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Home My WebLink About01-5495FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION OF PA 500 ENTERPRISE ROAD SUITE 150, HORSHAM, PA 19044 Plaintiff STACY L. MOTTER MARK D. MORRISON 3529 LiSBURN ROAD, MECHANICSBURG, PA 17055-670 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. OI - WYq~ CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, 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. '}* You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that it'you tail 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. II: 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 HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 450194964 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 VERIHCATION 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. Plaintiffis GMAC MORTGAGE CORPORATION OF PA 500 ENTERPRISE ROAD SUITE 150, HORSHAM, PA 19044 The name(s) and last known address(es) of the Defendant(s) are: STACY L. MOTTER MARK D. MORRISON 3529 LISBURN ROAD, MECHANICSBURG, PA 17055-670 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 8/7/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1276, Page 608.. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 5/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." The following amounts are due on the mortgage: Principal Balance Interest 4/1/01 through 9/1/01 (Per Diem $12.11) Attorney's Fees Cumulative Late Charges 8/7/95 to 9/1/01 Cost of Suit and Title Search Subtotal $57,044.35 1,864.94 2,852.00 108.70 550.00 $62,419.99 Escrow Credit 0.00 Deficit 778.35 Subtotal $ 778.35 TOTAL $63,198.34 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A'; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAiNTIfF demands an in rem Judgment against the Defendant(s) in the sum of $63,198.34, together with interest from 9/1/01 at the rate of $ ! 2.11 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff First Mortgage Loan Servicing ' .3451 Hammond Ave P.O. BOx 780 Waterloo, IA 50704-0780 GMAC Mortgage Date: July 16, 2001 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 lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEO%~NER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET %~ITH A CONSI~IER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counselin~ A~encv. The name, address and phone number of Consumer Credit Counseling Agencies serving your Count~' 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 hearing can call (717) 780-1869). This Notice contains important legal information. If you have any' questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The lacal bar association may be able to help you find a lawyer. LA NOTIFICACION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VI'v~ENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEO~NER°S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDI~HR SU HIPOTECA HOMEO%%~ER'S NAME(S): PROPERTY ADDRESS: MARK D. MORRISON 3529 LISBURN ROAD M]ECHANICSBURG, PA 17055-6702 LO~N ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: 450194964 N/A GMAC Mortqaqe Corporation F>(,HIBI'[' A First Mortgage Loan Servicing .3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 GMAC Mortgage Date: July 16, 2001 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 lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOVS~ER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see ff HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY W~ITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counselin~ Aeencv. 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 question% you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency' may be 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 AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR ~q¥~ENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINAaNCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEO%VNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDL~HR SU HIPOTECA HOMEO%~ER'S NAME(S): PROPERTY ADDRESS: STACY L. MOTTER 3529 LISBURN ROAD M~CHANICSBURG, PA 17055-6702 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: 450194964 N/A GMAC Mortgage Corporation [XHIBITA HOMEOVt."NER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, yon are entitled to a temporary stay of foreclo sure on your mortgage for thirty (30) days from the date of this Notice. Ihtring that time you rmtst arrange and attend a "face-to-face" meeting with one of the cons~uner credit coxmseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30} DAYS. IF YOU DO NOT .M~PLY 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. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone nmnbers of dasignated consumer credit cmmselin~ agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedxde one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in defanlt for the reasons set forth later in this Notice (see following pages for specific information about the nature of your defanlt.) If you have ttied and are unable to resolve this pmblem w/th the lender, you have the right to apply for financial assistance from the Homeoxvnex's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeoxvne?s Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consnmer credit cmmseling agencies have applications for the program and they xv/ll assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application *YCST be filed or post,harked within thirty (30) days of you face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE V*~LL BE DENIED. AGENCY ACTION -- Available fimds 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. DCrmg that time, no foreclosure proceedings xvill be pnrsned against you if you have met the time requirements set forth above. Ymt will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. FXHIBIT &. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If yon have filed bankruptcy yon can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender is on your property located at: 3529 LISBURN ROAD M~CHANICSBURG, PA 17055-6702 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the followinq amounts are now past due: May 1, 2001 through July 1, 2001. See attached Exhibit for payment breakdown. Monthly Payments Late Charges NSF Inspections Other Suspense TOTAL AMOUNT PAST DUE: 1,850.58 65.22 0.00 0.00 97.39 0.00 2,013.19 B. YOU HAVE FAILED TO TAKE THE FOLLOWqNG ACTION (Do not use if not applicable): ROW TO CURE TIlE DEFAULT -- You may cxtre the default xvithin THIRTY (30) DAYS of the date of this notice BY PAYING TIlE TOTAL AMOUNT PAST DUE TO TIlE LENDER, WHICH IS $ 2,013.19 , PLUS A~XPf MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashiers check, certified check or money order made payable and sent to: Payment Processing GMAC Mortgage Corporation PO Box 780 Waterloo, IA 50704-0780 You can calm any other defatdt by taking the folloxving action w/thin THIRTY (30) DAYS of the date of this letter: (Do not nsc if not applicable.) Not Applicable IF YOU DO NOT CURE TIlE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt x~Sll be considered due immediately and yon may lose the chance to pay the mortgage in monthly installments. Iffidl payment of the total amonnt 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 mortlla~ed properS-. IF TIlE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers ymtr case to its attorneys, Ntt yon cure the delinquency before the lender begins legal proceedings against you, yon will still be required to pay the reasonable attorney's fees that were actually inmtrred, up to $50.00. However, if legal proceedings are starred against against you, you will have to pay all reasonable attorney's fees actually inc~trred by the lender even if they exceed $50.00. Any attorney's fees x~5ll be added to the ammmt you owe the lender, which may also include other reasonable costs. If you cure the default w~thin the THIRTY (30) DAYS period, you will not be required to pay attorney's fees. VXHIBIT &. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and ali other s~nns dne under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If yon have not cured the defa~dt within the THIRTY (30) DAY period and foreclosure proceedings have begun, yon still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. Yon mag do so by pa¥in~ the total ammmt then past due, pins any late or other char~es then due, reasonable attorney's fees and costs connected xvith the foreclosure sale and any other costs connected w/th the Sberiffs Sale as specified in writin~ by the lender and by performin~ any other req~Lirements under the mortgage. 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 DATE -- It is estimated that the eariiest date that snch a Sheriffs Sale of the mortgaged property cmdd be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sate v~511 be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. Yon may fred 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: GMAC Mortgage Corporation 3451 Hammond Avenue Waterloo IA 50702 Phone Number: Fax Number: Contact Person: (800) 850-4622 (319) 236-7437 Collection Department EFFECT OF SHERIFF'S SALE -- You shonld realize that a Sheriffs Sale xvill end your ownership of the mortgaged pmpeay and your right to occupy it. If yon continne to live in thc property after the Sheriffs Sale, a lawanit to remove you and your fitmishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may not sell or transfer ymtr home to a buyer or transferee xvho will assume the mortgage debt, provided that all the ontstand/mg payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTMN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENrDAR YEAR.) TO ASSERT THE NONrEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANvf OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDEIL4L BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ENCLOSED PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTA~NCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REv. 8;00) CLINTON COUNTY COLUMBIA ~OUNTY CRAWFORD COUNTY Lycomthg-CIinton Counties Commiston for Communi~ Action (STEP) 2138 Lincoln Street P O. Box I328 Williamsport. PA 17703 (570) 326-0587 FAX (570) 322-2197 CCCS of Northeastern PA 201 Basin Street Williamsport, PA 17703 (570) 323-6627 FAX (570) 3234626 31 W Market Street POB 1 t27 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 Commission on Economics Opportunity of L~eme County 163 Amber Lane Wilkes-Borne, PA 18702 (570) 826-05 [0 or (800) 822-0359 FAX (570) 829-1665--~Call Before Fxxing) (570) 4554994 Haz¢ltown FAX (570) 45%563 [~Call Before Faxing) (570) 8364090 Tunkhannock Booker T Washington Center 1720 Holland Center Erie, PA 16503 (814) 453-5744 FAX (g14) 5749 John F Kennedy Center. Inc 2021 East 2ffh SIreet Erie. PA 16510 (8 [ 4) 898-0400 F.-L'((814) 898-1243 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6~ Street H ~'Ti sburg, PA 17 [ 0 [ (717) 234-5925 F,-LX (717) 234-9459 Community Action Corem of the Capital Region 15[4 Deny. Street H~rrisburg, PA 17104 (7t7) 232-9757 FAX (717) 234-2227 CUMBERLAND COL~qTY CCCS of Northeastern PA 163l South Atherton St., Suite I00 State College. PA 16801 (814) 238-3668 FcC'(~814) 238-3669 1400 Abington Executtye Park Suite 1 Claxk~ SummiL PA 18411 (570) 587-9163 or (800) 922-9537 F.~'((570) 587-9134-9135 Gremer Erie Communi~ Action Comm~tzee 18 West 9~ Street Eno, PA 16501 (814) 459-4581 FAX (814) 456-0161 Shenango Valley Urban League, [nc 601 Indiana .Avenue (412) 981-5310 Financ)al Counseling Services of Franklin 31 West 3'd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Cadisle 301 "G" Street Cai'lisle. PA 17013 .~ (717) 243-3818 F,.LX ~717) 731-9589 Adams County Housing Authorit2, 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX 334-8326 PENNSYLV,~NL4. BULLETIN, VOL. 29, NO. 23, JU,~E 5, 1999 E}(HIBffA County,. ?ennsy!van!a, bounded and described BEGINNING at a point w.hich point is nn iron pin located from an existing r~lroad spike on the eaeterly line of Lisburn Road (L.R. 21014); =hence North 76 degree~ 00 minutes 00 seconds East, 160.33 feet to said iron pin; ~hence along the cen~er!ine of a 2G.0G foot unopened right-of-way between Lot No. 1 on said p!a~ and lands now or late of T..~iller; thence North 76 degrees 0O ~nutes 00 seconds East, i13.00 ~eet to an existing iron pin: thence along s~d line 22.00 feet =o~ a poin~ along the Yellow Brmeches Creek; ~hmnc, along ~aid llne 14.25 feet ~o a poin~ the Yellow Breeches Creek; thence along the be4 of s~d Creek South 17 degrees 40 minutes 30 second~ East, 220.29 feet ~oa pein= ~i~hin =he bed of sai~ creek; thence along land~ no~ ~r la=e of W.R. Goudy (aka Lot ~o. 3 on ~d p!~) $ou~ 76 de~es 00 minutes 00 seconds West, 35.00 fee~ to a point along =he b~ of the Yellow Breeches Creek; thence along ~aid lin~ 24.0~ f~et ~o an iron pin; thence along ~d !in~ fee~ to an iron pin the place of BEGINNING. B-.~G io= No. on plan of Comp's Meadow in accordance with a survey By Ernest J. Walker, P.E., dated March 5, 1981 and recorded in Plan Book 7, Page 4. ~VING TBER~ON erected a dwelling known as 3529 Lisburn Road, Meoha.nicsburg, PA. TOGETHER with the.~ght to use a 20.00 foot wide road being existing gravel which is 10.00 feet either s~de of the center!ina of a line from ~he center!ina of Lisburn Road North 73 degrees 15 minutes 00 ~econ~s West, 200.00 fee=. BEING KNOWN AS U~ER and SUBJECT ~o certain restrictions now of record. BEING THE SAME PREMISES which M~chael L~ppert ' , By Indenture bearin~ the dace day of A.D. !995 and in:ended ~o be forthwith recorded in ~he office for recording'if Deeds, in and for ~he county of Cumberland , Con%~onwea!th of Pe .... granted and conveyed unto said Mor~a~ors, in fee. VERIFICATION KRISTINE WILSON hereby states that she is FORECLOSURE SPECIALIST of GMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification~ and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are tree and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. * FEDERMAN AND PHELAN By: Frank Federman, Esquire Atty. I.D. No.: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff GMAC MORTGAGE CORPORATION OF PA STACY L. MOTTER MARK D. MORRISON Plaintiff Defendant(s) Court of Common Pleas CUMBERLAND County No. 01-5495CIVIL PRAECIPE TO WITHDRAW COMPLAINT WITHOUT PREJUDICE t AND SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark this matter settled, discontinued and ended, upon payment of your costs only. Date Frank Federman Attorney for Plaintiff