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Home My WebLink About00-02445 -~""",' FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SillTE 900 PffiLADELPHIA, PA 19102 (215) 563-7000 WASHINGTON MUTUAL BANK 505 SOUTH MAIN STREET, SillTE 6000 ORANGE, CA 92868 ATTORNEY FORPLAINTITF COURTOFCO~ONPLEAS CIVIL DIVISION Plaintiff TERM NO. OC - :2t..{4~ (?tu<'C y~ CUMBERLAND COUNTY v. KAREN E. GEIDEL VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, P A 17007 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. ** Y (m have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE 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 AS SOCIA TION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Loan #: 0010850378 . ~ '- ,,' 1. Plaintiffis WASHINGTON MUTUAL BANK 505 SOUTH MAIN STREET, SUITE 6000 ORANGE, CA 92868 2. The name(s) and last known addressees) of the Defendant(s) are: KAREN E. GEIDEL VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, P A 17007 who is/are the mortgagor(s) and real owner(s) ofthe property hereinafter described. 3. On 311/99 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. 1525, Page 141. PLAINTIFF 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." "i<' , ,: I] " :j 6. The following amounts are due on the mortgage: Principal Balance Interest 10/1/99 through 411/00 (Per Diem $23.14) Attorney's Fees Cumulative Late Charges 311/99 to 4/1100 Cost of Suit and Title Search Subtotal $87,689.19 4,234.62 4,000.00 310.80 550,00 96,784.61 Escrow Credit Deficit Subtotal 0.00 0,00 0,00 TOTAL $96,784.61 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. ~ 1680A03c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $96,784.61 , together with interest from 411/00 at the rate of $23.14 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~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff " 1,' ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM DATE: February 17,2000 FORECLOSURE TO: Karen E. Geidel 178 Red Tank Road Boiling Springs, PA 17007 Virgil E. Geidel 178 Red Tank Road Boiling Springs, PA 17007 TillS 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 INFORMA TlON 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. Soecific information about the nature of the default is provided in the attached Dages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) 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 nlllne. address and ohone number of Consumer Credit Counseling Agencies serving vour County are listed at the end ofthis Notice. lfvou have anv auestions. vou mav call the Pennsvlvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with irnoaired hearing can call (717) 780-1869), This Notice contains important legal information. If you have any questions, representatives at the ConsUIller Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTlFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA 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 FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA. EXHIBIT A . ""'" ,~--~." ' . ~.'" STATEMENTS OF POLICY HOMEOWNER'S NAME(S): Karen E. Geidel and Virgil E. Geidel PROPERTY ADDRESS: 178 Red Tank Rd.-Boiling Springs, PA 17007 LOAN ACCT. NO.: 0010850378 ORIGINAL LENDER: Ameriquest Mortgage Company CURRENT LENDER/SERVICER: Ameriquest Mortgage Company HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. . IF YOUR 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 Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeting with one of the conswoer 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 TillS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEF AUL T" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES-Ifvou meet with one ofthe consumer credit counseling agencies listed at the end of this notice the lender mav NOT take action against YOU for thirtY (30) dayS after the date of this meeting. The names. addresses and telephone nwobers of designated conswoer credit counseling agencies for the county in which the propertY is located are set forth at the end of this Notice, It is only necessary to schedule one face-to-face meeting. Advise your lender inunediately of your intentions. APPLICATION FOR MORTGAGE ASSIST ANCE- 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 financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice, Only conswoer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. EXHIBIT A AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will 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. If au have filed bankru tc ou can still a I for Emer enc Mort a e Assistance. HOW TO CURE YOUR MORTGAGE DEF AUL T (Bring it uo to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 178 Red Tank Rd.-Boiling Springs, P A 17007 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 2/1/00 at $739.96 per month. Monthly Payments Plus Late Charges Accrued $3,181.84 NSF: $0.00 Inspections: $0.00 Other: $110.00 (Suspense): $0.00 Total amount to cure default $3,291.84 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not aoolicable): NlA 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 $3,291.84, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaYments must be made either bv cash. cashier's check. certified check or monev order made pavable 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 ofthe date of this letter. (Do not USe if not aoolicable.) 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 rights 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 uoon VOUr mortgage property, 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. Ifvou cure the default within the THIRTY (30) DAY oeriod. vou will not be recuired to pav attornev's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other SlDDS due under the mortgage, EYHr8'T A ,.. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-[fyou 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 orevent the sale at anv time un to one hour before the Sheriff's Sale. You mav do so bv navin2 the total amount then oast due, olus any late or other char2es then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as snecified in writin2 by the lender and by oerformin2 any other renuirements under the mort2a2e. 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, ext. 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. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time, ASSUMPTION OF MORTGAGE-You may or_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 PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEF AUL T. (HOWEVER, YOU NOT HA VB THIS RIGHT TO CURE YOUR DEFAUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY [S ATTACHED Very truly yours, AMERIQUEST MORTGAGE COMPANY Cc: Ameriquest Mortgage Company Ann: Collections Department Account No.: 0010850378 Mailed by t" Class mail/Certificate of Mailing and Certified Mail No: Z 2t5 965 355,356 EXHIBIT A . ". Pennsylvania Housing Finance Aaencv H ' E .. . omeowuer s mergency Mortguge Assistance Progr::tm Consumer Credit Counseling Agencies (Rev. 5/99) Lye:, , r" C =g-,~.lt":"[l C"=Ces oamus.ston :" or Co - \ _ . . 2130 , , ,..: =Wllt"! .==n \;::. ."'" Q ,,-,nC::J.I.Q, ....~,. _.) P, 0, Box 13"; --- Willi.:1=po"';: FA 17703 (S, 0) 326~)S87 F.o\.1: (570) 3""."0- --......1 C2 CCS af )(ar_"e3Sta~ 0' 01 Baoin S ~. .- ..~ W"1lliacu ~-- (S70) 32JP<::;,}'A 17703 F ~o_, A.1: (S70) 32:HS26 "', CL.I:N1'ON COf.;'"NTY CCCS ofN'orJ1eastern tl~ 1631 S .o\thertcn St .- Suite 100 St:lte eoneg", PA lS80' (814) 233-36S8 - F_~(814)23a-36S9 COLti'MBIA COU1'i-ry CCCS a{)(o,....he:astel"n Pennsvlvania 1400 Abingtan E.~~.lcve Park Suite 1 CIar3<s Sumctit: PA 13411 (S70) 587-9163 or (SOO) 922-9537 FA.'{ (570) 587-913419135 31 W. ),[ar!tet S=.t POB 1127 W"1lkes.Bar.-e. PA 18702 (570) 821'{)837 ar (800) 922-9537 F.';"'{ (570) 821-1785 ColllXllis.ian an Economics OpportUtUt"! of Lu::erne Co=t"! 163 .~ber 1:.=e Wilkes-Bar:-e. PA 18702 (570) 826-0510 or (800) 822'{)359 F.o\."C (570) 829-166S-CAlL BEFORE FAXDiG (570) 4554994 HAZELTON F_,;,,'{ (570) 455-5S31-CALL BEFORE F.';""GNG (570) 836...;090 TCNXH.o\.'<'NOCK Booker T. Washingmn Center 1720 Holland Si::'eet Erie. PA 16503 (814) 453-57~ FAX [814) 453-5749 John F, Kcr.nedy Center. Inc. 2021 East 20th St:'eet Erie, PA 16510 (814) 898-0400 FA."C (814) 898-1243 CCCS of W..ter:l PeWISvlvania. In", 2000 Ling!..""wn Road' H.u:o'..sburs, PA 17102 (717) 541-1757 Urban League of ),(et:'Opolitan Har.'..sburg N. 6th St:'eet Ham.burs. PA 17101 (717) 234-5925 F A."C (717) 234-9459 C.,=unit"! A",::on Comm of the Capit:1l Region 1514 Det":"'1 Street F.arr'..sbu:;;. PA 17104 (717) 232~9757 F.';""C (7171 23+-2327 CRAWFORD COlJ~'TY Greater Erie Cammw:::it:... .~=on COr."'......~:-...ee 18 West 9th Stre~t Erie, P." 1650 I (814) 459-1581 FA.1: (814) 456-0161 Shenango Valley Urban Le~e. Ir.c 601 Indiana Avenue Farrell. PA 16121 (412) 981-5310 C'tJl\1BERLA.'lD COCNTI' F~Co~e~gSern~sofF~m 31 West 3ni Street Waynesboro. PA 17268 (717) 762-3295 YWCA of Carlisle 301 G Streot Carlisle, PA 17013 (717) 243-3818 F.';"'{ (717) 731-9539 Adams COUIlt"! nousmg Aut!lorit'J 139-143 Carlisle St ~tt"JSb1lIi. PA 17325 (717) 334-1518 F.';",{(7171334-8325 EXHIBJT A PEHNSYl.VANIA BlJUETlN. VOL 29. NO. 2:l, JI.INE 50 1999 . ~" ALL. tho following described real est.u.te, together wH:h the improvcmenta thereon 'eroc:ted,. lring omd being situate in south Micklleton 'l"oWnShip. CI.lmlx>rla.nd O:>unty, li.''''!'lsylvarua, bourlded omd limited as follows: . , , BEGI1'INING at a steel pin set on the. southeJ:;I'l/l'lOst dedicated right-Qf~;'y line, of Reel,Tank Iload, I1lso I<l'lown as 'l'cwnshJp JilQad '1'-542, said ,pin mark.ing, the point 'of jOinder of the line which ext:c:mds between Iots 1>10. 1 and 2 on the hereinafter nocnticncd s~ivisicn with said dediCOltec:1 right-of-way line, atlQ,said, pincal60 ,bcinc; l="tOO SOuth 84 degrees 16, minutes SO seconds East for a distarice of' , 240_89 feet from a concreto ...,numcnt wh.ich marks the northw."sternmost'corner 'of the puxcel of which this tract was once a: part. thence extending in aitd along the southornmost dedicated right-of-way line of !'led Tank; Road by ail arc or curve to tJ'le left having a radius of 337.37 feet, a chord bearinq,of North 77 c3egrees 8 minutes 20 soc:onds East. for an arc distance of 218:82 feet. to, a pin on the &Outnerrun:>st dedicated. right-Of-way line of Red'l'anl< Jioad.. a1:,Lot No. 3 on the hereinafter lIlentioruad Plan of Lots; thence depoirtinq ,fran the, southernmost dedicated right-of__y line and. C!!Xter>:ting- alon;r Lot No~' '3 on the hereinafter men.t.ionec:1 Plan of Lots. the following- 'two "ecUrses'''ia:1d''distanl:E!s, ' South 8' dec;lrees 29 nu.lUttes 1,) seconds East for a dist:arlce of 291.25 f_t to a, steel pin. thence I c r ~' continuinq iUong LOt No.3, South 81 degrees 30 minutes 50 secol"lds. West for a distance of 171.09 feet to a steel. pin at Lot No. 1 on the hereinafter rrent.1oned Plan <?f .'/, Lots; thence continuing ,and extendincg along lot No.1, Nor1::h 17 degrees 26 rrunutes' 15 seconds West for a di stance ,of 278.24 feet 1:0 a steel pi n <)n the southOrTll1'Ost dedicated right-of-way line 'of ReO Tank. Foaa, said pin marking the PlaCG of BEGINNING. ' , CON1'IIINING L198 Peres. and BEING designAted, as let No. 2 on .. Final Plnn of Minor s~ivj.sion prepared for' Kiroba.. Inc., by ~y Lee Daclter ~ Asscx:iates, dat:ed July 31, 1979. =d recorded in the Office of the Recorder of I:Cec:1s in and for ~land County. l?eru=ylvani.a. in Plan l3ook. 36, Page 144$. . " Ii I; ~ ] if r l I " t: l' HAVING thereon erec:tec:1 a dwe11inq house k.n~ and numbered as 178 Red Tank. Foad. Boiling Springs, Pennsylvania 17007. BEING the same pr<omi ses '-'hich were eonveyed by Paul. R. Young. ~I. and Ki m R. . '{~, his ,..ife. fo:tmer1.y Kim R. Mixe1l. to Paul R. Your:g. II. and Ki,!, R. Younq. his w>fe" by deed dated January 24. 1986. and rec:onled January 27, 1986, >n CUmb:u:"J,and, County' Deed book S, vol.. 31, Page 20. I I I;' I l SUBJBCT, HOWEVER. to the fo11=;n9 restrictions: 1. No> ...,bi1e homes or trailers shall. bo,. placed UlX>n the wi thin descri bed premises. 2. No aceumulatlonof debris. j\IDl<. or unJ.icenscd vehicles shall be maint:aincd, ulX>" the wi thin described premises. 3. No dwelling ....ith a finished livincg area of less than 1.100 square feet shall bel constructed on the pre'mises. "'" VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorn~y 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. ;f::)( f- q .~1 ~ P<- DA1'E: LJ - ILl-cO .,.L."'"'~"'O"""ilPliml~~~ -. ~<a;;,;;;~~- iiIlI-' .,":',~,.~ -111, "_"~O,',M_.,,,",,,",~,,, _" __,",'_' ",r, ;',~,' "<, N (J \L~ :g ~ ~ ~ ~~. ~ ~iflli*' ( 1::) ~ ) ,-. -~-- ~ (y 'f.q ./:: hO , o L-r o () I ~ -~, - , ...." o c ""(j ~~~, fTit':'-;. ~~.. ~8 ~ -'oJ C) o J"7o ".U ::;::] ~" 8 \D ,- 1-:!"l ~~; -cc .,._(~ C.); I i s;: ::r> B :J1 ..,.., ~, -< ,,,_. -, . FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff WASHINGTON MUTUAL BANK PLAINTI FF COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY No. 00-2445 KAREN E. GEIDEL VIRGIL E. GEIDEL DEFENDANT PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. 1-:-~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: April 27, 2000 VERIFlCA TION Virgilio Andaya hereby states that he is FORECLOSURE SPECIALIST of AMERIQUEST MORTGAGE COMPANY mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civ.iI Action in Mortgage Foreclosure are ttUe and correct to the best of his /her kno,,;,le~ge, information and belief. The undersigned Wlderstands that this statement is made subject to the penalties of 18 Pa, e.s. Sec. 4904 relating to unsworn falsification to authorities. COy. DATE: 00 SHERIFF'S RETURN - REGULAR -'" CASE NO: 2000-02445 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS GEIDEL KAREN E ET AL CPL. TIMOTHY REITZ , 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 GEIDEL KAREN E the DEFENDANT , at 0014:45 HOURS, on the 3rd day of May 2000 at 178 RED TANK ROAD BOILING SPRINGS, PA 17007 by handing to KAREN E. GEIDEL a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.34 .00 10.00 .00 32.34 So Answers: ~~~J<~' R. Thomas Kline me this N<t: day of, 05/04/2000 FEDERMAN & PHELAN By: ~~' ~a- ~rilf- Sworn a,nd subscribed to before ~ ~ A~.D. ~Q.~# "', P othonotary, " '- '"'1 SHERIFF'S RETURN - REGULAR . -, CASE NO: 2000-02445 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS GEIDEL KAREN E ET AL CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GEIDEL VIRGIL E the DEFENDANT , at 0014:45 HOURS, on the 3rd day of May , 2000 at 178 RED TANK ROAD BOILING SPRINGS, PA 17007 by handing to KAREN E. GEIDEL (WIFE) 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: 6.00 .00 .00 10.00 .00 16.00 ~~~e'~~f R. Thomas Kline 05/04/2000 FEDERMAN & PHELAN me this. 1S't:!= day of Sworn ano."Subscribed to before By: ~ .',. 0lrnJ-0 A.D: Q~ a 11u.~, ~' P ,othonotary , - r 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, SUITE 6000 ORANGE, CA 92868 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CIYlL DIYlSION vs. : NO. 00-2445 KAREN E. GEIDEL VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 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 KAREN E. GEIDEL and VIRGIL E. GEIDEL, Defendant(s), for failure to fIle an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 4/1100 to 6/8/00 $96,784.61 $1,596.66 TOTAL $98,381.27 I hereby certify that (I) 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. ?/1tIM to .1/.IJ./'i/W1/'fl'o../ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: b .1J.aJ /sf k;t. ,e~ PRO PR BY /.e.?--' **TIllS FIRM IS A DEBT COLLEcrOR ATfEMPTING TO COLLEcr 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, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLEcr A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. ." ,,- " ,.'. -, - -, " '........~"-.:.,.."~ili-~"'~~"""'.-~~ ~,.~ 'll--~ ~m_"IIi"~ .1i~ ~ ,''''.. ,,'., " ''',~', ",,^ ~_. ...-' ,~ ~--~ "-,~~ ~,', . \ (') 0 0 C 0 " 'i::: C- '~ "00:1 C ~f;j-n mrn "'- "r- 7:J:.) I -"1fT! 2:5 ," ~Q.y (.0_., ~E ~:.iQ ~ .o' ;J>'> r ~"I" ::E>(...., ::zt: '20 ~t5 5 CSin )>e: u 'i::! :z; U'I :;J."J =< <::I -< .' " ~!<:"i , 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 MUTUAL BANK COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY KAREN E. GEIDEL VIRGIL E. GEIDEL NO. 00-2445 Defendant(s) TO: KAREN E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 DATE OF NOTICE: MAY 24. 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 A VENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff !ii."""'''~"''~Ii~~~iIlIli!!k'"ilii1~~:IiiI:Ilv:il!W~IMHlliii<ill~''''h'';""",=w:'r<fi>''"''t~--- "'~ " --, -. ~ ~~~'~ .I"~'.~ '. ~" -" , (') 0 0 C 0 ;:"'. il -Om , .-, C ~-r': ~rn :;;e ~~1~ I! ':71'--' I -'-'01 05''(> ..0 ~,DO -<7~ ':) I r;::c' -> ,() =>0 ;l> t~ :y~ :z 20 :2'0 :> S' c: Om 7" :;! ~ U1 <::> ~ , , 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 MUTUAL BANK COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY KAREN E. GEIDEL VIRGIL E. GEIDEL NO. 00-2445 Defendant TO: VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 DATE OF NOTICE: MAY 24, 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 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 2LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff 'Oii~""'~""';""'l~ '~."",l""'''"'<1iu~~;'lIl~ffiliU~~Ii!I~lnDWt..,-"""........~~ _ "'<' "r. -,' -', ,< ~ ,~" '." , " -, ~ ""'""llIill1f~ :....'""""~ .~ . , 0 0 0 C 0 -.'~ $: L. ,-; ""00:: m" c "'T'.' Z ., z !""l::;FR :JJ Zt;"' I ~-~:~ tJ ~C';~ <.D ~cj ,),J. > .;.1 .,.~ ~o :31: ;..;::: '"Tj ~-o 5 ~C) ;t>c Orn ~ o-i '-'1 ;t (::> -< ',' . FEDERMAN and PHELAN By: FRANK FEDERMAN IdentifIcation No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff W ASIllNGTON MUTUAL BANK : CUMBERLAND COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION KAREN E. GEIDEL VIRGIL E. GEIDEL : NO. 00-2445 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 KAREN E. GEIDEL is over 18 years of age and resides at 178 RED TANK ROAD, BOILING SPRINGS,PA 17007. (c) that defendant VIRGIL E. GEIDEL is over 18 years of age, and resides at 178 RED TANK ROAD, BOILING SPRINGS, PA 17007. This statement is made subject to the penalties of 18 Pa. CoSo Section 4904 relating to unsworn falsifIcation to authorities, f~ I~/WI#M./ FRANK FEDERMAN Attorney for Plaintiff ~idm:'lil~j "' ~ ""'~.. ~~ii'-~ ' ...."""'"'IWi~"....""-''-"'"' ~ UJ[IYI''t1~'"'' ~' " ~ ~ -"~~ ~ ~ , ~ ~ 0 (,;:) 0 ~~ C 0 -1'1 ~ :;;: c: fRU1 "T1 fT1 -.~"'" r::: 2::0 , .~ ~ ~ :\ Zr.;~ \.0 :]0 (j)",,,-- c-''', ,I ~." :~i~ t :<:C; ;l:o> ~ ~ ~ d"C 3: ~f~ ;So C5 . ~ ~ }>C ,-, " ~ U1 53 (::> -< . . ~ lID: < (Rule of Civil Procedure No. 236 - Revised) W ASIllNGTON MUTUAL BANK : CUMBERLAND COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIYlSION KAREN E. GEIDEL VIRGIL E. GEIDEL : NO. 00-2445 Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on JUNE 'f ,2000. /~ ~.~.X~. /~ By DEPUTY /,kJL- If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA 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. ** ~w. ' ~ '"" " '" , ~ '"\ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WASHINGTON MUTUAL BANK Plaintiff, CUMBERLAND COUNTY v. No. 00-2445 KAREN E. GEIDEL VIRGIL E. GEIDEL Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due // $98.381.27 ./ Interest from:6/8/00 -12/6/00 $2.926.77 and Costs (per diem - $6.17 ) $101.308.04 TOTAL ;It'k ~h~AA F FED , ESQUIRE TWO PENN CENTER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property.No. . . .. --~ . ,,~~, '., ". '.,'J N ~ - ..:< ~ Z 3~ o~ ;:::}:::J ?;w :;!Z '-'-Z '"J 1LI ,Do.- '5 :s o f.C, .<l. '\\\~ ~2t:, ,-.'-", i=;s \;=~ gii~~. G: C'J (")' (2 z: .~ " <5 o o :> >rj "= d2 ~. ~ ;0-3 0.. ~ '" ~ ~ P.- i."J= '" ~ :> ~~ ;; '" .... '" jt:il == =~~ :s,~ .... ~g '" Z (l 0-..1 o "'l ~.., l:;j~ ...., '0 FE ::to ~ 0-3 '" .g 1J(j~ 0 ~o ~ 2l:;jZ = Fz '" ~~ Z O"'l '" ~~ N '" ~0-3f"J f"Jf"J < a::: 8 ?' 0 ~~~ ~ 0-3 ~~ ~ 0-30 0 .ei 0 ~~~ ~ 0 i."Ji."J 0-3 .:<a::: :> cr" Q"'l .... .... ~ "=a::: ~ '" Z~l:;j 1::Il:;j ~ '" = i."J i."Ji."J i."JO '" ~0i."J Zz ~ ~~t"' 3-~ t"'t"' = Z,,= po ~ ~ "'t"' :> ~ ~i."J ~ ...., ~ <:> -..I .... ~~ :> 0 :> -..I Z :>"'l =~:s 9Q;l~ t"'[;:J~ .... .... Zl:;jt"' ~0-3i."J "':>~ ~~~ ~~~ ~~t"' :> ~ -..I :> :> -..I ~, .r . :. ~, . .= ~ "....",..A,_~""""" - ,.,.~~,~"., ~ ~ftiun ~<,,~, ~_, f~Ji;"~~~~,~~~~!;jffi~~rr"~""" ~",' ,;""','1""'[1 , '~ I; , l~<' ~ " DESCRIPTION ALL the following described real estate, together with the improvements thereon erected, lying and being situate in South Middleton Township, Cumberland County, Permsylvania, bounded and limited as follows: BEGINNlNG at a steel pin set on the southernmost dedicated right-of-way line of Red Tank Road, also known as Township Road T-542, said pin marking the point of joinder of the line which extends between Lots No. 1 and 2 on the hereinafter mentioned subdivision with said dedicated right-of-way line, and said pin also being located South 84 degrees 16 minutes 50 seconds East for a distance of 240.89 feet from a concrete monument which marks the northwesternmost comer of the parcel of which this tract was once a part; thence extending in and along the southernmost dedicated right-of- way line of Red Tank Road by iIl1 arc of curve to the left having a radius of 337,37 feet, a chord bearing of North 77 degrees 8 minutes 20 seconds East, for an arc distance of218.82 feet to a pin on the southernmost dedicated right-of-way line of Red Tank Road, at Lot No, 3 on the hereinafter mentioned Plan of Lots; thence departing from the southernmost dedicated right-of-way line and extending along Lot No.3 on the hereinafter mentioned Plan of Lots, the following two courses and distances: South 8 degrees 29 minutes 10 seconds East for a distance of 291.25 feet to a steel pin; thence continuing along Lot No.3, South 81 degrees 30 minutes 50 seconds West for a distance of 171.09 feet to a steel pin at Lot No. I on the hereinafter mentioned Plan of Lots; thence continuing and extending along Lot No, 1, North 17 degrees 26 minutes 15 seconds West for a distance of278,24 feet to a steel pin on the southernmost dedicated right-of-way line of Red Tank Road, said pin marking the Place of BEGINNING. CONTAINING 1.198 Acres, and BEING designated as Lot No. 2 on a Final Plan of Minor Subdivision prepared fro Kimba, Inc., by Rodney Lee Decker & Associates, dated July 31, 1979, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 36, Page 146. HAVING thereon erected a dwelling house known and numbered as 178 Red Tank Road, Boiling Springs, Pennsylvania 17007. TAX PARCEL NUMBER: 40-12-0342-033B TITLE TO SAID PREMISES IS VESTED IN Virgil E. Geidel and Karen E. Geidel, his wife by Deed from Paul R Young, II and Kim R Young, his wife dated 1/26/87 recorded 1/30/87 in Deed Book "L", Volume 32 Page 941. -, ,< 'Jaj,~ilil~-j,) 'AA.w~_" __' I, ~~tl!il1-M~\J;~"J$!~ilJ!$,""Ji_,il>>1;;';~"-' , <lilli*! ~~ ~~ '. ;! 'vJ ~ ~ ~ c....; --.I ~ -.. ~ cr ,..,-0 , '"~.- ~ ^ ,~"", ,,~ '"~ -n_ ."_",,,_,,_~~_",_ ~ ~~..-;,'""",'""""",~,,,,,,~....'~" ~ 'J " \6..l -f::' fD ~ ~ ~ 4::- ~ ~~~)U~\. \- ~. ~ ~ ^"., -' , ~ .'~ "N .L o,,-,,~ () <:::1 0 C 0 "<1 ? :no -ofj5 r:::: mfl'! c" Z::;:) 1'0 -~I lJJ zrn "'".' I C.0),: <.J1 ::...<Y ~O ~::_.J () ;0. -,--!oT'l >'0 .,~-,- --n ..:;;. r,_ Zo 40 :PC '2 Om ~ W ::t;! 5:J N -< .I' ... ~ ~ . . WASHINGTON MUTUAL BANK CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS KAREN E. GEIDEL VIRGIL E. GEIDEL CIVIL DIVISION NO. 00-2445 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 178 RED TANK ROAD, BOILING SPRINGS, PA 17007. 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) KAREN E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 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 ,,; . 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 178 RED TANK ROAD BOILING SPRINGS, P A 17007 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 of 18 Pa. CoSo Sec. 4904 relating to unsworn falsifIcation to authorities. August 22. 2000 DATE 2~~.~ FRANK FEDE AN, ESQUIRE Attorney for Plaintiff }tj(~i , .LilLUIw_~ilillllidil!i!SUi -~ ~-'1Ili!I!~~[., ,~ ,~" il'll(fliI'IiiilMl'IRit.~ ,- ~ -" - . 1Iltll1i~~ -,~" - " .'. ~"" '~ . () a C) C a ~'11 s: "'" uO) c:: l'n1T' ,:;-) ','; :.;:; Z:x, 1-' Zl- 1',) ,; i-'J (JJ .,..r:.~" (J, ~ ,,' , C---'I ~- -'-=r ,J ~tJ 2:::jCj :e: _r'--'---, p(--" ~'" ,:-~) ::T.! ;So ">0 0 ':'5 l l"j )>c: ~ 7"': W ~ =< f'V -< Pili - ~.. - WASHINGTON MUTUAL BANK Plaintiff, CUMBERLAND COUNTY v. No. 00-2445 KAREN E. GEIDEL VIRGIL E. GEIDEL Defendant(s). August 22, 2000 TO: KAREN E. GEIDEL VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 ""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 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."" Your house (real estate) at 178 RED TANK ROAD, BOILING SPRINGS, P A 17007, is scheduled to be sold at the Sheriffs Sale on DECEMBER 6, 2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by WASHINGTON MUTUAL BANK (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the _MARCH 7, 2001 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. ~Oj 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 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. 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA YE 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 " .. ~ , , ~' DESCRIPTION ALL the following described real estate, together with the improvements thereon erected, lying and being situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a steel pin set on the southernmost dedicated right-of-way line of Red Tank Road, also known as Township Road T-542, said pin marking the point of joinder of the line which extends between Lots No.1 and 2 on the hereinafter mentioned subdivision with said dedicated right-of-way line, and said pin also being located South 84 degrees 16 minutes 50 seconds East for a distance of 240.89 feet from a concrete monument which marks the northwesternmost comer of the parcel of which this tract was once a part; thence extending in and along the southernmost dedicated right-of- way line of Red Tank Road by an arc of curve to the left having a radius of 337.37 feet, a chord bearing of North 77 degrees 8 minutes 20 seconds East, for an arc distance of218.82 feet to a pin on the southernmost dedicated right-of-way line of Red Tank Road, at Lot No, 3 on the hereinafter mentioned Plan of Lots; thence departing from the southernmost dedicated right-of-way line and extending along Lot No.3 on the hereinafter mentioned Plan of Lots, the following two courses and distances: South 8 degrees 29 minutes 10 seconds East for a distance of 291.25 feet to a steel pin; thence continuing along Lot No.3, South 81 degrees 30 minutes 50 seconds West for a distance of 171.09 feet to a steel pin at Lot No. I on the hereinafter mentioned Plan of Lots; thence continuing and extending along Lot No, 1, North 17 degrees 26 minutes 15 seconds West for a distance of278.24 feet to a steel pin on the southernmost dedicated right-of-way line of Red Tank Road, said pin marking the Place of BEGINNING. CONTAINING 1.198 Acres, and BEING designated as Lot No.2 on a Final Plan of Minor Subdivision prepared fro Kimba, Inc., by Rodney Lee Decker & Associates, dated July 31, 1979, and recorded in the Office of the Recorder of Deeds in and for CUIIiberland County, Pennsylvania, in Plan Book 36, Page 146. HAVING thereon erected a dwelling house known and numbered as 178 Red Tank Road, Boiling Springs, Permsylvania 17007. TAX PARCEL NUMBER: 40-12-0342-033B TITLE TO SAID PREMISES IS VESTED IN Virgil E. Geidel and Karen E. Geidel, his wife by Deed from Paul R. Young, II and Kim R. Young, his wife dated 1/26/87 recorded 1/30/87 in Deed Book "L", Volume 32 Page 941. ~....o,._..",.J"_'''''''''~'''''~lliil:1~..!!j.~~~~~~~r,!'''~~ .1. .. ,=~~ -~"--'" .' ."1_ ~, ~ . --.+ . ~ ~" ~~ , ~ ~ o c:: :?> '"0 Q~ rilrrr ~'::r,i Zr-' cr3)> :-<2 ~Cj ::6...-, 2:' , );:0 c:: 2: ::< " 5 W f\J - . o o ". - G5 r" en o "T) ::;-:1 -~:j :n -::7f"1I ~~i6 -i:':I-, ,---." n '_I -...; >~o ~rn ~, b' r;; =< ;:::..,. -,- ~ " ". FEDE~andPHELAN By: FRANK FEDE~ Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CIVIL DIVISION KAREN E. GEIDEL VIRGIL E. GEIDEL NO. 00-2445 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. CoSo Section 4904 relating to unsworn falsifIcation to authorities. iIi",;,';i"""""~LL~~'IiIlliiml!~~ilit ~ '~~'~":&.IMJl!llIlill\n'-n ~,I ,..~ 0" " ~ ~, ill u. ....<i T~'= ~~ ",.! .' . 0 0 0 c: 0 oT1 s: ~ -ace L-=) -'1"' fT1rTJ 2:1] N ,:T; z:t; t:~ ~~~ ~z CTl r::C' :r;:.1I' ~o ~, ~~io Zc '? Orn ;Pc ,~ Z j) ..". =<! :J:) N -< I!r ,-d; " , -~. <\['- . . ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK Plaintiff CIVIL DIVISION vs. No. 00-2445 KAREN E. GEIDEL VIRGIL E. GEIDEL 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 25, 2000, true and correct copies of the Notice of Sheriffs Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on AUGUST 25,2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. ERMAN, ESQUIRE r Plaintiff Date: November 1, 2000 " ~~" .'"-1', ~r ------ co>:.: "'Co" ""Co;; -~ , m ;z ~ "'''' ~" Co"'.. ~.~ " '" " - - - - - - '0 00 ..., 0- U. ... 'w N - .., Co ~[ u. ... W N - C> I [1f ~ ~s. en n' n " = ll' z ~ c 3 a' ..,...,.., ~ ...~i:'l ,- . -" = :.',/,,,, .,CO ..., = f Co..,i:'l ",,,, ~ ""~ " CO -" H " ;; 'CI " ~. .. " 0 :'n> [[ ~ " '" ..., .P~z 3 - 1>: .:0- ;:;. ..,ar<o !!lot' ~ " :xl Q, >~"":l a'~ " ~ " " ~ :c..,= ~ 0 ;;; ~ - ~ 'CI $ -=~ 0:9- .. - s~ " o' en S&!t"" SO' " l .", ~ ~ ... '" ..., CO 50 co ... g - ~, ::0 n Q, " " " ~ '0 C. a <:> t:1' 0;> , ..., " 0 .. .., s "';!' " ;;; 8 "" " .[~ ::0 Co 1>: iJ <> n Q, .. ~ F- co " ~ "" I:ll " - ~ co :;< ~ ::: ;;" ... "" '" ~ ~ .., .., - ;;. ... ~ = .. .., " > ~ ... " .... .., g "" - .... ;;! " .- v: clSn .~ ./0 dsn ~ n - '" .. r(':~ ",/ .I\~ 3: '" ~ )~) j; .., " an~ .I.~ ,,)~ 8IlV 1$ > ... ~~ ;~' .... "~ 1V~~~ C> ... '" .. I . ", ~ , 09t9909 ~ . ' 1I;H3 VHhl . ~ '~ :: 0 2' I ~ , l~:J~oo,s'oo~ ~ ' - ~4.. .~' i';/ ~ ' i '1~lSnd'S'n (~~<Y'7::JO-<\ .. K ~ !(7~~ =-- -;' ~ -:".r -=__ ;r -. . ".,..:",," " " , -J"; ',<. ',,',~; ~ . '"RE;-'SALES- ~-"_.-..,-~."". ~"...' l> ,".. ",y,~~ :'.'..1f1 '. SE'NDER:/:DMK' " ,~ ,-:f '. >.j'i - .'0"', . ~~"" ..."... ..... ....., ..,....... .,." ,......... .,... .,.,. .,..,....... 3. Article Addressed to: VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 t~!? FYTI'111'lo,~S!!l!Il"'i ; <..': ' _,~_:;',"':'';:7:~;;:i::\,:~<;,~-:'~'''. ;j R~: SALES '..~,-,~--~---------- I, .. '. ,......""~. ~~, '. 'i '3,':' .. :;' j SENDER: uMK.;,,;': if' J .~; ':',; ", ~'i r',' :1, ~ ~ ~ ~ 3. Article Addressed to: ~ -KAREN E. GEIDEL " 178REDTANKROAD ~ BOILING SPRINGS, PA 17007 ~ ~ :~ " :."'C I also wish to receive the following service (for an "xtra fee): ~ og, Con~~ postmesterfor fee. 4a. Article Number P 9b 9 D 5b ], D 8 11111111111111111111111111I11111111111111111111111111111111 4b. Service Type jgJ CERTlI'IED 7. Date of Delivery 8. Addressee" Address , " ~t!jhfil"!l tf"~,'" '!,< " ~~ , ',:,- Domestic Return Rece I also wish to receive,the following service (for ariextra fee): ="" ," ug " " Cor1sukpostmaster.f"rfee, 4a. Article Number P 9b 9 D 5b ], [] 7 1IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIWlllnllll' CERTIFIED Domestic Return Rece . . >'." ,:""-""-- ,-" "'."" ". ',','., ",' ~'". - "'''' .'- - '~. ;"- "",,-, P.%9056108 TO: VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, P A 17007 SENDER: REFERENCE: DMK SALES PS FORM 3800 SEPTEMBER 1995 -... CertlftedFee RETURN RECEIPT SERVICE Retum Receipt Fee 2.25-_ ReslriCtedOElllvery ToIalPostageaodFees US Postal Service ... '__._~'_'H'___.' ,_._"'~_<'_' .." - TO: P"969 056107 KAREN E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 SENDER: REFERENCE: DMK SALES PS FORM 3800 SEPTEMBER 1995 -... eo"""'.... -lHlO-- RETURN RECEIPT SERVICE AetumRecelptFee _,.___-2.75.... RestrietedOellvery Total Poslageand Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do not use for Internationai Mail .> , J1&ftl 'I :!lWi11'l<~1~~~~d''"'~'''''''''''''<<>'~' ~" ~,cL ,~~ _ ~.' - - r. ~.ileu!~-"~<'~ ''''0' . 0 c::> C' c: 0 -"0 g: :z: ,-"', -0 OJ q , ' ~,'T,1 rn-ji~ <'<j;"" 'r'- z~c ,:n ,~ I ZC "-"...:J ~"'; 0" ~;\Q !.2C:: -0 ~Z~ 5-:Q J{: ..::::::LJ '-? Of'! )>c: -, Z N ~ =< ()'> -< ,"', - ~~'- ;,Ii . Washington Mutual Bank -vs- Karen E. Geidel Virgil E.Geidel In The Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-2445 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 Share of Bills Law Journal Patriot News 30.00 18.25 15,00 15.00 .50 1.00 7.44 2.98 15.00 20.00 30.00 23.15 428.15 324.15 $ 930.62 Paid by atty 12/01/00 Sworn and subscribed to before me ~rs: ~ , ,/~e II R Thomas Kline, Sheriff This .2)""", day of /..!)p.lO M< fl." ,) 2000, A.D. Qtl(. Q /'h/Pd,. 1 ?4' P 0 onotary BYiJt..~~ Real Estate Deputy \~ . ~() GY"\ Of<-. .5 ,/;)A \0.u,/D , =~ ~ -," '-" Iii, WASHINGTON MUTUAL BANK CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS KAREN E. GEIDEL VIRGIL E. GEIDEL CIVIL DIVISION NO. 00-2445 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 178 RED TANK ROAD, BOILING SPRINGS. PA 17007. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) , KAREN E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 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 - = ~ - ",- ,',"" , -'~ "'.-.,,;~': 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.) I , ! 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 178 RED TANK ROAD BOILING SPRINGS, P A 17007 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 of 18 Pa. C.S. Sec. 4904 relating to unsworn falsifIcation to authorities. August 22. 2000 DATE FRANK FEDE AN, ESQUIRE Attorney for Plaintiff :ul~"- , ~ , ~"" , , WASHINGTON MUTUAL BANK Plaintiff, CUMBERLAND COUNTY v. No. 00-2445 KAREN E. GEIDEL VIRGIL E. GEIDEL Defendant(s). August 22, 2000 TO: KAREN E. GEIDEL VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, P A 17007 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION 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 178 RED TANK ROAD, BOILING SPRINGS. PA 17007, is scheduled to be sold at the Sheriffs Sale on DECEMBER 6. 2000 at 10:00 a.m. in the Cumberland County Courhtouse, South Hanover Street, Carlisle, PA 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 7, 200 I Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE 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. ~~ "' " ., """;,1:1-.! . 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.) i ~: I 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 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. 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. I t I 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. 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 , .,"~i . --.'~Hl Ii i 1 , I Ii Ii, " q H DESCRIPTION II' ~ . , i , I , I I i: ALL the following described real estate, together with the improvements thereon erected, lying and being situate in South Middleton Township, Cumberland County, Permsy1vania, bounded and limited as follows: I I , I I i !i BEGINNlNG at a steel pin set on the southernmost dedicated right-of-way line of Red Tank Road, also known as Township Road T-542, said pin marking the point of joinder of the line which extends between Lots No, 1 and 2 on the hereinafter mentioned subdivision with said dedicated right-of-way line, and said pin also being located South 84 degrees 16 minutes 50 seconds East for a distance of 240.89 feet from a concrete monument which marks the northwesternmost comer of the parcel of which this tract was once a part; thence extending in and along the southernmost dedicated right-of- way line of Red Tank Road by an arc of curve to the left having a radius of337.37 feet, a chord bearing of North 77 degrees 8 minutes 20 seconds East, for an arc distance of 218.82 feetto a pin on the southernmost dedicated right-of-way line of Red Tank Road, at Lot No.3 on the hereinafter mentioned Plan of Lots; thence departing from the southernmost dedicated right-of-way line and extending along Lot No, 3 on the hereinafter mentioned Plan of Lots, the following two courses and distances: South 8 degrees 29 minutes 10 seconds East for a distance of 291.25 feet to a steel pin; thence continuing along Lot No.3, South 81 degrees 30 minutes 50 seconds West for a distance of 171.09 feet to a steel pin at Lot No. I on the hereinafter mentioned Plan of Lots; thence continuing and extending along Lot No.1, North 17 degrees 26 minutes 15 seconds West for a distance of278.24 feet to a steel pin on the southernmost dedicated right-of-way line of Red Tank Road, said pin marking the Place of BEGINNING, I I I I 1 I I I CONTAINING 1,198 Acres, and BEING designated as Lot No. 2 on a Final Plan of Minor Subdivision prepared fro Kimba, Inc., by Rodney Lee Decker & Associates, dated July 31, 1979, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 36, Page 146. HA VlNG thereon erected a dwelling house known and numbered as 178 Red Tank Road, Boiling Springs, Pennsylvania 17007. TAX PARCEL NUMBER: 40-l2-0342-033B TITLE TO SAID PREMISES IS VESTED IN Virgil E. Geidel and Karen E. Geidel, his wife by Deed from Paul R. Young, IT and Kim R. Young, his wife dated 1/26/87 recorded 1/30/87 in Deed Book "L", Volume 32 Page 941. -- "'.,;' . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 00-2445 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: Washington Mutual Bank To satisfy the debt, interest and costs due PLAINTIFF(S) from Karen E. & Virgil E. Geidel, 178 REd Tank Road, Boiling Springs PA 17007. DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located at 178 Red Tank Road, Boiling Springs PA 17007 (Se~ attached legal descriptio:Il~ ) ,-- ,~;~.,~,^ jr\:;' ,," ',~r, ~_J'I"""",," (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of _ ~_,~",_,....",,..,,,, ",.""..",,^ ,,,.,,, ,,',.' ',~,v""~~ .."......."~.,',' """, ~~~{ , '!'-', ';>,1: > J~Ji\~~', eo ill',; 'U:t',i,_ GARNISHEE(S) as follows: and to notKy the garnishee(s) that: (a) an al~~bHment 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 ofthe deiendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated, Amount Due $98,381.27 I 6/8/00 - 12/6/00 nterest $2,926.77 L.L. Due Prothy Other Costs $.50 $1.00 Atty's Comm Atty Paid Plaintiff Paid % $120.34 Date: August 25, 2000 CURTIS R. LONG . Civil Division by: Deputy REQUESTING PARTY: Name Frank Federman, Esquixe Address: Two Penn Center Plaza, Ste. 900 Philadelphia PA 19102 Attorney for: Plaintiff Telephone: (215) 563-7000 Supreme Court ID No. 12248 """.,.^.,"....^-"...~""....~-~.4iIl1' l1:~ 1&; . ~ilf'"'~"'.""'1ti~ , ,-''':h~~!l@,ir,.;,i;.i;.-:a''''~I''i~H)_W,~~ ~1Ii1"1ll4!It!l!i;l~)m~$'t;!\I\~ . REAL ESTATE SALE NO'. if' On ~ 31, ~rO the sheriff levied upon Ute d8f8ndams interest in the real property situated in t..-A /L4'If/:LJit~~~ Cumberland County, Pa, knl"^"~nd numbered as: }7~ /;J/-;{.-AI t-.I.- ~t2Arif"i/? aM more "icribed on exhibit "A" flied with this wrtt and Oy this reference incorporated herein. O:JJJl0'i,-??/~ ~~ '\"'1 ~ I \} l' -'I,!, c; t ! ~..1l {J I, ! ," " ,,'. I ...__.J ~!: . ' t..." <.' Pi DE ~Ilr .A.UH;,~ ,i'rn~ .Hlll:lfE,"~ ~0 ..l,J;lii (~) CViJ ~. = GV ~