HomeMy WebLinkAbout00-02163
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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55.
Robert P Ziegler 'f
I, ____________________________________________________~________________________Ilccordero
Deeds in and for said County and State do 'hereby certify that the Sheriff's Deed'in which ________________
\<111 Specialty Mtg LLC .
____________________________________________________________________________________ ~ thegr.antee
the same having been sold to said grantee on the _______~_t!:_____________n_____________n__n__ day of
02
-----1 under and by virtue of a wnL_____________
7th
___~_~~::~_:.~~:?__________________ _____ _________ _ issued. on the ______ _______ _______ __ ______ _________
March .
______________________n_________n__n_ A. D., '
day of ____~~l'}_"__~=.:____________ A. D.,
Civil
______________________________... ...______ __________ ____ __________ ___________________ Tenn, :
, 2163 Washington Mutual Bank
Number ___________ ___, at the s.uit of ___ ____________ ___ _ ____ ____ ___ ____ _ ______c_ _____ __ _____________
Frank M Romito Jr & Bonita J
___________________________________against____________________________________________________ G
251 3117
duly recorded in Sherifrs Deed Book No. ____________, Page ____________.
2001 .
_____) out of the Court of Cornman Pleas of said County as of
2000
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office th~ ___f_~__ day
of ----~71-----A--;4'f\d?fifd~
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Washington Mutual Bank
VS
Frank M. Romito, Jr. and
Bonita J. Romito
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001>>-2163 Civil Term
David McKinney, Deputy Sheriff, who being duly sworn according to law, states
that on Sept. 20, 2001 at 4:35 o'clock P.M., E.D.S.T., he served a true copy ofthe within
Real Estate Writ, Notice and Description, in the above entitled action, upon the within
named defendant, to wit: Frank M. Romito, Jr., by making known unto Frank Romito JI.
personally at 51 West Keller Street, Mechanicsburg, Pennsylvania, its contents and at the
same time handing to him personally the said true attested copy of the same.
David McKinney, Deputy Sheriff, who being duly sworn according to law, states
that on Sept. 20, 2001 at 4:35 o'clock P.M., E.D.S.T., he served a true copy of the within
Real Estate Writ, Notice and Description, in the above entitled action, upon the within
named defendant, to wit: Bonita J. Romito, by making known unto Frank Romito JI.,
adult in charge, at 51 West Keller Street, Mechanicsburg, Pennsylvania, its contents and
at the same time handing to him personally the said true attested copy of the same.
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on Oct. 01, 2001 at 6:34 P.M., E.D.S.T., he posted a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Frank M. Romito, Jr. and Bonita J. Romito, located at 51 West Keller Street,
Mechanicsburg, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being dilly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice ofthe pendency of the action to one of the within named
defendants to wit: Frank M. Romito, Jr., by regular mail to his last known address, 51
West Keller Street, Mechanicsburg, PA 17055. This letter was mailed under the date of
October 3,2001 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the al:1ove Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defeniIants to wit: Bonita J. Romito, by regular mail to her last known address, 51 West
Keller Street, Mechanicsburg, PA 17055. This letter was mailed under the date of
Octo~er 3,2001 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after
due a$d legal notice had been given according to law, exposed the within described
premi~es at public venue or outcry at the Courthouse, Carlisle, Cumberland County,
Penn~y1vania on March 6, 2002 at 10:00 AM, EST. He sold the same for the sum of
$1.00:to Attorney Frank Federman for WM Specialty Mortgage LLC, without recourse.
It beiryg the highest bid and best price received for the same, WM Specialty Mortgage
LLC, without recourse of 505 South Main Street, Orange, CA 92868, being the buyer in
this execution, paid SheriffR. Thomas Kline the sum of $778.79, it being costs.
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Sheriff s Costs:
Docketing
Poundage
Posting Handbills
Advertising
Acknowledging Deed
Auctioneer
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Postpone Sale
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff s Deed
$:~O.OO
15.27
15.00
15.00
30.00
10.00
1.00
13.00
2.44
15.00
30.00
20.00
288.65
216.27
25.66
25.00
26.50
$778.79
Sworn and subscribed to before me So Answers:
This J.3,u<dayof~ r~ ~<:~C4'
Cb ' R. Thomas Klme, Shenff
2002, A.D. ". ()~,~
r honotary
BY ~JArl.ll ~dtl
Real Estate Deputy
'-"^;m
30'vV
l.trU
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CIt. .31-31'1
~ 12:;"6'.27
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 00-2163 CIVIL ~ TERM
CIVIL ACTION - LAW
TO THE SHERIFF OF
Qnnberland
COUNTY:
Washington Mutual Bank
To satisfy the debt, interest and costs due
PLAINTIFF(S)
from Frank M. Ranito, Jr. and Bonita J. Ranito, 51 West keller Street, Mechanicsburg,
PA 17055
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other
thanai1amed garnishee. you are directed to not"y himlherthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $58,936.72
fran 6/6/00 to 12/5/01 - (per diem
Interest $9.69) $5,:100.4.3 and Costs
Ally's Coinm %
L.L
Due Prothy
Other Costs
$1.00
Ally Paid
Plainfijf Paid
$R'i2.06
Date:
SPpTAmhPr 7. 2001
Curtis R. Long
Prothonotary, Civil Division
<J2y:
ao~ t7
P 71((' J? /2A')L. r--
Deputy
REQUESTING PARTY:
Name
Address:
Frank Federman, ESq.
One Penn Center at Suburban Station, Suite 1400
Philadelphia, PA 19103
Attorney for: Plaintiff
Telephone: 215-563-7000
Supreme Court 10 No. 12248
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REAL ESTATE SALE No. 3'1
On September 17,2001, the sheriff levied upon the
defendant's interest in the real property situated in Borough of
Mechanicsburg, Cumberland County, P A, known and numbered as
51 West Keller Street, Mechanicsburg, and more fully
described on Exhibit "A" filed with this writ and by
this reference incorporated herein.
Date: September 17,2001
By: go ~ ~~
Real Estate Deputy
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WASHINGTON MUTUAL BANK
Plaintiff,
v.
FRANK M. ROMITO, JR.
BONITA J. ROMITO
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DMSION
NO.00-2163-CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
.
WASHINGTON MUTUAL BANK, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following infonnation concerning the real property located at 51 WEST KELLER STREET.
MECHANICSBURG. PA 17055
1. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
FRANK M. ROMITO,
JR.
BONITA J. ROMITO
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
NAME
2. Name and address of Defendant(s) in the judgment:
Same as above
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
None
""u.
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
,
~~-
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4.
Name and address of the last recorded holder of every mortgage of record:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
GREEN TREE
FINANCIAL
SERVICING CORP.
7360 S. KYRENE
TEMPLE, AZ 85283
5. Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
Domestic Relations of Cumberland
County
13 North Hanover Street
Carlisle, P A 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or infol1l1ation and belief. I understand that false statements herein are made subject to the
penalties of/8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
August 29.2001
DATE
'''''''1<l'
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WASHINGTON MUTUAL BANK
Plaintiff,
CUMBERLAND COUNTY
v.
No.00-2163-CIVIL
FRANK M. ROMITO, JR.
BONITA J. ROMITO
Defendant( s).
August 29, 2001
TO: FRANK M. ROMITO, JR.
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
BONITA J. ROMITO
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
"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 IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at 51 WEST KELLER STREET, MECHANICSBURG, P A 17055is
scheduled to be sold at the Sheriff's Sale on DECEMBER 5, 2001 at 10:00 a.m: in the Cumberland
County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained
by WASHINGTON MUTUAL BANK (the mortgagee) against you. If the Sheriffs sale is postponed,
the property will be relisted for the MARCH 6,2002 Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
""'11
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,
You may need an attorney to assert yo~r rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You maybe able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
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 LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
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ALL TH.-\ T CERT.-\I::i House and Loe of Ground siru:lte on the South side of \Vest Keller Street, in
me First \VJ.rd of the Borough of ~k:hanicsburg, Coumy of Cumberland and Common'.vea!ch of
Pennsylv::mia. bounded :md described J.S follows. to wit:
BEGI::i:'iI::iG at a poim at comer of loc now or formerly of Ch;ules Glenn and said West Kelle,
St,eet: me:lce along said West Kelle, SLreet in an East'.vardly direction. a distance of twemy-seven
(27) feet to a poim in the line of lot now or formerly of Ch;ules Eppley; thenc~' along the line of
said Lot no'.11 or formedy of Ch;u!es Eppley, in a Southwardly direction, aa distance of one hundred
forty (PO) feet. more or less. to a poim in a public .-I.lley: thence along said Alley in a \Vestwardly
direction. a distance of twenty-six (26) feet to a poim Ln the line of Lot now or formerly of Charles
Glenn, aforesaid: thence along the line of said lot now or formerlv of Charles Glenn in a
- .
Northw;udly direction, a distance of one hundred forty (140) feet to a poim in said West Keller
Street, aforesaid, at the poim and place of BEGI::iNI::iG.
HA VI::iG thereon erected a two and one-half story frame dwelling, known and numbered :lS 51
West Ketler Street, Mechanicsburg, Pennsylvania.
T.-\X P,\RCEL ,#16-2-1--0787-023
TITLE TO SAID PRHIISES IS VESTED IN Bonita I. Romito and Frank,yr, Romito, Ir" wife
and husband, by Deed from Bonica J. Romito and Frank ~l. Romito. Ir. wife and husband, dated
4123/99, re'corded -1-129/99, in Deed Book 198. Page .j.68.
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin} ss
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818
Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The
Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published
ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of October and the
6th day(s) of November 2001. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
'::~::~~~:~;ro;"g · 000" ;" "" ''':':"=O'?lt:="'='~'~.mm
COpy . t' 19th day Nove r 2001 A.D.
Notarial Seal
S ALE #39 Te,,\, I.. Russell, Notery Public
Harrisburg, Dauphin County
My commission EllIll19sJuneS, 2002 NO RY PUBLIC
Member penn.ylVellia Association ot Notarle. .. .
, My commiSSion expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
214.77
1.50
216.27
Publisher's Receipt for Advertising Cost
The Patriot News, Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and pUblication costs and certifies that the same have
been duly paid.
By,...................................................................
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REAL ESTATE SALE NO. 39
Writ No. 2000-2163 Civil
Washington Mutual Bank
vs.
Frank M. Romito, Jr.
Bonita J. Romito
Atty.: Frank Federman
ALL TIfAT CERTAIN House and
Lot of Ground situate on the South
side of West Keller Street, in the
First Ward of the Borough of
Mechanicsburg, County of CUmber'
land and Commonwealth of Penn-
sylvania, bounded and described as
follows, to Wit:
BEGINNING at a point at comer
of Lot now or formerly of Charles
Glenn and said West Keller Street:
thence along said West Keller Street
in an Eastwardly direction, a dis-
tance of twenty-seven (27) feet to a
point in the line of Lot now or for-
merly of Charles Eppley; thence
along the line of said Lot now or
formerly of Charles Eppley, in a
Southwardly direction. a distance of
one hundred forty (140) feet, Ip.ore
or less, to a point in a public Alley;
thence along said Alley in a West-
wardly direction, a distance of
twenty-six (26) feet to a point in the
line of Lot now or formerly of
Charles Glenn. aforesaid; thence
along the line of said Lot now or
formerly of Charles Gl= in a North-
wardly direction, a distance of one
hundred forty (140) feet to a point
in said West Keller Street. afore-
said, at the point and place of BE-
GINNING.
HAVING thereon erected a two
and one-half story frame dwelling.
known and numbered as 51 West
Keller Street, Mechanlcsburg, Penn-
sylvania.
TAX PARCEL #16-24-0787-023.
TITLE TO SAID PREMISES IS
VESIED IN Bonita J. Romito and
Frank M. Romito. Jr., wife and hus-
band, by Deed from Bonita J. Romito
and Frank M. Romito, Jr. wife and
husband, dated 4/23/99, recorded
4/29/99, in Deed Book 198, Page
468.
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgentha1, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
v!z:
October 12, 19,26,2001
Affiant further deposes that he is authorized to verify this statement by the Cumberland
,
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
'/~al' Edito;
SWORN TO AND SUBSCRIBED before me this
26 day of OCTOBER. 2001
NOTAR
LOIS E. SNYDER, Notary Public
CartisIe Bore. Cumberland County
My Commisslon ExpiRlS Man:h 5. 2005
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK
Plaintiff
CIVIL DIVISION
vs.
No. 00-2163 CIVIL
FRANK M. ROMITO, JR.
BONITA J. ROMITO
Defendants
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
SS:
CUMBERLAND COUNTY
I, FRANK FEDERMAN, ESQ., attorney for WASHINGTON MUTUAL
BANK, hereby verify that on AUGUST 28. 2000, true and correct copies of the Notice of
Sheriff's Sale were served by certificate of mailing to the recorded Iienholder(s), and any
known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was
sent to defendant(s) on AUGUST 28,2000 by first class mail and certified mail return
receipt requested, see Exhibit "B" attached hereto.
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Attorney for Plaintiff
Date: November 2. 2000
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TO:
P "Ib"l OSb LOb
BONITA J. ROMITO
51 WEST KELLER STREET
MECHAN1CSBURG, P A 17055
SENDER:
REFERENCE:
DMK
SALES
PS FORM 00 SEPTEMBER 1995
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RETURN
RECEIPT
SERVICE
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Return Receipt Fee
Restricted OeIIv8ry
Total Postage and F8es
US Postal Service
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Receipt for
Certified Mail
! No Insurance Coverage Provided
! Do not use for International Mail
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TO:
P "16"1 OSb 105
FRANK M. ROMITO, JR.
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
SENDER:
REFERENCE:
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SALES
PS FORM 00 SEPTEMBER 1995
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
Washington Mutual Bank
Plaintiff,
Cumberland County
v.
No. 00-2163 Civil
Frank M. Romito, Jr.
Bonita J. Romito
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$58,936.72 V
Interest from 6/6/00 - 12/6/00
$1.773.27 and Costs
(per diem - $9.69)
$60,709.99 TOTAL
, ESQUIRE
ERPLAZA
NKFE E
T OPENNCE
SUITE 900
PHILADELPHIA, PA 19102
Attorney for Plaintiff
Note: Please attach description of property. No.
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DESCRIPTION
ALL THAT CERTAIN House and Lot of Ground situate on the South side of West Keller Street, in
the First Ward of the Borough of Mechanicsburg, County of Cumberland and Commonwealth of
Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point at corner of Lor now or formerly of Charles Glenn and said West Keller
Street; thence along said West Keller Street in an Eastwardly direction, a distance of twenty-seven
(27) feet to a point in the line of Lot now or formerly of Charles Eppley; thence along the line of
said Lot now or formerly of Charles Eppley, in a Southwardly direction, aa distance of one hundred
forty (140) feet, more or less, to a point in a public Alley; thence along said Alley in a Westwardly
direction, a distance of twenty-six (26) feet to a point in the line of Lot now or formerly of Charles
Glenn, aforesaid; thence along the line of said Lot now or formerly of Charles Glenn in a
Northwardly direction, a distance of one hundred forty (140) feet to a point in said West Keller
Street, aforesaid, at the point and place of BEGINNING.
HAVING thereon erected a two and one-half storv frame dwelling, known and numbered as 51
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West Keller Street, Mechanicsburg, Pennsylvania.
TAX PARCEL #16-24-0787-023
TITLE TO SAID PREMISES IS VESTED IN Bonita J. Romito and Frank M. Romito, Jr., wife
and husband, by Deed from Bonita J. Romito and Frank M. Romito, Jr. wife and husband, dated
4/23/99, recorded 4/29/99, in Deed Book 198. Page 468,
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Washington Mntnal Bank
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
Frank M. Romito, Jr.
Bonita J. Romito
CML DMSION
NO. 00-2163 Civil
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No.1)
Washinlrton Mutual Bank, Plaintiff in the above action, by its attorney, FRANK FEDERMAN,
ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following
information concerning the real property located at 51 West Keller Street. Mechanicsburl!:. P A 17055.
1. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Frank M. Romito, Jr.
51 West Keller Street
Mechanicsburg, P A 17055
Bonita J. Romito
51 West Keller Street
Mechanicsburg, P A 17055
2. Name and address ofDefendant(s) in the judgment:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Green Tree Financial
Servicing Corporation
7360 South Kyrene
Tempe, AZ 85283
Washington Mutual
Bank
505 South Main Street
Orange, CA 92868
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4. Name and address of the last recorded holder of every mortgage of record:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
5. Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
51 West Keller Street
Mechanicsburg, P A 17055
Domestic Relations of
Cumberland County
13 North Hanover Street
Carlisle, PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
August 22. 2000
DATE
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Attorney for Plaintiff
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Washington Mntnal Bank
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-2163 Civil
Frank M. Romito, Jr.
Bonita J. Romito
Defendant(s).
August 22, 2000
TO: Frank M. Romito, Jr.
Bonita 1. Romito
51 West Keller Street
Mechanicsburg, P A 17055
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at 51 West Keller Street. Mechanicsburl!:. PA 17055, is scheduled to
be sold at the Sheriffs Sale on December 6. 2000 at 10:00 a.m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by Washinlrton
Mutual Bank (the mortgagee) against you. lfthe Sheriff's sale is postponed, the property will be
relisted for the March 7, 200 I Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
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You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
fmd out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
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 LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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DESCRIPTION
ALL THAT CERTAIN House and Lot of Ground situate on the South side of West Keller Street, in
the First Ward of the Borough of Mechanicsburg, County of Cumberland and Commonwealth of
Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point at corner of Lot now or formerly of Charles Glenn and said West Keller
Street; thence along said West Keller Street in an Eastwardly direction, a distance of twenty-seven
(27) feet to a point in the line of Lot now or formerly of Charles Eppley; thence along the line of
said Lot now or formerly of Charles Eppley, in a Southwardly direction, aa distance of one hundred
forty (140) feet, more or less, to a point in a public Alley; thence along said Alley in a Westwardly
direction, a distance of twenty-six (26) feet to a poim in the line of Lot now or formerly of Charles
Glenn, aforesaid; thence along the line of said Lot now or formerly of Charles Glenn in a
Northwardly direction, a distance of one hundred forty (140) feet to a point in said West Keller
Street, aforesaid, at the point and place of BEGINNING.
HA VING thereon erected a two and one-half story frame dwelling, known and numbered as 51
West Keller Street, Mechanicsburg, Pennsylvania.
TAX PARCEL #16-24-0787-023
TITLE TO SAID PREMISES IS VESTED IN Bonita J. Romito and Frank M. Romito, Jr., wife
and husband, by Deed from Bonita J. Romito and Frank M. Romito, Jr. wife and husband, dated
4/23/99, recorded 4/29/99, in Deed Book 198, Page 468.
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FEDE~andPHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
ATTORNEY FOR PLAINTIFF
Washington Mntual Bank
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
Frank M. Romito, Jr.
Bonita J. Romito
NO. 00-2163 Civil
Defendant(s).
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
() an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
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AFFIDAVIT OF SERVICE
PLAINTIFF
Washington Mutual Bauk
Cumberlaud County
No.00-2163 Civil
DEFENDANT(S)
Frank M. Romito, Jr.
Bonita J. Romito
Type of Action
- Notice of Sheriff's Sale
SERVE AT
51 West Keller Street
Mechanicsburg, P A 17055
Sale Date: December 6, 2000
SERVED
Served and made known tn:liJ.iJ...,y,J f11 ;((I-Yyt{.7t) I ~, Defendant, on the l? --u-- J)Y of f. f ~, , 200Q,
at t, ~ 3 3, o'clockf2...m., at /)"/ LJ I{ -' 1. t. liT.) IVy...... ~~ J', A"O'", ~ . Commonwealth
of Pennsylvania, in the manner described below:
x
Defendant personally served. g.
Adult family member with whom Defendant(s) reside(s). Relationship is <t1'J...'7;;,. IAAtf. ,
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. '
Manager/Clerk of place oflodging in which Defendant(s) reside(s),
Agent or person in charge ofDefendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company,
Other:
Description: Age&!;7) HeightQ Weigh61co+ Race uJ SexL Other
I, ~ t..~ ,a competent adult, being duly sworn according to law, depose and state t.'1at I personally handed
a e and correct copy of the Notice of Shenft's Sale m the manner as set forth herem, Issued m the captIOned case on the date and at
the address indicated above.
Sworn to and subscribed
befo'lme this /7-6..-day
of; . 1'-1' , 2000.
1Iat"8'
, N TARIAL SEAL
\ JOSEPH F. JOHNSON, Notary Public
Harrisburg, Dauphin County
My Commiss1,'r 0 Fe~. 3, 2qQ,3
"-'--6rr'.he day or_
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NOT SERVED
,200_, at
o'clock _,m" Defendant NOT FOUND because:
Moved
Unknown
No Answer
Vacant
Other:
Sworn to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire -to. No. 12248
Two Penn Center Plaza, Suite 900
Philadelphia, PA 19102
(215) 563-7000
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AFFIDAVIT OF SERVICE
PLAINTIFF
Washington Mutual Bank
Cumberland County
No.00-2163 Civil
DEFENDANT(S)
Frank M. Romito, Jr.
Bonita J. Romito
Type of Action
- Notice of Sheriff's Sale
SERVE AT
51 West Keller Street
Mechanicsburg, P A 17055
Sale Date: December 6, 2000
SERVED
Served and made known to /3 ~Ov .::T I? ~ ,Defendant, on the /7 -G... day of j.p ,200D
at &:8. 3. o'clock t:lm., at .til b) t(. eeH... :..b., /Jf:t'L!~,:'.t--Lur' ~ CV , Commonwealth
of Pennsylvania, in the manner described below:
Y Defendant personally served.
Adult family member with whom Defendant(s) reside(s). Relationship is
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place oflodging in which Defendant(s) reside(s).
Agent or person in charge ofDefendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Other:
Description: AgeJ&-!Sb Height~ WeightdDi9 f Race uJ SexL Other
1, ~ 1.-e-....L. ~ ' ). a competent adult, being duly sworn according to law, depose and state that I personally handed
a tru and correct copy of the Notice of Sheriff's Sale m the manner as set forth herem, Issued m the captioned case on the date and at
the address indicated above.
Sworn to and subsc~d
befor11I1e.!lJis .L2.:::. Oay
of ~ ,2000.
NOTARIAL SE L
JOSEPH F. JOHNSON, Notary Public
Harrisburg no. ,o"'n County
~ ~missic. 'c. day.:t.E:,3, 2003 '
y:'--f(~X. ~
NOT SERVED
,200_, at
o'clock _.m" Defendant NOT FOUND because:
Moved __ Unknown
No Answer
Vacant
Other:
Sworn to and subscribed
before me this _ day
of .200_.
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire - I.D. No. 12248
Two Penn Center Plaza, Suite 900
Philadelphia, PA 19102
(215) 563-7000
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09/14/2001 14:J8 F~Y 21556JJJ5~
21556JJJ52
141004
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AFFIDAVIT OF SERVlQ:
WASHINGTON MUTUAL llA.NK
FRANKM. ROMITO, .m..
BONITA J. aOMITo
SnVE FRANK M. ItOMlTO..m.. AT
51 'WEST raJ , Il~ STREET
MECBANICSBUJlG, PA 171155
PLAINTIFF
CtlMDERLANDCOUNTY
No.OO-lI63-CIVIL
Type of Adlon
. Nodee of Sberifrs $al"
DEFENDANT(S)
Sale Date: DECEMBER S, :001
DVIm
Served and made kDo"'D to ~~ ~ M. b-J-o.' 0tt. , Defendanr, OQ m" /7 ~ day of 5eq+. . 200~
318:/0 .o'e1ock-f-.m.,al.sf W. j<e.lle~ St Me('~tJ;c.s 0-.J~ I . Commonwealth
ofPellllsylvania, in m" manner descnbed below:
I
DefeodaDt pezs<mally strVed. ' . L,.
)( AduII family member with whO!l1 Det'endalII(s) relide(s). ReIatiOllSbip is l Ah , _
. Adult in chstge ofDe1'endlll1r(s)' s residence who retlised r& gi"e _ or teJatioDSlUp.
MaDagextClerlc ofplace oi~ in which ~s) reside(s).
Agenr or persOll il:I charge oiDet"eDdaDl(s)'s of6c.. or ~ place ofbUlWless.
moffioer ofsai4.Def~t(srs w1.<lp<u.j,
Other: ,": ,,,,' L.. /' /.1->")\,,\......\ v.~,~,
Descriprion: AWOJfiL Hcifl}J.tU Welf)Jr.r~O "BJb:..l!L-sex r Ow ~ "JI<ll>5<:l"'
L c/~~tJCL (.... C~t<.t~ J~. .llcompeteiln.dl.\lt.~<iulyswom'WlM;"gfAlaw.dqloseand_tbatlpexsotlZlly~
a _:md eoma copy of~" . 5 . issued in the captioned -.. OBlhe dawand at
the addtess i;adicared above.
.'&/-l;ta:r. ~~-to
,
. eel
. ,,,,1' ~
~~wt
By:
NOT SE:RVEI>
.200_, at
o'clock _,m.. Defendant NOT FOtlND because:
_ Moved -.- Unknown._ NQ ~r
'_ Vataut
Other:
SWOOI to ""-Ii sub$cn'bed
""fon: me Ibis _ day
(If .2oo~
~o1lll'Y:
By:
~ttorJlIIrV ~ Phi..titt
,,,,,"k ,... bOlll, Esquire . J.D. No. IZUlI
OIle Peaa Ceater Sub... b... StalioD, S~ 1400
Pldbdelphila, PA 19103
(:15) 563--71100
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09/14/2001 14:39 FAX 2155~33352.
2155633352
@oos
.
APPtDA VIT OF SJl:RVICE
.
WA.SHINGTO~ MUTUAL BANK
FR.A.NK M. ROMITO, JR..
BONITA J.llOMITO
SERVE BONITA J.llOMlTO AT
51 ~ leU) lI'.R STREET
MEc8ANICSBURG, PA 17055
PLAINTIFF
CUMBERLAND COUNTY
N0.80-2163-CIVB..
1Jpe of Action
- Noliee of Sheriff's Sale
DEFENDANT(S)
Sale Date: DEaMBER S, 1001
SER.vED dt..
Served and made kD,own lD g,1I j tll 'J. R 6 M; -\: 0 . Def"eJldlgu:, on 1ile / 7
aI8:/5' .Q'clockt.m.,al 51 w. K~Ie.1C.. St-..' f{e"t..1J.v,c..."'u~~'
dayof 5'fi!ff, .2OO.L
. Commonwealth
ofPeDDSy1VBIJia. in the 1DllDIleT deseribcd below:
X Oef~t petsoually served. I
Ad14t tamily member with whom ~1(s) rcsidc(s). Relatiaaship is
Adu1t in chaxge oftlefendaut(s)'s residence who refi:lsed In give Jl8Q1e or relationship.
Manager/CIeri: of place of lodging ill wbichDe!eudan1(s) reside(s).
A$ent or person in <wile ofDefeDdallt(s)". office or usual pJag, ofbusiDess.
ilII o~ of said Detimdanl(srs COIDpU.y.
Olher:
Description: .Age.f:/:lL Heiglu:.M 1/ Weight I MY IbSR.ace WI... &xL 01her /" ~".::> \10 )b\l>l-l. \...'0' Il..
5 <wses-
I, s:J eM I'lC... 1-.. C. all,," 1.' ,n.. . a COIllpete:tn adult, being duly swom according to law, depose and state that I personally banded
a uue and comet copyofdte . in the l11lllIIl.Cr as .set 1Or1h herein, issued in the cllplioned ease on the date and at
the address indicated abov..
Notarial Seal
Stacy L. Heefner, Notary Public
Sworn to and sll\>l;cpbed Chamllarsburg B , Franklin County
ber. n . ~ da: My CommlSSlo x lr Aug. 5, 2002
;{,,~~. ~/. I.. . iMemb;;ennSy n cialion ot N ie
ll) ~ a' ~ NOTSERvm>
011 the day of . 200~ at o'cloc:k_.m., J:>erendant NOT roUND because:
9
~ Moved _ UI1kDo"",_ NoAnswer
_ Vacant
Other:
Sworn to and subs<:nbed
befine me 1his _ day
of .200_.
NoJaIy:
By:
Attomev ft!r Plainli~
Prank FedIll'JD,ltD, Esquire -LI). No. 12248
ODeP_ c_ at~ Slatkm
1617 Jon F. KelIDedy BOldevard, Suite 1400
PhiladelplUa, FA 19103-1814
(liS) 563-7000
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SALE DATE: DECEMBER 5. 2001
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
WASHINGTON MUTUAL BANK
No.: 00-2l63-CIVIL
vs.
FRANK M. ROMITO, JR.
BONITA J. ROMITO
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RETURN OF SERVICE PURSUANT TO
Pa. R.C.P. 405 OF NOTICE OF SALE
Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of
Execution was filed the following infonnation concerning the real property located at:
51 WEST KELLER STREET. MECHANICSBURG. PA 17055.
As required byPa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner
required byPa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth
on the attached Affidavit No.2 (previously filed) and Supplemental Affidavit No.2 on the date
indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing
(Fonn 3817) and/or Certified Mail Return Receipt stamped by the U.S, Postal Service is attached
for each notice.
f
November 29,2001
.
,.-..
"
1--
CUMBERLAND COUNTY
WASHINGTON MUTUAL BANK
No.: 00-2163-CNIL
vs.
FRANK M. ROMITO, JR.
BONITA J. ROMITO
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No.2)
Plaintiff in the above action, by its attorney, Frank Federman, Esquire, sets forth
as of the date the Praecipe for the Writ of Execution was filed the following information
concerning the real property located at 51 WEST KELLER STREET, MECHANICSBURG, PA
17055:
3. Name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
'~~
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WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
FRANK M. ROMITO, JR.
BONITA J. ROMITO
CIVIL DIVISION
NO.00-2163-CIVIL
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
WASHINGTON MUTUAL BANK, Plaintiff in the above action, by {ts attorney, FRANK
FEDERMAN, ESQUlRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 51 WEST KELLER STREET,
MECHANICSBURG, PA 17055
1. Name and address of Owner(s) or reputed Owner(s):
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
FRANK M. ROMITO,
JR.
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
BONITAJ. ROMITO
51 WEST KELLER STREET
MECHANICS BURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
';1'$Il""'"
"._..0-. '".__".
,.
4. Name and address of the last recorded holder of every mortgage of record:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
GREEN TREE
FINANCIAL
SERVICING CORP.
7360 S. KYRENE
TEMPLE, AZ 85283
5. Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6, Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
Domestic Relations of Cumberland
County
13 North Hanover Street
Carlisle, P A 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or infonnation and belief. I understand that false statements herein are made subject to the
penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
August 29. 2001
DATE
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,
Washington Mutual Bank
-vs-
Frank M. Romito, Jr. and Bonita J. Romito
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 2000-2163 Civil
R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ
is returned STAYED.
Sheriff s Costs:
Docketing
Poundage
Advertising
Posting Bills
Law Library
County
Mileage
Certified Mail
Levy
Postpone Sale
Surcharge
Law Journal
Patriot News
Share of Bills
30.00
14.07
15.00
15.00
.50
1.00
6.82
1.07
15.00
20.00
30.00
293.30
252.45
23.15
$ 717.36 pd by arty
12/07/00
Sworn and subscribed to before me
so~~
R. Thomas Kline, Sheriff
This .2/M-'dayof ~..)
2000, A.D. ~ () lhdl<. / ~.
r thonotary
Byjf;"A U-
Real Estate Deputy
~ \.($0
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Washington Mutual Bank
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
:'
Frank M. Romito, Jr.
Bonita J. Romito
CIVIL DIVISION
NO. 00-2163 Civil
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
Washinlrton Mutual Bank, Plaintiff in the above action, by its attorney, FRANK FEDERMAN,
ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following
information concerning the real property located at 51 West Keller Street, Mechanicsburl!. PA 17055.
1. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Frank M. Romito, Jr.
51 West Keller Street
Mechanicsburg, PA 17055
Bonita J. Romito
51 West.Keller Street
Mechanicsburg, P A 17055
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every j!ldgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Green Tree Financial
Servicing Corporation
7360 South Kyrene
Tempe, AZ 85283
Washington Mutual
Bank
505 South Main Street
Orange, CA 92868
,-
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4. Name and address of the last recorded holder of every mortgage of record:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
5. Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
51 West Keller Street
Mechanicsburg, P A 17055
Domestic Relations of
Cumberland County
13 North Hanover Street
Carlisle, P A 17013
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
August 22. 2000
DATE
~~4;1;Q~~--
Attorney for Plaintiff
-
I
""~~'
.
Washington Mutual Bank
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-2163 Civil
Frank M. Romito, Jr.
Bonita J. Romito
Defendant(s).
August 22, 2000
TO: Frank M. Romito, Jr.
Bonita J. Romito
51 West Keller Street
Mechanicsburg, P A 17055
--THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT ADEBT AND ANY INFORMATION
OB.TAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.--
Your house (real estate) at 51 West Keller Street. Mechanicsburl!. FA 17055, is scheduled to
be sold at the Sheriffs Sale on December 6. 2000 at 10:00 a.m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by Washinlrton
Mutual Bank (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be
relisted for the March 7, 200 I Sheriff s Sale.
.-"
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERITF'S SALE
To prevent this Sheriff-5..Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) -563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3 . You may also be able to stop the sale through other legal proceedings.
.
,-,~
,
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAYE.XOURERQI'ERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DO'ES TAKE PLACE. '
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property. . .
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To"'!"'''''
find out if this has happened, you may call (717) 240-6390. 0",,, ;i,"-
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened..., ,.;.
5. You have the right to remain in the property until the full amount due is paid to the'Sh~ritt,..r;'~i~~if<
and the Sheriff gives a deed to the buyer. At tb~t tinJ,e, the buyer may bring les;al proceedings to evict
you.
. '.' ,;'i.\!i!i:,:~~&fi~lj~\
6. You may be entitled to a share of the money which was paid for your house. A schedule of '" . '. ,
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale, This
schedule will state who will be receiving that money. Thenioney will be paid out in accordance with".~,.~..,!
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the;,*,#~;;~~".'..~~
Sheriff within ten (10) days after the distribution is filed. ',C;,!,:';'!;j;'i'i\i,'
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7. . You may also have other rights and defenses, or ways of getting your home back, if you a.ct' .
immediately after the sale.
YOU SHOULD TAKETIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. .
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
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DESCRIPTION
ALL THAT CERTAIN House and Lot of Ground siruate on the South side of West Keller Street, in
the First W3.rd of the Borough Of Mechanicsburg, County of Cumberland and Commonwealth of
Pennsylv3.nia, bounded and described as follows, to wit:
BEGINNI='IG at a point 3.t corner of Lot now or formerly of Charles Glenn and said West Keller
Street; thence along said West Keller Street inan Eastwardly direction, a distance of twenty-seven
(17) feet. to a J.loim ill the line of Lot ~Qw or formerly of Charles Eppley; thence along the line of
said Lot now or formerly of Charles Eppley, in a Southwardly direction, aa distance of one hundred
forty (140) feet, more or less, to a poim in a public Alley; thence along said Alley in a Westwardly
direction, a distance of twenty-six (26) feet to a point in the line of Lot now or formerly of Charles
Glenn, aforesaid; thence along the line of said Lot now or formerlv of Charles GleIiIJ. in a
- .
Northwardly direction, a distance of one hundred forty (140) feet w a point in said West Keller
Street, aforesaid, at the point and place of BEGINNING. '
HA VING thereon erecled a two and one-half storv frame dwelling, known and numbered as 51
. -
West Keller Street, Mechanicsburg, Pennsylvania.
L\X PA,RCEL #16-24-0787-023
TITLE TO SAID PREMISES IS VESTED IN Bonita J. Romito and Frank M. Romito, Jr., wife
and husband, by Deed from Bonita J. Romito and Frank M. Romito, Jr. wife and husband, dated
4/23/99, recorded 4/29/99, in Deed Book 198. Page -\.68.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO.
00-2163 CIVIL 19
CIVIL ACTION - LAW
TO THE SHERIFF OF
CUMBERLAND
COUNTY:
Washington Mutual Bank
To satisfy the debt, interest and costs due
PLAINTIFF(S)
Frank M Romito, Jr., and Bonita J. Romito, 51 W. Keller St.,
from
Mechanicsburg PA 17055.
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located
at 51 W. Keller St., Mechanicsburg PA 17055 (See attached legal
descripton.l
(2) You are also directed to attach the property of the defendant(s) not levied upon,in the possessiqn!i)f
GARNISHEE(S) as follows:
and to notny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defeflelaRt{-s)-and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property ofthe defendant(s) not levied upon an subjectto attachment is found inthe po!;session of anyone other
than a named garnishee. you are directed to notffy him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $58,936.72 L.L. $.50
Interest 6/6/00 - 12/6/00 $1,773.27 Due Prothy $1.00
Atty's Comm % Olher Costs
Atty Paid $122.20
Plaintiff Paid
Date: August 25, 2000 CURTIS R. LONG
by:
Deputy
REQUESTING PARTY:
Name Frank Feder~an, Esquire
Address: Two penn" Center Plaza, Ste. 900
Philadelphia PA 19102
Attorney for: Plaintiff
TelephOne: (215) 563-7000
Supreme Court 10 No, 12248
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REAL ESTATE SALE No. ~I
on ~ 3/,"J-o-ro the sheriff levied upon the defendants
tnterest In the real property siturlted in411 () -' a. AI'....,.., In 7) ~~
Cumberland County, Pc, {,timbered as:,)1 c.J1lA ~ /.,/t~ )I
(/VIh a _"-,, tl'r and mo:'''u on Exhibit" A" filed with
this writ and by this reference !i1corporated herein.
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO, 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000
WASHINGTON MUTUAL BANK
505 SOUTH MAIN STREET
ORANGE, CA 92868
ATTORNEY FOR PLAlNTITF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
Plaintiff
NO. 60 - ';;'1 t,.,J
Cu~L~
v.
CUMBERLAND COUNTY
FRANK M. ROMITO, JR.
BONITA J. ROMITO
51 WEST KELLER STREET
MECHANICSBURG, P A 17055
Defendant( s)
CIVIL ACTION - LAW
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 if you fail to
do so the case may proceed without you and a judgment may be entered against yon 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 TillS PAPER TO YOUR LAWYER AT ONCE. IT 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, P A 17013
(717) 249-3166
Loan #: 0011455862
I
1. Plaintiff is
WASHINGTON MUTUAL BANK
505 SOUTH MAIN STREET
ORANGE, CA 92868
2. The name(s) and last known address(es) of the Defendant(s) are:
FRANK M. ROMITO, JR,
BONITA J. ROMITO
51 WEST KELLER STREET
MECHANICSBURG, P A 17055
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 4/23/99 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to AMERIQUEST MORTGAGE COMPANY which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 1538, Page 72. PLAINTITF is now the legal owner of the mortgage and is in the
process of formalizing an assignment of same.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 11/1/99 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."
-"""'-, -"
.
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6. The following amounts are due on the mortgage:
Principal Balance
Interest
10/1/99 through 4/1/00
(per Diem $18.38)
Attorney's Fees
Cumulative Late Charges
4/23/99 to 4/1/00
Cost of Suit and Title Search
Subtotal
$50,940.25
3,363.54
2,547.00
304.47
550.00
57,705.26
Escrow
Credit
Deficit
Subtotal
0.00
0.00
0.00
TOTAL
$57,705.26
7, 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
Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. 91680.403c 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 Plaintiffs 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, PLAINTITF demands an in rem Judgment against the Defendant(s) in the sum of
$57,705.26, together with interest from 4/1/00 at the rate of$18.38 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.
:r~r~
/s/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
I""
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ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
DATE: January 28, 2000 FORECLOSURE
TO:
Frank M. Romito, Jr.
51 West Keller Street
Mechanicsburg, P A 17055
Bonita J. Romito
51 West Keller Street
Mechanicsburg, PA 17055
THIS F1RM IS A DEBT COLLECTOR A TTEMPTlNG TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, 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.
This is an official notice that the mortgage on vour home is in default and the lender intends to foreclose.
Specific information about the nature of the default is orovided in the attached Dages,
.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to helD to save
vour home. This Notice exolains how the orogram works.
To see ifHEMAP can helD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet the
Counseling Agencv.
The name. address and ohone number of Consumer Credit Counseling Agencies serving vour County are
listed at the end of this Notice. lfvou have anv auestions. vou mav call the Pennsvlvania Housing Finance
Agencv toll free at 1-800-342-2397, (Persons with imoaired 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 NOTIFlCACION EN ADJUNTO ES DE SUMA lMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. Sl NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFlCAClON OBTENGA UNA TRADUCCION INMEDIT AMENTE LLAMANDO EST A
AGENCIA (PENNSYL VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SAL V AR SU CASA DE LA FERDlDA DEL DERECHO A REDlMAR SU HIPOTECA.
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STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): Frank M, Romito, Jr. and Bonita J. Romito
PROPERTY ADDRESS: 51 W. Keller St.-Mecbanicsburg, PA 17055
LOAN ACCT. NO.: 0011455862
ORIGINAL LENDER: Ameriquest Mortgage Company
CURRENT LENDER/SERVICER: Ameriques! Mortgage Company
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE ELIGIBLE FOR FINANCIAL ASSIST Al"1CE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE FA YMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOlYlEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE.
. IF YOUR DEF AUL T 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 REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Acr, 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 MEETING 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 DEF AUL Tn EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-Ifvou meet with one of the consumer credit
counseline aeencies listed at the end of this notice the lender mav NOT take action aeainst vou for thirtv
(30) davs after the date of this meetine. The names. addresses and teleohone numbers of desienated
consumer credit counseline aeencies for the county in which the orooertv 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 immediatelv
of your intentions,
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in a default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default) If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for fmancial
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 PROMPTL Y. 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 IMMEDlATEL Y AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
E.XH\B\T A
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AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They wiIl 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 proceedings wiIl be pursued against you if you have met the time requirements set forth
above. You wiIl be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
f ou have filed bankru tc ou can still a I for Emer enc Mort a e Assistance.
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UD to date).
NATURE OF THE DEF AUL T- The MORTGAGE debt held by the above lender on your property located
at: 51 W. Keller St.-Meefianicsburg, P A 17055 IS SERIOUSLY IN DEF AUL T because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due: Start/End: 11/1/99 thru 1/1/00 at $563.77 per month,
Monthly Payments Plus Late Charges Accrued $1,928.12
NSF: SO.OO
Inspections: SO.OO
Other: $0,00
(Suspense): SO.OO
Total amount to cure default $1,928.12
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use ifnot aDDlicable): N/A
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,928.12,.
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
THE. THIRTY (30) DAY PERIOD, Pavments must be made either bv cash. cashier's check. certified
check or monev order made Davable and sent to: AMERIQUEST MORTGAGE COMPANY, 505
South Main Street, Suite 6000, Orange, CA 92868, Attention: Collections Department.
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter. (Do not use irnot aDDlicable,) N/A.
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rigfits to accelerate the mortgage debt. The 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 monthly installments, If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to
foreclosure UDon your mortllalle orooertv.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage 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 against you, you
will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00.
Any attorney's fees will be added to the amount to the lender, which may also include other reasonable
costs. If vou cure the default within the THIRTY (30) DAY Deriod. vou will not be required to pav
attornev's fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
E)(.H\B1T A
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.
- -,
-, ~ I
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to
cure the default and Drevent the sale at anv time UD to one hour before the Sherifi's Sale. You mav do so
bv Davine the total amount then Dast due. Dlus anv late or other charees then due. reasonable anornev's fees
and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sale as
sDecified in writine bv the lender and bv Derfonnine anv other reauirements under the morteaee. 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 earliest date that such a Sheriff's
Sale of the mortgage property 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 will be sent to you before the sale. Of course,
the amount needed to cure the default will increase the longer you wait. You may fmd out at any time
exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER: AMERIQUEST MORTGAGE COMPANY
. 505 South Main Street, Suite 6000, Orange, CA 92868
Phone (800) 430-5262 Fax (713) 835-0739
Contact: Collections Department, exl. 5931
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. 1fyou 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-You mayor _X_may not (CHECK ONE) sell or transfer
your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost 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 OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT.
. TO HAVE THIS DEF AUL T CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
. TO ASSERT THE NONEXISTENCE OF A DEF AUL T 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 ACTION BY
THE LENDER
. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
Very truly yours,
AMERIQUEST MORTGAGE COMPANY
Cc: Ameriquest Mortgage Company
Attn: Collections Department
Account No.: 0011455862
Mailed by 1" Class mail/Certificate of Mailing and Certified Mail No: Z 215 965 199,200
~){r\\ar( 1\..
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, -
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Penn~ylvania Housing Finance Agency
Homeowner's Emergency Mortgage Assistance Program
Consumer Credit Counseling Agencies
(Rev. 5/99)
Lycomi::g-Cli::ton Counties
2CommlSs'on For Community Action (STEP)
138 Lincoln Street
P. O. Box 1328
W.;UiAmspor-:, PA 17703
(5.0) 326-0587
FA."'l: (570) 322-2197
CCCS of Northe3.Stern Pi\.
201 Basi:: St;-eec -
W:illiamspor-:, PA 17703
(5,0) 323-6627
FA."'l: (570) 323-d626
CLlN'I'ON COUNTY
CCCS of Northeastern p.i\.
1631 S Athel'tCn St -
Suite 100
State College, PA 16801
(81~) 238-3668
FA."'l: (81~) 238-3669
COLUMBIA COlJ!'o"l'Y
CCCS of Northeastern Pennsvlvania
1400 Abington Exec-..ltive Park
Suite 1
Clarks Summitt PA 18411
(570) 587.9163 or (800) 922.9537
F......"'l: (570) 587-913419135
31 W. Market Street
POB 1127
W1lkes.Barre, PA 18702
(570) 821-0837 or (800) 922-9537
F......"'l: (570) 821-1785
Commission on Economics Opportunity of LU%erne Count-J
163 Amber Lane
W1lkes.Barre, PA 18702
(570) 826-0510 or (800) 822-0359
F......"'l: (570) 829-1665-CALL BEFORE FA.'IDl'G
(570) 455-4994 HAZELTON
F......"'l: (570) ~55-5631-<;ALL BEFORE FA.'IDl'G
(570) 836-~090 TUNKH.-'.i.""1.mCK
Booker T. Washi::gton Center
1720 Holland Street
Erie, PA 16503
(814) ~53.57 4-1
F......"'l: (814) ~53.5749
John F. Kennedy Center, Inc,
2021 East 20th St:-eet
Erie, PA 16510
(814) 898-0400
FAX (814) 898-1243
CCCS of We.tern Pennsv1vania, Inc.
2000 Lingle.town Road'
Harr'.sburg. PA 17102
(7171 541-1757
U rbao League of :Ylel:ropolitan Harrisburg
N. 6th Stre<!t
Harrisburg, PA 17101
(717) 234.5925
FA."'l: (717) 23~-9459
Community Action Co= of the Capital Region
151~ De,.,..,. Street
Hamsburi-. PA 17104
(717) 232.9757
F......"'l: (717) 234-2227
CRAWFORD COUNTY
Greater Erie Communit-J .-\<:tion Committee
18 We.t 9th Stre<!t
Erie, PA 16501
(814) 459-4581
FAX (814) 456-0161
Shenango Valley U man League, lnc
601 Indiana Avenue
FarI"l!1l, PA 16121
(412) 981.5310
CUMBERLA.'lD COUNTY
Fino",.;o1 Counseling Services of Franklin
31 West 3rd Stre<!t
Wayuesboro, PA 17268
(717) 762-3285
YWCA of Carlisle
301 G Stre<!t
Carlisle, PA 17013
(717) 243-3818
FA."'{ (717) 731.9589
Adams County Housing Authorii:"J
139-143 Carlisle St
Gettysburg, PA 17325
(717) 334-1518
F......"'{ (717) 334-8326
E.)C.ruerr ~
?,' I~' ,
PENNSYl.VANIA BULI.ETIN, VOL 29, NO. 2:l, JUNE 5, 1999
.
ALL lhal certain House and Lot of Ground situate on the South ~d.. of West Kcller Street, in
thc First Ward of the Borough of MeohanicsburS. County of Cumberland and Commonwealth of
Pennsylvania. bounded iI%Id. dcsc:ribed as follows, to-wit:
BEGlN.NING at a point at comer of Lot now or formerly of Charles Glenn and said.W cst
:Keller Street; thence along said West Keller Street in an Eastwardly direction, a dista.I1ce o{tWenty- .
sc:VCJ:I (27) feet 10 a point in the. line ofLat now or formerly of Charles. Eppley,' thlOl1cea1ong tha line of
said Lot now or fonnerly of Charles Eppley, in a Soathwardly diret:tion. a distance of one hundred
fa:rty (140) feet, more or less, to a point in a public Alley; thel10e along said Alley in a WeStwardly
direction. a dist;lflce: of twenty-six (26) feet to a point in the: line of Lot now or fonnerly of Charles
Glenn. a.fol:esaid; thance lllong thc line of said Lot now or {oanerly of Charle. Glenn in a Natthwarclly
.dil~c:tiOn, a distance of one hunc1red faTty (140) feet to a poinl in said West Keller Street, aforesaid, at
tho.' poinl mcl place ofBEGINl'lING.
PREMISES: 51 WEST KELLER STREET
.
.
>-.. "~
"un
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---., ~~"
VERITICA nON
JAMES BROWNELL hereby states that he is FORECLOSURE SPECIALIST of
AMERIQUEST MORTGAGE COMPANY mortgage servicing agent for Plaintiff in this matter,
that he is authorized to take this Verification, and that the statements made in the foregoing Civil
Action in Mortgage Foreclosure are true and correct to the best of his 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 unsworn falsification to authorities.
2jfi.w-D ~ QfL
DATE:
1//7/U 0
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,
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-02163 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK
VS
ROMITO FRANK M JR ET AL
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
ROMITO FRANK M JR
the
DEFENDANT
, at 0015:04 HOURS, on the 17th day of April
2000
at 51 WEST KELLER ST
MECHANICSBURG, PA 17055
by handing to
BONITA J. ROMITO
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
6.20
.00
10.00
.00
34.20
;!""'~~lI'~~"'
R. Thomas Kline
04/18/2000
FEDERMAN &
.
Sworn and Subscribed to before By:
''"' ~
7 day of
me this
~:JI e2ovo A.D.
Cjp~thoc2"t::y IJP", I A~'
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.
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-02163 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK
VS
ROMITO FRANK M JR ET AL
RICHARD SMITH
, Sheriff or Deputy Sheriff of
cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
ROMITO BONITA J
the
DEFENDANT
, at 0015:04 HOURS, on the 17th day of April
2000
at 51 WEST KELLER ST
MECHANICSBURG, PA 17055
by handing to
BONITA J. ROMITO
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Pocketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
So Answers:
r'f/t?~~e:~t
R. Thomas Kline
04/18/2000
FEDERMAN &
Sworn and Subscribed to before By:
me this
t>;:>
/q ~ day of
~ .;;L1}""lJi) A.D.
Cf-t'- (l YlA .o~. , ^Jtpli;
rothonotary ~
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No, 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
Attorney for Plaintiff
Washington Mutual Bank
505 South Main Street
Orange, CA 92868
: Cumberland COUNTY
: COURT OF COMMON PLEAS
Plaintiff
vs.
: CML DMSION
Frank M. Romito, Jr.
Bonita J. Romito
51 West Keller Street
Mechanicsburg, P A 17055
: NO. 00-2163-Civil
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment, in rem, in favor of the Plaintiff and against Frank M. Romito, Jr.
and Bonita J. Romito, Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20
days from service thereof and for foreclosure and sale of the mortgaged premises, and assess
Plaintiff's damages as follows:
As set forth in Complaint
Interest 4/1/00 to 6/6/00
$57,705.26
$1.231.46
TOTAL
$58,936.72
I hereby certifY that (1) the addresses of the Plaintiff and Defendant(s) are as shown above,
and (2) notice has been given in accordance with Rule 237.1, copy attached.
~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: (j",e.,.. 1. ,UlJ1J
~1A7,~ ~~k~
**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 COLLECf
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
'--' ,
,"
. 'FEDBRMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAK BANK
COURT OF COMMON PLEAS
,;
,
Plaintiff
CIVIL DIVISION
vs.
CUMBERLAND COUNTY
FRANK M. ROMITO, JR.
BONITO J. ROMITO
NO. 00-2163-CIVIL
Defendant
TO: BONITO J. ROMITO
51 WEST KELLER STREET
MECHANICSBURG, PA PA
DAT~ OF NOTICE: MAY 25. 2000
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS
NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A
DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
cou~t your defenses or objections to the claims set forth against
you. Unless you act wi thin ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PAl 70 13
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
,
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~--
. -., Y.
. 'FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAK BANK
COURT OF COMMON PLEAS
.;
Plaintiff
CIVIL DIVISION
vs.
CUMBERLAND COUNTY
FRANK M. ROMITO, JR.
BONITO J. ROMITO
NO. 00-2163-CIVIL
Defendant(s)
TO: FRANK M. ROMITO, JR.
51 WEST KELLER STREET
MECHANICSBURG, FA 17055
DATE OF NOTICE: MAY 25. 2000
THIS fIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A. DISCHARGE IN BANKRUPTCY, 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.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
- ~~,
~ . ,_,_'__,_ ,_ . ^ ,T_ ""
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-"
"
SHERIFF'S RETU~N - REGULAR
CASE NO: 2000-02163 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK
:I.
VS
ROMITO FRANK M JR ET AL
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, Pensyl vania , who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
ROMITO FRANK M JR
the
DEFENDANT
, at 0015:04 HOURS, on the 17th day of April
, 2000
at 51 WEST KELLER ST
MECHANICSBURG, PA 17055
by handing to
BONITA J. ROMITO
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
6.20
.00
10.00
.00
34.20
~~-.~ct:~:-
R. Thomas Kline
04/18/2000
FEDERMAN &
puty Sheriff
Sworn and Subscribed to before By:
day of
me this
A.D.
Prothonotary
,~, ~~ ..~
-,~'-" --,-~-
.
.,
"
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-02163 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK
J
"
VS
ROMITO FRANK M JR ET AL
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, Pensyl vania , who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
ROMITO BONITA J
the
DEFENDANT
at 0015:04 HOURS, on the 17th day of April
2000
at 51 WEST KELLER ST
MECHANICSBURG, PA 17055
by handing to
BONITA J. ROMITO
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
,00
10.00
.00
16.00
So Answers:
~~~ct:~!
R. Thomas Kline
04/18/2000
FEDERMAN &
Sworn and Subscribed to before By:
me this
day of
A.D.
jlDep
ty Sheriff
Prothonotary
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(Rule of Civil Procedure No. 236 - Revised)
Wilshington Mutual Bank
: Cumberland COUNTY
Plaintiff
: Court of Common Pleas
vs.
: CIVIL DIVISION
Funk M. Romito, Jr.
Bonita J. Romito
: NO. 00-2163-Civil
Defendant(s)
Notice is given that a Judgment in the above captioned matter has been entered against you on June
'7 .2000,
By
C)Uf/11 0 ~
I
DEPUTY
lfyou have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESOUIRE
Attorney for Filing Party
SUITE 900
TWO PENN CENTER PLAZA
PIDLADELPHIA. PA 19102
(215) 563-7000
**TIllS 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 TillS DEBT WAS NOT REAFFIRMED, TIllS IS NOT
AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
". ',' "r
FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
Attorney for Plaintiff
Washington Mutual Bank
: Cumberland COUNTY
Plaintiff
: Court of Common Pleas
vs.
: CIVIL DIVISION
Frank M. Romito, Jr.
Bonita J. Romito
: NO. 00-2163-Civil
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the
following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act
of Congress of 1940, as amended
(b) that defendant Frank M. Romito, Jr. is over 18 years of age and resides at 51
West Keller Street, Mechanicsburg, P A 17055.
(c) that defendant Bonita J. Romito is over 18 years of age, and resides at 51 West
Keller Street, Mechanicsburg, P A 17055.
Ibis statement is made subject to the penalties of 18 Pa. C.S, Section 4904 relating
to unsworn falsification to authorities.
~~
FRANK FEDERMAN
Attorney for Plaintiff
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WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
FRANK M. ROMITO, JR.
BONITA J. ROMITO
CIVIL DIVISION
NO.OO-2163-CIVIL
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No, I)
WASHINGTON MUTUAL BANK, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 51 WEST KELLER STREET.
MECHANICSBURG. PA 17055
1. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
FRANK M. ROMITO,
JR.
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
BONITA J. ROMITO
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
2. Name and address ofDefendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate,)
None
',,,~
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4. Name and address of the last recorded holder of every mortgage of record:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
GREEN TREE
FINANCIAL
SERVICING CORP.
7360 S. KYRENE
TEMPLE, AZ 85283
5, Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest rnay be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate,)
Tenant/Occupant
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
Domestic Relations of Cumberland
County
13 North Hanover Street
Carlisle, P A 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of rny personal
knowledge or information and belief. I understand that false staternents herein are rnade subject to the
penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
August 29.2001
DATE
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 1400
One Penn Center at Snburban Station
Philadelphia, PA 19103
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
FRANK M. ROMITO, JR.
BONITA J. ROMITO
NO.OO-2I63-CIVIL
Defendant{s).
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
o an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is rnade subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities,
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W ASIDNGTON MUTUAL BANK
Plaintiff,
CUMBERLAND COUNTY
v.
No.OO-2163-CIVIL
FRANK M. ROMItO, JR.
BONITA J. ROMITO
Defendant(s).
August 29,2001
TO: FRANK M. ROMITO, JR.
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
BONITAJ. ROMITO
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
."THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.""
Your house (real estate) at 51 WEST KELLER STREET, MECHANICSBURG, P A 17055is
scheduled to be sold at the Sheriff's Sale on DECEMBER 5, 2001 at 10:00 a.rn: in the Cumberland
County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained
by WASHINGTON MUTUAL BANK (the mortgagee) against you. If the Sheriffs sale is postponed,
the property will be relisted for the MARCH 6, 2002 Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1.
The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
can: (215) 563-7000.
2.
You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was irnproperly entered. You may also ask the Court to
postpone the sale for good cause.
3,
You may also be able to stop the sale through other legal proceedings.
1---
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)
You may need an attorney to assert your rights, The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney,)
yOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder, You may
find out the price bid by calling (215) 563-7000.
2. You maybe able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out ifthis has happened, you may call (717) 240-6390.
4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened,
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7 . You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
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 LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LmERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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ALL TH.\ T CERT,\I:.i House and Loe of Ground situate on the South side of West Ketler Street, in
the Firsr \Y::Ird of rhe Borough of '\;lechanicsburg, COUntY of Cumberland and Commonwealrh of
Pe:U1sylv::lni::l. bounded ,md described ::IS follows, co wir:
BEGI:.iNI:.iG ::Ir ::I poim ::It comer of Lot now or formerly of Ch:lfles Glenn ::Ina said Wesr K:ller
Street; rhe::tce along said Wesr Keller Screer in an East'.v::Irdly direcrion, a disrance of twenty-seve::t
(27) feet co a poim in the line of Lot now or formerly of Charles Eppley: thence' along che line of
said Lot nO'.\1 or formerly of Ch:lfles Eppley, in ::I Southw::lrdly direction. aa distance of one hundred
forty 0-+0) feet, more or less. co a poim in a public .\lley: che::tce along said Alley in a \Yesrwardly
direcrion. a distance of rwemy-six (26) feet co a poim in the line of Lor now or formerly of Charles
Glenn. aforesaid: chence along the line of said Lot no\v or formerly of Charles Glenn in a
Northwardly direction, a distance of one hundted forty (1-+0) feet to a poim in said West Keller
Street, aforesaid, at the polm and place of BEGI)[NI)iG,
HA VI:.iG thereon erected a two :md one-half story rr:une dwelling, known and numbered as 51
Wesr Ke!1er Srreer, Mechanicsburg, Pennsylvania.
TAX P-\RCEL ,*'16-2-+-0787-023
TITLE TO SAID PRE~IISES IS VESTED IN Bonira J. Romico and Frank: M, Romiro, Jr., wife
and husband, by Deed from Bonita 1. Romiro and Frank: M, Romiro. Jr. wife and husband. do.red
4/23/99, recorded -+/29/99, in Deed Book 198. Page '+68.
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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
oc, I ( 4 C:;;5?k 2
~(It~i)+
IN RE:
Frank M. Romito, Jr.
Bonita J. Romito
Bk. No. 00-05295 RJW
Debtors
Chapter No. 13
Washington Mutual Bank
Movant
v.
11 U.S.C. ~362
Frank M. Romito, Jr.
Bonita J. Romito
Respondents
Motion of
ORDER MODIFYING ~362 AUTOMATIC STAY
AND NOW, this ~'6 rrJ- day of '~L~
Washington Mutual Bank, (Movant), it is:
, 2001, upon
ORDERED that the Automatic Stay of all proceedings, as
provided under ~362 of the Bankruptcy Code 11 D.S.C. ~362 is modified
with respect to premises 51 West Keller Street, Mechanicsburg, I?A
17055, as to allow the Movant to foreclose on its mortgage and allow
the purchaser of said premises at Sheriff's Sale (or purchaser' s
assignee) to take any legal action for enforcement of its right to
possession of said premises.
ORDERED that Rule 4001 (a) (3) is not applicable
Washington Mutual Bank may immediately enforce and implement
Order granting Relief from the Automatic Stay.
Is/RcbertJ. WOodside
ROBERT J. WOODSIDE
Chief Bankruptcy Judge
and
this
cc: Judith T. Romano, Esquire
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Charles J. Dehart, III, Esquire (Trustee)
P.O. BOl< 410
Hummelstown, PA 17036
HARRISBURG
PA
James K. Jones, Esquire
7 Irvine Row
Carlisle, FA 17013-3019
I FI~ED
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ICIPr~~ p, I
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Frank M. Romito, Jr.
Bonita J. Romito
51 West Keller Street
Mechanicsburg, PA 17055
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
WASHINGTON MUTUAL BANK
Plaintiff,
CUMBERLAND COUNTY
v.
No.OO-2163-CIVIL
FRANK M. ROMITO, JR.
BONlTA J. ROMITO
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above rnatter:
Amount Due
$58,936.72
Interest from 6/6/00 to 12/5/01
(per diem - $9.69)
TOTAL
$5,300.43and Costs
$64,237.15
F DE
NE PENN CE
UITE 1400
HILADELPHIA, PA 19103
Attorney for Plaintiff
, ESQUIRE
ER at SUBURBAN STATION
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ALL IHA T CERIAI~ House and Lot of Ground siru:lte on the South side of West Keller Street. in
the First \Vard of [he Borough of ~!echanicsburg, County of Cumberland and Commonwe:J.lth of
Pennsylvani:J.. bounded :ind described as follows. to wit:
BEGI)j~I)jG at a point at comer of Lo[ now or formerly of Charles Glenn ana said \Vest Keller
S[reet; [hence along s:J.id West Keller Street in an E:J.stwardlv direction. a distance of twemv-seven
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(27) fee: to a point in the line of Lot now or formerly of Charles Eppley; thence along the line of
said Lot rrow or formerly of Charles Eppley. in a Southwardly direction. aa distance of orre hundred
forty 0.+0) feet, more or less, to a point in a public Alley: thence along said Alley in a \Vestwardly
direction. a disrance of twenty-six (26) feet to a point in the line of Lot now or formerly of Charles
Glenn, aforesaid; thence along the line of said Lot now or formerly of Charles Glenn in a
Northwardly direction, a distance of one hundred forty (1.+0) feet to a point in said West Keller
Street, aforesaid, at the point and place of BEGINNING,
HA VI~G thereon erected a two and one-half stOry frame dwelling, known and numbered as 51
West Keller Street, Mechanicsburg, Pennsylvania.
TAX P,\RCEL #16-2.\-0,8,-023
TITLE TO SAID PREMISES IS VESTED IN Bonita J. Romico and Frank M, Romico, Jr" wife
and husband, by Deed from Bonita J. RomitO and Frank 1101, RomitO, Jr. wife and husband, dated
4/23/99, recorded '+/29/99, in Deed Book 198. Page '+68.
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I.D. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
CIVIL DIVISION
FRANK M. ROMITO, JR.
BONITA J. ROMITO
NO. 00-2163-CIVIL
RULE
AND NOW, this
,5;""
day
Of~
, 2001, a Rule is entered
upon FRANK M. ROMITO, JR. & BONITA J. ROMITO, Defendant(s) to show cause why
the attached Order for Reassessment of Damages should not be entered.
RULE RETURNABLE
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PENNSYLVANIA
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I.D. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
1215\ 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
CIVIL DIVISION
FRANK M. ROMITO, JR.
BONITA J. ROMITO
NO. 00-2163-CIVIL
ORDER
AND NOW, this
day of
, 2001, the
Prothonotary is ORDERED to reassess the damages in this case as follows:
Principal Balance
Interest Amount
11/1/99 through 12/5/01
Late Charges
Legal fees
Cost of Suit and Title
Sheriff's Sale Costs
Inspections/Other
Appraisal Fees
Escrow
Credit
Deficit
50,927.91
13,849.84
304,47
2,547.00
1,521.00
717.36
100.50
325.00
0,00
1,072,00
TOTAL
$71,365.08
Plus interest per diem from 12/5/01 through Date of Sale at six (6%) percent.
NOTE: THE ABOVE FIGURE IS NOT A PAY OFF - SHERIFF'S SALE COSTS
AND COMMISSION ARE NOT INCLUDED IN THE ABOVE FIGURES,
BY THE COURT:
J.
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FEDERMAN AND PHELAN
by: Daniel G, Schmieg, Esquire
Atty. I.D, No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
CIVIL DIVISION
FRANK M. ROMITO, JR.
BONITA J. ROMITO
NO. 00-2163-CIVIL
PLAINTIFF'S PETITION FOR REASSESSMENT OF DAMAGES
Plaintiff, by its Attorney, Daniel G. Schmieg, Esquire, moves the Court
to direct the Prothonotary to reassess the damages in this matter/and in
support thereof avers the following:
1. This is an action in Mortgage Foreclosure in which Judgment was
entered by default dated on JUNE 7, 2000 in the amount of $58,936.72.
2. A Sheriff I s Sale of the mortgaged premises was postponed or stayed
for the following reasons:
The Defendant (s) filed a Chapter 13 Bankruptcy
(#00-05295RJW) filed on DECEMBER 5, 2000.
Plaintiff obtained relief from the
automatic stay by the Order of Court dated JUNE 28, 2001
3. The mortgaged premises are listed for Sheriff I s Sale on DECEMBER 5,
2001.
4. Additional sums have been incurred or expended on Defendant (s) I
behalf during the time the sale was postponed or
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stayed, and Defendant(s) have been given credit for any payments that have been
made since the judgment, if any.
The amount of damages should now read as
follows:
Principal Balance
Interest Amount
11/1/99 through 12/5/01
Late Charges
Legal fees
Cost of Suit and Title
Sheriff's Sale Costs
Inspections/Other
Appraisal Fees
Escrow
Credit
Deficit
50,927.91
13,849.84
304.47
2,547.00
1,521.00
717.36
100.50
325.00
0,00
1,072.00
TOTAL
$71,365.08
5.
Under the terms of the mortgage, Plaintiff is entil~l('d r-~-, i r' "
of the figures set forth in paragraph four in the amount ot i'Jdgment ,'-J II ~
the Defendant(s).
WHEREFORE, Plaintiff respectfully requests this llt):,::,,- 11. ','!I'
Order to the Prothonotary to
CC'"'C"'o3~~
tortn
aoo\}.::.' .
Daniel G. Schmieg, ESQUTr~
Attorney for Plaintiit
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I.D. No. 62205
One Penn Center plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
CIVIL DIVISION
FRANK M. ROMITO, JR.
BONITA J. ROMITO
NO. 00-2163-CIVIL
BRIEF OF LAW IN SUPPORT OF
PLAINTIFF'S MOTION TO REASSESS DAMAGES
I . BACKGROUND OF CASE
Plaintiff and Defendant (s) entered into a Promissorv l\Jc<>-, i:-
Agreement, wherein Defendant (s) agreed to pay Plaintiff principal, lJ l2re5:: I
late charges, real estate taxes, hazard insurance prernlums and n!vI r._:.jQ"_]C
insurance premiums as said roonies became due.
In turn, Plaintiff' s Note was
secured by a mortgage on the subject premises.
The Mortgage Agreement
indicates that in the event Defendant(s) defaults, Plaintiff may pay any
necessary obligations in order to protect its collateral, the subject premises.
In the case sub ludicia, Defendant (s) failed to abide by the Mortgage
Agreement by failing to tender numerous I promised monthly mortgage payments.
Accordingly, after Plaintiff determined that Defendant (s) were not going to
cure the default and bring the loan current, Plaintiff commenced a Mortgage
Foreclosure Action.
Judgment was subsequently entered by the Court, and the subject property
is scheduled for Sheriff's Sale.
Because of the excessive period of time between the initiation of the
Mortgage Foreclosure Action, the entry of Judgment and the Sheriff's Sale date,
damages as previously assessed by the Court are outdated and must be increased
to include current interest, real estate taxes, insurance premiums, and other
expenses which Plaintiff has been obligated to pay under the Mortgage Agreement
in order to protect its interest.
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II. ARGUMENT FOR REASSESSMENT OF DAMAGES
The Pennsylvania Rules of Civil Procedure are siJ(-,(\t_- ',,'i ,-1-, .-,
issue of Reassessment of Damages; however f hull.:.'
Prothonotary shall assess damages for the amount which Plain! iff ~_
it is a sum certain or which can be made certain by compLitot-'--ofl.
instant case, the amount to which Plaintiff is entitled is readil Y l:a L..'lA; d t i;
by review of the Mortgage Agreement, which is of record, together wi lh t I 'e
Complaint which specifically lists the items chargeable.
Clearly, if Rule 1037 gives the Prothonotary the right to assess damages
for the amount to which Plaintiff is entitled as set forth in the Complaint,
the Court has similar power to reassess damages at a later date.
In addition, Rule 1037(a) provides that the Court, on motion of a party,
may enter an appropriate judgment against a party upon default or admission.
If the Court has the power to enter judgment, it certainly has the power to do
a lesser act, to wit, reassess damages.
It is settled law in pennsylvania that the Court may exercise its
equi table powers to control the enforcement of a judgment and to grant any
relief until that judgment is satisfied. 20 P.L,E., Judgments Sec. 191. See
also, Stephenson v. Butts, 187 Pa.Super 55, 59, 142 A.2d 319, 321 (1958); Chase
Horne Mortqaqe Corporation of the Southwest v. Good, 537 A.2d 22, 24 (Pa.Super
1988) ,
In Chase Home Mortoaoe, the Court stated that where a judgment has been
assessed following defendant's failure to file a responsive pleading in a
mortgage foreclosure action, a mortgagee "... could properly move the court to
amend the judgment to add additional sums due by virtue if the mortgage's
failure to comply with the terms of the mortgage agreement..." Id. at 24.
Because a judgment in mortgage foreclosure is strictly in rem, it is critical
that the judgment reflect those amounts expended by the Plaintiff in protectlng
the property. See Meeo Realitv Company v. Burns, 414 Pa. 495, 200 P-..:::J -r~l-,
(1971) .
Plaintiff submits that if Plaintiff went to sale without reas.seS:.;l[iCj
damages, and if there was competitive bidding for the subject premises,
Plaintiff would suffer irreparable harm in that it would not be able rr-
monies it paid to protect its interest. Conversely, a reassessment of ddrllagc~
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will not be detrimental whatsoever to Defendant (s) as it imputes no personal
liability.
The Supreme Court of Pennsylvania found in the Landau v. Western Pa. Nat.
Bank case that the debt owed on a mortgage
changes and can be expected to change from day to day, because Western
Pennsylvania must pay expenses for the property in order to protect its
collateral. 445 Pa. 117, 282 A.2d 335 (1971). Because a mortgage lien is not
extinguished until the debt is paid, Plaintiff must protect its collateral up
until the date of sale. See Beckman v. Altoona Trust Co., 332 Pa. 545, 2 A.2d
826 (1939).
Therefore, Plaintiff respectfully submits that if the enforcement of its
rights are delayed by legal proceedings and enforcement of its judgment, and
such delays require the mortgagee to expend additional sums pursuant to the
Mortgage, then said expenses become part of the mortgagee's lien and should be
included in said judgment. As the Court indicated in FNMA v. Jefferson, an
unreported case a copy of which is attached hereto, since the charges
enumerated in Plaintiff's Motion for Reassessment of Damages were incurred
pursuant to the Mortgage Agreement, and the mortgage had not yet been paid,
said charges should be included in Plaintiff I s judgment amount. May Term, 1986,
No. 2359 (CCP PHILA. 1986).
III. CONCLUSION
Plaintiff respectfully requests this Honorable Court grant i I-os Pet-" ')"; r
Reassess Damages. Plaintiff respectfully submits that it r-,a~: 0'1,,'-.1
faith in maintaining the property in accordance with the H01-tr:.-FHJl'--',
reliance on said instrument
with the understanding that it would recover the monies it expended tC) f- r(;L'~ r
its collateral.
WHEREFORE, Plaintiff respectfully requests this Honorable Court tc
reassess the damages as set forth in the Petition to Reassess Damages.
OO"D
DANIEL G. SCHMIEG, ESQUIRE
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FEDERAL NhTIONi\L ~IORTG1,GE
ASSOCIATION
C:OUR7 OF COMMON PLm\S
l'H!L~.DELPllIi\ CO.Utl'rY
C!V~L TRIAL DIVISION
vs.
. JOSEPH JEFFERSON' and.
, ROSIE JEFFE.!<SON, hi,. ',;ife
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lo\i\Y '!ERM, :1962' j,,.,
NO . 235 9 ~ ."}j ~
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ORDER AND OPINION
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WRITE, J.
AND NOI~, this '. 7' day of
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rea
UPon consideration of Plaintiff: Fedcra,l National t10rtgaQc
As$ociatiOn's Petition for Reconsideration Nunc Pro Tunc of
this Court's Order of November 7,1985 and the Answer th"r"to
of Defendants, Joseph Jefferson and Rosie Jeife:son, it is
hereby'ORDERED and DECREED as'fo110WS:1
1) Said p~~~~on is GRANTED:
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REVERSED and <:P laintiff!' 11 'Motio~_for Reassessmont.'a; Damaqes
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3) J'u'~~~t is h~re!'i; 'incrc~~..,d to $6,147-.71.
13ecaU5(~ l'l,aintiff was required to ac(:ept CUrr(lnt
mortgage payments upon the f.iling of ,Defendants' bi:tnkrupt,:y
Plltition and in fact did so, it is necessary to I'cnSSl!SS
the altount of da~lage,s that i.nitially were aSSE,sscd ~ft.cr
judqment by default was entered in this action. Because
Defendants have not refuted the specific amounts claimed
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by Plaintiff in the instant Motion for ReassesslIlcr:t, thi,.
pursuant to Pa. R.C.P. 1029{c).
Court finds that Defendants have admitted these amounts"
EY THE COURT:
~.;:-~
THOMAS A. WHITE, J~
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VERIFICATION
Daniel G. Schmieg, Esquire, hereby states that he is the attorney for Plaintiff
in this action, that he is authorized to take this affidavit, and that the
statements made in the foregoing Petition for Reassessment of Damages are true
and correct to the best of his knowledge, information and belief. The
undersigned understands that this statement herein is made subject to the
penal ties of
18
Pa.
c.s,
54904
relating to unsworn
falsification
t,;
authorities.
DATE: November 23, 2001
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Daniel G. SChlfl_fc:-(!,
Attorney for Plain~i1t
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. 1.0. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
WASHINGTON MUTUAL BANK
vs.
FRANK M. ROMITO, JR.
BONITA J. ROMITO
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 00-2163-CIVIL
AFFIDAVIT OF SERVICE
Daniel G. Schmieg, Esquire, hereby certifies that a copy of
Plaintiff's Petition for Reassessment of Damages have been sent [0 the
individuals indicated below on November 23, 2001.
FRANK M. ROMITO, JR.
BONITA J. ROMITO
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
DATE: November 23, 2001
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Daniel G. Schmieg, Esquire
Attorney for Plaintiff
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. 1.0, No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
/2151 563-7000
WASHINGTON MUTUAL BANK
vs.
FRANK M. ROMITO, JR.
BONITA J. ROMITO
TO THE PROTHONOTARY:
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 00-2163-CIVIL
PRAECIPE FOR RULE TO SHOW CAUSE
Kindly enter a Rule upon FRANK M. ROMITO, JR. & BONITA J. ROMITO,
should not be entered.
Defendant(s) to show cause why the attached Order for Reassessment of Damages
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Daniel G. Schmieg, Esquire
Attorney for Plaintiff
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I.D. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
CIVIL DIVISION
FRANK M. ROMITO, JR.
BONITA J. ROMITO
NO. 00-2163-CIVIL
CERTIFICATION OF SERVICE
I, Daniel G. Schmieg, Esquire, hereby certify that a copy of the Rule
Returnable Date of December 31, 2001 and a copy of Plaintiff's Petition for
Reassessment of Damages have been sent to the individuals indicated below on
December 12, 2001.
FRANK M. ROMITO, JR.
BONITA J. ROMITO
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
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Daniel G. Schmieg, Esquire
Attorney for Plaintiff
Date: December 12, 2001
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. 1.0. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(2151 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
CIVIL DIVISION
FRl\NK M. ROMITO, JR.
BONITA J. ROMITO
NO. 00-2163-CIVIL
AND NOW, this
ORDER
/7-tn day of V.ANUA rd
,2002, upon consideration of
Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED that
the Rule entered upon Defendant (s) shall be and is hereby made absolute and
Plaintiff's Petition is GRANTED and it is further
ORDERED that the Prothonotary reassess the damages in this case as
follows:
Principal Balance
Interest Amount
11/1/99 through 12/5/01
Late Charges
Legal fees
Cost of Suit and Title
Sheriff's Sale Costs
Inspections/Other
Appraisal Fees
Escrow
Credit
Deficit
50,927.91
13,849.84
304.47
2,547.00
1,521.00
717.36
100.50
325.00
0,00
1,072.00
TOTAL
$71,365.08
Plus interest per diem from 12/5/01 through Date of Sale at six (6%) percent.
NOTE: THE ABOVE FIGURE IS NOT A PAY OFF -
AND COMMISSION ARE NOT INCLUDED IN
SALE COSTS
FIGURES,
BY THE
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FEDERMAN ANP PHELAN
by: Daniel G. Schmieg, Esquire
Atty. 1.0. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
CIVIL DIVISION
FRANK M. ROMITO, JR.
BONITA J. ROMITO
NO. 00-2163-CIVIL
MOTION TO MAKE RULE ABSOLUTE
Plaintiff, by its Attorney, Daniel G. Schmieg, Esquire, hereby petitions
this Honorable Court to make Rule to Show Cause absolute in the above captioned
mortgage foreclosure action, and in support thereof, avers as follows:
1. That it is the Plaintiff in this action.
2. A Petition for Reassessment of Damages was filed with the Court on
December 12, 2001 and Rule was entered upon Defendant(s) FRANK M, ROMITO, JR. &
BONITA J. ROMITO on December 12, 2001 to show cause why the Order for
Reassessment should not be entered.
A true and correct cop of the Rule is
attached hereto as Exhibit A.
3. 'rhe Rule to Show Cause was timely served upon all parties in
accordance with the applicable Rules of Civil Procedure, and a Certification of
Service is attached hereto B.
4. Defendant (s) failed to respond or otherwise plead to the Rule
Returnable date of Januarv 3, 2002.
WHEREFORE, Petitioner prays this Honorable Court make the Rule to Show
Cause absolute and enter the Order for Reassessment of Damages.
Respectfully submitted:
GC
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Daniel G. Schmieg, Esquire
Attorney for Petitioner
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EXHIBIT A
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, FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. I,D. No, 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563 7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs,
CIVIL DIVISION
FRAWK M. ROMITO, JR,
BONtTA J. ROMITO
NO, 00-2163-CIVIL
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RULE
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. 1.0. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
CIVIL DIVISION
FRANK M. ROMITO, JR.
BONITA J. ROMITO
NO. 00-2163-CIVIL
CERTIFICATION OF SERVICE
I f Daniel G. Schmieg / Esquire, hereby certify that a copy of the Rule
Returnable Date of December 31, 2001 and a copy of Plaintiff' 5 Petition for
Reassessment of Damages have been sent to the individuals indicated below on
December 12, 2001.
FRANK M. ROMITO, JR.
BONITA J, ROMITO
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
OJ~
Daniel G. Schmieg, Esquire
Attorney for Plaintiff
Date: December 12, 2001
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VERIFICATION
Daniel G. Schmieg, Esquire, hereby states that he is the attorney for
Plaintiff in this action, that he is authorized to take this affidavit, and
that the statements made in the foregoing Motion to Make Rule Absolute are true
and correct to the best of his knowledge, information and belief. The
undersigned understands that this statement herein is made subject to the
penalties of 18 Pa.
C,S. 54904 relating to unsworn falsification to
authorities.
DATE: January 3, 2002
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Daniel G. Schmieg, Esquire
Attorney for Plaintiff
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FEDERMAN AND PHELAN
by: Daniel G. Schmieg, Esquire
Atty. 1.0. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19102-1799
(2151 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs,
CIVIL DIVISION
FRANK M. ROMITO, JR.
BONITA J. ROMITO
NO. 00-2163-CIVIL
CERTIFICATION OF SERVICE
I, Daniel G. Schmieg, Esquire, hereby certify that a copy of the Motion to
Make Rule Absolute has been sent to the individuals indicated below on Januarv
3, 2002.
FRANK M. ROMITO, JR.
BONITA J, ROMITO
51 WEST KELLER STREET
MECHANICSBURG, PA 17055
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Daniel G. Schmieg, Esquire
Attorney for Plaintiff
Date: January 3, 2002
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