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Home My WebLink About06-2277GOLDBECK McCAFFERTY & McKEEVER BYC JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 W W W.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF CITIMORTGAGE INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 CLAIRE L. DICK JOHN M. DICK VS. Mortgagors and Real Owners 2902 Glenwood Road Camp Hill, PA 17011 Plaintiff Defendants Term No. CIVIL ACTION: MORTGAGE NOTICE LQftRE 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 the 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 claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE LISTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A o? - as`7 7 fit' I L'?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE-ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call the following number: 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.sov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call Beth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of FN-0927. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is CITIMORTGAGE INC., PO Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898- 9481. 2. The names and addresses of the Defendants are CLAIRE L. DICK, 2902 Glenwood Road, Camp Hill, PA 17011 and JOHN M. DICK, 2902 Glenwood Road, Camp Hill, PA 17011, who are the mortgagors and real owners of the mortgaged premises hereinafter described. On November 07, 1997 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE INVESTORS CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1416, Page 855. The mortgage has been assigned to: CITIMORTGAGE INC. by assignment of Mortgage which assignment is lodged for recording. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for January 01, 2006 and each month thereafter and by the terms the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance Interest from 12/01/2005 through 04/30/2006 at 7.5000% Per Diem interest rate at $23.24 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 01/01/2006 to 04/30/2006 Monthly late charge amount at $35.59 Costs of suit and Title Search Servicing Fees Escrow Delinquency Expense Credit Unapplied Funds Monthly Escrow amount $275.34 $113,111.27 $3,509.23 $5,655.56 $142.36 $900.00 $47.00 -$652.72 -$288.68 -$461.47 $121,962.55 If the Mortgage is reinstated prior to a Sheriff s Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff s Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in nersonam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $121,962.55, together with interest at the rate of $23.24, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: ?J ?(L XGOL ECK MCCAYFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION 1, Malinda A. Caywood , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: b- ZI -0? Malinda A. Caywood, Vice P 'es ent ?hibitA Leval Des riatioD Name: JOHN M DICK III CLAIRE L DICK Loan Number: 0505040775 A PARCEL OF LAND LOCATED IN THE STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND, WITH A SITUS ADDRESS OF 2902 GLENWOOD RD, CAMP HILL PA 17011-7209 CURRENTLY OWNED BY DICK JOHN MIDICK CLAIRE L 111 HAVING A TAX ASSESSOR NUMBER OF 23-0551.0137-0000000- 13 AND BEING THE SAME PROPERTY MORE FULLY DESCRIBED AS LOT 6 BL C PB 6 PG 49 AND DESCRIBED IN DOCUMENT NUMBER 15&901 DATED 0011997. Page 4 Ey?hifiit B 04/21/2006 I 08:37 FAX 301 696 3160 03/0606 CITI-MORTGAGE 71078381654004050678 JOHN M DICK III CLAIRE L DICK 2902 GLENWOOD RD CAME HILL PA 17011-7209 RE: CitiMortgage Loan 0: 0505040775 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the leader intends to foreclose- Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able tc- help to save your home. This Notice explains how the program worFz. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT 00t)XSELING AGENCY WITHIN 30 DAYS OF TIE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency- Cm6ol The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice- If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearincr can call (717)780-1869). This Notice contains important legal information. If you have and questions, representatives at the consumer Credit Counseling Agency may he able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA Sty DERECHO A CONTINUAR VIVIENDO EN Su CASA. SI NO COMPR$NDE EL CONTENIDO DE ESTA NOTIFICACION OHTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDC ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUM RO MENCIONADO ARRIBA. PUEDSS SZR ELEGIHLE PARA UN PRESTAMO PCR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRP,M" EL CUAL PUEDE SA.LVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 04/21/2006 08:38 FAX 301 696 3160 CITI-MORTGAGE 10002 Page Two 03106/06 0505040775 HOMEOWNER'S NAME(S): John M Dick III Claire L Dick PROPERTY ADDRESS: 2902 Glenwood Rd Camp Hill,PA 17011-0000 LOAN ACCT_ NO.: 0$05040775 ORIGINAL LENDER: Mortgage Investors Corporation CURRENT LENDER/SERVICER: CitiMortgage, Inc_ is providing this notice as lender or servicing agent for the lender. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR F:OME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH TEE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1903 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REGUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, yoU are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEBTIN3 MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE. UP TO DATE. 04/21/2006 08:38 FAX 301 696 3160 CITI-MORTGAGE 10003 Page Three 03/06/06 0505040775 CONSpMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agencies listed at the and of this notice, the lender may NOT take action against you for thirty (30) days a:'aer the data of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county %11 which the property is located are set forth at the end of this Notice. it is only necessary to schedule one face-to-face meeting. Advise: your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set forth later in this Notice (see following pages fur specific information about the nature of your default)_ If you helve tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW TBE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL Bfi DENIED. AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceeding will be pursued against you if you have met the time requirements set forth above. You will be notified directly by thq Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING 017 A PETITION 174 BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLEC'P THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) 04/21/2006 08:38 FAR 301 696 3160 CITI-MORTGAGE Page Four 03/06/06 0505040775 HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above property located at: 2902 Glenwood Rd,, Camp Hill, PA 17011-0000 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following following amounts are now past due: 01101106 thru 03101106 Previous late charge(s) Delinquency Expensee(s) TOTAL AMOUNT PAST DUE: 3 2 $1,102.94/month $35.59/late charge/month Q 004 lender = your months and the $3,330.00 :30-00 ;;0.00 $3,3130.00 HOW TO CURB THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of this notice nY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,380.00, PLUS ANY MORTGAGE PAYMENTS, LATE CHARGES AND DELINQUENCY EXPENSES WHICH WrOME DUE DURING THS THIR'_.'Y (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: CitiMortgage, Inc. PO Box 8003 South Hackensack, NJ 07606-8003 IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default witk,in THIRTY (30) DAYS of the date of this Notice, the lender intends t[, exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in morthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property- IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started 04/21/2006 08:59 FAI 301 696 9160 CITI-MORTGAGE Q 005 Page Five 03/06/06 0505040775 against you, you will have to pay all reasonable attorney'a fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgag_. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-I4 you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sherif E's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees asui costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgagi__ Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATB-It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged propert, could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale w:.ll be sent to you before the sale. Of course, the amount needed to cute the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Fax Number: Contact Person: CitiMOrtgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2240 1-500-723-7906- 1-636-261-7716 Kevin Leppanen . Calls are randomly monitored and recorded to ensure quality service- • 54/21/2006 08:39 FAX 301 696 9160 CITI-MORTGAGE 000 Page six 03/06/06 0505040775 EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-Please refer to your original loan documents to determine whether or not you may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's Pees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. You may also call the 1-800 Number above to find out whether your loan is assumable- YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DE3T OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CORED EY ANY THIRD PARTY ACTING ON YOUR BEiALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF,WLT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE 'CRIS RIGRT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS- * TO ASSERT ANY OTHER. DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACi1ION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL, BANKRUPTCY LAW- Under IRS regulation, we must report any foreclosure to the IR£! on form 1099-A- The foreclosure may result in income tax consequences to you. Consult the IRS or your tax advisor for further information- Enclosure: Consumer Credit Counseling Agencies, including those fcr your county. 060306D0002953 d G ? ,r t, ? A, "It % CASE NO: 2006-02277 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIMORTGAGE INC VS DICK CLAIRE L ET AL SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE DICK JOHN M DEFENDANT the at 1555:00 HOURS, on the 25th day of April , 2006 at 2902 GLENWOOD ROAD CAMP HILL, PA 17011 JOHN DICK was served upon by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 R. Thomas Kline nn 16.UU Sworn and Subscribed to before me this day of A. D. 04/26/2006 GOLDBECK MCCAFFERTY MCKEEVER By. eputy Sheriff Prothonotary . .A. SHERIFF'S RETURN - REGULAR CASE NO: 2006-02277 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIMORTGAGE INC VS DICK CLAIRE L ET AL SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE DICK CLAIRE L the DEFENDANT , at 1555:00 HOURS, on the 25th day of April 2006 at 2902 GLENWOOD ROAD CAMP HILL, PA 17011 JOHN DICK, HUSBAND was served upon by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.32 Affidavit .00 Surcharge 10.00 .00 4h 40.32 Sworn and Subscribed to before me this day of A. D. So Answers: R. Thoma.s.Kline ` 04/26/2006 GOLDBECK MCCAFFERTY MCKEEVER By: D uty Sheri Prothonotary GOLDBECK McCAFFERTY & McKEEVER BY: Lisa A. Lee Attorney I.D. #78020 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 CITIMORTGAGE INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. CLAIRE L. DICK JOHN M. DICK Mortgagors and Record owners 2902 Glenwood Road Camp Hill, PA 17011 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 06-2277 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. RU -{kfICE 2009 OCT -I PM 3= 0 4 PENNSYLVANIA