HomeMy WebLinkAbout02-3193IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VVaypoint Bank,
CIVIL ACTION-EQUITY
Plaintiff,
vs. No.: 0,~-
Jeffrey S. Cohick and Luann E. Cohick, his wife
Defendants.
COMPLAINT
And now comes Waypoint Bank by and through its counsel, Benjamin F.
Riggs, Jr., Esquire and states the following in support of its complaint.
Plaintiff is Waypoint Bank, a federal savings bank, with
executive offices at 235 North Second Street, Harrisburg, PA
17101.
Defendants are Jeffrey S. Cohick and Luann E. Cohick, adult
individuals who reside at 534 Big Spring Road, Newville,
Cumberland County, Pennsylvania 17241.
That on or about December 3, 1998, Defendants borrowed
$280,000 from Waypoint Bank, formerly Harris Savings Bank,
for the purchase of their residence at 534 Big Spring Road,
Newville, Pennsylvania and executed a mortgage in favor of
Waypoint Bank in the like amount. A true and correct copy of
the mortgage is attached hereto and incorporated herein by
reference as Exhibit A.
That Defendants' mortgage debt due Waypoint Bank has not
been repaid in full and as of June 26, 2002 the amount of
principal, interest and charges outstanding is $235,597.93.
That on or about October 9, 2001, Waypoint, as the result of a
clerical error, executed and recorded a Satisfaction Piece
effectuating the satisfaction of record of the Defendants'
mortgage. The erroneous satisfaction piece is attached hereto
and incorporated herein by reference as Exhibit B.
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -- EQUITY
WAYPOINT BANK
Plaintiff
VS.
JEFFREY S. COHICK AND
LUANN E. COHICK, HIS WIFE
Defendants
NOTICE
You have been sued in court. If you wish to defend against the claims set forth
in the following pages, you must take action within twenty (20) days after this complaint
and notice are served, by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the claims set forth against
you. You are warned that if you fail to do so, the case may proceed without you and a
judgment may be entered against you by the court without further notice for any money
claimed in the complaint or for any other claim or relief requested by the Plaintiff. You
may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUTWHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct
to the best of my knowledge, information, and belief. I further verify that I am the
Default Manager of Waypoint Bank, and that as such, I am authorized to make this
Verification on its behalf. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.
WAYPOINT BANK
Dated:
June 26, 2002
By; Stacy~strong~~
Default Manager
.... O~ DEEDS
...... ~IID
(Space Above This Line For Recording Data)
MORTGAGE
THIS MORTGAGE ("Security Instrument") is given on ....,,O,{~{~[~1~£ ............. ~. .................................................................................. l,,,~,,~ .........
The mortgagor Is .............................. .Jeffr. ey,,S..C, obick.~md..Lu~nr~..F~.C~.bi~l~ ..........................................................................................................................
.~.~Z~ZZZ~ZZ;;;~;~;;~i~i~iii;~i~X~i~EZZE~;~;Z~ .......................................................... i:.'~;;;;~;;;;:i ......
This Security Instrument is given to ........................ J~ar, l~i~..~.a~lO.~.~J]~. ....................................................................................................................................
~;~ ;;'~",;';;;;; ;:;ii';;';;; ;'2; ;;i~;';;;;'.';';~ ;'; ;;J ;7'.'.'.'.'.'.'.'~ ~'~.~ ~i~.'.'.'.'.'.'.'.';;; ;.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.";; j,j;';' 17;;;;2';'i 7.'.'.'ZZ.ZZi Z'ZZ'.'.'.'.'.'Zi
....................... ,P., .Q, BO~ .1Zll .............. Har. t'lsb~'g,..P.A..17..10~ ............................................................................................... ( Lender ).
Borrower owes Lender the principal sum of .................. .T.w.o.,~l~O~r.~J..F~ig~tY. Ibo. u~.i~o~.lloZ1O.0 ...............................................................................
..................................................................................................................................................................... Dollars (U.S. $ ,...;~l~,O~O,DO ............................ ).
This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with
the full debt, if not paid sadist, due and payable on .,,~.~/~.1,~ .............................................................. This Security Instrument secures to
Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensfons and modifications of the Nots; (b) the
payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance
of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage,
grant and convey to Lender the following described property located in ......................... ~:UrP, bBl~i~{~ ........................... County, Pennsylvania:
See attached Property Description
which has the address of ........ 5~,~.~Jg.,~rJ)30.~o~ ............................................................................... N.~/YJ~I~ ................................................
[Street] [City]
Pennsylvania .............. ,~ ~,~.~ ................................... ("Prooertv Address'q:
6. Occupancy, Preservation, Maintenance and Protegt~n~of.the pro~e~y; Borrower's Loan Application;
Leaseholds. Sorrower shall occupy, establish, and use the Property as Borrower's princfp~i r~sidenca within sixty days after the execution of
this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of
occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances
exist which are beyond Borrower's control. Sorrower shall not destroy, damage or impair the Property, allow the Property to deteriorate, or
commit waste on the Property. Borrower shall be in default if any fodeiture action or proceeding, whether civil or criminal, is begun that in
Lender's good faith judgment could result In fodeiture of the Property or otherwise materially impair the lien created by this Security Instrument
or Lender's security interest. Borrower may cure such a default and reinstate, as provided in paragraph 18, by causing the action or proceeding
to be dismissed with a ruling that, in Lender's good faith determination, precludes fodeifure of the Borrower's interest in the Property or other
material impairment of the lien created by this Security Instrument or Lender's security interest. Sorrower shall also be tn default if Borrower,
during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any
material information) in connection with the loan evidencad by the Nots, including, but not limited to, representations concerning Borrower's
occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Sorrower shall compty with all the provisions
of the lease, ff Borrower a~quires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in
writing.
7. Protection of Lender's Rights in the Property. If Borrower fails to pedorm the covenants and agreements contained in
this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in
bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulations), then Lender may do and pay for whatever is necessary to
protect the value of the Property and Lender's rights in the Property. Lender's actions may include paying any sums secured by a lien which has
priority over this Security Instrument, appearing in court, paying reasonable attorneys' fees and entering on the Property to make repairs.
Although Lender may take action under this paragraph 7, Lender does not have to do so.
Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument.
Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from the date of disbursement at the Note rate
and shall be payable, with Interest, upon notice from Lender to Borrower requesting payment.
8. Mortgage Insurance. If Lender required mortgage ineuranca as a condition of making the loan secured by this Security
instrument, Borrower shall pay the premiums required to maintain the mortgage insurance in effect. If, for any reason, the mortgage insurance
coverage required by Lender lapses or ceases to be in effect, Borrower shall pay the premiums required to obtain coverage substantially
equivalent to the mortgage insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the mortgage insurance
previously in effect, from an alternate mortgage insurer approved by Lender. If substantially equivalent mortgage Insurance coverage is not
available, Borrower shall pay to Lender each month a sum equal to one-twelfth of the yearly mortgage insurance premium being paid by Borrower
when the insurance coverage lapsed or ceased to be in effect. Lender will accept, use and retain these payments as a toss reserve in lieu of
mortgage insurance. Loss reserve payments may no longer be required, at the option of Lender, if mortgage insurance coverage (in the
amount and for the period that Lender requires) provided by an insurer approved by Lender again becomes available and is obtained. Sorrower
.shall pay the premiums required to maintain mortgage insurance In effect, or to provide a loss reserve, until the requirement for mortgage
~nsurance ends in accordance with any written agreement between Borrower and Lender or applicable law.
9. Inspection. Lender or Ifs agent may make reasonable entries upon and inspections of the Property. Lender shall give Borrower
notice at the time of or prior to an inspection specifying reasonable cause for the inspection.
10. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation
or other taking of any part of the Property, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid to Lender.
In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument, whether or
not then due, with any excess paid to Sorrower. In the event of a partial taking of the Property in which the fair market value of the
Property immediately before the taking is equal to or greater than the amount of the sums secured by this Security instrument immediately
before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced
by the amount of the proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediataly before the taking,
divided by (b) the fair market value of the Property Immediately before the taking. Any balanca shall be paid to Sorrower. In the event
of a partial taking of the Property in which the fair market value of the Property immediately before the taking is less than the amount
of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise
provides, the proceeds shall be applied to the sums ceoured by this Security Instrument whether or not the sums are then due.
If the Property is abandoned by Borrower, or if, after notice by Lender to Sorrower that the condemner offers to make an award or settle a
claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collest
and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums secured by this Security instrument,
whether or not then due.
Unless Lender and Borrower otherwise agree in writing, any application of proCeeds to principal shall not extend or postpone the due date
of the monthly payments referred to in paragraphs 1 and 2 or change the amount of such payments.
11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification
of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate
to release the liability of the original Sorrower or Borrower's successors in interest. Lender shall not be required to commence proceedings
against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security
Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in
exercising any right or remedy shall not be a waiver of or preclude the exemise of any right or remedy.
12. Successora and Assigns Bound; Joint and Several Liability; Ce.signers. The covenante and agreements of this
Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower. subi~nt fn fha nrn,,r~inn~ ,'~ ........ =.. ~.
24. Reinstatement Period. Borrower's time to reinstate provided in paragFaph 1~ shall extend to one hour prior to the
commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument.
25. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title
to the Property, this Security Instrument shall be a pumhase money mortgage.
26. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note
or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note.
27. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this
Security Instrument, the covenants and agreements of each such dder shall be incorporated into and shall amend and supplement the covenants
and agreements of this Security Instrument as if the rider(s) were e part of this Security Instrument. [Check applicable box(es)]
[~ Adjustable Rate Rider
] Graduated Payment Rider
] Balloon Rider
[] Other(s) [specify]
~-~ Condominium Rider
] Planned Unit Development Rider
] Rate Improvement R~der
~--] 1-4 Family Rider
] Biweekly Payment Rider
] Second Home Rider
BY SiGNiNG BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any rider(s)
executed by Borrower and recorded with it.
............................................................................................................. (Seal) -Borrower
Social Security Number .........................................................................
............................................................................................................. (Seal) -Borrower
Social Security Number .........................................................................
[Space Below This Line For Acknowledgment]
CO~ONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF CUMBERLAND )
On this, the ~-~ day of ~~ , 1998, before me a notary public,
the undersigned officer, personally appeared Jeffrey S. Cohick and Lusnn E. Cohick,
husband and wife, known to me (or satisfactorily proven) to be the persons whose nsmes
are subscribed to the within instrument, and acknowledged that they executed the same
for the purposes therein contained.
In witness whereof,
I hereunto set my hand and official seal.
Notary ~bl~c '
The- land referred to in this Commitment is described as follows:
ALL T~AT CERTAIN piece or parcel of land, together with the improvements
erected thereon, situate in North New~on Township, Cumberland County,
Pennsylvania, bounded and described as follows, to wit:
BEGINNING at an Oak Stump in the Big Spring; thence along by the middle of the
Spring by the several courses and distances, to wit, South 06 degrees West
16.4 perches; South 4 de,tees West, 11 perches; South 49 1/2 de,tees West, 10
perches; South 25 degrees West, 28 perches; South 19 1/2 degrees East, 22
perches; South 10 degrees East, 17 perches to a point in said Spring at corner
of land formerly of W. H. Lehman, and now or formerly of Richard M. Smith and
wife; thence by the same, South 80 degrees West, 40 perches to a locust tree;
thence North 12 degrees West, 20.9 perches to a stone; thence by the same,
North 88 degrees West, 33.3 perches to a stone; thence by the same, North 86
1/4 degrees West, 110 perches to a stone; thence by the same, South 85
degrees, 67.38 perches to an iron pin; thence by land now or formerly of S. D.
Miller, formerly part of same tract, North 24 degrees 05 minutes West, 4?.8
perches to an iron pin along a Public Road; thence alon&j said public road,
North 82 degrees East, 86.85 perches to a stone; thence by property now or
formerly of Carlisle Deposit Bank and Tr~st Company, North 62 1/2 degrees
East, 69.8 perches to a point, corner of said public road and said Carlisle
Deposit Bank and Trust Company lands; =hence by the latter, South 24 1/4
degrees Bast, 20 perches to a stump; nhence by lands of the same, South 67 1/4
degrees East 25.4 perches to a stone; thence by the same, North 88 1/2 degrees
East, 96.7 perches to the place of BEGINNING.
CONTAINING 121 acres and 85 perches, more or less.
UNDER AND SUBJECT, NEVERTHELESS, to all rights of way, easements, restrictions
and/or conditions of record.
BEING the same premises which became vested in Jeffrey S. Cohick and Luarin E.
Cohick, by virtue of deed recorded in Cumberland County Records in Deed Book
32 A at Page 837.
ALTA C~mmita~nt
ScheduLe C
HARRIS
SAVINGS BANK
235 North Second Street
P.O. Box 1711
Harrisburg, Pennsylvania 17105-1711
717/235-4041
AUTOMATIC PAYMENT RIDER TO MORTGAGE
Mortgagor: J~*ffr~y ~ Cnhink ~nd LH~nn E Co, hick
Dated: 1
Automatic Payment Provisions. If the indebtedness evidenced by the Note is intended to finance real
property, borrower agrees to comply with the covenants and conditions of the Automatic Payment Agreement,
which is hereby incorporated by reference into and made a part of this Mortgage.
You have elected an automatic payment option and received the interest rate benefit therefrom. If you
cancel, or cause the termination of automatic payments as provided for in the Automatic Payment Agreement,
you will be assessed a cancellation fee equal to 1 % of the remaining balance on your mortgage
account. The cancellation fee will be charge effective when the automatic payments cease and will be due and
payable in full at that time pursuant to the terms of the Note and Mortgage. Failure to promptly pay the
cancellation fee will be an event of default under the Note and Mortgage and at Lender's option it may: (i) invoke
any of the rights or remedies provided in the Mortgage; (ii) accelerate the sums secured by this Mortgage and
invoke those remedies provided in paragraph (21) thereof; or (iii) do both.
Witness
J~r~y% Col~ick
Luann E Cohick
M999 Harris (11/98)
SATISFACTION PIECE
Made this 4th day of October, 2001
Name of MORTGAGOR/S: Jeffrey S Cohiek & Luann E. Cohick
Name of MORTGAGEE/S: Waypoint Bank formerly Harris Savings Bank
EXHIBIT B .'
7 }~ ~'j ! i' ". · 1707017365
'01 OOT 9 PPI 1 55
Date of Mortgage: 12/03/98
Original MORTGAGE DEBT: $280,000.00
Mortgage RECORDED ON: 12/09/98 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Mortgage Book
1504, Page 712
Name/s of LAST ASSIGNEE/S:
Last ASSIGNMENT recorded on in the Office of the Recorder of Deeds of County, in Mortgage Book, Page
Name/s of LAST ASSIGNEE/S:
Last ASSIGNMENT recorded on in the Office of the Recorder of Deeds of County,, in Mortgage Book, Page
Name/s of LAST ASSIGNEE/S:
Last ASSIGNMENT recorded on in the Office of the Recorder of Deeds of County,, in Mortgage Book, Page
Brief Description or Statement of LOCATION of Mortgage Premises:
534 Big Spring Road, North Newton Township, Cumberland County, Newvflle, PA 17241
The undersigned hereby cerdfy/ies that the debt sEcUred by the above mentioned Mortgage has been fully paid or discharged
and that upon the recording hereof, said Mortgage shall be and is hereby fully and forever satisfied and discharged.
IN WITNESS THEREOF, the undersigned executed this satisfaction on the 4th day of October 2001 A.D.
,:.'~;?: '~.7~:WITNESS PRESENT WAYPOINT BANK
':" ~' ;(s~d) ;Assistant SecreUny
COUNTY OF Dt~PItlN
Assistant Vice President,
Robc~ L. IIcndrick5
ON THIS, die 4th day of October A.D. 2001 before me, A NOTARY, the undersigned officer, personally appeared Robert
L. Hendrieks, who aclmowtedged himself u) be the Assistant Vice President of WAYPOINT BANK, a corporation, and that Robert
L. Hendricks, he as such Assistant Vice President being authorized to do so, executed the within instrument for the purposes therein
contained by sJ~tmlng the flame of the corporation by himself as Assistant Vice President.
WITNESS my hand and NOTARY seai.
· * c~ r~ {.My t2r~ml~fi~ ~:.._~ ~ 8. ~
Waypoint Bank,
Plaintiff,
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-EQUITY
No.: c~.z. 3/~'3 ~ ~
Jeffrey S. Cohick and Luann E. Cohick, his wife
Defendants.
Type of Pleading:
Praecipe for Lis Pendens
Filed on behalf of:
Waypoint Bank
Counsel of Record for this Party:
Benjamin F. Riggs, Jr.
Attorney for Plaintiff
101 South George Street
P.O. Box 15068
York, PA 17405-7068
Phone: (717) 815-4518
I.D. No. 72030
Waypoint Bank,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
VS.
CIVIL ACTION-EQUITY
No.:
Jeffrey S. Cohick and Luann E. Cohick, his wife
Defendants.
PRAECIPE FOR LIS PENDENS
TO THE PROTHONOTARY:
Please index the above-captioned action as a lis pendens against the
following real property located at 534 Big Spring Road, Newville, Pennsylvania
17241, more fully described in the attached Property Description recorded in
Book 1504 Page 717 and marked as Exhibit A.
Date: June 26, 2002 BYBenjamin
F.
Riggs,
Jr.
Attorney for Plaintiff
101 South George Street
P.O. Box 15068
York, PA 17405-7068
Phone: (717) 815-4518
I.D. No. 72030
2
EXHIBIT A
The land referred to in this Commitment is described as follows:
~ THAT CERTAIN piece or parcel of lend, together with t. he improvements
erected thereon, situate in North Newton Township, Cumberland County,
Pennsylvania, bounded and described as follows, to wit:
BEGINNING at an Oak Stump in the Big Spring; thence along by the middle of ~he
Spring by the several courses and distances, to wit, South 06 degrees West
16.4 perches; South 4 de,tees West, 11 perches; South 49 1/2 de,tees West, 10
perches; South 25 de,tees West, 28 perches; South 19 1/2 degrees Bast, 22
perches; South 10 degrees Bast, 17 perches to a point in said Spring at corner
of land formerly of W. H. Lehman, and now or formerly of Richard M. Smith and
wife; thence by the same, South 80 degrees West, 40 perches to a locust tree;
thence North 12 degrees West, 20.9 perches to a stone; thence by the same,
North 88 degrees West, 33.3 perches to a stone; thence by the same, North 86
!/4 degrees West, 110 perches to a stone; thence by the same, South 5S
degrees, 67.35 perches to an iron pin; thence by lend now or formerly of S. D.
Miller, formerly part of same tract, North 24 degrees 05 minutes West, 47.8
perches to an iron pin along a Public Road; t. hence along said public road,
North 52 de,tees East, 86.85 perches to a stone; thence by property now or
formerly of Carlisle Deposit Bank end Trust Company, North 62 1/2 degrees
Bast, 69.8 perches to a point, corner of said public road and said Carlisle
Deposit Bank and Trust Company lands; thence by the latter, South 24 1/4
degrees Bast, 20 perches to a stump; thence by lands of the same, South 67 1/4
degrees Bast 25.4 perches to a stone; thence by the same, North 88 1/2 degrees
East, 96.7 perches to the place of BEGINNING.
CONTAINING 121 acres and 85 perches, more or less.
UNDER ARD SUBJECT, NEVERTHELESS, to all rights of way, easements, restrictions
end/or conditions of record.
BEING the same premises which became vested in Jeffrey S. Cohick and Lua~n E.
Cohick, by virtue of deed recorded in Cumberland County Records in Deed Book
32 A at Page 837.
ALTA Cofllwi 'l:mnt
Sch~.~duL e C
SHERIFF'S RETURN -
CA~ NO: 2002-03193 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WAYPOINT BANK
VS
COHICK JEFFREY S ET AL
REGULAR
SGT DAVID ZEIGLER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to
says, the within COMPLAINT - EQUITY was served upon
COHICK JEFFREY S the
law,
DEFENDANT , at 1053:00 HOURS, on the 15th day of July
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQ
CARLISLE, PA 17013 by handing to
JEFFREY COHICK
a true and attested copy of COMPLAINT - EQUITY
, 2002
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.28
Affidavit .00
Surcharge 10.00
.00
36.28
Sworn and Subscribed to before
me this 2~ day of
~ ~O~ A.D.
thonotary
So Answers:
R. Thomas Kline
07/16/2002
WAYPOINT BANK
Deputy
SHERIFF'S
CASE NO: 2002-03193 p
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WAYPOINT BANK
VS
COHICK JEFFREY S ET AL
RETURN - REGULAR
JODY SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EQUITY was served upon
COHICK LUANN E
the
DEFENDANT , at 1232:00 HOURS, on the 10th day of ~ul¥
at CUMBERLAND CO SHERIFF,S OFFICE ONE COURTHOUSE SQ
CARLISLE, PA 17013 by handing to
LUANN E COHICK
, 2002
a true and attested copy of COMPLAINT - EQUITY
together with
and at the same time directing ~er attention to the contents thereof.
Sheriff,s Costs: So Answers:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
16.00 07/16/2002
WAYPOINT BANK
Sworn and Subscribed to before
me this _~ day of
~ ~.L A.D.
~rothonotary~ ~ z
By:
Deputy Sheriff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - EQUITY
WAYPOINT BANK
VS.
Plaintiff
No. 02..3193
JEFFREY S. COHICK AND
LUANN E. COHICK, HIS WIFE
Defendants
PRAECIPE TO DISMISS
Please dismiss the above-captioned case without prejudice.
Dated:
November 21, 2002
By:
Benjamin
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
(717) 815-4518
No. 72030