deficit 3,175.29
(This figure includes projected additional charges that may be incurred by the Plaintiff and
transmitted to the sheriff as charges on the writ prior to the date of the sheriffs sale)
BALANCE DUE 30,727.28
EXHIBIT `"A"
LEGAL DESCRIPTION
ALL 'THAT CERTAIN vacant parcel of ground situate in the Borou h of
Shippensburg, Cumberland County, Pennsylvania, on the South side of
Walnut Street (formerly Long Avenue) , having a frontage on said Walnut
Street of fifty-two and one-half (52 1/2) feet and a depth of one
hundred fifty (150) feet to a public alley in the rear, bounded and
described as follows:
BEGINNING at a point at corner of Lot No. 37 one hundred forty-give
(145) feet from corner of Washington Street and Walnut Street; thence
with the latter in a Northerly direction fifty-two and one-half (52
1/2) feet to the middle of Lot No. 39; thence in an Easterly direction
by the middle line of said Lot No. 39 one hundxed fifty (150) feet to
a fourteen (14) foot alley; thence along the line of said alley in a
Southerly direction fifty-two and one-haI.f (52 1/2) feet to a corner
of Lot No. 37 aforesaid; thence in a westerly direction along Lot No.
37 one hundred fifty (150) tett to the first mentioned point and place
of BEGINNING. The said described parcel of ground cotaprising the
whole of Lot No. 39 and one-half (1/2) of Lot No. 39 in a plan of
building lots laid out by Philip Harman, Trustee of C. Long, Jr., and
recorded in the Recorder's office at Carlisle, Pennsylvania, in Plan
Book No. 1, Page 37.
VERIFICATION
AND NOW Lois M. Vitti verifies that the statements made in this Complaint are true
and correct to the best of her information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn
falsification to authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the
verification cannot be obtained within the time allowed for the filing of this pleading, the
pleading is submitted by counsel based upon the information provided her by the Plaintiff.
Lois M. Vitti
Dated: April 28, 2014
FORM 1
Rose Acceptance, Inc.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
Plaintiff(s) r,
Vs. i—
Colby D. Neil and Cynthia E. Neil o`er
Defendant(s) roi l J"'CD ,
� -
Za
NOTICE OF RESIDENTIAL MORTGAGE FORECLGSU-
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 foreclosure 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)243-9400 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 file 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 attempt to 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 lawyer 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 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 attempt to work out reasonable arrangements
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 F 4* d:
Respectful
Date [Signature f u sel 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
Please provide the following information to the best of your knowledge:
CUSTOMER/PRIMAI1Y 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?
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.
2.
3.
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/Tuit. 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:
2
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 informationjf know, regarding your lender or 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 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:
-V! Proof of income
Y Past 2 bank statements
Y Proof of any expected income for the last 45 days
V Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
Listing agreement(if property is currently on the market)
3
FORM 3
Rose Acceptance, Inc. : IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
vs.
Colby D. Neil and Cynthia E. Neil
Defendant(s) CIVIL
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated , 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program,the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a"Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel/Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
FORM 4
Rose Acceptance, Inc. ; IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
CIVIL ACTION
VS.
NO.
Colby D. Neil and Cynthia E. Neil
Defendant(s)
CASE MANAGEMENT ORDER
AND NOW, this day of , 20 ,the defendant/borrower in
the above-captioned residential mortgage foreclosure action having filed a Request for
Conciliation Conference verifying that the defendant/borrower has complied with the
Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby
ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on at M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one(21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet"(Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court,the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of`the completed Form 2 is to be made may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 within the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court; the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of
the plaintiff/lender is not available by telephone during the Conciliation Conference,
the Court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference,the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement;paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage;paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
J.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson ,- -Of-
Sheriff
O Sheriff THE PRCTHONOW
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
�Qtttitl?
O F iCE OF ME S RIFF
201111.1N 13 2: U
CUMBERLAND COUNTY
PENNSYLVANIA
Rose Acceptance, Inc.
vs.
Colby D. Neil (et al.)
Case Number
2014-2816
SHERIFF'S RETURN OF SERVICE
05/28/2014 10:37 AM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the
Defendant, to wit: Cynthia E. Neil at 1012 Deerfield Commons, Shippensburg Township, Shippensburg,
PA 17257.
RYAN BURGETT, DEP
05/28/2014 11:09 AM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by handing a true copy to a person representing themselves to be Eric Neil, son,
who accepted as "Adult Person in Charge" for Colby D. Neil at 126 W Burd Street, Shippensburg
Borough, Shippensburg, PA 17257.
RYAN BURGETT, DEPUTY
SHERIFF COST: $79.20 SO ANSWERS,
June 04, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Teleosofi, Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Rose Acceptance, Inc.,
Plaintiff,
vs.
Colby D. Neil and Cynthia E. Neil,
Defendants.
No. 2014-2816
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please reinstate the complaint in the above -captioned case
Respectfully submitted,
Vitti & Vitti
BY:
DATE: July 1, 2014
fates P.C.
M. Vitti, Esquire
r
r
c
#26S1.252
IN THE COURT OF COMMON PI FAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Rose Acceptance, Inc., CIVIL DIVISION
NO. 2014-2816
Plaintiff, PRAECIPE TO REINSTATE
COMPLAINT
vs. MORTGAGE FORECLOSURE
Colby D. Neil and Cynthia E. Neil, Filed on behalf of Plaintiff
Counsel of record for this party:
Defendants.
Lois M. Vitti, Esquire
PA I.D. #209865
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
iLEL1- J F :c
" THE PROTHONO TipR
20I4 AUG 22 PH 3: j` I
CUMBERLAND COUNTY
PENNSYLVANIA
QFFlCE OF TWE SHERIFF
Rose Acceptance, Inc.
vs.
Colby D. Neil (et al.)
Case Number
2014-2816
SHERIFF'S RETURN OF SERVICE
07/21/2014 07:17 PM - Deputy Jeff Kolodzi, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be Pennelope Summerville, Step mother, who
accepted as "Adult Person in Charge" for Colby D. Neil at 126 W Burd Street, Shippensburg Borough,
Shippensburg, PA 17257.
JEFj5'KOf_OD
.57,/,1(/'
ZI DEPUT
SHERIFF COST: $73.20 SO ANSWERS,
July 22, 2014
(c) CountySuite Sheriff, Teleoseft, Inc.
RONNY R ANDERSON, SHERIFF
FIi_k
CP THE Pi\0ItIONOTAR'r
2014 DEC - PH 3: 37
.CUMBER AND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS,OF CUMBERLAND COUNTY, PENNSYLVANIA
ROSE ACCEPTANCE, INC., CIVIL DIVISION
NO.. 2014-2816
Plaintiff, PRAECIPE FOR DEFAULT
JUDGMENT, CERTIFICATION OF
MAILING AND AFFIDAVIT OF NON -
vs. MILITARY SERVICE
COLBY D. NEIL and CYNTHIA E. NEIL, Code MORTGAGE FORECLOSURE
Filed on behalf of
Defendants. Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti & Vitti & Assoc., P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
clopa 1 lo ,4DP
Lit 2Pa9-7
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ROSE ACCEPTANCE, INC.,
Vs
COLBY D. NEIL and CYNTHIA E. NEIL,
Plaintiff,
Defendants.
PRAECIPE FOR DEFAULT JUDGMENT
AND ASSESSMENT OF DAMAGES
TO: PROTHONOTARY OF CUMBERLAND COUNTY
: No: 14-2816
' Enter judgment in Default of an Answer in the amount of $31,698.03, in favor of the
Rose Acceptance, Inc., Plaintiff in the above -captioned action, against the Defendants, Colby D. Neil
and Cynthia E. Neil and assess Plaintiffs damages as follows and/or as calculated in the Complaint:
Unpaid Principal Balance
Interest from 9/01/13- 11/24/14
(Plus $5.2106 per day after 11/24/14)
$ 24,335.46
2,095.51
Late charges (Plus $35.00 per 875.00
month from 4/15/14-3/4/15 $385.00)
Attorney's fee
Escrow Deficit
(Plus any additional charges that may be
incurred by the Plaintiff and transmitted
to the sheriff as charges on the writ prior
to the date of the sheriffs sale)
1,216.77
3,175.29
Total Amount Due $31,698.03
The real estate, which is the subject matter of the Complaint, is situate in Borough of
Shippensburg, Cty of Cumberland and Cmwlth of PA. Being a vacant lot. Parcel No. 32-34-2413-
136A.
Louis P. Vitti, Esquire
Attorney for the Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ROSE ACCEPTANCE, INC.,
Vs
COLBY D. NEIL and CYNTHIA E. NEIL,
Plaintiff,
Defendants.
: No: 14-2816
CERTIFICATION OF MAILING
I, Louis P. Vitti, do hereby certify that a Notice of Intention to Take Judgment was mailed to the
Defendant(s), in the above -captioned case on November 4, 2014, giving ten (10) day notice that judgment
would be entered should no action be taken.
BY:
SWORN to and subscribed
before me this 24th day
of November, 2014.
.jr rayiY,
Notarial Seal
Sherry i... House, Notary R,tbllc
City of Pittsburgh, Allegheny Courny
My Commission Expires M ; 15 'n15
VITTI & VITTI & ASSOCIATES, P.C.
Louis P. Vitti, Esquire
Attorney for Plaintiff
-..._.____.- —..1141148 COURT OF COMMONP7.ECIAS-OFtUMBERLANIMCOUNTY,PENNSYLVANIA._._._..
VIL DIVISION
ROSE ACCEPTANCE, INC.,
Vs
COLBY D. NEIL and CYNTHIA E. NEIL,
TO: Colby D. Neil
126 W. Burd Street
Shippensburg, PA 17257
Plaintiff,
Defendants.
IMPORTANT NOTICE
:NO: 2014-2816
Cynthia E. Neil
1012 Deerfield Commons
Shippensburg, PA 17257
Date of Notice: November 4, 2014 .
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH nth COURT YOUR DEFENSES OR
OBJECTIONS TO TrLe 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 YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TET PHONE DAB FOLLOWING OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
IE YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ON AGENCIES THAT MAY ONN!✓R LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET •
CARLISLE, PA 17013
1-800-990-9108
(717) 249-3166
BY:
VITTI & VITTI & ASSOCIATES, P.C.
GrA
Louis P. Vitti, Esquire
Attorney for Plaintiff
215 Fourth Avenue
Pittsburgh, PA 15222
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE
OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT
TO COLLECT A DEBT, BUT ONLY ENFORCEMENT. OF A LIEN AGAINST PROPERTY.**
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
COMMONWEALTH OF PENNSYLVANIA, SS:
COUNTY OF ALLEGHENY
BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire, who,
being duly sworn according to law, deposes and says that he is advised and believes that
DEFENDANT(S) is/are not presently in the active military service of the United States of America
and not members of the Army of the United States, United States Navy, the Marine Corps, or the
Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with
the Army or Navy; nor engaged in any active military service or duty with any military or naval units
covered by the Service Members Civil Relief Act of 2003 formerly known as Soldiers and Sailors
Relief Act of 1940 and designated therein as military service, and t s the best of this affiant's
knowledge is/are not enlisted in military service covered by said act, 4. th4 the averments herein
set forth, insofar as they are within his knowledge, are correct, and true;mdi sofar as they are based
on information received from others, are true and correct as he verily belie es. In the alternative,
should the defendant(s) be currently serving in the military the Service Members Relief Act does not
apply as the mortgage in question did not originate before the period of the Service Members
military service and is secured by a mortgage pursuant to 50 U.S.C. App §533 formerly cited as 50
U.S.C. App §532 (a)(1)(2).
This Affidavit is made under the provisions of the Se ce Members Civil Relief Act of 2004.
SWORN to and subscribed
before me this 24th day
of November, 2014.
Aki
Notary Publ6
Louis P. Vitti, Esquire
ti��il�if3Nllur.�t firq
UF Pell ibYLVAlli, -
Notarial Seal
Sherry L, House, Notary Public
City of Pittsburgh, Allegheny County
My Commission Expires May 15, 2015
Fit E1 � r
(;F rHE Prio1H0 °TA;;Y
26Pi DEC ! PH" 3: 38
CUM3EffLi;t,t?. ,
PEW'S yli,VANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ROSE ACCEPTANCE, INC.,
Plaintiff,
vs.
COLBY D. NEIL and CYNTHIA E. NEIL,
6/\
402/00/
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319D
Defendants.
naso
vim,,
226W/7
CIVIL DIVISION
NO. 2014-2816
PRAECIPE FOR WRIT OF
EXECUTION AND AFFIDAVIT OF
LAST KNOWN ADDRESS
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti & Vitti & Assoc., P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ROSE ACCEPTANCE, INC.,
Vs
COLBY D. NEIL and CYNTHIA E. NEIL,
Plaintiff,
Defendants.
: No: 14-2816
•
PRAECIPE FOR WRIT OF
EXECUTION IN MORTGAGE FORECLOSURE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the
above -captioned matter as follows:
Amount Due
Interest 11/25/14-3/04/15
Total
in:
$ 31,698.03
515.85
$32,213.88
The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate
Borough of Shippensburg, Cty of Cumberland and Cmwlth of PA. Being a vacant lot.
Parcel No. 32-34-2413-136A.
Louis P. Vitti, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND. COUNTY, PENNSYLVANIA
CIVIL DIVISION
ROSE ACCEPTANCE, INC.,
Vs
COLBY D. NEIL and CYNTHIA E. NEIL,
Plaintiff,
Defendants.
AFFIDAVIT
: No: 14-2816
I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief,
the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute . That the
Defendants' Cynthia Neil last known address is 1012 Deerfield Commons, Shippensburg, PA 17257.
Defendants' Colby D. Neil last known address is 126 W. Burd Street, Shippensburg, PA 17257.
cf,„„-g
Louis P. Vitti, Esquire
SWORN TO and subscribed
before me this 24th day of
November, 2014.
tary Public
.:.914MONIk A 4:11„44F ti-,!' bCU!.4rlsr.
I I
Notarial Seal
Sherry L. House, Notary Public
City yr Pittsburgh, Allegheny County
My Commission Expires May 15, 2015
OF .THE P CTNWU0 TA,i'
2eI1, DEC I Pfl 3: 39
CUMBERLAND COUNTY ..
PEUUSYLVAHiA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ROSE ACCEPTANCE, INC.,
Vs
COLBY D. NEIL and CYNTHIA E. NEIL,.
Plaintiff,
Defendants.
AFFIDAVIT PURSUANT TO RULE 3129.1
: No: 14-2816
Rose Acceptance, Inc., Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of
Execution was filed the following information concerning the real property located at Walnut Street,
Shippensburg, PA 17257.
1. Name and address of Owner(s) or Reputed Owner(s):
Name:
Colby D. Neil
Cynthia E. Neil
Address (Please indicate if this
cannot be reasonably ascertained)
126 W. Burd Street
Shippensburg, PA 17257
1012 Deerfield Commons
Shippensburg, PA 17257
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 above.
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name:
Patriot Federal Credit Union
Asset Acceptance, LLC
C/o Fulton Friedman & Gullace
Address (Please indicate if this
cannot be reasonably ascertained)
P.O. Box 778
Chambersburg, PA 17201
130 B Gettysburg Pike
Mechanicsburg, PA 17055
Name
4. Name and address of the last recorded holder of every mortgage of record:
Address (Please indicate if this
cannot be reasonably ascertained)
MERS as nominee for First Horizon Home 4000 Horizon Way
Loan Corporation Irving, TX 75063
Members 1st Federal Credit Union 5000 Louise Drive
Mechanicsburg, PA 17055
5. Name and address of every other person who has any record lien on the property:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
6. Name and address of every other person who has any record interest in or record lien on the
property and whose interest may be affected by the sale:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name
Tax Collector of Shippensburg Borough
Shippensburg Township
Shippensburg Water Department
Pennsylvania Department of Revenue
Office of Chief Counsel
Address (Please indicate if this
cannot be reasonably ascertained)
2 Partiage Trail
Shippensburg, PA 17257
P.O. Box 219
Shippensburg, PA 17257
201 Dykeman Road
Shippensburg, PA 17257
Inheritance Tax Dept.
PO Box 281061
Harrisburg, PA 17128
NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1.
TO: Colby D. Neil
126 W. Burd Street
Shippensburg, PA 17257
AND: ALL LIEN HOLDERS"
CI
_.. 1r.:-/CL
CBA
DEC -f PH 3: 39
c✓rf�i r
P'EWiS`YE V,�fDuliTy
Cynthia E. Neil
1012 Deerfield Commons
Shippensburg, PA 17257
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in Cumberland County Courthouse on March 4, 2015 at 10:00 A.M., the
following described real estate, of which Colby D. Neil and Cynthia E. Neil are owners or reputed owners:
Borough of Shippensburg, Cty of Cumberland and Cmwlth of PA. Being a vacant lot.
Parcel No. 32-34-2413-136A.
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of Rose
Acceptance, Inc. vs. Colby D. Neil, et al at 2014-2816 in the amount of $31,698.03.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment -against you. It may cause your
property to be held or taken to pay the judgment. You may have legal rights to prevent your property from
being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights
you must act promptly.
YOU, SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR.
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. Inorder to
exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to
Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court
alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is
opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff
has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right, you would have to file a petition to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or
equitable right.
You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly
inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a
petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The
Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date
when the Schedule of Distribution is filed in the Office of the Sheri
Otti
Louis P. Vitti, Esquire
Attorney for Plaintiff
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION
WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN
AGAINST PROPERTY.**
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
ROSE ACCEPTANCE, INC.
Vs. NO 2014-2816 Civil Term
CIVIL ACTION — LAW
COLBY D. NEIL AND CYNTHIA E. NEIL
WRIT OF EXECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell
the following described property:
(1) See legal description.
(2) (Specifically describe personal property when judgment results from a mortgage covering
both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code)
NOTE: Description of property must be attached to the writ.
Amount Due: $31,698.03
Interest 11/25/14 - 3/04/15 - $515.85
Atty's Comm:
Atty Paid: $312.90
Plaintiff Paid:
Date: 12/1/14
L.L.: $.50
Due Prothy: $2.25
Other Costs:
12i.teL) PetaiL
David D. Buell, Prothonotary
(Seal) B
REQUESTING PARTY:
Name: LOUIS P. VITTI, ESQUIRE
Address: VITTI & VITTI & ASSOC., P.C.
215 FOURTH AVENUE
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-1725
Supreme Court ID No. 01072
Deputy
.w°
-'1 t' z
•
2f/ii-DEC --$ Pis1 3:17
COLMTY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ROSE ACCEPTANCE, INC.,
Plaintiff,
vs.
CIVIL DIVISION
NO. 2014-2816
AMENDED AFFIDAVIT PURSUANT
TO RULE 3129.1
Code MORTGAGE FORECLOSURE
Filed on behalf of
COLBY D. NEIL and CYNTHIA E. NEIL, Plaintiff
Defendants. Counsel of record for this
party:
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti & Vitti & Assoc., P.C...
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
IN. THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ROSE ACCEPTANCE, INC.,
Vs
COLBY D. NEIL and CYNTHIA E. NEIL,
Plaintiff, .
Defendants.
: No: 14-2816
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
Rose Acceptance, Inc., Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of
Execution was filed the following information concerning the real property located at Walnut Street,
Shippensburg, PA 17257.
1. Name and address of Owner(s) or Reputed Owner(s):
Name:
Colby D. Neil
Cynthia E. Neil
Address (Please indicate if this
cannot be reasonably ascertained)
126 W. Burd Street
Shippensburg, PA 17257
1012 Deerfield Commons
Shippensburg, PA 17257
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 above.
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name:
Patriot Federal Credit Union
Asset Acceptance, LLC
C/o Fulton Friedman & Gullace
Address (Please indicate if this
cannot be reasonably ascertained)
P.O. Box 778
Chambersburg, PA 17201
130 B Gettysburg Pike
Mechanicsburg, PA 17055
4. Name and address of the last recorded holder of every mortgage of record:
Name
MERS as nominee for First Horizon Home
Loan Corporation
Members 1st Federal Credit Union
MidFirst Bank
A Federally Chartered Savings Association
MERS as nominee for Tidewater Mortgage
Name
None
Address (Please indicate if this
cannot be reasonably ascertained)
4000 Horizon Way
Irving, TX 75063
5000 Louise Drive
Mechanicsburg, PA 17055
999 NW Grand Blvd., Suite 100
Oklahoma City, OK 73118
Services 200 Golden Oak Court, Ste 100
Virginia Beach, VA 23452
5. Name and address of every other person who has any record lien on the property:
Address (Please indicate if this
cannot be reasonably ascertained)
6. Name and address of every other person who has any record interest in or record lien on the
property and whose interest may be affected by the sale:
Name
None
Address (Please indicate if this
cannot be reasonably ascertained)
7. Name and address of every other person of whom the Plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name
Tax Collector of Shippensburg Borough
Shippensburg Township
Shippensburg Water Department
Address (Please indicate if this
cannot be reasonably ascertained)
2 Partiage Trail
Shippensburg, PA 17257
P.O. Box 219
Shippensburg, PA 17257
201 Dykeman Road
Shippensburg, PA 17257
Pennsylvania Department of Revenue
Office of Chief Counsel
Commonwealth of PA -DPW
Clerk of Courts
Criminal/Civil Division
Tax Claim Bureau of Cumberland County
Cumberland County Courthouse.
Court of Common Pleas of
Cumberland County
Domestic Relations Division
PA Dept. of Sheriff Sales
Bureau of Compliance
Tenant/Occupant
Inheritance Tax Dept.
PO Box 281061
Harrisburg, PA' 17128
P.O. Box 8016
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
One Courthouse Square
Carlisle, PA 17013
P.O. Box 320
Carlisle, PA 17013
Dept. #281230
Harrisburg, PA 17128-1230
Walnut Street
Shippensburg, PA 17257
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unsworn f ation to au tt' ies.
December 4, 2014
Date
SWORN TO and subscribed
before me this 4th day
of December, 2014.
ouis P. Vitti, Esquire
Attorney for Plaintiff
.<Jfrfl ONWEALTH OF PENNSYLVANIA
Notarial Seal
Sherry L. House, Notary Public
City of Pittsburgh, Allegheny County
Commission Expires May 15, 2015