Motion-Secondary: SOVEREIGN BANK V HAYNES, THOMAS B

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                                SOVEREIGN BANK IN THE CIRCUIT COURT OF THE 15TH +
7 JUDICIAL CIRCUIT IN AND FOR
/ Plaintiff. PALM BEACH COUNTY, FLORIDA
: ree mB
vs. CASENO. 50 OTCA O24NAG
THOMAS B. HAYNES, et ux,, et al., AFFIDAVIT IN SUPPORT OF
MOTION FOR FINAL SUMMARY
Defendant(s). JUDGMENT Bo
/
STATE OF PENNSYLVANA
COUNTY OF BERKS

 

BEFORE ME this day personally appeared Constance Cocroft__, who upoi 2
on personal knowledge and says:

1, This Affidavit is submitted in support of Plaintiff's Motion for Final Judgment for
the purpose of showing that there is in this action no genuine issue as to any material fact, and
that Plaintiff is entitled to a judgment as a matter of law.

2. My name is Constance Cocroft, and I am the Vice President of SOVEREIGN
BANK. SOVEREIGN BANK is the owner or servicer for the owner of the note and mortgage
herein. SOVEREIGN BANK is responsible for the collection of this loan transaction and pursuit
of any delinquency in payments. I am familiar with the books of account and have examined all
books, records, and documents kept by SOVEREIGN BANK concerning the facts alleged by
SOVEREIGN BANK in this cause. All of these books, records and documents are kept by
SOVEREIGN BANK in the regular course of its business as servicer of the loan transaction and
are made at or near the time by, and from information transmitted by, persons with personal
knowledge of the facts such as your affiant. It is the regular practice of SOVEREIGN BANK to
make and keep these books, records, and documents. The books, records, and documents which

Affiant has examined are in the custody, supervision and control of Affiant, and are complete,, eran and correct. Furthermore, Affiant personal knowledge of the matters contained in the
books, records and documents kept by SOVEREIGN BANK.

3. J have personal knowledge of the facts contained in this affidavit. Specifically, I
have personal knowledge of the facts regarding the sums of money which are due and owing to
SOVEREIGN BANK pursuant to the Note and Mortgage which is the subject matter of the
lawsuit. ;

4. The following amounts are due and payable:

A. Principal Balance of $_276,031.51

 

B. Accrued interest from 07/01/07 through 03/01/08 in the
amount of $ 12,148.54 thereafter at the rate of $ 49.6959 per diem

C. Late charges accrued up to default date $449.50.
D. Escrow Advances $ 1,548.99.

Hazard Insurance advance $
Taxes for the year 2007 $ 1,548.99

Taxes forthe year oS

Other $
E. Maintenance and Inspections $. $41.40.
F. Other advances Lien Search $80.00.
G. Other advances $
H. $

5. SOVEREIGN BANK has employed the services of the law firm of Spear and
Hoffman in this action against the Defendant(s), and is obligated to pay Spear and Hoffman a

reasonable attorney’s fee for its services, along with all costs and expense of this action.a
FURTHER AFFIANT SAYETH NAUGHT.

a
“a
Zz LA
AFFIANT Constance Cocroft

STATE OF PENNSYLVANA
COUNTY OF BERKS

The Affiant, [ of st nee Cony ott has sworn before me that he/she has personal

knowledge of all the statements that he/she has made in this affidavit, and that all statements are true

and correct this 4” day of JANUA Y , 2008, and Affiant is the | |ce Pres dent of

SOVEREIGN BANK, and who is personally known to me and who did take an oath.

 

 

Notary Public, Stateof PENNSYLVANA

 

at Large
My Commission Expires: Oct: Y 1 30049
Loan No: 0826863882/ Hayne-Thomas.aff COMMONWEALTH OF PENNSYLVANIA
7 paral aaloubi
jannon M. Shugaz, Notary Public
SBH-C-055/bao City of Reading, Barks County
My Commission Expires Oct. 4, 2008

 

 

 

Member, Pennsylvania Association of Notaries