HomeMy WebLinkAbout14-6473 Supreme Courtof Pennsylvania
C o u At f C mfr" Pleas
l'IVllwl. over,�eet For Prothonotary Use Only:
C �V1B RL ND'a,
.� COU.IIty Docket No:
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 of court.
Commencement of Action:
I S ® Complaint ❑ Writ of Summons ❑ Petition
❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiffs Name: Deutsche Bank National Trust Company,as Lead Defendant's Name: William J.Ragni
C Indenture Trustee,on behalf of the holders of the Accredited
Mortgage Loan Trust 2004-1 Asset Backed Notes
ET
Are money damages requested?: ❑Yes ® No Dollar Amount Requested: within arbitration limits
I (Check one)
U x outside arbitration limits
N Is this a Class Action Suit? ❑Yes ® No Is this an MDJAppeal? ❑Yes ® No
Name of Plaintiff/Appellant's Attorney: Scott A.Dietterick,Esq.c/o Zucker,Goldberg&Ackerman,LLC
A_ ❑ 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
El Board of Elections
El Nuisance
❑ Dept.of Transportation
j ❑ Premises Liability ❑ Statutory Appeal: Other
S ❑ Product Liability(does not include
mass tort) ❑ Employment Dispute:
} E ElSlander/Libel/Defamation Discrimination
❑ Other: ❑ Employment Dispute: Other
C ❑ Zoning Board
T ❑ Other:
I MASS TORT ❑ Other:
O
El Asbestos
❑ Tobacco
N ❑ Toxic Tort-DES
❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
# ❑ Toxic Waste
4
El Other: ❑ Ejectment ElCommon Law/Statutory Arbitration
❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent El Mandamus
# B ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations
® Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto
❑ Dental
❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title
❑ Other:
❑ Medical ❑ Other:
y ❑ Other Professional:
I
E
Updated 1/1//2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DEUTSCHE BANK NATIONAL TRUST COMPANY, CIVIL DIVISION '
AS INDENTURE TRUSTEE, ON BEHALF OF THE
HOLDERS OF THE ACCREDITED MORTGAGE NO.: i ~!
1 ,
LOAN TRUST 2004-1 ASSET BACKED NOTES,
TYPE OF PLEADING
Plaintiff,
vs. ,.q
CIVIL ACTION -COMPLAINT
IN MORTGAGE FORECLOSURE
William J. Ragni; Michelle Lee Ragni;
FILED ON BEHALF OF:
Defendants.
Deutsche Bank National Trust Company as
TO: DEFENDANTS
Indenture Trustee on behalf of the holders of
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE the Accredited Mortage Loan Trust 2004-1
ENCLOSED COMPLAINT WITHIN TWENTY(20)DAYS Asset Backed Notes
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE
ENTERED AGAINST YOU.
COUNSEL OF RECORD FOR THIS PARTY:
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS: ZUCKER,GOLDBERG&ACKERMAN, LLC
3815 South West Temple
P.O.Box 65250 Scott A. Dietterick, Esquire-Pa. I.D.#55650
Salt Lake City,UT 84115-4412
Kimberly A. Bonner,Esquire-Pa. I.D.#89705
AND THE DEFENDANT: Joel A.Ackerman, Esquire-Pa I.D.#202729
1451 Ryland Drive Ashleigh Levy Marin, Esquire-Pa I.D.#306799
Mechanicsburg,PA 17050 Ralph M.Salvia, Esquire-Pa I.D. #202946
Jaime R.Ackerman, Esquire-Pa I.D.#31103-2---
CERTIFICATE OF LOCATION Jana Fridfinnsdottir, Esquire-Pa I.D.#315944
I HEREBY CERTIFY THAT THE LOCATION OF Brian Nicholas, Esquire-Pa I.D.#317240
THE REAL ESTATE AFFECTED BY THIS LIEN IS Denise Carlon, Esquire-Pa I.D.#317226
1451 Ryland Drive mechapoicsburg PA 17050
Munici ali Ham de
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
ATrOR F F (908)233-8500
(908)233-1390 FAX
ATTY F NO.:XCP 190518 office@zuckergoldberg.com
File No.:XCP- 190518/bbec
S
0.�u- - : (15 .75
7 LA,
2 3� �67a
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF
DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION
THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY(30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S)
THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD
FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH
THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO
REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30)
DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE
DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY(30) DAY PERIOD
THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE
REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE
CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO
COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company, as CIVIL DIVISION
Indenture Trustee,on behalf of the holders of
the Accredited Mortgage Loan Trust 2004-1 NO.:
Asset Backed Notes
Plaintiff,
VS.
William J. Ragni; Michelle Lee Ragni;
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim 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 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.
NOTICE TO DEFEND&LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone(800)990-9108 Phone(800)990-9108
(717) 249-3166 (717)249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company,as CIVIL DIVISION
Indenture Trustee,on behalf of the holders of
the Accredited Mortgage Loan Trust 2004-1 NO.:
Asset Backed Notes
Plaintiff,
VS.
William J. Ragni; Michelle Lee Ragni;
Defendants.
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en
las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la
notificacion de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una
comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas
establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe
anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de
dinero reclamada en la demanda 0 cua Iquier otra reclamacion o remedio solicitado por el
demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o
propiedades u otros derechos importantes para usted.
LISTED DEBE LLEVAR ESTE DOCLIMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN
ABOGADO O NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR
DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL.
NOTICE TO DEFEND&LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone(800) 990-9108 Phone(800) 990-9108
(717)249-3166 (717)249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company,as CIVIL DIVISION
Indenture Trustee, on behalf of the holders of
the Accredited Mortgage Loan Trust 2004-1 NO.:
Asset Backed Notes
Plaintiff,
VS.
William J. Ragni; Michelle Lee Ragni;
Defendants.
CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Deutsche Bank National Trust Company,as Indenture Trustee,on behalf of
the holders of the Accredited Mortgage Loan Trust 2004-1 Asset Backed Notes, by its attorneys,
Zucker, Goldberg&Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Deutsche Bank National Trust Company, as Indenture Trustee, on
behalf of the holders of the Accredited Mortgage Loan Trust 2004-1 Asset Backed Notes, (hereinafter
"plaintiff") through its servicing agent SELECT PORTFOLIO SERVICING, INC. located at 3815 South
West Temple P.O. Box 65250,Salt Lake City, LIT 84115-4412.
2. The Defendant, William J. Ragni, is an individual whose last known address is 1451
Ryland Drive, Mechanicsburg, PA 17050.
3. The Defendant, Michelle Lee Ragni, is an individual whose last known address is 1451
Ryland Drive, Mechanicsburg, PA 17050..
4. Deutsche Bank National Trust Company, as Indenture Trustee, on behalf of the
holders of the Accredited Mortgage Loan Trust 2004-1 Asset Backed Notes, directly or through an
agent, has possession of the Promissory Note. Deutsche Bank National Trust Company, as Indenture
Trustee, on behalf of the holders of the Accredited Mortgage Loan Trust 2004-1 Asset Backed Notes
is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A
true and correct copy of said Promissory Note is marked Exhibit A, attached hereto and made a part
hereof.
5. On or about December 31, 2003, William J Ragni and Michelle Lee Ragni, Husband
and Wife made, executed and delivered to Mortgage Electronic Registration Inc., as nominee for
Accredited Home Lenders, Inc. a Mortgage in the original principal amount of $139,750.00 on the
Zucker,Goldberg&Ackerman, LLC
premises described in the legal description marked Exhibit B, attached hereto and made a part
hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County
on January 12, 2004, in Mortgage Book\Volume 1850, Page 4947. The mortgage is a matter of public
record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule
relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of
public record.
6• Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded October 11,
2011, the mortgage was assigned to Deutsche Bank National Trust Company, as Indenture Trustee,
on behalf of the holders of the Accredited Mortgage Loan Trust 2004-1 Asset Backed Notes. which
assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument
#201128004. The Assignment is a matter of public record and is incorporated herein by reference in
accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach
documents to pleadings if those documents are of public record.
7. William J. Ragni and Michelle Lee Ragni, husband and wife are record and real
owners of the aforesaid mortgaged premises.
8• Defendants are in default under the terms of the aforesaid Mortgage for, inter alfa,
failure to pay the monthly installments of principal and interest due February 1,2014.
9• As of 10/24/2014 the amount due and owing Plaintiff by Defendant(s) is as follows:
Principal $121,072.72
Interest through 10/24/2014 $6,782.75
Escrow Advance $1,932.96
Total Fees $187.18
Late Charges $968.92
Recoverable Balance $1,421.19
Total $132,365.72
Plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law,
actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow
advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in
the above-captioned action to add such additional sums authorized under the Mortgage and
Pennsylvania Law to the above amount due and owing when incurred.
Zucker,Goldberg&Ackerman,LLC
10. 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).
11. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is
not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in
a separate legal action if such right exists. If Defendant(s) have received a discharge of personal
liability in a bankruptcy proceeding,this action is in no way an attempt to re-establish such liability.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount
due of $132,365.72 with interest thereon plus additional costs (including additional escrow
advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged
premises.
ZUCKER,GOLDBER CKE , LLC
BY:
Dated: Scott A. D' Brick, Esquire; PA I.D.#55650
Kimberly A. Bonner, Esquire; PA I.D.#89705
Joel A.Ackerman, Esquire; PA I.D.#202729
Ashleigh L. Marin, Esquire; PA I.D.#306799
Ralph M.Salvia, Esquire;PA I.D. #202946
Jaime R.Ackerman, Esquire; PA I.D.#311032,,_
Jana Fridfinnsdottir, Esquire; PA I.D.#315944
Brian Nicholas, Esquire; PA I.D.#317240
Denise Carlon, Esquire; PA I.D.#317226
Attorneys for Plaintiff
XCP-190518/bbec.
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
(908)233-8500;(908)233-1390 FAX
Email: Office@zuckergoldberg.com
THIS IS'AN ATTEMPT TO COLLECT ADEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT.PURPOSE.
Zucker,Goldberg&Ackerman, LLC
EXHIBIT A
b
a
j
II
I
Y
Zucker,Goldberg&Ackerman, LLC
1 .
ADJUSTABLE RATE NOTE
(LIBOR Index - Rate Caps)
THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE AND MY MONTHLY
PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN CHANGE AT ANY ONE TIME AND
THE MAXIMUM RATE I MUST PAY.
12/31/2003 MECHANICSBURG PENNSYLVANIA
[City] [State]
1451 RYLAND DRIVE , MECHANICSBURG, PA 17050
[Property Address]
1. BORROWER'S PROMISE TO PAY
In return for a loan that I have received, I promise to pay U.S.$ $139,750.00
(this amount is called "principal"), plus interest, to the order of the Lender. The
Lender is Accredited Home Lenders, Inc., A California Corporation
2. INTEREST
Interest will be charged on unpaid principal until the full amount of principal
has been paid. I will pay interest at a yearly rate of 6.950 8. The interest rate
I will pay will change in accordance with Section 4 of this Note.
The interest rate required by this Section 2 and Sections 4 of this Note is the
rate I will pay both before and after any default described in section 7(B) of this
Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by making payments every month.
I will make my monthly payments on the lst day of each month beginning on
March 1, 2004 I will make these payments every month until I have paid all
of the principal and interest and any other charges described below that I may owe
under this Note. My monthly payments will be applied to interest before principal.
If, on February 01, 2034 , I still owe amounts under this Note, I will pay those
amounts in full on that date, which is called the "Maturity Date".
I will make my monthly payments at p,0• Box 502480 San Diego, CA 92150-2480
, or at a different place if required by the Note Holder.
(B) Amount of My Initial Monthly Payments
'Each of my initial monthly payments will be in the amount of U.S.$925.08
This amount may change.
(C) Monthly Payment Changes
Changes in my monthly payment will reflect changes in the unpaid principal of my
loan and in the interest rate that I must pay. The Note Holder will determine my new
interest rate and the changed amount of my monthly payment in accordance with Section 4
of this Note.
4. INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change Dates
The interest rate I will pay may change on the 1st day of February
2007 and on that day every sixth month thereafter. Each date on which my
interest rate could change is called a "Change Date".
(B) The Index
Beginning with the first Change Date, my interest rate will be based on an Index.
The "Index" is the average of interbank offered rates for six-month U.S.
dollar-denominated deposits in the London market("LIBOR"), as published in the Wall
Street Journal. The most recent Index figure available as of the first business day of
the month immediately preceding the month in which the Change Date occurs is called the
"Current Index".
If the Index is no longer available, the Note Holder will choose a new index that
is based upon comparable information. The Note Holder will give me notice of this
choice.
(C) Calculation of Changes
Before each Change Date, the Note Holder will calculate my new interest rate by
adding Five And Forty-five Hundredth(s)
percentage points( 5.450 8) to the Current Index. The
Note Holder will then round the result of this addition to the nearest of one-eighth of
one percentage point (0.125%) . Subject to the limits stated in Section 4(D) below,
this rounded amount will be my new interest rate until the next Change Date.
MULTISTATE ADJUSTABLE RATE NOTE-LIBOR INDEX - Single Family - FHLMC - 6 Month Fo— 3590 7/92 (modified) AHL modified 9/97
inifi.k-
MIN 1 RAGNI Loan
—1. 77n1-1 11— � I /O P.— 1 of Z (k
The Note Holder will then determine the amount of the monthly payment that would
be sufficient to repay the unpaid principal that I am expected to owe at the Change
Date in full on the maturity date at my new interest rate in substantially equal
payments. The result of this calculation will be the new amount of my monthly
payment.
(D) Limits on Interest Rate Changes
The interest rate I am required to pay at the first Change Date will not be
greater than 8.450 % or less than 6.950 %. Thereafter,
my interest rate will never be increased or decreased on any single Change Date by
more than One And One-half percentage point ( 1.500 $)
from the rate of interest I have been paying for the preceding six months.
My interest rate will never be greater than 13.950 % or
less than 6.950 %
(E) Effective Date of Changes
My new interest rate will become effective on each Change Date. I will pay the
amount of my new monthly payment beginning on the first monthly payment date after the
Change Date until the amount of my monthly payment changes again.
(F) Notice of Changes
The Note Holder will deliver or mail to me a notice of any changes in my
interest rate and the amount of my monthly payment before the effective date of any
change. The notice will include information required by law to be given me and also
the title and telephone number of a person who will answer any question I may have
regarding the notice.
5. BORROWER'S RIGHT TO PREPAY
Prepayment Charge Rider to the Note attached hereto.
I have the right to make payments of principal at any time before they are due.
A payment of principal only is known as a "prepayment". When I make a prepayment, I
will tell the Note Holder in writing that I am doing so.
I may make a full prepayment or partial prepayments. The Note Holder will use
all of my prepayments to reduce the amount of principal that I owe under this Note. If
I make a partial prepayment, there will be no change in the due dates of my monthly
payments unless the Note Holder agrees in writing to those changes. My partial
prepayment may reduce the amount of my monthly payments after the first Change Date
following my partial prepayment. However, any reduction due to my partial prepayment
may be offset by an interest rate increase.
6. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loan charges, is
finally interpreted so that the interest or other loan charges collected or to be
collected in connection with this loan exceed the permitted limits, then: (i) any such
loan charge shall be reduced by the amount necessary to reduce the charge to the
permitted limit; and (ii) any sums already collected from me which exceeded permitted
limits will be refunded to me. The Note Holder may choose to make this refund by
reducing the principal I owe under this Note or by making a direct payment to me. If a
refund reduces principal, the reduction will be treated as a partial payment.
7. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charges for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the
end of Ten calendar days after the date it is due, I will pay a late charge
to the Note Holder. The amount of the charge will be 6.000 % of my
overdue payment of principal and interest. I will pay this late charge promptly but
only once on each late payment.
(B) Default
If I do not pay the full amount of each monthly payment on the date it is due, I
will be in default.
(C) Notice of Default
If I am in default, the Note Holder may send.me a written notice telling me that
if I do not pay the overdue amount by a certain date, the Note Holder may require. me to
pay immediately the full amount of principal which has not been paid and all the
interest that I owe on that amount. That date must be at least 30 days after the date
on which the notice is delivered or mailed to me.
(D) No Waiver By Note Holder
Even if, at a time when I am in default, the Note Holder does not require me to
pay immediately in full as described above, the Note Holder will still have the right
to do so if I am in default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described above,
the Note Holder will have the right to be paid back by me for all of its costs and
expenses in enforcing this Note to the extent not prohibited by applicable law. Those
expenses include, for example, reasonable attorneys' fees.
MULTISTATE ADJUSTABLE RATE NOTE-LIBOR INDEX - Single Family - FHLMC - 6 Month Form 3590 7/92 (modified) AHL modified 9/97
Initials: ,`
/^y�(
01� MIN 9 RAGNI Loan i
M. � Tui. 7inl-7 11CC Oanp 7 of Z Is
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given
to me under this Note will be given by delivering it or by mailing it by first class
mail to me at the Property Address above or at a different address if I give the Note
Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given
by mailing it by first class mail to the Note Holder at the address stated in Section
3(A) above or at a different address if I am given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one persons signs his Note, each person is fully and personally
obligated to keep all of the promises made in this Note, including the promise to pay
the full amount owed. Any person who is a guarantor, surety or endorser of this Note
is also obligated to do these things. Any person who takes over these obligations,
including the obligations of a guarantor, surety or endorser of this Note, is also
obligated to keep all of the promises made in this Note. The Note Holder may enforce
its right under this Note against each person individually or against all of us
together. This means that any one of us may be required to pay all of the amounts
owed under this Note.
10. WAIVERS
I and any other person who has obligations under this Note waive the rights of
presentment and notice of dishonor. "Presentment" means the right to require the Note
Holder to demand payment of amounts due. "Notice of dishonor" means the right to
require the Note Holder to give notice to other persons that amounts due have not been
paid.
11. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions.
In addition to the protections given to the Note Holder under this Note, a Mortgage,
Deed of Trust or Security Deed (the "Security instrument"), dated the same date as
this Note, protects the Note Holder from possible losses which might result if I do
not keep the promises that I make in this Note. That Security Instrument describes
how and under what conditions I may be required to make immediate payment in full of
all amounts I owe under this Note. Some of those conditions are described as follows:
Transfer of the Property or a Beneficial Interest in Borrower. If all or any
part of the Property or any interest in it is sold or transferred (or if a beneficial
interest in Borrower is sold or transferred and Borrower is not a natural person)
without Lender's prior written consent, Lender may, at its option, require immediate
payment in full of all sums secured by this Security Instrument. However, this option
shall not be exercised by Lender if such exercise is prohibited by applicable law.
If Lender exercises the option to require immediate payment in full, Lender
shall give Borrower notice of acceleration. The notice shall provide a period of not
less than 30 days from the date the notice is delivered or mailed within which
borrower must pay all sums secured by this Security Instrument. If Borrower fails to
pay these sums prior to the expiration of this period, Lender may invoke any remedies
permitted by this Security Instrument without further notice or demand on Borrower.
Witness The Hand(s) and Seaiil,,((s)) Of The Undersigned
)�?
V V
Borrower Borrower
WILLIAM J. RAGNI MICHELLE LEE RAGNI
(Seal) (Seal)
Borrower Borrower
(seal) _ (Seal)
Borrower Borrower
_(Seal) (Seal)
Borrower Borrower
Sign original Only
MULTISTATE ADJUSTABLE BATE NOTE-LIBOR INDEX - Single Family - FHlMC - 6 Month Form 3590 7/92 (modified) AHL modified 9/97
MIN 4 RAGNI Loan N
AHI. 2301-3.UFF Pace 3 of 3
Loan No:
Mortgagee: WILLIAM J. RAGNI, MICHELLE LEE RAGNI
Address: 1951 RYLAND DRIVE
MECHANICSBURG, PA 17050
Loan Amount:$139,750.00
ALLONGE TO NOTE
PAY TO THE ORDER OF:
WIW
ECOURSE
, , - �2,
ilomena A Labao
Assistant Secretary
Accredited Home Lenders, Inc., A California Corporation
MIN $ RAGNI Loan A
AHL 620017.UFF Page 1 of 1
Legal Description Addendum
Borrowers:WILLIAM J. RAGNI, MICHELLE LEE RAGNI
Loan li
Property Address:1451 RYLAND DRIVE
MECHANICSBURG, PA 17050
Legal Description
SEE LEGAL DESCRIPTION ATTACHED HERETO AND MADE APART THEREOF
lnitial—��
MIN t .. RAGNI Loan t
AHL 610101.UFF Page 1 of 1 y �
�-VQ:
EXHIBIT B
Zucker,Goldberg&Ackerman, LLC
Conestoga Title Insurance Company
Commitment Number:
SCHEDULE C
PROPERTY DESCRIPTION
The land referred to in this Commitment is described as follows:
All that certain parcel of land situate in Hampden Township, Cumberland County, Commonwealth of
Pennsylvania, more particularly bounded and described to wit:
Beginning at a point on the north right-of-way line of Valley Brook Drive,said point being located South 33
degrees 32 minutes 35 seconds West a distance of 8.89 feet from the intersection of the west right-of-way line
of Ryland Drive and north right-of-way line of Valleybrook Drive and being the northwest corner of Valleybrook
Drive as conveyed to Hampden Township and indicated on the approved Revised Final Subdivision Plan for
Hampden Hearth Phase I;
Thence south 33 degrees 32 minutes 35 seconds West along other lands of Hampden Hearth Joint Venture,a
distance of 91.81 feet to a point at the corner of other lands of Hampden Hearth Joint Venture;
Thence North 49 degrees 42 minutes 49 seconds West, along the same;a distance of 112.34 feet to a concrete
monument on the same and being the southern corner of Lot 39;
Thence North 37 degrees 25 minutes 26 seconds East, along the southeast line of Lot 39, a distance of 100.12
feet to a point on the west right-of-way line of Byland Drive and being the eastern corner of Lot 39;
Thence South 49 degrees 42 minutes 50 seconds East along the west right-of-way line of Ryland Drive, a
distance of 96.63 feet to a point of curvature;
Thence on a curve to the right having a radius of 10.00 feet, an arc length of 14.53 feet, a delta angle of 83
degrees 15 minutes 25 seconds, a chord bearing South 08 degrees 05 minutes 07 seconds East a distance of
13.29 feet to the point of beginning, and containing 10,876.97 square feet or 0.250 acres of land more or less.
Being Lot 38 on the Revised Final Subdivision Plan Phase I, Hampden Hearth, recorded in Plan Book 61, page
13, Cumberland County Courthouse.
Under and Subject to certain restrictions and easements filed on September 21, 1987, in Misc. Book 340, page
491, in Cumberland County, Pennsylvania.
Parcel#: 10-16-1062-069
FOR INFORMATIONAL PURPOSES ONLY. Cumberland County has property assessed as 1451 Ryland Drive
and Valleybrook Drive
I cc
rtify this to be recorded
In Cumberland County.PA
p ecorder of Deeds
ALTA Commitment
Schedule C
. . 11)r'49 3
VERIFICATION
Ryan Fullmer, Document Control Officer
I, (title),depose and
say subject to the penalties of 18 Pa.C.S.A.,sec.4904 relating to unsworn falsification to authorities that
the facts set forth in the foregoing pleading are true and correct to the best of my information,
knowledge and belief.
Select Portfollo Servicing, Inc. as Attorney,in Fact
By: Deutsche Bank National Trust
Company,as Indenture Trustee,on
behalf of the holders of the Accredited
Mortgage Loan Trust 2004-1 Asset
Backed /Notes
Name: P,� r
Title: Ryan Fullmer, nnoumAnt Control GUI er
File No: 190518
Borrower Name: William J. Ragni
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
y'
Deutsche Bank National Trust Company,as Indenture Trustee,on CIVIL DIVISION
behalf of the holders of the Accredited Mortgage Loan Trust 2004-1
Asset Backed Notes NO.: f���f I r.-}
Plaintiff,
V$.
j
William J.Ragni;Michelle Lee Ragni;
Defendants.
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM r
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.TIDS PROGRAM IS
FREE.
ZUCKER,GOLDBERG&ACKMOAAN,LLC
By:
Dated: November ,2014 Scott A.Di ,Esquir ; PA I.D.#55650
Kimberly A. onner,Esquire; PA I.D.#89705
Joel A.Ackerman,Esquire; PA I.D.#202729
Ashleigh L.Marin,Esquire; PA I.D.#306799
Ralph M.Salvia,Esquire;PA I.D.#202946
Jaime R.Ackerman,Esquire;PA I.D.#311032`~
Jana Fridfinnsdottir,Esquire;PA I.D.#315944
Brian Nicholas,Esquire; PA I.D.#317240
Denise Carlon,Esquire;PA I.D.#317226
Roger Fay,Esquire;PA I.D.#315987
Attorneys for Plaintiff
XCP-190518/emed
200 Sheffield Street,Suite 101
Mountainside,NJ 07092
(908)233-8500;(908)233-1390 FAX
Email: Office@zuckergoldberg.com
Zucker,Goldberg&Ackerman, LLC
XCP-190518
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/PRI
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:
Zucker,Goldberg&Ackerman, LLC
XCP-190518
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:
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
2nd 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 Support/Alim. Spending Money
Day/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:
Email:
Zucker,Goldberg&Ackerman, LLC
XCP-190518
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 or lender's loan servicing
company:
Lender's Contact(Name):
Phone:
Servicing Company(Name):
Contact:
Phone:
AUTHORIZATION
I/We,
authorize the above ed to use/refer
information to my lender/servicer for the sole purpose.of evaluating my financial situation for possibles
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
V Past 2 bank statements
V Proof of any expected income for the last 45 days
V Copy of current utility bill
V Letter explaining reason for delinquency and any supporting documentation (hardship letter)
V Listing agreement(if property is currently on the market)
Zucker,Goldberg&Ackerman, LLC
XCP-190518
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company, as CIVIL DIVISION
Indenture Trustee, on behalf of the holders of
the Accredited Mortgage Loan Trust 2004-1 NO.:
Asset Backed Notes
Plaintiff,
VS.
William J. Ragni; Michelle Lee Ragni;
Defendants.
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28,2012 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;
1. Defendant lives in the subject real property,which is defendant's primary residence;
2. 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 unworn
falsification to authorities.
Signature of Defendant's Counsel/Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
Zucker,Goldberg&Ackerman,LLC
XCP-190518
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company,as CIVIL DIVISION
Indenture Trustee,on behalf of the holders of
the Accredited Mortgage Loan Trust 2004-1 NO.:
Asset Backed Notes
Plaintiff,
VS.
William J. Ragni; Michelle Lee Ragni;
Defendants.
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.
1. 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.
2. 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
Zucker,Goldberg&Ackerman, LLC
XCP-190518
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.
3. 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.
4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation
conference.
BY THE COURT,
J.
Zucker,Goldberg&Ackerman, LLC
XCP-190518
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
L .,3-Oi F Is;
i
<iO� � # ,�O I t: tip
LG 3 DEC 10 Pik 3: 23
CUMBERLAND COUNTY
PENNSYLVANIA
Deutsche Bank National Trust Company, as Indenture Trustee, on behalf
vs.
William J Ragni (et al.)
Case Number
2014-6473
SHERIFF'S RETURN OF SERVICE
11/07/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: William J Ragni, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Lackawanna, Pennsylvania to serve the
within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage
Foreclosure according to law.
11/07/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Michelle Lee Ragni, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Lackawanna, Pennsylvania to serve the
within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage
Foreclosure according to law.
11/19/2014 04:28 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in . ga• - oreclosure by handing
a true copy to a person representing themselves to be Michelle Ragni, o a•cepted as "Adult
Person in Charge" for William J Ragni at 1451 Ryland Drive, Hampde ;y .hip, echanicsburg, PA
17050.
1
S `• WN HA' = ON, DEPUTY
11/19/2014 04:28 PM - Deputy Shawn Harrison, being duly sworn according to law, s- -d the re • . -sted Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in • •=•e F. ecl.sure by
"personally" handing a true copy to a person representing themselves t D- end:nt, to wit:
Michelle Lee Ragni at 1451 Ryland Drive, Hampden Township, Mecha • , 'A 170.0
12/05/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in
Mortgage Foreclosure returned by the Sheriff of Lackawanna County, the within named Defendant
William J Ragni, not found. Mark P. McAndrews, Sheriff, Return of Service attached to and made part of
the within record.
12/05/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in
Mortgage Foreclosure returned by the Sheriff of Lackawanna County, the within named Defendant
Michelle Lee Ragni, not found. Mark P. McAndrews, Sheriff, Return of Service attached to and made part
of the within record.
SHERIFF COST: $84.30 SO ANSWERS,
December 05, 2014 RONR-R ANDERSON, SHERIFF
(c) CountySui;e Sheriff, Teleosoft. Inc.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2014-00648 T
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF Lackawanna County
DEUTSCHE BANK
VS
WILIAM RAGNI
DAVID PASCOLINI , Deputy Sheriff , who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named COMPLAINT to wit
MICHELLE RAGNI was
unable to locate Her ,within the limits of Lackawanna County and the
State of Pennsylvania nor to ascertain the DEFENDANT 's present
whereabouts, and I do therefore return the within
COMPLAINT , NOT FOUND , as to the said
318 BRIDGE STREET
OLD FORGE, PA 18518
NOT FOUND,NEVER LIVED THERE,11/24/2014
Sheriff's Costs:
Docketing .00
Service .00
Affidavit ")C11.00
Surcharge 1 .00
.00
.00
Sworn and subscribed to before me
this day of
A.D.
Notary
So answers:
Mark P. McAndrew, Sheriff
B
ASCOLINI
Deputy Sheriff
00/00/0000
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2014-00648 T
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF Lackawanna County
DEUTSCHE BANK
VS
WILIAM RAGNI
DAVID PASCOLINI , Deputy Sheriff , who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named COMPLAINT to wit
WILLIAM RAGNI was
unable to locate Him ,within the limits of Lackawanna County and the
State of Pennsylvania nor to ascertain the DEFENDANT 's present
whereabouts, and I do therefore return the within
COMPLAINT , NOT FOUND , as to the said
318 BRIDGE STREET
OLD FORGE, PA 18518
NOT FOUND,DOES NOT LIVE THERE,11/24/2014
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
.00
Sworn and subscribed to before me
this day of
A.D.
Notary
So answers:
Mark P. McAndrew, Sheriff
B �
(2404•474(1:
I• PASCOLINI
Deputy Sheriff
00/00/0000