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HomeMy WebLinkAbout00-03476 ~"~, FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO, 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPillA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURTOFCO~ONPLEAS CIVIL DIVISION CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC 5373 WEST ALABAMA, SUITE 600 HOUSTON, TX 77056 Plaintiff TERM NO, 00 - .347$ Ciu~l ~~ v, CUMBERLAND COUNTY MALINDA S. MEEHAN F/KlA MALINDA S. RASMUSSEN CHARLES MEEHAN 517 NORTH HANOVER STREET CARLISLE, fA 17013 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 [S 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 fol1owing pages, you m~st take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personal1y 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. Y o~ may lose money or property or other rights important to you, YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A ] 7013 (717) 249-3166 Loan#: 8089815 ~ 1".:- - 'J" - ' ""'t ~ 1. Plaintiff is CRfDTT BASED ASSET SERVTCING AND SECURITIZATION, LLC 5373 WEST ALABAMA, SUITE 600 HOUSTON, IX 77056 2, The name(s) and last known addressees) of the Defendant(s) are: MALINDA S, MEEHAN F/K/A MALINDA S, RASMUSSEN CHARLES MEEHAN 517 NORTH HANOVER STREET CARLISLE, PA 17013 L who is/are the mortgagor(s) and real owner(s) of the property hereinafter described, 3, On 617/99 mortgagor( s) made, executed and delivered a mortgage upon the premises hereinafter described to CONTIMORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1553, Page 209, PLAINTIFF is now the legal owner of the mortgage and is in the process of fomlalizing 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 2/7/00 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," . "" -:1' 6, The following amounts are due 011 the mortgage: Principal Balance Interest 117100 through 5/1 /00 (Per Diem $22.64) Attorney's Fees Cumulative Late Charges 617199 to 5/1/00 Cost of Suit and Title Search Subtotal $87,181.62 2,626.24 4,000.00 108.93 550.00 94,466,79 Escrow Credit Deficit Subtotal 234,54 0,00 (234,54) TOTAL $94,232,25 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 Sheriffs 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, 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 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, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $94,232,25, together with interest from 5/1/00 at the rate of $22,64 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, ;)-~k!)Lio~' . . fshrank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - , '1 'J'; APPE"DIX A Page 1 of 5 APPENDIX A Date: 4/17/00 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE* This is an official notice that the mortl!3!!e 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 Da!!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM IHEMAP' mav be able to helD to save your home. This Notice eXDlains how to DrO!!ram works. To see if HEl\lAP can helD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGE:"CY WITH IN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when ,\'0" meet with the Counselinl! A!!encv. The name. address and ohone number of Consumer Credit Counseline A!!encies servine vour County are listed at the end of the Notice. If vou have anv auestions. vou mav call the Pennsvlvania Housin!! Finance Aeencv toll free at I-800-342-2397.IPersons with imoaired hearine can caU 171 TI780-I869. This :"otice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agenc)' may be able to help explain it. Vou may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA "OTIFCACIO:-l EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTI;IIUAR \'lVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NO'TIFICACION OB'TENGA UNA 'TRADUCCION INMEDITAMEN'TE LLAMANDO ES'TA AGENCIA (PENl'"SYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS ALNUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTA:-ICE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR SU HIPOTECA. . (~Iust be at least 30 point Q'pe) - Carlisle, P A 17013 L)~t 1-60 (CUlV Z 331 133 463 liS Postal Service Receipt for Certified Mail No 'nsurance Coverage Provided. Do not use for InternationaJ MaillS _. (Sent 10 ee rev8lSeJ r I i Certified Fee' ..- l Spedal Delivery Fee HO~IEOWNER'S :-IAME(S): Malinda Meeban Charles :\Ieehan MAILI:>IG ADDRESS: 517 North Hanover Stree PROPERTY ADDRESS: 517 North Hanover S Carlisle, P A 17013 EXHIBIT A Restricted OeIIvef'l Fee "" ~ : Re1urn Receipt Showing 10 T""" 'Whom & Dale Oeivered ~ Rehlm Receipt SOOwilg lOWOOm, c:{ ,Date, & Addressee's AOhss g TOTAL Po..age & Fees $ !Xl M Postmark or Date E :; "-, <f>' a.i LOAN ACCT. NO.: 8089815 ORIGI:-;AL LENDER: , . " APPENDIX A Page 2 of5 CURRENT LENDER/SERVICE: HOMEOW:\"ER'S EMERGENCY MORTGAGE ASSISTANCE PROGRA.'\1 YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSIST~"'CE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSIST A:"iCE; IF YOUR DEI' AUL T HAS BEEN CAUSED BY CIRCUMSTANCES BEYO:'<D YOUR CONTROL, IF YOl' HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU ~IEET OTHER ELEGIBILlTY 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 consumer credit counseling agencies listed at the end of the Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (301 DAYS. IF YOU DO NOT APPLY' FOR EMERGENCY MORTGAGE ASSISTANCE. YOU :vILST BRING YOUR MORTGAGE UP TO DATE, THE PART OF THIS NOTICE CALLED .'HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE, CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and teleohone numbers of desienated consumer credit counseline agencies for the county in which the orooertv is located are set fonh 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 ASISTANCE-Your mortgage is in default for the reasons set fonh 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 :\otice. 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 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 "OR MORTGAGE ASSISTA:"CE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They EXHIBIT A ~... ~ APPDlDIX A Page 3 of 5 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 pursed 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. :-;OTE: IF YOUR ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLO\\I!\G PAIn OF THIS NOTICE IS FOR liWORMATlON PURPOSES ONLY A!\D SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy )'OU can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT !Brin!! it uo to date). NA Tl"RE OF THE DEF AUL T - The MORTGAGE debt held by the above lender on "our property located at: 517 Nonh Hanover S IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and Ihe following amounts are now past due: 2,'/'00 tluough \;):;: 2riiir; totaling $3,~21.J7 Other charges Late Charges $ 0 Deferred late charges $ 285.48 TOTAL AMOUNT PAST DUE 53,221.37 B. YOL: HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not aoolicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL MOUNT PAST DUE TO THE LENDER, WHICH IS $$3,221.37_, 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 oavable and sent to: Litton Loan Servicin!! LP. 5373 West Alabama. Suite 600. Honston. Texas 77056. You can cure any other default by taking the following action within TIIIRTY (30) DAYS of the date of this letter: (Do not use ifnot aoolicable.) 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 rl!!hts to accelerate the mort!!a!!e debt. This 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 EXHIBIT A ~, , ~, ., '. APPE}..TDLX A Page 4 of 5 to instruct its attorneys to start legal action to foreclose upon your mortl!al!ed property. IF THE !\-IORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff 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 fee that were actually incurred, up to $50,00, However, it legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if the exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable cost. If vou cure the default within the TIDRTY (30) DAY Deriod. vou will not be reauired to Dav attornev's fees. OTHER LE"IDER RE:\fEDIES - The lender may also sue you personallv for the unpaid principal balance and all other sums due under the mortgage, RIGHT TO CURE THE DEF AUL T 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 ri"ht to cure the default and mevent the sale at anv time UP to one hour before the Sheriff's Sale, You mav do so bv Davine the total amount then past due. plus anv late or other charees then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writine bv the lender and bv performine 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 DATE - It is estimated that the earliest date that such as Sheriff's Sale of the mortgaged property could be held would be approximately _6 months from the date of this Notice. A notice of the actual d.te of the Sheriffs 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 fwd out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: LITTON LOAN SERVICING Address: 5373 W. ALABAMA, SUITE 600 Phone Number: (713) 960-9676 (713) 966-8906 Fax Number: Contact Person: Keisha Nelson 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 _ mayor _ 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, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. EXHIBIT A ~ 'O. '. .. APPENDIX A Page 5 of5 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 PAY OF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCUR,RED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT 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 (Fill in a list of all Counselinl! Al.'encies listed in ADDendix C. FOR THE COUNTY in which the DroDertv is located. usinl! additional Dal!eS if necessary). CumberlandCountv CCCS of Western Pennsylvania. Inc. 2000 Linl!lestown Road Harrisburl!. PAl 71 02 1717(541-1757 Financial Counselinl! Services of Franklin 31 West 3rd Street Wavnesboro. PA 17268 l717l762-3285 Urban Leal!ue of MetroDolitan Harrisburl! N. 6th Street Harrisburl!. P A 171 01 (71 7)234-5925 F A..X(717)234-9459 YWCA of Carlisle 3001 G Street Carlisle. P A 17013 (71 '7)243-3818 FAX(717)731-9589 EXHIBIT A Pennsylvania Housing FiDanl:e Aaenl:Y Homeowner's Emergency Mortgage Assis~nl:e Program Consumer Credit Counseling Agendes (Rev. 5/99) Lyc:cming-Clint.::ln Counties ' COmIn.lSS1on ~Ot" C . 2138 Linc:cin Sc:-e . ommuzut"j A.::tion (STEP) P. O. Box 1328 .e. "r;:linmspor:. P.\ 17703 (5.0) 326-0587 FA.X (570) 322-2197 ioCCS of "'or~"eastern p", Wi: 1 Basin Street - (5~Oiamsport. PA 17703 I ) 323"';627 FA.X (570) 323-6626 CLINTON COt.J'NTY CCCS of Notthaastern P\ 1631 S .o\thertcn Sc . Suite 100 St:1te College, PA 16801 (814) 238-3668 F.~X(814)238-3669 COLtJ'"'MBIA COtJ",TI CCCS ofNort!leastern Pennsylvania 1400 Allington E."ec-~tive Park Suite 1 Clarks Summitt PA 18411 (570) 587-9163 or (800) 922-9537 FA.1: (570) 587-913419135 31 W. Market St:'eet PO B ll27 W"Ukes-Barre. P.\ 18702 (570) 821-0837 or (800) 922-9537 F.~X (570) 821.1785 Commission on Economics Opportunity of Luzerne CountoJ 163 Amber Lane WUkes-Barre, PA 18702 (570) 826-0510 or (800) 822-0359 F.~X (570) 829-1665--CALL BEFORE FA."illiG (570) 455-4994 H..>,ZELTON F.~1: (570) 455.5631-CALL BEFORE FA."illiG (570) 836-1090 TUNKH.-\i.'<"NOCK Booker T. Washington Center 1720 Holland St:'eec Erie, PA 16503 (814) 453-5744. F.~1: (814) 453-5749 John F. Kennedy Center, Ino. 2021 East 20th Sc=t . Erie, PA 16510 (814) 898-0400 F.~(814) 898-1243 CCCS of Western Pennsylvania, Inc. 2000 Ling!estown Road' Har:'.sburg, PA 17102 (717) 541-1757 Urban League oDletropolitan Harrisburg N. 6th Street Har:'.sburg. PA 17101 (717) 234-5925 F A.1: (717) 234-9459 Co=unit"1 .-\I::on Co= of the Capital Region 1514 Derrv St:'eet Harr'.sbu:i-. P.\ 17104 (717) 232.9757 F.~1:(717) 234-2227 CRAWFORD COL"'TI Greater Erie Co=unitoJ .-\I::on Commit""..... 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Shenango Valley Urban League. Inc 601 IndiaD.a Avenue Farrell. PA 16121 (412) 981.5310 CUMBERI.A..'lD COUNTY Fin.n,.;.l Counseling Set"nces ofF=klin 31 West 3ni Street Waynesboro, PA 17268 (717) 762.3285 YWCA of Carlisle 301 G Street Carlisle, P.... 17013 (717) 243-3818 F.~1: (717) 731-9589 Adams County Housing Authorit"J 139-143 Carl;.,le St Gettysburg, P.'" 17325 (717) 334-1518 FA.1:(7l7) 334-8325 EXHIBIT A PENNSYl.VANIA BULLETIN, VOl. 29, NO. 2:1, JUNE 50 1999 ~.,' ALL that ce.rtam lot of ground with the improvements thereon erecled situate in Carlisie Borough, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at the northeast corner of lot formerly ofF"illmore Mause, on North Hano'y'er Street; then.;e in a northeasterly direction along said North Hanov'::T" Street, 75 f=t 10 inches to lot now or formerly' of Lawrence L. Shenk and Marjorie L.' Shenk, his wife; thence in . southeasterly direction along said last mentioned lot, 150 feet; thence In a nortbensterly dlreetio,' along same, 9 feet; thence in a southeasterly direction along same, 53 feet to a public alley; tIle",e along said alley in a southwesterly direction, 103:feet to lot now or formerly of Mrs_ Mowery; thence in a northwesterly direction along said lot and other lots fronting on McBride Avenue, and said lot now or formerly of FUlmore Maust. 220 feet to North Hanover Street, the place of the BEGtNNING, and known as 517 North Hanover Street,Ca.rlisle. Pennsylvania. BEING the same property which R. Thomas Kiine, Sheri!( in and tor Cumberland County. Pennsylvania..,ll1"anted and.eonvcyecl to Raymond E. Diehl and Genevieve Piehl, his wife, by Sheriff's deed dated May 6, 1998. and recorded on May 13, 1998. in the Office of the R=order of Decds for Cumberland County in Deed Book 177, Pase 145. VERIFICATION LUCY HERRADA hereby states that he/she is FORECLOSURE COORDINATOR of LITTON LOAN SERVICING, L.P. 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 Civil Action in Mortgage Foreclosure are true and correct to the best of his!her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: & /2/ DO ( { - ^",.' ~,,',iQ,"~-' 0 '-"''''''-'''"'~'''^","h'''i';'~'k.''v"".' '*,,, ,-..', ','. '=;", , ,~ " -,,;.,..... ,.; ,'..;;"', -'" ',' ,"'~,~.. ~", T ." '-I ~l .o'\) ~ ~ ~ -. ~ "~"",",.,,, .'n"~'h"," ;t ~ !t1 rt ~ ~ D fI) V 0 C), , I p:>~ $~ - ('") ,,- ?" -UO~ fTln\ Z:T) ~~;;~: ~Cj i> " Z'- ~O PC Z ::<! ,,,' p . "'I c:> o () -n ;: ~,~~ 8 ~~("~ ~'~rl ~ ""~-n ::ili~ ~~"j (J 2m o > ~ S? N <.n , I I ""'""'w" tc '- SHERIFF'S RETURN - REGULAR CASE NO: 2000-03476 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CREDIT BASED ASSET SERVICING VS MEEHAN MALINDA S ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MEEHAN MALINDA S F/K/A RASMUSSEN MALINDA S the DEFENDANT , at 1900:00 HOURS, on the 12th day of June , 2000 at 519 HAMILTON STREET CARLISLE, PA 17013 by handing to MALINDA S. MEEHAN 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 18.00 3.10 .00 10.00 .00 31.10 So Answers:r~~ R. Thomas Kline 06/13/2000 FEDERMAN AND PHELAN Sworn and Subscribed to before By, ~~ / Duty S ri f me this .2/.....r day of ~.zn.,.; A.D. ~ t2 n"dR,. ,~. thonotary "'"""- ,- r. 1- CASE NO: 2000-03476 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CREDIT BASED ASSET SERVICING VS MEEHAN MALINDA S ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MEEHAN CHARLES the DEFENDANT , at 1900:00 HOURS, on the 12th day of June 2000 at 519 HAMILTON STREET CARLISLE, PA 17013 by handing to MALINDA S. MEEHAN, ADULT IN CHARGE 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 6.00 .00 .00 10.00 .00 16.00 So Answer~~~ R. Thomas Kline 06/13/2000 FEDERMAN AND PHELAN Sworn and subscribed to before By: me this ~/~ day of ~ ~ A.D. ~o.~~ rothonotary , .. " FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC 5373 WEST ALABAMA, SUITE 600 HOUSTON, TX 77056 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. : NO. 00-3476 MALINDA S. MEEHAN F/KIA MALINDA S. RASMUSSEN CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, P A 17013 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 MALINDA S. MEEHAN F/KJA MALINDA S. RASMUSSEN and CHARLES MEEHAN, 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 5/1100 TO 7/18/00 $94,232.25 $1.788.56 TOTAL $96,020.81 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. ~l~ F K FEDE AN, ESQUIRE Attorney for Plaintiff DAMAGES ARE IIEREIlY ASSESSED AS INDICATED. ~ DATE:... L 1\/ ..JI"~ .JOOO ']/{1AL Jk ( , PRO PRO **THIS FIRM IS A DEBT COLLECTOR ATIEMPTING 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 ATIEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ~ ,<, 12.0" 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 CRDIT BASED ASSET SERVICING AND SECURITIZATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY MALINDA MALINDA CHARLES S. MEEHAN,A/K/A S. RASMUSSEN MEEHAN NO. 00-3476-CIVIL Defendant TO: CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, PA 17013 DATE OF NOTICE: JULY 5. 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 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,PA 17013 (717)249-3166 Frank Federman, Esquire Attorney for Plaintiff 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 CRDIT BASED ASSET SERVICING AND SECURITIZATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY MALINDA S. MEEHAN,A/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN NO. 00-3476-CIVIL Defendant(s) TO: MALINDA S. MEEHAN,A/K/A MALINDA S. RASMUSSEN 519 HAMILTON STREET CARLISLE, PA 17013 DATE OF NOTICE: JULY 5. 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 ~, ,~l" FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 00-3476 MALINDA S. MEEHAN FIKIA MALINDA S. RASMUSSEN CHARLES MEEHAN 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, 01 otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant MALINDA S. MEEHAN FIKIA MALINDA S. RASMUSSEN is over 18 years of age and resides at 519 HAMIL TON STREET, CARLISLE, P A 17013. (c) that defendant CHARLES MEEHAN is over 18 years of age, and resides at 519 HAMILTON STREET, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 3~ :Prt~ FRANK FEDERMAN Attorney for Plaintiff (Rule of Civil Procedure No. 236 - Revised) CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. ; NO. 00-3476 MALINDA S. MEEHAN F/KJA MALINDA S. RASMUSSEN CHARLES MEEHAN Defendant(s) Notice i~iven that a Judgment in the above captioned matter has been entered against you on JULY 0 ,2000. . '-By ~D.P ~~nmpUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Filing Party SUITE 900 TWQ PENN CENTER PLAZA PHILADELPHIA, PA 19102 (215) 563-7000 **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, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ';~ ,~ 'lliliIiii.lllqn ,".L'. !II! 'w.. , ".";"iJ~~ 'lliu~' if \,., ~ ~~, "'" """'ilillaiijjj ,; , ~,,, - I HHlI!l L~_ " t~~ ~ ~~.,{) 8 ~ ~ ~ ~ k0 tJ ~ '<'-,,,~~.',:,,, "~',,~~,'~' '''.,' ""'",, ..~~ <~,,"~-. ........ ..",,~ ~, , -. ~-"IIl" (") c: -0 ~~~ ~f;~~ :22:: 1<c5 2?(~ z- "",0 ...-c ;7 -=j -, - "'''"i C":,! CJ t..~ 1"'>.:) C' , ,--i , ~.-' r"-, V 1 ~(l n :t' ,-< ~~: ...... ~? t.,) L.J '1 "",.-' -, '"~ !\..~i ,. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC Plaintiff, CUMBERLAND COUNTY v. No. 00-3476 CIVIL TERM MALINDA S. MEEHAN FfK/A MALINDA S. RASMUSSEN CHARLES MEEHAN Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $96.020.81 1/ Interest from 7/L8/00 - 12/6/00 $2.224.98 and Costs (per diem - $15.78) $98.245.79 TOTAL . ~~ F KF D ., ESQUIRE TW PENN CENTER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney fOI Plaintiff Note: Please attach descliption of property.No. ~' '"'" '"'~ . iJlj,n~r'J!Jjillij iIdIl~lii.i;;1i..."m"h)@g"w..,A}..**<J!',~...~jliiLiBtUI - (" ~ ," . ~ "' ,,~oo. "ill ~~"~. i; I ['; ~ I I' (I ii Z roo< 00. 00. i 00. ~ rJ.i < Z ~ roo< ... 00. ~ 00. r..;$ ~ ... r-l o~ ~ 00. Z ~ ~ ~ ~ 0 00.> ... ... ~s: ~ ... 00. Z rJ.i ~ Z ~ ...:loo. < U .,; ~z "'u ~'E' ~~~~ <l) Zz U...:l ~~ i:: ......:l roo<'O~ Q o roo< ~ ~ ~= roo< = <l) '" ~roo<~~ '" ~~ ~~ r.. 0 <l) ~ roo<Z O~ on O!: 00.0 " rJ.i~=~ ~ 0 ...'" ~ ... .. 0 roo<'" .; ~~ S 0 UZ @~ <00. roo< N r..~ oo.~ ... ~roo<tit;3 '" Ef .... 00 00.... ~~O'" <l) ...u <... r..; ~~ g. <l) ~~ ~~ 01:: p. E-< ~~ ~u~~ ~~ :~ ! oo.u 8; <roo<' roo<U ~ !Xl 00.' ~ ... U '" ;Jroo< ... '" ... ~ -i::J ~ ...!Xl ~ rJ.i <l) ~~ ~ < - .~ < ~ ~ ~ u u ~ ~ ",.". ,~,'~~,.~ ~~, ~ , ~ ,~" " ",~ ",.,~ !~ i ,. DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected Situate in Carlisle Borough, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at the Northeast comer of lot formerly of Fillmore Mause, on North Hanover Street: thence in a Northeasterly direction along said North Hanover Street. 75 feet 10 inches to lot now or formerly of Lawrence L. Shenk and Marjorie L. Shenk, his wife; thence in a Southeasterly direction along said last mentioned lot, 150 feet; thence in a Northeasterly direction along same, 9 feet; thence in a Southeasterly direction along same, 53 feet to a public alley; thence along said alley in a Southwesterly direction, 103 feet to lot now or formerly of MIS, Mowery; thence in a Northwesterly direction along said lot and other lots froming on McBride Avenue, and said lot now or formerly of Fillmore Maust, 220 feet to North Hanover Street, the place of the beginning, and known as 517 North Hanover Street, Carlisle, Pennsylvania', T;L,( Parcel # 02-20-1800-075 TITLE TO SAID PREMISES IS VESTED IN Malinda S, Meehan, formerly Malinda S, Rasmussen, married woman bv Deed from Ravmond E, Diehl and Genevieve A, Diehl husband .. , and wife dated 6/30/98, recorded 7/17/98. in Deed Book 181, Page 706, , ,J~~ "".' "AJ.Il1....~ - ~". '~f..;, , 'Iiii ,- j" '0".... ,,"'.. ,~" '-' -, "',~, ,.' ~, .~ .~ -~ ~~"'=illlI~"!'.J." . t',::i \ li,i 1,1 I, :::~ C'::> Vl .~ ~ ~ C) C~ -- C~ CJ ~ ~ ~ >'" ji~ :/:J --...\ "fu P --0 ,.C ,i;'" w (ti ('q -J <.J\ - --',:] ~ 1_' -,1 W c V) 8 - ~ ;;, V\ 0 't.' .....;:"'';'-- .~~...; ~ 0 IH, e , C=(~'= 0 ~~J ~. 0- \ ' , I ~2~~ ~~;1 Cl L -:: p- s: .,,}' ;r."'c= I~~I' -'. .'!t' ;.c- " - ,;: :,;! ~ ~ c ~ --j ::.n ""y-->- -<- ,j;:- :':0 -< ". Q > '" , - ~, ~~ ~~ l ._" ^i , . · CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION MALINDA S. MEEHAN FfK/A MALINDA S. RASMUSSEN CHARLES MEEHAN NO. 00-3476 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CREDIT BASED ASSET SERVICING AND SECUlUTIZATION. LLC, 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 517 NORTH HANOVER STREET. CARLISLE. PA 17013. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) MALINDA S. MEEHAN F/KIA MALINDA S. RASMUSSEN 519 NORTH HANOVER STREET CARLISLE, PA 17013 CHARLES MEEHAN 519 NORTH HANOVER STREET CARLISLE, PA 17013 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.) Pennsylvania Power and Light Company 827 Hausman Road Allentown, PA 18104 Cline's Plumbing and Heating 2103 Newville Road Carlisle, PA 17013-8957 , f"'--- ~ .. -,,- " .. 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.) Raymond E. Diehl and Genevieve A. Diehl 401 Myers Road Carlisle, P A 17013-9234 And 315 Myers Road Carlisle, PA 17013-9234 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 517 NORTH HANOVER STREET CARLISLE, PA 17013 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. C.S. Sec. 4904 relating to unsworn falsification to authorities. September I. 2000 DATE ~~~~~~RE / Attorney for Plaintiff .l ',-' "~. ~. -~ 1l111Ui!! wlietillt 0 -c.~, '~W._~i~~'li:fm~ei'i,&q:",,,,,,},~bi'l~.m.t~iliJ)j :.<; . .~. """'~'. ~ '-' . ,"V 'U'~,~ ""~' ",' =~ >~ Iii~ ~'''''l!ii:IIi~;'"'~''. -...... i'-'JIi.~_"- (") S UI::;', 9Jif :::;;.,^, ~.I'- ~:~~,' ~C=I 1"", ~~G: "'C,.C" -- c= ::::: _.~ -~ , ,ie' ~ , - C:) U) P1 "U C_"':, "T) .-2 :n ',-, ., =,} -< <- - " "'~, FEDE~andPHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN NO. 00-3476 CIVIL TERM 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. .Ji lii" """"iv~l:l~i!ll~m~~;;~~.M~'Jlli~:J;i'.Jl;IiH."",;",.J,~...,.",,,,,,,,,,.!,",~,~'~l~" r -....~_."'iH'~,~~~~il!i~ilti!I~~ll!~i"liiii'" C) S.; -or; Dl{f, 7'1- z(" U),-:' -<. r., ::<: -' ~~~ z .< . "l~ '" I I " I' I " ~ 'I i I , 1 C) C) (/) r:f '-':1 "-'~ .....1 {-'I ."'c.} ()l .~- " - ,'~~ J'-;,_ -- ,I CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC Plaintiff, CUMBERLAND COUNTY No. 00-3476 CIVIL TERM v. MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN Defendant(s). September 1,2000 TO: MALINDA S. MEEHAN, F/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN 519 NORTH HANOVER STREET CARLISLE, P A 17013 "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 517 NORTH HANOVER STREET. CARLISLE. PA 17013, 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, Carlis1e,PA 17013, to enforce the court judgment obtained by CREDIT BASED ASSET SERVICING AND SECURITIZATION. LLC (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 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. .d i.;:~~, -~ _ ~._. J ' "~.~<~" ~ ""~" "_. -=' " , " .~ ~ "~f;-; You may need an attorney to assert yoU! 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, yoU! 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 YOU! property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call (717) 240-6390. 4. If the anlount 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 yoU! house. A schedule of distribution of the money bid for yoU! house will be filed by the Sheriff within 30 days ofthe 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 yoU! 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 ".l/. DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected Simate in Carlisle Borough. Cumberland County. Pennsylvania, bounded and described as follows: BEGINNING at the Northeast corner of lot formerly of Fillmore Mause, on North Hanover Street; thence in a Northeasterly direction along said North Hanover Street, 75 feet 10 inches to lot now or formerly of Lawrence L. Shenk and Marjorie L. Shenk, his wife; thence in a Southeasterly direction along said last mentioned lor, 150 feet; thence in a Northeasterly direction along same, 9 feet; thence in a Southeasterly direction along same, 53 feet to a public alley; thence along said alley in a Southwesterly direction, 103 feet to lot now or formerly of Mrs, Mowery: thence in a 0iorthwesterly direction along said lor and other lots fronting on McBride Avenue, and said lot now or formerly of Fillmore Maust, 2:20 feet to North Hanover Street, the place of the beginning, and known as 517 North Hanover Street, Carlisle, Pennsvlvania, T:L'{ Parcel # 02-20-1800-075 TITLE TO SAID PREMISES IS VESTED IN Malinda S, Meehan. formerly Malinda S, Rasmussen, married woman by Deed from Raymond E, Diehl and Genevieve A. Diehl, husband and wife dated 6/30/98, recorded 7/17/98, in Deed Book 181, Page 706, .' ~1IiMi~!!IljIl!i~~"~1&Ji~~lll.<lJ1~~4i1lIiJllgilli"'"'''' .h..lli''lIwIIiIlIiil&tl:iiii-"~..,."~ ,~"'..~'" 'h'-""'-' ~ '1iiI ~~-, o ~ lJr:~ ~S~! (7:1.)2 ~i~~,~ ~f~ ...:::::- :2 (-~ (:-3 :.0 PI -'0 C) "J; __,j .,....! :~? :Jl '''.'0...... t 4 Credit Based Asset Servicing and Securitization,LLC -vs- Melinda S. Meehan F!K/ A Malinda S Rasmussen and Charles Meehan , '. "oiiii".,,;,,", In The Court of Co=on Pleas of Cumberland County, Pennsylvania No. 2000-3476 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 Sworn and subscribed to before me 30.00 12.86 15.00 15.00 .50 1.00 6.20 .69 15.00 20.00 30.00 270.05 216.60 23.15 $ 656.05 by arty 12/07/00 ~~~; R. Thomas Kline, Sheriff This dIM- day of At",.. I... ) 2000,A.D. ~a.~/~\ P 0 onotary BY~u JLtr Real Estate Deputy /.,-u Cle- 3D 7'<-'/ lilv.J bS-'I jJ " " " i CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC CUMBERLAND COUNTY . . Plaintiff, , COURT OF COMMON PLEAS v. CIVIL DMSION MALINDA S. MEEHAN FIK/A MALINDA S. RASMUSSEN CHARLES MEEHAN NO. 00-3476 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CREDIT BASED ASSET SERVICING AND SECURITIZATION. LLC, 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 ill NORTH HANOVER STREET. CARLISLE. P A 17013. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) MALINDA S. MEEHAN FIKJA MALINDA S. RASMUSSEN 519 NORTH HANOVER STREET CARLISLE, P A 17013 CHARLES MEEHAN 519 NORTH HANOVER STREET CARLISLE, P A 17013 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.) Pennsylvania Power and Light Company 827 Hausman Road Allentown, PA 18104 Cline's Plumbing and Heating 2103 Newville Road Carlisle, P A 17013-8957 -'~-':" ''C<,,- " ,..i.f&,~;;c , """.~ ~.'~~~ I , -~, " " 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.) Raymond E. Diehl and Genevieve A. Diehl 401 Myers Road Carlisle, P A 17013-9234 And 315 Myers Road Carlisle, PA 17013-9234 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 517 NORTH HANOVER STREET CARLISLE, P A 17013 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. C.S. Sec. 4904 relating to unsworn falsification to authorities. Sentember 1. 2000 DATE ~~.~ F F r:~~, ESQUIRE ~ Attorney for Plaintiff ....""~.~, " ~ I ,I ~ . , ~_: '. '-, w. , CREDrJ:-.BASED ASSET SERVICING ANDSECUlUTIZATION,LLC Plaintiff, CUMBERLAND COUNTY No. 00-3476 CIVIL TERM v. MALINDA S. MEEHAN FfKlA MALINDA S. RASMUSSEN CHARLES MEEHAN Defendant{s). September 1, 2000 TO: MALINDA S. MEEHAN, FIKJA MALINDA S. RASMUSSEN CHARLES MEEHAN 519 NORTH HANOVER STREET CARLISLE, PA 17013 "',':eT.' "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR lliA T PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, TIllS IS NOT AND SHOULD NOT BE CONSTRUED j,)y<;; TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." , ':'!;W~~~ Your house (real estate) at 517 NORTH HANOVER STREET. CARLISLE. PA 17013, is scheduled to be sold at the Sheriff's 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 CREDIT BASED ASSET SERVICING AND SECURITIZATION. LLC (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the March 7, 2001 Sheriff's Sale. "'~i;;",,n '~",:,:; ,"",'d,~ NOTICE OF OWNER'S RIGHTS YOU MAY BE 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 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. ,"' :'>H',Y. .j.'}{i?;,~'j;f1'@;if. ~ ~ "~ ~ w'~ _." ~. I ,I '~" ~ , - J;ln~, 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\.":" 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 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. C''',,'M 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. " i,',;';.~ill'~';!;'f~~:.: 6. You may be entitled to a share of the money which was paid for your house. A schedule9(~'" ,? distribution of the money bid for your house will be filed by the Sheriff within 30 days of the s~f~,: " schedule will state who will be receiving that money. The money will be paid out in accordancewi!h. 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 "~"_".___'.;.._'::'LLi.'~;;-$.~,!.~"(-'f.~,'~~~~~:~ . " . " "'- '~ . ' - .. DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected Situate in Carlisle Borough, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at the Northeast corner of lot formerly of Fillmore Mause, on North Hanover Street: thence in a Northeasterly direction along said North Hanover Street, 75 feet 10 inches to lot now or formerly of Lawrence L. Shenk and Marjorie L. Shenk, his wife; thence in a Southeasterly direction along said last mentioned lot, 150 feet; thence in a Northeasterly direction along same, 9 feet; thence in a Southeasterly direction along same, 53 feet to a public alley; thence along said alley in a Southwesterly direction. 103 feet to lot now or formerly of Mrs. Mowery; thence in a Northwesterly direction along said lot and other lots fronting on McBride A venue, and said lot now or formerly of Fillmore Maust, 220 feet to North Hanover Street, the place of the beginning, and known as 517 North Hanover Street, Carlisle, Pennsylvania, Tax Parcel # 02-20-1800-075 TITLE TO SAID PREMISES IS VESTED IN Malinda S, Meehan, formerly Malinda S, Rasmussen, married woman by Deed from Raymond E. Diehl and Genevieve A, Diehl. husband and wife dated 6/30/98, recorded 7/17/98, in Deed Book 181, Page 706, '.._' lhO ~'<' ". WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND} TO THE SHERIFF OF OUMBERLAND NO. 00-3476 CIVIL _ CIVIL ACTION - LAW COUNTY: To satisfy the debt, interest and costs due CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC from MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN AND CHARLES MEEHAN PLAINTIFF(S} DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell SEE ATIACHED lEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of , >;' ;', l ,! _ ,,' ,~ :.; , ':" ,. , ..,...." I""' " .'" ,'~' "~-'"." "",-.- ,,,,...--,, GARNISHEE(S) as follows: and to notffy ttie-gaiilishee(Snf1'af:\(a)aR~ttachriWl'ntlias 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; Iq)!H ';. i't.,[;n:' (3) If property of the defendant(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,mliTi.t!lilrthat he/she has been added as a garnishelilcllnd is enjoined as above stated. Amount Due $96,020. 81 \~, L.L. $ . 50 Due ~"\,,,''\~'''~',,l..~':,~:.'_,..>,,...:.,,,~,,,,";.:,_':; ~::; " :. ' "" 'I. ,,!,,' Interest am a:stB $2,224 :'?$.:f~7j~8/0:0"712/6J~OP Due Prothy $1.00 (Per lJbe, $l:>./!:l) , . . Atty's Comm % Other Costs Atty Paid Plaintiff Paid $119.10 Date: September 7, 2000 CURTIS R. LONG ~. --&UA~~i:&,~ Deputy REQUESTING PARTY: Name Frank F~derman Esq. Address: TWO PENN CENTER PLAZA SUITE 900 Philadelphia PA 19102 Attorney for: Plaintiff Telephone: 215 - 56 3 -7000 Supreme Court ID No. 12248 ~',"~,~o. "lta&~""",~~~"..1flj;;~'",M"''''=~,d;'''''''2''^'''''''~';;''~''.i,;.<l''''~~1'''~''''bp,l'''''''''b''<A;.~!Il@~iBi!l~~.illlif;Il1ii1ii~I;I.I'Il'''!ljjjlil'~iiHfO,J'~~~iIIililIIliiIIliiIli~~ REAL ESTATE SJ.\LE NO.?-1 -,:,~,,~ the sheriff levied upon the d8fendam~ interest in the real property situated in o..~ /L fJ. a -" ~-~1.. Cumberland County, Pa., known and numbered as: SJ1 IJ ~lL.~ ~aAQ. and more fully :1escribed on Exhibit "A" flied with this writ and by this reference incorporated herein. 'MOJ.,d;..#.. 'l..:m.> ~i~ , "I! - I , _ c ~j d3S AJ.i-:l: ' , ;-l~) .:l:lHJ;t:, ,:un ~JT[[1 TWiti' "k, <,N' f'.' . .- e r:;;:a r:;;:a t::::::lI ~ CiVil , ..J_J --- , '~;) .-:.'..., -,: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC Plaintiff CIVIL DIVISION vs. No. 00-3476 CIVIL MALINDA S. MEEHAN, F/KJA MALINDA S. RASMUSSEN CHARLES MEEHAN Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for CREDIT BASED ASSET SERVICING AND SECURITIZATION. LLC, hereby verify that on SEPTEMBER 5.2000, true and correct copies of the Notice of Sheriff's 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 SEPTEMBER 5, 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. 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RASMUSSEN 519 NORTH HANOVER STREET CARLISLE, PA 17013 ~ SENDER: REFERENCE: DMK SALES PS FORM 3800 SEPTEMBER 1995 """" RETURN RECEIPT SERVICE CertlfiedFee RetumRecelptF&ll """""""""- TotatPostageefldFees US Postal Service PO Receipt for Certified Mail No Insurance Coverage Provided Do not use for International Mail - - _.----"- '-"",- ---- .P "l6"l D55 362 . CHARLES MEEHAN 519 NORTH HANOVER STREET CARLISLE, PA 17013 TO: SENDER: REFERENCE: DMK SALES PS FORM 3800 SEPTEMBER 1995 ""... RETURN RECEIPT SERVICE CertlfledFee AetumAeceiptFee RestrlctedDelivery Total Poslage and Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do not use for International Mail \ -1l000--. o'()ll-- ....-.--2.1S-- iIil~W;~~Iilll'fulH2m.\i>l~,"","""l<-~~~llI."'''~-. '^'-> ,. ,-,. ~~ ,-, .. .. - . () <::> 0 c <:::> " <'" Z -~ ...,,! ;:gm C> -Y._,. r"'-- < '~1 i}d Z:j] ZI- t ":11,1 wJ:; 0", ~~ -<,~.. ~C; -U ~r' ::J;: --0 )>0 S>? ::~rn u C ;-1 ~ N :n .-< .-1 -< " 1-". ' . , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC Plaintiff, v. No.OO-3476-CIVIL MALINDA S. MEEHAN, FfK/A MELINDA S. RASMUSSEN CHARLES MEEHAN Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $96,020.81 Interest from 7/19/00 to 12/4/02 (per diem -$15.78) $13,712.82 and Costs TOTAL $109,733.63 111 (iMJ .1-2) O/ll/llAiyh FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. __.' ~~I~r,i!ii!>iI"*,~~,"","fu.d'~""~lh1.~4",~~iDIIliillIll!"~~'~""'~"'d'~'~- .""," ...~~ ~ ~ ... ':<1: t"'l t"'l... 1:1 i >r:I ":l > ~ cj':<1: ~. ~ ;..., - r" <1> 1:1 ?- ~ ... l'"J= tn t"'l ..., ~~ ~ ~ ... l'"J 00= ":l l'"J l'"J> ~ Ul il'"J t"'l= t"'loo ~g .... Q "':I =~ cjl'"J (Il \0 ::1.0 el:l 1:Ii:l '1:l = ~; {j ~ a:::c ...,> t"'lo ~ ~~ l'"J..... "'00 g"':l tn oo~ < ~oo s t= "':Ie ~ ...,l'"J ':<1:t"'l ~ ..., ::; ..., ~~ ......, ""0 0 ~ 0 000 ~>< ~ r: l'"Jl'"J ':<1:l'"J (Il ':<1: 0"':1 =t"" ~ ::c ":l~ tn 00 ~ l'"J ~~ t"";:$ l'"Jo ~ ..., .. ~ ':<1:':<1: ~ ~ t""t"'l ':<1:":l (Il t"'l... p.. t"'l > ':<1: 00t"" l'"J cj r" ~ ><l"'l ~..., ~ ..., ~ ~ t""> t"'l ;S ... ~~ 0 ~ ':<1: 00 1:1 a >"':1 ... 00 00 t"" 00 !"l l"'l ":l ':<1: > .... -.J Q .... ... ~i:, . / . \ DESCRIPTION ALL TH.'\ T CERT.'\IN 10{ of ground with the lrnprovements thereon c::rected Siruate in Carlisle Borough. Cumberland Coumy. Pennsytv~mia. bounded and described as follows: BEGINNI.'iG at the .'ionheast corner of lot formerly of Fillmore 'vfause. on North Hanover Streer: thence in a Northeasterly direction along said Nonh Hanover Street. 75 feet 10 inches to 10{ now or formerly of LawrenCe L. Shenk and Marjorie L. Shenk. his wife: thence in a Suutheasterly Jire'~tion alung said last mentioned 1m. 150 reet: thence in a Northeasterly direction along same. 9 reet: thence in a Southeasterly direction along same. 53 feet to a public alley: thence along said alley in a Southwesterly direction, 103 feet to lot now or formerly of Mrs. Mowery: thence in a Nonhwesterly direction along said lot and other Ims fronting on .\ofcBride .'\venue. and said lot [lOW or formerly of Fillmore Maust, 220 feet to North Hanover Street. the place of the beginning, and ~'1own as 517 North Hanover Street, Carlisle, Pennsylvania. T<lX Parcel II 02-20-1800-0;5 TITLE TO SAID PRE'vfISES IS VESTED IN Malinda S. Meehan. formerly 'vblinda S Rasmussen. married woman bv Deed from Ravmond E. Diehl and Genevieve.'\ Diehl. husband . ~ ~ . and wire dated 6/30/98, recorded 711;/98. in Deed Book 181. Page 706. PREMISES BEING KNOWN AS 517 NORTH HANOVER STREET, CARLISLE, PA 17103 ~-"";<W'io:l,";l<""l'H._~'" ,I ~~._;,'" !IlilIlil~w -- E: ~. +- ~ Q0 t Q , l ~ l --- "T-l ~ 'if[ - ti ?0 ~ ~ ~ ~=<~ -tq ;-.. 8 ~ ~ --~ iliilMlIl$Ili"''f-' "~-h'~'t,..,\l.\l;!~ -'-- -. ~ "0 :') 0- r" l 6' w~ 'C;) ...Q ~ ~ ~ ~ .Cr) . 0,",080,8 8coCl} j I / (::) ft! c ~~~~:1i ... , , YI ,- - - ~. ~1liiI Cf () r....:. C :po s:. c:: -cr.' mrlI ,~ :z:~' N ~,~ -' 2;:; ~Q J>~ ~ "'- ..0 / -0 :J: r:-? w ()"\ ~~ ...; "_r -r: -';ir ::gO C'b :r:=H 06 c5f'1"t ~ '< m FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BLVD., SUITE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION MALINDA S. MEEHAN, FfK/A MELINDA S. RASMUSSEN CHARLES MEEHAN NO. 00-3476-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 unswom falsification to authorities. '1n CUM bt ~fVL/J1.tt~'1,", FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff "....~~ -1iOI1~iII.lIo1IlII,il~,:>Mil!/i.1;lWi~;""",,,,,,,,,"'W~""'L''',.~4,;"*,,,~f,<jjj'{lit~_i5lli~ I ~, ="',IjIX ._, "~ ~.-, -. >, , --.J"'_iIIliiiIIlIIiIImliNiilllliU 1 (') 0 0 c: f'<.;) ~ -n ~g l>o ..~ c:: .. <:i? r::iiJd ZS' N J2Z 0) " _I () ~<<, .......C) v 5:1,.. ~ :1:' ~~ :ii .--8 "'?4 >c ~ cj' 2: -< :,., ~. =< 5;, {Jl ...: . - I j ~ .- Docket for Case:_" + GetCaseNoO + " (" + DktTypeExpand(m.gsDktType) + ") Page 1 of 1 Bankruptcy Docket Report 1 02-03023 (Harrisburg) RASMUSSEN, MALINDA S Docket items entered between 01/01/1931 and 08/23/2002 Filing No. Docket Entry View Date document 06/04/02 I VOLUNTARY PETITION under Chapter 13 & Mailing Matrix [EOD 06/05/02] Doc #1 PDF (2 [DD] MWl. 06/05/02 2 NOTICE of intent to dismiss case unless missing documents are fried: due by None 06/20/02 Re: Item # 1. [EOD 06/05/02] [DD] 06/26/02 3 CORRESPONDENCE to Attorney allowing untill July 5, 2002 to file missing None documents. Re: Item # 2. [EOD 06/26/02] [CA] 07/31102 4 ORDER dismissing case for debtor's failure to FILE THE NECESSARY None SCHEDULES, STATEMENTS AND CHAPTER 13 PLAN/PLAN SUMMARY. [EOD 07/31/02] [CR] 08/05/02 5 NOTICE to creditors of dismissal of case [EOD 08/05/02] [AUT] Doc #5 PDF (2 MWl. 08/05/02 6 FINAL REPORT ofCh. 13 Trustee [EOD 08/05/02] [CR] None Pnnted: 08/23/02 12:02:25 ,-, ~- I PACER Service Center I I Transaction Receipt I I 08/23/2002 12:02:25 I Ip ACER Login: IIfp0039 IIClient Code: I IDescription: IIDocket IICase Number: III 2002-03023 I IBilIable Pages: III IICost: 110.07 I ""........n_.........".____",. " "....., ~Need help? Try the PACER User's Guide EPacer Service Center .../nPacer?ExecThis=docket&puid=O 1 030 118487 &case _no=2002-03023&office= 1 &DktType=8/23/2002 , L CREDIT BASED ASSET SERVICING AND \ SECURITIZATION, LLC CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION MALINDA S. MEEHAN, FfK/A MELINDA S. RASMUSSEN CHARLES MEEHAN NO.OO-3476-CIVIL Defendant( s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CREDIT BASED ASSET SERVICING AND SECURITIZATION. LLC, 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 conceming the real property located at .517 NORTH HANOVER STREET. CARLISLE. P A 17013 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MALINDA S. MEEHAN, F/K/A MELINDA S. RASMUSSEN 519 HAMILTON STREET CARLISLE, P A 17013 CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, P A 17013 2. Name and address of Defendant(s) in the judgment: Same as above 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) 827 HAUSMAN ROAD PENNSYL VANIA POWER & LIGHT CO. ALLENTOWN, PA 18104 CLINE'S PLUMBING & HEATING 2103 NEWVILLE ROAD CARLISLE, P A 17013 l^ 4. Name and address oflast recorded holder of every mortgage of record: . Name Last Known Address (if address cannot be reasonably ascertained, please indicate) RAYMOND E. DIEHL AND GENEVIEVE A. DIEHL 401 MYERS ROAD CARLISLE, P A 17013 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 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 indicate) None 7. Name and address of every other person of 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 indicate) Tenant/Occupant 517 NORTH HANOVER STREET CARLISLE, P A 17013 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 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 23. 2002 DATE 11/..../J /1"1)- 1& &t/) /JlU~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,;""" -."..-." ~"~i!l:jlifltiliS~-l""''''!llIai_~~(;;~...;;~~"",.,LI~~::iillbli1il:i_llli!.iiIlIiia "~ -liIITIIliIIIIIlliiiliillllilll . () C:l 0 ,,.- N -n :g: :co :c:::l .,,~ c:: \''M :!J ~:::d <n . , 6jr N "'l:Jm ~~ -J ~J;]O ,--, :S ~t.. <::::'1...-' -0 .-<,". ~O ~ O::!J -0 .".0 ;l>C f.'i' Om :z C,,s.,) ~ =< (}1 -< . .~ -" CREDIT BASED ASSET SERVICING AND ) SECURITIZATION, LLC Plaintiff, CUMBERLAND COUNTY No. 00-3476-CIVIL v. MALINDA S. MEEHAN, FfK/A MELINDA S. RASMUSSEN CHARLES MEEHAN Defendant(s). August 23, 2002 TO: MALINDA S. MEEHAN, F/K/A MELINDA S. RASMUSSEN CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, PA 17013 * *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 . 517 NORTH HANOVER STREET. CARLISLE. P A 17013. is scheduled to be sold at the Sheriff's Sale on 12/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $96.020.81 obtained by CREDIT BASED ASSET SERVICING AND SECURITIZATION. LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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. 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.) ~~ . , q.- . 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 bidby 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 ~ J.-.~", 1<\4, " DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected Situate in Carlisle Borough, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at the Northeast corner of lot formerly of Fillmore Mause, on North Hanover Street: thence in a Northeasterly direction along said North Hanover Street, 75 feet 10 inches to lot now or formerly of Lawrence L. Shenk: and Marjorie L. Shenk:, his wife; thence in a Southeasterly direction along said last mentioned lot, 150 feet; thence in a Northeasterly direction along same, 9 feet; thence in a Southeasterly direction along same, 53 feet to a public alley; thence along said aHey in a Southwesterly direction, 103 feet to lot now or formerly of Mrs. Mowery; thence in a Northwesterly direction along said lot and other lots fronting on McBride Avenue, and said lot now or formerly of Fillmote Maust, 220 feet to North Hanover Street, the place of the beginning, and known as 517 North Hanover Street, Carlisle, Pennsylvania. Tax Parcel # 02-20-1800-075 TITLE TO SAID PREMISES IS VESTED IN Malinda S. Meehan, formerly Malinda S. Rasmussen, married woman bv Deed from Ravmond E. Diehl and Genevieve A. Diehl husband ,. ' and wife dated 6/30/98, recorded 7/17/98, in Deed Book 181, Page 706. PREMISES BEING KNOWN AS 517 NORTH HANOVER STREET, CARLISLE, PA 17103 ......... ~ ~-''-_~",~"",w''''''''~la.;_b"",,,...lHI,j,,.,'<Jil!.W,,",".',,'h''';;:,~!:ih,illm.;;j;,,}.ICkcl-~~~OO~--~"~~~"""'" ..,. .." .".~ _ ,"~ ,~. ~_"~"Y~_R"~,,, <~ . -~~~~~~Ii -_.~'" ~'^ - "_c"__ ~-"'~1iIiIlHIilItiii . > (') <:::> 0 C r" ..., g: E= :~ -tJt.lJ 1;29) '.- .: -,-n (,"') 'Tl, ;Z. N 3!(9 cn'J'~ _I "'\ 1. ~6 --==.tL) -0 ;~:B ~(~ ::x --~,C5 ~(): r:~ ,~m )>c ,-' Z 0-1 ::;! 7..0 :ii Ul '< ~. .--~-- ,- , "- ~_.~. ~- I,~ ,,_ .',__ WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLV ANTA) COUNTY OF CUMBERLAND) NO 00-3476 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC., Plaintiff (s) From MALINDA S. MEEHAN, F/K/A MELINDA S. RASMUSSEN, CHARLES MEEHAN, 519 HAMILTON STREET, CARLISLE, PA 17013 (I) 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 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) Ifproperty of the defendant(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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $96,020.81 L.L. Interest FROM 7/19/00 TO 12/4/02 (PER DIEM - $15.78) - $13,712.82 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $787.65 Other Costs Plaintiff Paid Date: AUGUST 27, 2002 (Seal) . CURTIS R. LONG Prothonotary p ~ r <J:!y. aO/yl g / l12/?...()6.-./ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 .'~~~ - " - ~a "oj "'"'&%" , CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION MALINDA S. MEEHAN, FIKIA MELINDA S. RASMUSSEN CHARLES M~EHAN NO.OO-3476-CIVIL Defendant(s). AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC, Plaintiffin 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 ,517 NORTH HANOVER STREET, CARLISLE, PA 17013. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MALINDA S. MEEHAN, F/KIA MELINDA S. RASMUSSEN 519 HAMILTON STREET CARLISLE, P A 17013 CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, P A 17013 2. Name and address ofDefendant(s) in the judgment: Same as above 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) 827 HAUSMAN ROAD PENNSYLVANIA POWER & LIGHT CO. ALLENTOWN, PA 18104 CLINE'S PLUMBING & HEATING 2103 NEWVILLE ROAD CARLISLE, P A 17013 - '" ~',' "." , , j', , 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) RAYMOND E. DIEHL AND GENEVIEVE A. DIEHL 401 MYERS ROAD CARLISLE, P A 17013 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 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 indicate) BOROUGH OF CARLISLE 53 WEST SOUTH STREET CARLISLE, PA 17013 7. Name and address of every other person of 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 indicate) Tenant/Occnpant 517 NORTH HANOVER STREET CARLISLE, P A 17013 Domestic Relations of Cnmberland Connty 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisbnrg, PA 17105 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 unswom falsification to authorities. November 4. 2002 :r-:-;-? ./~ DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff iiiIi ~,~ _~il~:lhl)Www,f,;~"~~~lr.J. c ~. '""1"...;[',: Cf'ljT' 2~~ u:;".;: -~-";-:-. r~l_. -"-,.,.- ~;~ :2. =<. (::> ~,_." ;V', ---.<<;;,,' ,-,,- 'r:~-~ j~ ." _~ 'z ~~ ~ C) N ~. '2 I'J Iilal~ \ -'"1 --,:) ~"n- (...:J . . .-..'- , ,- ~~ -" ~ '"" p Credit Based Asset Servicing and Securitization, LLC VS Malinda S. Meehan f/k/a Melinda S. Rasmussen and Charles Meehan In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-3476 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriffs Costs: Docketing Surcharge Advertising Posting Bills Law Library Prothonotary Mileage Levy Certified Mail Law Journal Patriot News Poundage Postpone Sale Share of Bills 30.00 30.00 15.00 15.00 1.00 6.90 15.00 2.07 288.65 222.55 13.43 20.00 25.20 $ 684.80 paid by attomey 03/06/03 Sworn and subscribed to before me So Answers: ThisJ.J.,~dayof~ r~~l"'~~-r..fI ~/ R. Thomas Kline: Sheriff 2003, A.D. ~(2.7h.Jk < tjaZil . i r rt-/! BYVG cL i ,-WvU':/LPl; Prothonotary Real Estate Deputy /.iTD Ue.... 'I D tro ::0 ~. /35''11'1 ,,' ..I."", ....it_ , CREDIT BASED ASSET SERVICING AND SECURlTIZATlON,LLC , CUMBERLAND COUNTY c Plaintiff, COURT OF COMMON PLEAS v '-->-. f'JI r:-;; ----_ . . Sj'wl C .;~~,g=F~ t"~IVILDIVISION MALINDA s. MEEaM I I I . ,;,,"' FfK/A MELINDA S. RASMUS~O py : ~O. 00-3476.CIVIL CHARLES MEEHAN V : Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CREDIT BASED ASSET SERVICING AND SECURITIZATION. LLC, 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 .517 NORTH HANOVER STREET. CARLISLE. P A 17013 . 1. Name and address of Owner( s) or reputed Owner( s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MALINDA S. MEEHAN, F/K/A MELINDA S. RASMUSSEN 519 HAMILTON STREET CARLISLE, P A 17013 CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, P A 17013 2. Name and address of Defendant(s) in the judgment: Same as above 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) 827 HAUSMAN ROAD PENNSYLVANIA POWER & LIGHT CO. ALLENTOWN, P A 18104 CLINE'S PLUMBING & HEATING 2103 NEWVILLE ROAD CARLISLE, P A 17013 . . ~" 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) RAYMOND E. DIEHL AND GENEVIEVE A. DIEHL 401 MYERS ROAD CARLISLE, P A 17013 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 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 indicate) None 7. Name and address of every other person of 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 indicate) Tenant/Occupant 517 NORTH HANOVER STREET CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 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 unswom falsification to authorities. August 23.2002 DATE -:;h1J () /il/.J '~JPI1 /liUtln~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff T.""" ~, ~ I~"~, ~~ ""~ .. . CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC , Plaintiff, . . CUMBERLAND COUNTY No. 00-3476-CIVIL v. MALINDA S. MEEHAN, FfK/A MELINDA S. RASMUSSEN CHARLES MEEHAN Defendant(s). August 23, 2002 TO: MALINDA S. MEEHAN, F/K/A MELINDA S. RASMUSSEN CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, P A 17013 "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, 517 NORTH HANOVER STREET, CARLISLE, P A 17013, is scheduled to be sold at the Sheriffs Sale on 12/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $96,020.81 obtained by CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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. 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.) ,_w~."..~ , "",; . '~ ~ ~'-' - j ..,,, .. . 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 ifthe 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. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe 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 . .~. ~" ~ ., DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected Situate in Carlisle Borough, Cumberland County. Pennsylvania, bounded and described as follows: BEGINNING at the Northeast corner of lot formerly of Fillmore Mause, on North Hanover Street: thence in a Northeasterly direction along said North Hanover Street, 75 feet 10 inches to lot now or formerly of Lawrence L. Shenk and Marjorie L. Shenk, his wife; thence in a Southeasterly direction along said last mentioned lot, 150 feet: thence in a Northeasterly direction along same, 9 feet; - . - thence in a Southeasterly direction along same, 53 feet to a public alley; thence along said alley in a Southwesterly direction, 103 feet to lot now or formerly of Mrs. Mowery; thence in a Northwesterly direction along said lot and other lots fronting on McBride A venue, and said lot now or formerly of Fillmore Maust, 220 feet to North Hanover Street, the place of the beginning, and known as 517 North Hanover Street, Carlisle, Pennsvlvania. Tax Parcel # 02-20-1800-075 TITLE TO SAID PREMISES IS VESTED IN Malinda S. Meehan, formerly Malinda S. Rasmussen, married woman bv Deed from Ravmond E. Diehl and Genevieve A. Diehl husband " ' and wife dated 6/30/98, recorded 7/17/98, in Deed Book 181, Page 706. PIlEKISES BEING KNOWN AS 517 NORTHIlANOVER STREET. CARLISLE, PA 17103 .~ ~ I . - ~ J....~~ '1",,"_"_, WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) , NO 00-3476 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY, To satisfy the debt, interest and costs due CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC., Plaintiff (o) From MALINDA S. MEEHAN, FfKfA MELINDA S. RASMUSSEN, CHARLES MEEHAN, 519 HAMILTON STREET, CARLISLE, PA 17013 (I) You are directed to levy upon the property of the defendant (oland to selI 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 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) Ifproperty of the defendant{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 himJher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $96,020.81 L.L. Interest FROM 7119/00 TO 12/4/02 (PER DIEM - $15.78) - $13,712.82 AND COSTS Ally's Conun % Due Prothy $1.00 Ally Paid $787.65 Other Costs Plaintiff Paid Date: AUGUST 27,2002 CURTIS R. LONG (Seal) ProthO~ 2 ~ <...Bv: O/Jo {! . /?~~/ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPIllA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Suprenle Court ill No. 12248 ~~lIfj,fi~~R!t.;$!l'll;i#Wtiij;lli.,"iil"';'''''''-''''';'\l';;'',;'',i'''''-'''~'C_''':''~","-:,l.,,'.c,,", '_I"J.H":;P~ffi"H'%i\1~liW~~Mill'MilillliliK~o<ri--k "~ ... '-~"""~~~!I!ilIiiliili!lillb""'- .... Real Estate Sale # 21 On August 30, 2002 the sherifflevied upon the defendant's interest in the reatproperty situated in Borough of Carlisle, Cumberland County, P A known and numbered as 517 North Hanover S1., Carlisle more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 30, 2002 By: J<<L; J1tli~ Real Estate Deputy , "I (.,17 t);";!1l ~"..:;, "'.1:, ~ ~ ~l ~) tJ;;;l 11"'- I\~. i:, :1;11113"' ',' .~r ,',: ,.'~/.j'o , r~-"'~'" <<(;J%>!\lN tot of ground wit!> em~ thereon erected Situate ):!.(l}:ough, cumberland CoUtl11. _ ytyal)ia,- bO~nded ~ ,described ~ ""' 51WS.:,' ~ ,_.;,;::.,- ~.,"',..:". . ~J$nl'>g"A\h~ortb""t co"'" o[\ot ~.'l'i of E\\\111o", M"'se. on North ano;.cr -Str~; }:hence 'in a- NortheasterlY . . UqIl_ ~Q~1d J'-lo:rth }lano"ller Street, _ ~O\ncheS tQ.lo~ noW or formerly of . _S~aod Marlone L. Shenk. _ . .\1i~nce in n $o1,1theWoterlj ~p~~g$_S'4QJ~lrnenuonedlot, 150 ~;~ in. a. NorIh,ast'rty direction ~png-------, swnc,_ ,9 r feet thence in a. ~~_. d)~_ctiQn glong same. 53 {eel. ~c ~....JhJ;nl;tftOng said alley 1lJ. a ~udr-W::tl'teny....dire;ti.O~- 103 feet to lot 1:0~o{'tArs. MQlN.er'j~ thence In esteW djrec.uon along said lot _ ~o er lots ~rontinS on McBride Avenue. :=- .:~~t.._n~~ or formerly of FUlmore _ ~~ J~)O North Hanover Street. __ 'nning. and 'knoWn as lWtoye.r _S~ Carli~e, ",-,I!!!'" ,~_~~-;;:.;F' iJ,&OO.Q1;< . p1lJlMlSES JS VESTED .J,Ie<n"" lormed) Malinda '1r."""marli.,d .woman b) D@. c maud E. Di.ehl and GenevieVe;'" -band and ;0fe dated 6/30/98, 1il?I9S, in p~_U:,o,~,~~1., ~~e. .--.-., -.. -,.,,~' - A _~. ~ .' _ SES BBlNG KNOW fo.S 511 NoM :~~'i..~~~~~t,_~~~le,~_rl1tl3_~- -.' ~ ~ w _~ ~",."..,,_~:~ i.~__~, .... 'IiIIIll 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 FrankJ. Epler being duly SWOrn according to law, deposes and says: That he is the Controller 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 Sundav 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 22nd and 29th day(s) of October and the 5th day(s) of November 2002. 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 the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #21 It :~~' ,.. ~ . .. ;,U.~ Notanal Seal TElII)f L. Russell. Notaly. Public City Of HarrisbUrg. Dauphin County My Commission Expires June 6. 2006 Member. Pennsylvania Associalion Of NolarieS My commission expires June 6, 2006 . '.', ,t .... ";,'_i' 'Jr~.""i:"':'.i -. " a-~, 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 $ 220.80 1.75 222.55 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.................................................................... - '-' REAL ESTA1'E SALE NO. 21 Writ No. 2000-3476 Civil Credit Based Asset Servicing and Sectuitization LLC vs. Malinda S. Meehan. f/k/a Melinda S. Rasmussen and Charles Meehan Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN loi of ground with the improvements thereon erected Situate in Carlisle Borough, Cumberland County, Pennsylvania. bounded and described as follows; BEGINNlNG at the Northeast cor- ner oflat formerly of Fillmore Mause, on North Hanover Street; thence in a Northeasterly direction along said North Hanover Street, 75 feet 10 inches to lot now or formerly of Lawrence L. Shenk and MaIjorie L. Shenk. his wife; thence in a South- easterly direction along said last mentioned lot, 150 feet; thence in a Northeasterly direction along same, 9 feet; thence in a Southeasterly di- rection along same, 53 feet to a pub- lic alley; thence along said alley in a Southwesterly direction. 103 feet to lot now or formerly of Mrs. Mowery; thence in a Northwesterly direction along said lot and other lots fronting on McBride Avenue, and said lot now or formerly of Fillmore Maust, 220 feet to North Hanover Street, the place of the beginning, and known as 517 North .Hanover Street, Carlisle. Pennsylvania, Tax Parcel #02-20-1800-075. TITLE TO SAID PREMISES IS VESTED IN Malinda S. Meehan. for- merly Malinda S. Rasmussen. mar- ried woman by Deed from Raymond E. Diehl and Genevieve A. Diehl. husband and wife dated 6/30/98. recorded 7/17/98. in Deed Book 181. Page 706. PREMISES BEING KNOWN AS 517 NORTH HANOVER STREET. CARLISLE, PA 17103. . , 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. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being dilly 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, V1Z: OCTOBER 25, NOVEMBER I, 8, 2002 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. SWORN TO AND SUBSCRIBED before me this 8 day of NOVEMBER. 2002 LOIS E. s'WDER, No!aIy PublIc CllIlilIle 110m, CumllerIand County My COllillllssloo ExpiIes MaR:I15, 2005 ~,~."". ~ ~ '" ~""'''-~'''''' - , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC Plaintiff, v. No. 00-3476-CIVIL MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $96,020.81 j Interest from 7/21/00 to SEPTEMBER 3,2003 (per diem -$15.78) $17,989.20 and Costs TOTAL $114,010.01 ~ rill.JdJ ~J'fUh)O FRANK. FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. ~illlWlfulJj",~$O;I':t!'"t'_;';,f"~.l!~fjii.<.:,"'\b"r""""-'i!!:ili"'ffi,,,.!,,,,,,_,,;'~~j",,""",;,,"HA~'bM-WI\;\!i:\:Mi~:.ft':'- - AIll r I-I .....''-'',. ._,.,~~ .......iIlillll1Ii8iII ~ Ii , , II II , - """" ~l .... e>e> t-. r- .... .... << ll-<~ Z ~r4' "" ..;l... 00 moo 00 .., .... ...;::; ;:;l ~~ ~ ~ Z OZ 00 m~ ~ ~ 0 UU .... ~~ ~~ (j E-< CIi ;:;l roJ,," "'00 Z < U ~~ "Ci ~Z ....u ~'E' ll) u... ~~ , Zz ....... E-<E-< 0,," ~ . "" = moo ll) ....= '" '" ~~ ~"" ... 0 Zz ll) ~ . ,,"Z O<l 00 ..0 000 ~~ Q,l ;>, or:: E-<E:: E-< .. E-<E-< to UZ ""< .; ~~ ~~ ...... S .. .... .... ...;:;l mN ~~ ~~ '" 00 00.... fi;~ ~ E-<U <E-< ~~ g. ~~ 0.... 0- ~~ ~= ... S a- a- ;:;lZ "";:;l .... .... ~ mu =u ""6 III III 0< <"" "" u~ ~ ~m "" .... U '" E-< ~ '" """" ~ ll) =~ .... -i:i -B E-<~ ~ CIi ll) ~ < - "" .~ << Z;:;l ~ ~ iJ:. ....u U Z .... ~ . I . . ~_u .', --I ~F ",....... '-,:. DESCRIPTION ALL THAT CERT.\IN lOll)[ ground with the improvements thereon erecIed Siruate in Carlisle Borough. Cumberland County. Pennsylvania. bounded and described as follows: BEGINNI:'-iG at the Northeast corner of lot formerly of Fillmore ylause. on N0rth Hanover Street: thence in a Northeasterly direction along said North Hanover Street. 75 feet to inches ro [Ol now or formerly of LawrenCe L. Shenk and Marjorie L. Shenk. his w'ife: thence in a SoutheasIerly direction along said last mentioned lot, 150 feet: thence in a NorrheasIerlv direction along same, 9 feet: - . - thence in a Southeasterly direction along same. 53 feet [0 a public alley: thence along said alley in ;l Southwesterly direction. 103 feet to lot now or formerly of Mrs. Mowery: thence in a Northwesterly direction along said lot and other lots framing on .'vfcBride .\venue. and said lot now or formerly of Fillmore Maust. 220 feet ro :'-iorth Hanover Street, the place of the beginning. and known .is 517 North Hanover Street. Carlisle, Pennsylvania. Tax Parcel :I 02-20-1800-075 TITLE TO SAID PRE.'vIISES IS VESTED [N y[alinda S, y[eehan. formeriy y[alinda S. Rasmussen, married woman by Deed from Raymond E. Diehl and Gene'lieve .',,, Diehl. husband and wife dated 6/30/98. recorded 7/I7i98. in Deed Book 181. Page 706, PREMISES BEING KNOWN AS 517 NORTH HANOVER STREET. CARLISLE. PA 17103 ".. ~~liEdIilll~-' ~,_Ml:1l!,,~;'W.!ii1M';l' "'_ I !;l!W",,,,,,..~,,,,,,,,-.."M'~..&1\j~iii_ .@j.~ ;- ~--.l ~ <:~ -". <0 .t::: ':" If' ...,.., ~ "' ~ .A; -1' -.J" '\~ E;" ~ y <:X1 __ 0]. ~ ~ S>i ~:>\ ~ ~ 0- C:> v- I -, '.o'~'''_ ,>' f';: rU ~ ~ --. C) -t:: ........... ~ ';>\ ~- ~ (") ~; -rJU n1f-: 2:.';:' zi~' co ~:~ c;f~; "" ~2 L' :3 , - > .. ,~~- c::> 0,) ~;: ",J (,,::0 --,--, ~.~.~ , ; ~.~-! _~ :',~; z:) ~ji~ '.':;;rTl ~:i :1) ~.. >-:-';. ,...~ ~J "J (.J ! I '''.- I Qj o ~T' - "~ --. .j~ '"<IM;i: WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF cuMBERLAND) NO 00-3476 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC Plaintiff (s) From MALINDA S. MEEHAN, FfKJA MALINDA S. RASMUSSEN AND CHARLES MEEHAN, 519 HAMILTON ST., CARLISLE PA 17013 (I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 517 N. HANOVER ST., CARLISLE PA 17013 (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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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) Ifproperty of the defendant(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/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $96,020.81 L.L. Interest 7/21/00 TO 9/3/03 @ $15.78 PER DIEM = $17,889.20 Ally's Comm % Ally Paid $1.477.45 Plaintiff Paid Date: JUNE 11, 2003 Due Prothy 1.00 Other Costs (Seal) CURTIS R. LONG :e~ ;( ~~ Dep~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER @ SUBURBAN STATION 1617 JFKBLVD., SillTE 1400 PlIILADELPIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ill No. 12248 ,"diil:B&!'i>ill.'!WL, " ~-~~~ I ." ~- .~ - j . ""~"""",y . Doc1<et for Case: "+ GetCaseNoO +" (" + DktTypeExpand(m.gsDktType) + ") Page 1 00 Bankruptcy Docket Report 1 02-06571 (Harrisburg) MEEHEN, MALINDA S -it (J7)- 3lf70 Docket items entered between 0110111931 and 06/0912003 Filing' No. Docket Entry View Date, . document 12/03/02 I VOLUNTARY PETITION under chapter 13 [EOD 12/03/02] [CA] Doc #1 PDF , 12 nages) 12/03/02. 2 NOTICE of intent to dismiss case unless missing documents are filed: due by None . 12/18/02 Re: Item # 1. [Complied] [EOD 12/03/02] [CA] 12/30/02 3 Schedules, Statements, Plan & Sununary and all missing documents Re: Item # 2. Doc.#3 PDF [EOD 12/30/02] [CA] 125~ 12/30/02 4 Ch. 13 Plan Re: Item # 3. [EOD 12/30/02] [CA] Doc'#4 PDF (5 pages) 01/02/03 . , MOTION for relieffrom stay Re: EMC Mortgage Corporation (Fee paid, Receipt Doc #5 PDF 5 #590312, $75.00) [Disposed] [EOD 01102/03] [KZ] (4 pages) CERTIFICATE OF NON-CONCURRENCE [EOD 01102/03] [KZ] 01102/03 6 ORDER that answers aredue on 01122/03 Re: Item # 5. [EOD 01102/03] [KZ] Doc'#6 PDF (I page) 01108/03 7 CERTIFICATE of service Re: Item # 6. [EOD 01108/03] [DS] None 01/14/03 8 OBJECTION to Claim #1 of U.S. Bank National Association by the Debtor [EOD Doc #8 PDF 01/14/03] [KZ] 13 pages) 01/15/03 9 ANSWER byRe: Item # 5. [EOD 01115/03] [DS] Doc #9 PDF (3 pages) 01/16/03 10 CORRESPONDENCE SETTING Preliminary Phone Conference on 02/05/03 at Doc #10 PDF 03:00 P.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT (! page) STS., HARRISBURG,PA. 17108 Re: Item # 5. [EOD 01116/03] [KZ] 01116/03 11 CERTIFICATE of Mailing of Notice of341 Meeting. Objections to the plan are due Doc # 11 PDF 15 days after meeting held. [EOD 01/16/03] [AUT] 0..~ Art: PLAN PDFI6 ~ 01/16/03 12 ORDER fixing hearing date (Phone Conference) on 02/18/03 at 01:30 P.M. at Doc #12 PDF FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., (! page) HARRISBURG,PA. 17108 Re: Item # 8. [EOD 01116/03] [KZ] 01/21103 13 CERTIFICATE of service Re: Item # 12. [EOD 01/21/03] [KZ] None . ../nPacer?ExecThis=docket&puid=O 1 0551641 02&case _ no=2002-06571 &office= 1 &DktType=-6/9/2003 jJ~MlI"".'"'' .~..~ -~., .-- .....J~................l:"'ll ~ _..I~~,odll-",j~~ I~~ ..~. ~ '_OiIJ~~.........~_~kIIiI~""'Q~" _,~~ ...._~. '^"''''' - "I - ll.;&;' Do~ket for Case: n + GetCaseNoO + n (n + DktTypeExpand(m.gsDktType) + n) Page 2 of3 01/23/03 14 c. OBJECTION to plan by U.S. BANK NATIONAL ASSOCIATION, as Trustee Doc #14 PDF under thy Pooling and Servicing Agreement dated as of May I, 2000, among (13 oa2es) Financial Asset Secmities Corp., as Depositor, Greenwich Capital Financial Products, Inc., as seller, Litton Loan Servicing LP, as servicer, and U.S. Bank National Association, as Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 Re: Item# 4. [EOD 01/23/03] [KZ] 01/24/03 15 ANSWER by the Respondent Re: Item # 8. [EOD 01/27/03] [KZ] Doc #15 PDF 16tJa2es) 01/28/03 16 CO~SPONDENCE SETTING StatuS Conference (Judge Bentz) on 03/27/03 at Doc #16 PDF 0J:30 P.M. at fED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT (1 tJa2e) , S1;S., HARRI$BURG,PA. 17108 Re: Item # 14. [EOD 01/28/03] [KZ] 01/28/03 17 ANSWER by Debtor Re: Item # 14. [EOD 01/28/03] [KZ] Doc #17 PDF " I, 13 tJa2es) 02/05/03 i 18 :I':ii i ;PROCEl;iDIN(l MEMO: phone conference not held - order will be submitted. Re: Doc #18 PDF , It~\n # 5: [EOn 02/05/03] [CL] (1 page) Ii . "_," I ' , 02/18/03 :19 ~ROCEEDING MEMO: phone conference held. Amended Proof of Claim to be None ;fjl~d. Re: Item # 8. [EOD 02/18/03] \[JG] 1.1; : q! 02/19/03 '20 '(j)iUlERgranting relief from stay Re: Item # 5. [EOD 02/19/03] [KZ] None ,!" , 02121/03 21 ~4!1 meeting not held-to be rescheduled. [EOD 02/21/03] [CA] None ",I , , , 03/07/03 22 'C~RTIFICATE of service of notice of rescheduled 341 Meeting [EOD 03/07/03] Doc #22 PDF '"I 12 pa?es) [l\iW] , , ' 03/07/03 23 M~)'rION TO DISMISS BY TRUSTEE WITH NOTlC;E SETTING HEARING on None 04110/03 at 02:00 P.M. atFED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 [EOD 03/07/03] [KZ] 03/11103 24 MOTION for relief from stay filed by U.S. BANK NATIONAL ASSOCIATION, Doc #24 PDF as Trustee under the Pooling and Servicing Agreemen~ dated May I, 2000, among 14tJages) Financial Asset Securities Corp., as 4epositor, Greenwich Capital Financial Products, Inc. as seller, Litton Loan Servicing, LP as servicer, and U.S. Bank !':lationa! Association, as Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1, without recourse. (fee paid rec#592749 $75.00) [EOD 03/11/03] [DS] 03/11/03 25 CERTIFICATE OF NON-CONCURRENCE Re: Item # 24. [EOD 03/11/03] [DS] Doc #25 PDF (1 oa2e) 03/11/03 26 ORDER that answers aredue on 03/31/03 Re: Item # 24. [EOD 03/11/03] [DS] Doc #26 PDF (2 pages) 03/19/03 27 CERTIFICATE of service Re: Item # 26. [EOD 03/20/03] [DS] Doc #27 PDF 12 pages) 03/24/03 28 ANSWER by DEBTOR Re: Item # 24. [EOD 03/24/03] [DR] Doc #28 PDF 13 tJa2es) 03/24/03 29 CORRESPONDENCE from Movant reqnesting that matter be rescheduled. Re: Doc #29 PDF Item # 16. [EOD 03/25/03] [JG] (1 page) 03/26/03 30 CORRESPONDENCE SETTING PRELIMINARY PHONE CONFERENCE on Doc #30 PDF 04/15/03 at 10:45 A.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & (I page) WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 24. [EOD 03/26/03] [KZ] .../nPacer?ExecThis=docket&puid=O 1 0551641 02&case _ no=2002-06571 &office= 1 &DktType= 6/9/2003 "{'"~~ ._...... ..1 .l ~~ ~ ~ ~~ ~I 1L:;!~L'_ . Docket for Case: "+ GetCaseNoO +" (" + DktTypeExpand(m.gsDktType) + ") ~ , Page 3 of3 03/27/03 31 PROCEEDING MEMO: conference not held. Continued to April 24, 2003 at 9:30 Doc #31 PDF a.m. This will be held as a video conference with Judge Bentz. Re: Item # 14. [EOD (J page) 03/27/03] [IG] 04/14/03 32 341 meeting not held-to be dismissed. [EOD 04/15/03] [CA] None 04/15/03 33 ORDER dismissing case due to Debtor's failure to appear at scheduled 341 meetings None [EOD 04/15/03] [KZ] 04/17/03 34 ADDENDUM TO ORDER DISMISSING CASE - DEBTOR PROHIBITED None FROM FIILNG ANOTHER PETITION FOR 180 DAYS FROM THE DATE OF THIS ORDER [EOD 04/17/03] [KZ] 04/18/03 35 NOTICE to creditors of dismissal of case [EOD 04/18/03] [AUT] Doc #35 PDF (2 pages) 04117103 36 FINAL REPORT ofCh. 13 Trustee [EOD 04118103] [KZ] None Printed: 06/09/03 09:09:58 --.-.-.... ...... ^ ._~---- ,.--..--. ----,---.,.-.....- I PACER Service Center I I Transaction Receipt I 1 06/09/2003 09:09:58 1 Ip ACER Login: IIfp0039 IIClient Code: 1 IDescription: \IDocket lIease Number: 1112002-06571 \ IBillable Pages: 114 IICost: 110.28 1 ~ Need help? Try the PACER User's Guide li:&lPacer Service Center . ../nPacer?ExecThis=docket&puid=O 10551641 02&case _ no=2002-06571 &office= 1 &DktType= 6/9/2003 ~l;jj,.),1j~-",.kk~;,~_~~~'f&';j"'.kB':''''.>t''i-"',:,-''i,l1;c,",-"",~,,-""_L-.,,Wt.lrli);qi,Ii;i~~,~- iJ ~ ~. - .'~--~~ Ii 1II ~'" '--~-.. ~." ~~. ,~ -- 0 C' 0 C c.~; -n _7 <.. e:: -oG~ ~D rnr. :;~::: 2" .-,...;''0 2 -.';::J ::!~,~ -: i . (~) ~C" . ",~1 'ri --,--n ;p,C ) -,- -:;.(~ be' i'v (~)rn >e:. -, -'7 1) ~- :" _.~ -< {.:> '< . -,,-,"-" ~.~ ~ I , - ,-, , I "~ , "'li'i<- FEDE~ANandPHELAN,LLP By: FRANK FEDE~AN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BL YD., SUITE 1400 PIllLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION MALINDA S. MEEHAN FfK/A MALINDA S. RASMUSSEN CHARLES MEEHAN NO. 00-3476-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 made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~JJlX1 ('j rfo...) FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff ii.1i_' -. """""'~~i!Ol&fr~"1!!ik",,$!I__I~,,;;fuiM.i;S-k.,.,~'!i'l\>"'" "",',.,-c":"r,''-'''),''i''<f,~tl~~~l!Uj:.i(il ' '~'," -,--- ~ *"i~~~lli.. A_~_&II () C ;;,: .'00:. rn!T' ;f;~\- (:f:l .-< .- !!f :Pc ~ C-. ." (....:. o -" S= ,--- z ..-.~ ::':-:l~.' , ~-T; .,\-.1 .'l~ ,j ~ -< f'J '..) c..) " I.' "~" <" ~".. ~-<~ - "--~f,i , .. CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN NO.00-3476-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC, 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 ,517 NORTH HANOVER STREET, CARLISLE, P A 17013 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MALINDA S. MEEHAN F/K/ A MALINDA S. RASMUSSEN 519 HAMILTON STREET CARLISLE, P A 17013 CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, P A 17013 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last Imown 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) PENNSYLVANIA POWER & LIGHT CO. 827 HAUSMAN ROAD ALLENTOWN, PA 18104 CLINE'S PLUMBING & HEATING 2103 NEWVILLE ROAD CARLISLE, P A 17013 _0; .,~~ _...~ . J_ '~, -' , 4. Name and address ofJast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) RAYMOND E. DIEHL AND GENEVIEVE A. DIEHL 401 MYERS ROAD CARLISLE, PA 17013 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 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 indicate) BOROUGH OF CARLISLE 53 W. SOUTH STREET CARLISLE, PA 17013 7. Name and address of every other person of 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 indicate) Tenant/Occupant 517 NORTH HANOVER STREET CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 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 information and belief. I understand that false statements herein are made subject to the penalties ofJ8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. June 9. 2003 DATE FRAJ{KFEDE~,ESQUIRE Attomey for Plaintiff ~~ill>li;i~")ij,""","ik"j']t:JU"l!jli';!l"I;,"",">!\L"'1>t~"'ht~'-''''~\,"";'-;Hj-,,',Y'''I8\'''_;WJ'iM~",<%>.,i(ij1l!'~fu;~jjI;jlljlrnl:-Jftftr'''-' , """,. , j , ~~r ..- '- (") C~.... '-' C ( . '.---' -~ " :~ , veil mrT! --,,, T] Z Z. I"!~ Ul u - -' -~\Cl r::: "" ,- ~,. C ~, Z " (") ;po Ci !,,,J n1 C '._", :z '0 .:;~ -, :D -< (,) -< '" .j" "'" I ' ~"","; CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC Plaintiff, CUMBERLAND COUNTY No.00-3476-CIVIL v. , MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN Defendant(s). June 9, 2003 TO: MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN 519 HAMILTON STREET CARLISLE, PA 17013 CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, P A 17013 ""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, 517 NORTH HANOVER STREET. CARLISLE. PA 17013. is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 3, 2003 at 10:00 a.m. in the Cumber/and County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $96.020.81 obtained by CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERlFF'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. . .;d;dIlrO.~""-~ -". , I~"~ '_q_~ ,/ 3. You may also be able to stop the sale through other legal proceedings. You may need an attomey 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 attomey.) 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. 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 ofthe 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 ALA WYEROR 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'Jj DESCRIPTION ALL THAT CERTAIN 10( of ground with th~ improvements th~reon ~rected Situate in Carlisle Borough. Cumberland County. PetuJsylvania. bounded and describ~d :is follows: BEGINNING at th~ Nonheast comer of lot formerly of Fillmore y[ause. on Nonh Hanover Street: th~nce in 1 "ionheasterly direction along said "ionh Hanover Street. 75 feet to inches w [at now or form~rly of Lawrence L. Shenk and Marjorie L. Shenk. his wife: thence in a SOUIheasterly direction along said last mentioned lOt. 150 feet: thence in 1 :-';orrheasterly direction 110ng same, 9 feet: thence in 1 Southeasterly direction 110ng same. 53 feet to a public alley: thence along said 111ey in a Southwesterly direction, 103 feet LO lot now or formerly of Mrs. Mowery: thence in a :-';onhwesterly direction along said lot and other lots froming on :VlcBride .\venue. and said lot now or formerly of Fillmore Maust, 220 feet to :-';orth Hanover Street. the place of the begituJing, and known 1S 51"7 North Hanover Street, Carlisle, PetuJsylvania. Tax Parcel .'1 02-20- 1800-0i5 TITLE TO SAID PRE:V!ISES [S VESTED I"i :Vlalinda S. :Vkehan. formerly yblinda S. Rasmussen, married woman by Deed from Raymond E. Diehl and Genevieve .\. Diehl. husband and wife dated 6/30/98, recorded 7/lii98. in Deed Book 181. Page i06. PREMISES BEING KNOWN AS 517 NORTH HANOVER STREET. CARLISLE. PA 17103 '1liIiIiIllI:ii1l~~liilOl!H\loI'("W~l1r!illfe;""'2'~~J.AS<,,"",,"\J~~ """",,", ,- .. ,--~,'," >, ~" " "', (") C -ot!.; rnE Z.'- ~!~ rl...-.. ..~l ' )>c'c Z -;I -- ..~- C:'; LJ ," "'~, i:.j il I -" t._.J --n ~':'~, 'i~} ;J~~ ~~~ ~,-- ~ ;"') ") t..) . , ->'"\""'- ~ --, -. ,~,..., , . . ""'"" M~ ---o...,"~, . Credit Based Asset Servicing And Securitization, LLC VS Malinda S. Meehan f/k/a Malinda S. Rasmussen and Charles Meehan In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-3476 Civil Term R. Thomas Kline, Sheriff, who being duly swom according to law, states this writ is returned STAYED pursuant to instructions from Attomey Frank Federman. Sheriff's Costs: Docketing POlUldage Posting Handbills Advertising Mileage Levy Surcharge Postpone Sale Law Library Prothonotary Law Journal Patriot News Share of Bills 30.00 12.69 15.00 15.00 6.90 15.00 30.00 20.00 1.00 265.40 207.19 28.90 $ 647.08 paid by attomey 12/18/03 Sworn and subscribed to before me So An~""s~ ~' ." . r~,,:..< _~ This 3D ~ day of ~ ~ (R. Thomas Kline, Sheriff 2003, A.D. '- off"~ ,Q /M.I(Jh.; fiBy . IMl" Q...~1fJ Prothonotary R:;-~; ,0 1,00 Lk-'f3;:<'~ /!....... I'Wi;2b ....-' ~-^ . 4 CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION MALINDA S. MEEHAN FfK/A MALINDA S. RASMUSSEN CHARLES MEEHAN NO.OO-3476-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC, Plaintiff in the above action, by its attorney, FRANK. FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,517 NORTH HANOVER STREET, CARLISLE. P A 17013 . 1. Name and address of Owner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN 519 HAMILTON STREET CARLISLE, P A 17013 CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 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) PENNSYLVANIA POWER & LIGHT CO. 827 HAUSMAN ROAD ALLENTOWN, PA 18104 CLINE'S PLUMBING & HEATING 2103 NEWVILLE ROAD CARLISLE, P A 17013 -,,-. ~~~."" 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) RAYMOND E. DIEHL AND GENEVIEVE A. DIEHL 401 MYERS ROAD CARLISLE, P A 17013 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 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 indicate) BOROUGH OF CARLISLE 53 W. SOUTH STREET CARLISLE, PA 17013 7. Name and address of every other person of 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 indicate) Tenant/Occupant 517 NORTH HANOVER STREET CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 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, June 9, 2003 DATE ~ n n.~lH(i n rI...) FRANK FEDERMAN, ESQUlRE Attomey for Plaintiff " ~ , ~ -"-- 'r&i.:, , , CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC Plaintiff, CUMBERLAND COUNTY No.00-3476-CIVIL v. MALINDA S. MEEHAN FfK/A MALINDA S. RASMUSSEN CHARLES MEEHAN Defendant(s). June 9, 2003 TO: MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN 519 HAMILTON STREET CARLISLE, PA 17013 CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, PA 17013 "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 , 517 NORTH HANOVER STREET. CARLISLE. P A 17013, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 3. 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $96.020.81 obtained by CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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 attomey'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. ..;'.S.. - l, 'il.;-".,,-_'_ , , 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 attomey.) 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 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 Sheriffthe 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 ofthe 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 ALA WYEROR 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 . .iJkt': t f DESCRIPTION ALL THAT CERT.-\IN lot of ground with th~ improvem~ms th~reon ~rected Siruate in Carlisle Borough. Cumb~rland Couni:'j. Pennsylvania. bound~d and described as follows: BEGINNING at th~ Northeast comer of lot form~riy of Fillmore Ylause. on North Hanover Stre~t: m~nc~ in :.l :.iortheasterly direction along said North Hanover Streer. 75 feet to inches to lot now or formerly of Lawrence L. Shenk and Marjorie L. Sh~nk. his wife: thence in a SOUTheasterly direction along said last memioned lor. 150 feet: mence in a :.iorth~asterly direction along same, 9 feet: mence in a SOUTheasterly direction along same. 53 feet [0 a public alley: thence along said alley in a Southwesterly direction, 103 feet to lot now or formerly of Mrs. Mowery: thence in a :.iorthwesterly direction along said lot and orner lors froming on y!cBride Avenue. and said lot now or formerly of Fillmore Maust, 2:20 feet to North Hanover Streer. the place of me beginning, and kIlown as 517 North Hanover Street, Carlisle, Pennsylvania. Tax Parcel !t 02-20-1800-075 TITLE TO S,-\ID PREyfISES IS VESTED I:.i Malinda S. ,\-feehan. formerly .\lalinda S Rasmussen, married woman by Deed from Raymond E. Diehl and Gen~vieve ,-\. Diehl. husband and wife dated 6/30/98, recorded 7/17198. in Deed Book 181. Page 706, PREMISES BEING KNOWN AS 517 NORTH HANOVER STREET, CARLISLE, PA 17103 ~" "'h.,:-L WRIT OF EXECUTION andlor ATTACHMENT COMMONWPALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) I NO 00-3476 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC Plaintiff (s) From MALINDA S. MEEHAN, FIK/A MALINDA S. RASMUSSEN AND CHARLES MEEHAN, 519 HAMILTON ST., CARLISLE P A 17013 (I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 517 N. HANOVER ST., CARLISLE PA 17013 (SEELEGAL 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 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) Ifproperty of the defendant(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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $96,020.81 L.L. Interest 7/21/00 TO 9/3/03 @ $15.78 PER DIEM = $17,889.20 Ally's Comm % Due Prothy 1.00 Ally Paid $1.477.45 Other Costs Plaintiff Paid , Date: JUNE 11, 2003 CURTIS R. LONG REQUESTING PARTY: . . ~~ N~ FRANK FEDtRMAN, ESQUIRE Addr~ss: ONE PENN'CENTER@SUBURBAN STATION 1617 JFK BLVD., SUITE 1400 PHILADELPIA PA 19103-1814 ~'t) ~~ L By, ~ !- tul U Depu (Seal) Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ill No. 12248 ~~tiL~!!1~...ili<1~'lI!~'t;/i;l~~iitWi\~,!lI:"ii~i'li".;.,' 1.""~,.,.L,",,j""f~"";~'i>liI~\m.iJl[:1ilJljlWiF!ill~bfiUl' ~., _.'I!l~t_~~i--' . -"j ~"'-, ""~ ~ \ Real Estate Sale # 69 On June 17,2003 the sherifflevied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, P A known and numbered as 517 North Hanover Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 17,2003 By~JG(ltj J-mriL. Real Estate Deputy ~ .n " ~~. ~ H~.. , ."'1ililJ!11~0i~' L C~ ,;:~l ~' ~ ~ ~i "7="ffEAL EstATe-sALE No: 69' .'- . c~.co Writ No. 2000-3476 -~ Civil Term .~'Credlt Based Asset Servicing 'l~____ --and Securitization, LLC ~~- _,--- va_ . ,;;.~-;.~_ _'. Malinda S. Meehan , ~, _ ~ f/kIa Malinda S. ~asmussen ~=, ,and Charfes Meehan _ ._.-~~Atty.: Fmnk Federman c~- . DESCRIPTION ~'THAT cap'AfrUoJ_oLwund_Jllld che ~mpKWemen\S lKereOn eretted Situate in Carlisle _:~. ._ ugh,. -Cumker1l!nQ CQunty. Pennsylvania, ~{j~citind_describedasfollows: -~l:UiGINt\lJNG at the Northeast comer of lot ~ly of fillmr,Jre Mause._on North Hanover ~~~thence in a North.easterly direction along ~d.NorthHano\'erStreet,75feetlOinchestolQt ~QW or fonnerly of Lawrence. L. Shenk and ;-~orieL.Shenk,_biswife;_thenceiI1a ~bIfieasterlydirectfonaIong5a[d]astmentioned ~Qt, 150 feet; thence in a Northeasrerly direction ~ong same 9 feet; thence in a Southeasterly ~direction along same 53 feet (0 a public alley; ~~_.along said==.nlley in a Southwesterly ~;;Plrec~on._l03 feet to lot now or fonncrly oLMrs. :w.oVie.ry; thence in a Northwestedy direction ;~_saidJot and other lots fronting on McBride =-Avenue;' and said lot now ot formerly of Fillmore ,:...Maus~ 220 feet to 4~rth Hanover Street, the place - of..tbe BEGINNING, and known as -517 North .;-Hinoyer Street, Carlisle, Pennsylvania. ~PARCEL NO.: 02.10.1800.075. 9'fI'!] TO SAID premises is vested in Malinda =;hS;:;:Meehan, formerly Malinda S. Rassmus~en, K.I11ani~ woman, by Deed from Raymond E. Diehl .- ~d_ Genevieve A. Diehl, husband and wife, dated ~~,recc~_:Il~I9~, ~n Deed Book IB1, ~PREIolISES 1rEING KNOWN" 517 North ~~~'ier Slretl.Carlisle, PA 17013. , , ", "',! ."""'4."'"'' " Jc":::'~"~"-".'''" -" "",,,,<k,i THE P ATItIQ'T NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sWOrn according to law, deposes and says: That he is the Ass!. Controller 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 Sundav 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 22nd and 29th day(s) of July and the 5th day(s) of August 2003. That neither he nor said Cornpany 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 the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy SALE#69 ..........................k~................. S tad ubscribed before is 13th day of 03 A.D. Notarial Seal Terry L. Russell. Notary P . City Of Han1sburg,Dauphin MyCommlsslonExplresJune6,2006 NOT RY PUBLIC Member,PennsylvanlaAssoclallonorNola~ commission expires June 6, 2006 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 $ 205.44 1.75 207.19 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.................................................................... loWd.l.il""""'" '. -;,:' an -- ESIJ'A~ SALE NO. 69 Writ No..c2QOO-3476 Civil Credit Based Asset Servicing and Securltization, LLC vS. Malinda S. Meehan. f/k/a Malinda S. Rasmussen and Charles Meehan Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected Situate in Carlisle Borough. Cumberland County. Pennsylvania. bounded and described as follows: BEGINNING at the Northeast corner of lot formerly of Fillmore Mause. on North Hanover Street: thence in a Northeasterly direction along said North Hanover Street. 75 feet 10 inches to lot now or formerly of Lawrence L. Shenk and Marjorie L. Shenk. hlswife: thence in a South- easterly direction along said last mentioned lot, 150 feet; thence in a Northeasterly direction along same, 9 feet; thence in a Southeasterly direction along same, 53 feet to a public alley; thence along said alley in a Southwesterly direction. 103 feet to lot now or formerly of Mrs. Mowery; thence in a Northwesterly direction along said lot and other lots fronting on McBride Avenue. and said lot now or formerly of Fillmore Maust, 220 feet to North Hanover Street, the place of the heginnlng. and known as 517 North Hanover Street, Carlisle, Pennsyl- vania. Tax Parcel # 02-20-1800-075. TITLE TO SAID PREMISES IS VESTED IN MalInda S. Meehan. for- merly Malinda S. Rasmussen, mar- ried woman by Deed from Raymond E. Diehl and Genevieve A. Diehl, hushand and wife dated 6/30/98. recorded 7/17/98, in Deed Book 18!. Page 706. PREMISES BEING KNOWN AS 517 NORTII HANOVER STREET. CARLISLE. PA 17103. - -~ , " " < ~:A-!: . . 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 : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, ofthe 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 ofthe said Cumberland Law Journal on the following dates, viz: JULY 18, 25, 2003 AUGUST 1, 2003 Affiant further deposes that he is authorized to veritY 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. TO AND SUBSCRI ED before me this 1 day of AUGUST, 2003 N LOIS E. SNroER, Notmy Cilrlisle Bom, Cl.imblll'land County My CoinmlsBion Expir8B MardlIS, 2005 , .' - '1"'$, FEDERMAN AND PHELAN, LLP. by: Daniel G. schmieg, Esquire Atty. I.D. No. 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19102-1799 (215) 563-7000 APR 2 8 201I4~ 'h , : , ATTORNEY FOR PLAINTIFF us Bank National Association, As Trustee Unser The Pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial Asset Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, As Sevicer, And US Bank National Association, As Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. Malinda S. Meehan F/K/A Malinda S. Rasmussen CIVIL DIVISION NO. 00-3476-CIVIL RULE AND NOW, this -3d~ day of ~ I 2004, a Rule is entered upon Malinda S. Meehan F/K/A Malinda S. Rasmussen, Defendant(s) to show cause why the attached order for Reassessment of Damages should not be entered. RULE RETURNABLE~~ (tM) ~ /A-t7?1V dd~ 'i ~ , BY THE COURT: J. ;l l1\J;o-9J:1\C;t. rJr 1\"IE. t>t\O\r\Ol'iOiw.'i 2Qn"~~ -3 ~l\\\I?S ~\J.NQ CQ\.lN1'l p~NNS,{L\JAN\~ fI , ,~ - ~, --~'". _~~v i. ~. ~ <::l ~~c) ~ - J~ ;mJ1IA-~'l!j8"!~' I ~!!I\'lj,I'!'iP;;<>Wl~~ . _1\\"""""',~~,.".,..,,IlI'IIIMl . -- ~, """7', FEDERMAN AND PHELAN, LLP. 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 US Bank National Association, As Trustee Unser The pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial Asset Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, As Sevicer, And US Bank National Association, AS Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. Malinda S. Meehan F/K/A Malinda S. Rasmussen CIVIL DIVISION NO. 00-3476-CIVIL ORDER AND NOW, this day of , 2004, the Prothonotary is ORDERED to reassess the damages in this case as follows: Principal Balance Interest Amount May 7, 2001 through June 9, 2004 Per Diem $22.13 Late Charges Legal fees Cost of Suit and Title Sheriff's Sale Costs Property Inspections MIP/PMI NSF Fees Suspense/Misc. Credits Appraisal/BPO Escrow Credit Deficit 86,385.57 24,987.38 637.03 3,600.00 1,680.42 4,000.00 2,163.90 98.00 0.00 (0.00). 400.00 0.00 4.563.13 TOTAL Plus interest per percent. $128,515.43 diem from June 9, 2004 through Date of Sale at six (6%-) NOTE: THE ABOVE FIGURE IS NOT A PAY OFF - SHERIFF'S SALE COSTS AND COMMrSSION ARE NOT INCLUDED IN THE ABOVE FIGURES. BY THE COURT: J. ,I FEDERMAN AND PHELAN, LLP. 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 US Bank National Association, As Trustee Unser The pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial Asset Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, As Sevicer, And US Bank National Association, As Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. Malinda S. Meehan F/K/A Malinda S. Rasmussen CIVIL DIVISION NO. 00-3476-CIVIL PRAECIPE FOR RULE TO SHOW CAUSE TO THE PROTHONOTARY: Kindly enter a Rule upon Malinda S. Meehan F/K/A Malinda S. Rasmussen, Defendant(s) to show cause why the attached Order for Reassessment of Damages should not be entered. BY:~~ Daniel G. Schmieg, Esquire Attorney for Plaintiff . . _. FEDERMAN AND PHELAN, LLP. 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 US Bank National Association, As Trustee Unser The Pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial Asset Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, As Sevicer, And US Bank National Association, As Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. Malinda S. Meehan F/K/A Malinda S. Rasmussen CIVIL DIVISION NO. 00-3476-CIVIL AFFIDAVIT OF SERVICE Daniel G. Schmieg, Esquire, hereby certifies that a copy of Plaintiff's Petition for Reassessment of Damages have been sent to the individuals indicated below on April 23, 2004. Malinda S. Meehan F/K/A Malinda S. Rasmussen 519 Hamilton Street, Carlisle, PA 17013 DATE: April 23, 2004 FEDERMAN AND PHE~L.L.P. By: ~ S ./'... Daniel G. Schmieg, Esquire Attorney for Plaintiff :""'.-, FEDERMAN AND PHELAN, LLP. 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 US Bank National Association, As Trustee Unser The Pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial Asset Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, As Sevicer, And US Bank National Association, As Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. Malinda S. Meehan F/K/A Malinda S. Rasmussen CIVIL DIVISION NO. 00-3476-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 and Rule was entered upon Defendant (s) Malinda S. Meehan F/K/A Malinda S. Rasmussen on to show cause why the Order for Reassessment should not be entered. A true and correct copy of the Rule is attached hereto as Exhibit A. 3 . The 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 WHEREFORE, Petitioner prays this Honorable Court make the Rule to Show Cause absolute and enter the Order for Reassessment of Damages. FEDERMAN AND PHELAN, L.L.P. BY:~~ Daniel G. Schmieg, Esquire Attorney for Plaintiff L '"Jill"""'- FEDERMAN AND PHELAN, LLP. 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 US Bank National Association, As Trustee Unser The pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial Asset Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, As Sevicer, And US Bank National Association, As Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. Malinda S. Meehan F/K/A Malinda S. Rasmussen CIVIL DIVISION NO. 00-3476-CIVIL PLAINTIFF'S PETITION FOR REASSESSMENT OF DAMAGES Plaintiff, by its Attorney, Federman and Phelan, LLP and 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 July 20, 2000 in the amount of 96,020.81. 2. A Sheriff's Sale of the mortgaged premises was postponed or stayed for the following reasons: The Defendant (s) filed a Chapter 13 Bankruptcy (#1-03-05080) on August 29, 2003. Relief was Granted by order of court dated December 24, 2003. 3. The mortgaged premises are listed for Sheriff's Sale on June 9, 2004. 4. Additional sums have been incurred or expended on Defendant(s) I behalf during the time the sale was postponed or stayed, and < ~- -I.. n"j;6.,-' Defendant (s) have been given credit for any payments that have been made since the judgment, if any. As a result, the amount of damages should now read as follows: Principal Balance Interest Amount May 7, 2001 through June 9, 2004 Per Diem $22.13 Late Charges Legal fees Cost of Suit and Title Sheriff's Sale Costs Property Inspections MIP/PMI NSF Fees Suspense/Misc. Credits Appraisal/BPO Escrow Credit Deficit 86,385.57 24,987.38 637.03 3,600.00 1,680.42 4,000.00 2,163.90 98.00 0.00 (0.00) 400.00 0.00 4,563.13 TOTAL $128,515.43 5. Under the terms of the mortgage, which mortgage is recorded in the Office of the Recorder of Deeds in Book (#1553), Page (#209), Plaintiff is entitled to judgement in the amount as set forth in paragraph four herein against the Defendant(s). WHEREFORE, plaintiff respectfully requests this Honorable Court issue an Order to the Prothonotary to reassess the damages as set forth above. FEDERMAN AND ~P. BY~ Daniel G. Schmieg, Esquire Attorney for Plaintiff -2- ."' '....."""" FEDERMAN AND PHELAN, LLP. 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 US Bank National Association, As Trustee Unser The Pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial Asset Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, As Sevicer, And US Bank National Association, As Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. Malinda S. Meehan F/K/A Malinda S. Rasmussen CIVIL DIVISION NO. 00-3476-CIVIL BRIEF OF LAW IN SUPPORT OF PLAINTIFF'S MOTION TO REASSESS DAMAGES I. BACKGROUND OF CASE Plaintiff and Defendant (s) entered into a Promissory Note and Mortgage Agreement, wherein Defendant(s) agreed to pay Plaintiff principal, interest, late charges, real estate taxes, hazard insurance premiums and mortgage insurance premiums as said monies 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 iudicia, Defendant (s) failed to abide by the Mortgage Agreement by failing to tender numerous, 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 -, ..1,," expenses which Plaintiff has been obligated to pay under the Mortgage Agreement in order to protect its interest. II. ARGUMENT FOR REASSESSMENT OF DAMAGES The Pennsylvania Rules of Civil Procedure are silent with respect to the issue of Reassessment of Damages; however, Rule 1037 provides, "the Prothonotary shall assess damages for the amount which Plaintiff is entitled if it is a sum certain or which can be made certain by computation... 11 In the instant case, the amount to which Plaintiff is entitled is readily calculated by review of the Mortgage Agreement, which is of record, together with the 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 equitable 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 Home Mortqaqe Corporation of the Southwest v. Good, 537 A.2d 22, 24 (Pa.Super 1988) . In Chase Home Mortqaqe, 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 protecting the property. See Meco Reality Company v. Burns, 414 Pa. 495, 200 A.2d 335 (1971) . Plaintiff submits that if Plaintiff went to sale without reassessing damages, and if there was competitive bidding for the subject premises, . ~'"" Plaintiff would suffer irreparable harm in that it would not be able to recoup monies it paid to protect its interest. Conversely, a reassessment of damages 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's judgment amount. May Term, 1986, No. 2359 (CCP PHlLA. 1986). III. CONCLUSION Plaintiff respectfully requests this Honorable Court grant its petition to Reassess Damages. Plaintiff respectfully submits that it has acted in good faith in maintaining the property in accordance with the Mortgage, and in reliance on said instrument with the understanding that it would recover the monies it expended to protect its collateral. WHEREFORE. Plaintiff respectfully requests this Honorable Court to reassess the damages as set forth in the Petition to Reassess Damages. F~RMAN AND C5.~ P. _ BY:~ . Daniel G. Schmieg, Esquire Attorney for Plaintiff I I . , I , I ' . 111ac; , I ~ " ~ " . - . '. -,.' f~c-'~3/~ :...:-....,...:...~(;:~ ~.:.~~. 'i .o..!:n --..' F:~!l~~i:.. 'NA'1"rO~l\!.' ~1bit~~l:.G2: AsSGC!!\.'r!<lN COU9.'? '0= ..CO?A_~Ot.f 'p-t.U"S ?!{.:::~~.!)~P!(!.i\ CO!Jtt;CY C~V~ TR1~ OrViSION t(5"-.: : .. . Jo:si?,it'Jip~tisQtl <;nc., "~qS'!$!:.42.?.i'-::-:asnfl:~ . fits' t.;.~f~. "!-~R.~.t -19.8']: 23.59 ...~~ NO., ~~~~! , . !)R~_~3: AN"O Oy"r:r!Ot'" , , . - -,~i!!i~~';i ~~.~ .' A!iIo H(x~ .t.'t!s '. t' day of ~ j reO' , UPdn~~onsid~~a~i9n 0= ?l~in~if~# Fe=c=al National ~c~aqc . . ~S'dCla..;ion:.'.s . ~'e.ti ti.O:il f :Jr.. ~econs- .ide~;a cion Nunc _?rc T"..l1lC cf . t~is,.Co.ui't's: Orde::- 0:: :lova%llbe:;- 7, LliaS a.:\c ;:,."e Ans'-'e. thc,rGtQ "oi-'.Def'f{nd~~ts.~ .lase'?h. ..1efte=so:n a.nc =l'csi~ S2.:f-fe=sQ~, ~t is hetebt OROE3.::.-o a.:>d OEG~"'D "^".. .fo!! 0\013' I 1) S i~ " ...~.' . 'G~"""'~^' -. a_u -.<;:'=-0"- "-S ,~'~'_'_"" .O.....r, ,'.1 .~'>.:., . .' . . . 1.)~~~.<.@r1:;s Ocle,i of tt'ovembe= 7, 19<15 t::c k>fl:;iSZD ar.<!1f:~nCfcf;;~. ~ S~:i~~:YorR"eassessG.en:t:'Of Oa~Gcs is . .....-c.......:;. (o~~~"I . . .. . ..... ~ -: . .. \:.' ' GRANTED; ~ " .(\.~".)'". ~,"'- . - J) :ru"~~;t is h.-"rcfiy lnc::cz,,;:-d. to S6,l41.H. ~. -tle.c.aiJ:$c - p ~;1iil~i=E ~as requice~ to ac=ep-t CU-C-rq.I~:t.' mart~~qe payme:xts upoq t.!le f.!.till,<J of ,Defendan~' .benkl:'Uptc;y . . . . . .. :petti1.oit~al'l4'1n factdi4 so, t~isrieccssaty .::0 reass(~ss ~ea:JtOurtt '9€dat>laga.s t~a~ initially ....e::-e assessed ilftcr. jUd~ni:by.default ....as entered L, this act!.on. Beca1.;sP, I. " , .1.' '- ! Oeferidantsnave not're::ut.ed the speci.fic z::lclInts claimed. - 1 - , " , 1l\I1!e~" -6 ,. .:. :-.: t' \.- r~ I , / . \ "..\ ~ I""" ". . " (0 , . . <by ?Jaitt"t!.ff' l.tt .-t..~~- L~:i~an.t:. M6"~-~on. fcj~ Rea~s<!ss~tit... t..'1-'I.'s" GOti;,tfit1~tih4tp..!e:;~.u..~tih~ve- adl!\Lt~t::c.\1l>~e ;ui\6~i\tS.. '?':lci.U4~~ ~iJ ~a'~- It..C'~'_~~"" !.otCJ ee)" ". , i: ! "R 3! .'Ts'Z' COGa~: . . ',' "~' .... .' .......,.......~r-:r-?~.. ' 'tflO/!t;lS A. wtUTE, .J:;. i , 1 .. . \-" - ,~,I '"'~'L :;.' ~ ;- .- :- :.:- .... : . - .- 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 penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. DATE: April 23, 2004 F~RMI\N AND PHELAN t\ L. L. P . BY:~ ~~~ Daniel G. Schmieg, Esquire Attorney for Plaintiff _.~"- ,~_",Ii;..,..dt...l1Jl'!.i!llIW~III""~""'_"~h""'I>li_'~hiJIlHMi~;t,~"";(~..~.._':w,,,,,,,,Jl;;;lm;uH!IU_i~,<:;~_~1 ", ~ ~ ,,-~ "" ,~_..~ " .. ,'_,~".O" "' "~. ,. .1iIIIIiIiliIIIl..~~IiIIiIIlW ".. 0 ~ - Q ~ :po ~ ~ -U :::0 I N a> I~ ~' - t5?;{ - ~ .- CD _ '< t -, ,.'. ~. "t~ _do.. ... FEDERMAN AND PHELAN, LLP. by: Daniel G. Schmieg, Esquire Atty. I.D. No. 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19102-1799 (215) 563-7000 ~.- ~ -<01:.,-" ATTORNEY FOR PLAINTIFF US Bank National Association, As Trustee Unser The Pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial Asset Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, As Sevicer, And US Bank National Association, As Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 vs. Malinda S. Meehan F/K/A Malinda S. Rasmussen CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 00-3476-CIVIL vs. CIVIL DIVISION Malinda S. Meehan F/K/A Malinda S. Rasmussen CERTIFICATION OF SERVICE NO. 00-3476-CIVIL I, Daniel G. Schmieg, Esquire, hereby certify that a copy of the Rule Returnable Date of June 1, 2004 and a copy of Plaintiff's petition for May 7, 2004. Reassessment of Damages have been sent to the individuals indicated below on Malinda S. Meehan F/K/A Malinda S. Rasmussen 517 North Hanover Street, Carlisle, PA 17013 By: niel G. Schmi g, Attorney for Plai Date: May 7, 2004 L.L.P ire ..~ ~1lIiMllIIrIi~mlb'""",""",<......~tlhlr$ii.<JM.;Wli;..",",",,'*"'*-'0~~-'" ~ --,- .- ""~,, .' - ---~u",.";"..".,, ','..",,',:-; " ~' - ("') "-> 0 = C = -n ~.;: ... 'urn ::l!: 'j:! lTlf :'", :':;oa h1 :1J Z -<: r ----;~, . 'um ?~:~-.- 'TI6 ~? ';2 ::~' I!-.- -0 : -ri ?(:: ::ll: ~;Jo ~;~ ~ i~m "'- :); :;2 0 :Xl ~-! ,< "L, _ ~ v MAY 0 4 2004 V FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CREDIT BASED ASSET SERVICING AND SECURlTIZATION, LLC ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 00-3476-CIVIL vs. MALINDA S. MEEHAN FIKIA MALINDA S. RASMUSSEN CHARLES MEEHAN ORDER AND NOW, this L day of 1'11~ ,2004, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service ofthe Notice of Sale on the above captioned Defendant(s), MALINDA S. MEEHAN FIKIA MALINDA S. RASMUSSEN and CHARLES MEEHAN, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last known address, which is the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service. ~~~ ~ O~ , \J ~,O o BY THE COURT: . /}J. J. j , . .,="~~~!Il. ~"", .. 'f<',....'>.4~j:""1" ,~,,,,,... ".~_. fILED-OffiCE OF 1\-\E p?O\\-IOI\\cYiNW 2UU4 r\~~ -& PH 12: 51 C' I~/'~C>::, c.;. ".. ,'.r", "\,rN VI' k...,.~: \~..r'.j \:1.-1 vU-..) .\11 1 PcN~,\8,{l\!i\N\A '-""'.". ~i~'~\?!',_"!';F.=,_,," "''''i'l'J1111l:l!J1:!l!!\\mf'! . ~ll'f~~'4I -~-I" 1M' -"~ " ~-',,-. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 00-3476-CIVIL vs. MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN ORDER AND NOW, this _ day of , 2004, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s), MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN and CHARLES MEEHAN, by mailing a true and correct copy ofthe Notice of Sale by certified mail and regular mail to Defendant's last known address, which is the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attomey, who will file with the Prothonotary's Office an Affidavit of service. BY THE COURT: J. ._~ .I.~ FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC CUMBERLAND COUNTY No.: 00-3476-CIVIL vs. MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN ORDER AND NOW, this _ day of ,2004, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant( s), MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN and CHARLES MEEHAN, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last known address, which is the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attomey, who will file with the Prothonotary's Office an Affidavit of service. BY THE COURT: J. I,~,~ iU FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC CUMBERLAND COUNTY No.: 00-3476-CNIL vs. MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Frank Federman, Esquire, moves this Honorable Court for an Order directing service of the Notice of Sale upon the above captioned Defendant(s) by certified mail and regular mail to Defendant's last known address. 1. Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated by the Affidavit of Service attached hereto as Exhibit "A." 2. Pursuant to peunsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the result there from is attached hereto as Exhibit "B." WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service ofthe Notice of Sale by =ti""' m,iI md mgW~ mffil 10 Dclmdml" i>;1 ko"~2L a-- FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAlNTIFF I~ ~...-"",. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO., 12248 ONE PENN CENTER PLAZA, SUlTE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION CUMBERLAND COUNTY CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC No.: 00-3476-CNIL vs. MALINDA S. MEEHAN FIK/A MALINDA S. RASMUSSEN CHARLES MEEHAN MEMORANDUM OF LAW PennsylvilI1ia Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant and the reasons why service cannot be made. Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa. 165,360 A,2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations oflocal telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Affidavit of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Notice of Sale. A good faith effort to discover the ,~ -~' , whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit "B." WHEREFORE, Plaintiff respectfully requests service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. Respectfully submitted: ;:::;:/ G:7 FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF -'" - .1 ~ 'lIiI"., AFFIDAVIT OF SERVICE COUNTY PLAINTIFF CUMBERLAND US BANK NATIONAL ASSOCIATION, ET. AL. No.00-3476-CIVIL PIT DEFENDANT(S) MALINDA S. MEEHAN FfK/A MALINDA S. RASMUSSEN CHARLES MEEHAN ACCT. #8089815 Type of Action - Notice of Sheriff's Sale SERVE CHARLES MEEHAN AT 517 NORTH HANOVER STREET CARLISLE, PA 17013 Sale Date: JUNE 9, 2004 SERVED 'l Served and made known to .a{).~\e.~ t\1-e t;~6N\ _ '(',200_, at , o'clock _.m, at , Defendant, on the day of Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adolt in charge of Defendant(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. ~." , Commonwealth of Pennsylvania, in tbe manner described below: ~ Other: ~'Description: Age_ Height_ Weight_ Race Sex Other '1-' I, , a competent adoll, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this _ day of ,200_. Notary: By:\( PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED - 'r On the p.. '7 day of /fill A c.ft Moved Unknown , 200jl, at C;:) S o'clock h.rn., Defendant NOT FOUND because: No Answer /Vacant 2~Attempt: / / Time: 't- 1 st Attempt: / / Time: '{3rd Attempt: / / , "~ " AFFIDAVIT OF SERVICE COUNTY PLAINTIFF CUMBERLAND US BANK NATIONAL ASSOCIATION, ET. AL. No. 00-3476-CIVIL PJT DEFENDANT(S) MALINDA S. MEEHAN FIK/A MALINDA S. RASMUSSEN CHARLES MEEHAN ACCT. #8089815 Type of Action - Notice of Sheriff's Sale SERVE OR L - - ;?! AT 517 NORTH HANOVER STREET CARLISLE, PA 17013 Sale Date: JUNE 9, 2004 SERVED (served and made known to .t\AJ ,~clA l' , VV\ ee,~c../\ , Defendant, on the 'f.' ,200_, at . o'clock_.m., at , Commonwealth of Pennsylvania, in the manner described below: day of ~,. Defendant personally served. Adult family member with whom Defendant(s) reside(s). RelatioIlBhip is Adult in charge ofDefendant(s)'s residence who refused to give name or relatioIlBhip. Manager/Clerk of place of lodging in which Defendant( s) reside( s). Agent or person in charge ofDefendant(s)'s office or usual place ofbusiness. an officer of said Defendant( s)' s company. y Other: y" Description: Age_ Height_ Weight_ Race Sex Other )<- I, , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this _ day of ,200_. Notary: By:?, PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED - y: On the ;;;''7 day of Moved y 1 st Attempt: / 'f 3rd Attempt: / fIh;ec.f.. ,200.Jl,at CliPS '.m., Defendant NOT FOUND because: Unknown No Answer / Time: 2yttempt: / / Time: ue~ /14 a-&7iiL 'OC<, r SKN Data Research Inc. AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 4-11628PA Attomey Firm: Federman & Phelan Subject: Malinda S. Meehan & Charles Meehan 'e Current Address: 517 N. Hanover St. Carlisle, P A 17013 Property Address: 517 N. Hanover St. Carlisle, P A 17013 Mailing Address: 517 N. Hanover St. Carlisle, P A 17013 I Scott Nulty, being duly sworn according to law, do hereby depose and state as follows, I have conducted an investigation into the whereabouts ofthe above-noted individual(s) aud have discovered the following: I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following to be true and correct Malinda S. Meehan - 168-48-3379 Charles Meehan - 188-58-0078 B. EMPLOYMENT SEARCH A review ofthe credit reporting agencies provided no employment information. Malinda S. Meehan - not available Charles Meehan - not available C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Malinda S. Meehan & Charles Meehan reside(s) at: 517 N. Hanover St. Carlisle, P A 17013 II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH On 4-21-04 our office contacted directory assistance which indicated that Malinda S. Meehan & Charles Meehan reside(s) at: 517 N. Hanover St. Carlisle, P A 17013. Our office made a telephone call to the mortgagors phoue number and received the following information: 717-249-44504/16 7:31p, 4/20 1:07p, 4/219:25a no answer. m. INQUIRY OF NEIGHBORS Our office attempted to contact M. Leach 523 Hamilton St. 4/20 1 :27p who said the house is empty, they were not able to verify that Malinda S. Meehan & Charles Meehan reside(s) at: 517 N. Hanover St. Carlisle, PA 17013 IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 4-21-04 we reviewed the National Address database and found the following information, Malinda S. Meehan & Charles Meehan - 517 N. Hanover St. Carlisle, PA 17013 B. ADDITIONAL ACTIVE MAILING ADDRESSES. Per our inquiry of creditors, the following is a possible mailing address: 519 Hamilton St. Carlisle, P A 17013 V. DRIVERS LICENSE INFORMATION A. MOTOR VEIDCLE & DMV OFFICE Per the P A Department of Motor Vehicles, we were unable to obtain address information on Malinda S. Meehan & Charles Meehan. VI. OTHER INQUIRIES DEATH RECORDS A. As of 4-21~04 Vital Records and all pnblic databases have no death record on fIle for Malinda S. Meehan & Charles Meehan. ""'""""" - , ~-- fly!,' .~ ~~8 B. COUNTY VOTER REGISTRATION The Cumberland County Voter registration was unable to confirm a registration for Malinda S. Meehan & Charles Meehan residing at: last registered address. VII. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH Malinda S. Meehan -YOB 1954 Charles Meehan -YOB 1968 B. A.K.A. none * All accessible public databases have been checked and cross-referenced for the above named individual( s). * Please be advised ail database information indicates the subjects reside at the current address. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. AFFIANT Sc .Nulty SKN Data Research Inc. President Swom to and subscribed before me this ..2/~ day of ~ 2004 ~KAlfrft~ o AR UBLIC Notarial Seal Margaret E. Nulty. Notary Public East Goshen Twp.. Chester County My Commission Expiras Dec. 19, 2005 Member, Pennsylvania Association Of Notaries The above information is obtained from available public records and we are only liable for the cost of the affidavit ~ "~ ^ J...mv VERIFICATION FRANK FEDERMAN, ESQUIRE, hereby states that he is the Attomey for the Plaintiff in this action, that he is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT 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. Soc. 4904 reh,"", w -= f..i"""i"" "';;;:!L. U' F~FEDE~,ESQlITRE ATTORNEY FOR PLAINTIFF "" .' Lc". FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 COURT OF COMMON PLEAS (215) 563-7000 CIVIL DIVISION CREDIT BASED ASSET SERVICING AND CUMBERLAND COUNTY SECURITIZATION, LLC No.: 00-3476-CIVIL vs. MALINDA S. MEEHAN F/K/A MALINDA S. RASMUSSEN CHARLES MEEHAN CERTIFICATION OF SERVICE I, FRANK FEDERMAN, ESQUIRE, hereby certify that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individuals indicated below on April 30, 2004. MALINDA S. MEEHAN F/K/ A MALINDA S. RASMUSSEN 519 HAMILTON STREET CARLISLE, PA 17013 CHARLES MEEHAN 519 HAMILTON STREET C22& FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff Date: April 30, 2004 iIi6iI <=_Ill~~\j,i'dl",,__li"'oo;'!lI~'!f~..*~W,:~..lliliiili:jlb:iI\1!il.~t;l;W.k;IIM~lMi~~~ilUnJl;I:i'~" ~~, - nrlflJ.' '"J*;iiI ~iil!Iill~ . ; i: li (') ""- ~ <:::> 0 <:::> .c- "T1 '-c.rGj :::!Ir :r m(n :n. 6"=0 -< rn:n Zr" hi c:.6 ~~i; I ~~ ;56 w .,.... ):> ;;;::0 :0- .::r -H j>() ::Ii:: <:)6 f"~ r;? ~~m 0 ..;.- ~;! ~ N _.13 Q'\ -< ~ " ~ , """ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA US BANK NATIONAL ASSOCIATION, AS ) CIVIL ACTION TRUSTEE UNDER THE POOLING AND ) SERVICING AGREEMENT, DATED AS OF MAY I, 2000, AMONG FINANCIAL ASSET SECURITIES CORP., AS DEPOSITOR, GREENWICH CAPITAL FINANCIAL PRODUCTS, INC., AS AS SELLER, LITTON LOAN SERVICING LP, AS SERVICER, AND US ) CIVIL DIVISION BANK NATIONAL ASSOCIATION, AS ) NO. 00-3476-CIVIL TRUSTEE, SOUNDVIEW HOME EQUITY LOAN ASSET-BACKED CERTIFICATES, SERIES 2000-1 vs. MALINDA S. MEEHAN FfKJA MALINDA S. RASMUSSEN CHARLES MEEHAN AMENDED AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for US BANK NATIONAL ASSOCIATION. AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT. DATED AS OF MAY I. 2000. AMONG FINANCIAL ASSET SECURITIES CORP.. AS DEPOSITOR. GREENWICH CAPITAL FINANCIAL PRODUCTS. INC.. AS AS SELLER. LITTON LOAN SERVICING LP. AS SERVICER. AND US BANK NATIONAL ASSOCIATION. AS TRUSTEE. SOUNDVIEW HOME EOUITY LOAN ASSET-BACKED CERTIFICATES. SERIES 2000-1 hereby verify that on March 12. 2004 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: Mav 13. 2004 '11W11[ ie1it; mOll FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff --,' I- ~"" ,,~ " # 1~-~~---__~illIilIllIIliIi~ . I. .. :Y:;j t""' h. ~ ~ ~ ~ ~ ~ '" 00 -J '" V. .... IN '" ~ ~. . z v. .... IN '" ~ 0 t::1 11 0. "," )> ~ il, ;:\. 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RASMUSSEN ) CIVIL DIVISION ) NO. 00-3476-CIVIL CHARLES MEEHAN AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) ss: I, FRANK FEDERMAN, ESQUIRE attorney for CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC hereby verify that on March 12,2004 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: May 7. 2004 iMn~ Wil/!/I?(])I} FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff ~ , 1iIIIIIIlIIlIL....._,~~____,lIiIliIiIliI~ ::9.~ t""' ~g - - - - - - ;:'Z '" .... W N - 0 '" 00 -.J 0-, '" .... W N - Or ~~ " "'. "," ~ '< !l, ~ ;l. . i 1r CD z c: 3 0' CD .., ~~ i ~ tl:I "d () ~ 8 0 z 0 ~ ~ 0 . ~<z a ~ ~ ~ . ~l ~ . ~ ~ <Zl > "'. ~ <Zl ~ ~ '" . " . 0 > '" - ~ "d ~ - , 0'" I:Il ~ 0 () !l !:!lO" rn ~ () . 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"'"' :r: n1 :!J ~-r,.'_ -< fTi :gO ~C7 C> 96 -,-;~ :t>o ..J.:.:n ~-'. ~--~ o--;..-l"., :;J1l: Qc5 ~.:'::O{-} ";-"c: S? om z 'D! -j w :u -,. \.0 -< ~ J" -~~ ~ - ,01 "';'i'-~ FEDERMAN AND PHELAN, LLP. by: Daniel G. Schmieg, Esquire Atty. I.D. No. 62205 One Penn Center Plazar Suite 1400 Philadelphia, PA 19102-1799 (215) 563-7000 y/ ATTORNEY FOR PLAINTIFF dUN \l8_e US Bank National Associationr As Trustee Unser The Pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial Asset Securities Corp'r As Depositor, Greenwich Capital Financial Products, INC'r As Sellerr Litton Loan Servicing LPr As Sevicer, And US Bank National Associationr As Trusteer Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. Malinda S. Meehan F/K/A Malinda S. Rasmussen CIVIL DIVISION NO. 00-3476-CIVIL ORDER AND NOW, this II' day of ~.... I 2004r 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 May 7, 2001 through June 9, 2004 Per Diem $22.13 Late Charges Legal fees Cost of Suit and Title Sheriff's Sale 'Costs Property Inspections MIP/PMI NSF Fees Suspense/Misc. Credits Appraisal/BPO Escrow Credit Deficit 86,385.57 24,987.38 637.03 3,600.00 1,680.42 4,000.00 2,163.90 98.00 0.00 (0.00) 400.00 TOTAL Plus interest per diem from June 9, percent. 0.00 4,563.13 $128,515.43 2004 through Date of Sale at six (6%) NOTE: THE ABOVE FIGURE IS NOT A PAY OFF - SHERIFF 1 S SALE COSTS AND COMMISSION ARE NOT INCLUDED IN THE ABOVE FIGURES. 1914 J. I , -~. !"I"_~l!I. """"""",I.-. < F\\.f.D-OfF\CE OF 'THE PBOiHONOTAP.Y 2804 JUN \ \ Pt1 3: 02 ~ ':l- ..... , CUMl3f:J\L\i\{1 COUNT{ PENNS'!i.:'JA~,iIA ~ .~ ~ ~ J~ Pel. G.:tcJ' Cj.UD Ck.. i,,!(3 lo ~ JS).IOY . ,~ ","_1"Jl"""",l'll,,Nl~~ _, ~"t_ri"J";f@!O,~"~,~~l'!ry""'1Mg~''1l!q"'~''''',,"",'~~'''''~1II1l!1II.<~~ "<',' ~ I*~, " FEDERMAN AND PHELAN, LLP, 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 US Bank National Association, As Trustee Unser The Pooling And Servicing Agreement I Dated As Of May 1,2000, Among Financial Asset Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, AS Sevicerl And US Bank National Association, As Trustee, Soundview Horne Equity Loan Asset-Backed Certificates, Series 2000~1 CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. Malinda S. Meehan F/K/A Malinda S. Rasmussen CIVIL DIVISION NO, 00~3476-CIVIL MOTION TO MAKE ROLE ABSOLUTE Plaintiff I by its AttorneYI 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 April 26, 2004 and Rule was entered upon Defendant(s) Malinda S. Meehan F/K/A Malinda S. Rasmussen on April 30, 2004 to show cause why the Order for Reassessment should not be entered. A true and correct copy of the Rule is attached hereto as Exhibit A. 3. The 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 June 1, 2004 WHEREFORE, Petitioner prays this Honorable Court make the Rule to Show Cause absolute and enter the Order for Reassessment of Damages. By: 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 Fa. C.S. ~4904 relating to unsworn falsification to authorities. DATE: June 1, 2004 1-- --'Wi' APfU & 2od4\D FEDERMAN AND PHELAN, LLP. 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 US Bank National Association, As Trustee Unser The Pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial A~et Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, As Sevicer, And US Bank National Association, As Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. Malinda S. Meehan F/K/A Malinda S. RaSmussen CIVIL DIVISION NO. 00-3476-CIVIL RULE -w 17 nA,ft AND NOW, this 30 ~ day of V-' , 2004/ a Rule is entered upon Malinda S. Meehan F/K/A Malinda S. Rasmussen Defendant(s) to show cause why the attached Order for Reassessment of Damages should not be entered. RULE RETURNABLE ~J:i (,;J.{)).ct.ar r dJ.:ti:.., i'~ BY THE COURT: Is) 1~lYU..".J 0 4~ I { J. TRUE COPY FROM RECoRO In T 8Itlmooy wheroof. I here ooto set my hand an~ UllJ, saalllf said ~ at ~. Pa. rnl ' , 'I . ~MJ 'I . ~ ~J. y~' (] . :1P'~ Pmtho '. FEDERMAN AND PHELAN, LLP. by: Daniel G. Schmieg, Esquire Atty. I.D. No. 62205 One Penn Center Plaz.a" Suite 1400 Philadelphia', PA 19102-1799 (215) 563-700tJ ATTORNEYFORPLAINTLFF "~~ ~~~ ~'" .. ...l~~~~~ e(,. ",'" ,-,' US Bank National Association, As Trustee Unser The Pooling And Servicing Agreement, Dated As Of May 1,2000, Among Financial Asset Securities Corp., As Depositor, Greenwich Capital Financial Products, INC., As Seller, Litton Loan Servicing LP, As Sevicer, And US Bank National Association, As Trustee, Soundview Home ~ Equity Loan Asset-Backed Certificates, .~~. Series 2000-1 . ~~~ ~"l.~~ ~~ ~~ CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Malinda S. Malinda S. vs. Meehan F/K/A Rasmussen o c R -11m NO. 00-3476-CIV~CR ,~~ r:::c; ;;;; CIVIL DIVISION ~8 ,Pc ',NO. 00-3476-CIVIL~ vs. MalindaS.Meehan F/K/A Malinda S. Rasmussen CERTIFICATION OF SERVICE ...., = = ..,- X "'" -< o "t1 :!!.." 111- r -om :0.9 96 :e=H 0- ......0 ""'--m 9. .~ -0 :::I:: ~ o -.I I, Daniel G. Schmieg, Esquire, hereby certify that a copy of the Rule Returnable Date of June 1. 2004 and a copy of Plaintiff's Petition for May 7, 2004. Reassessment of Damages have been sent to the individuals indicated below on Malinda S. Meehan F/K/A Malinda S. Rasmussen 517 North Hanover Street, Carlisle, PA 17013 FEDE, 7,AND PH~LAN, L. L. P --d ~. By: .' I?'~" ~" ,f~ . niel G. Schmi g~ .El~.qUire Attorney for PlaiDt'~ff Date: May 7, 2004 "."--~- .,.., l........ "1Oll,-"jt '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC ) CIVIL ACTION ) vs, MALINDA S, MEEHANF/K/A MALINDA S, RASMUSSEN ) CIVIL DIVISION ) NO. 00-3476-CIVIL CHARLES MEEHAN AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUlRE attorney for CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC hereby verify that on June 10,2003 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto, DATE: August 11. 2003 1'~ 1pJiJ/UlYUh . FRANK FEDERMAN, ESQUlRE Attorney for Plaintiff ~c - ~......, -~~. , ....~__w . ~ ".., t:: -'0 ge- 0 - ;: - - - - . OOz v. V.> N - 0 '"' 00 -> '" v. ... V.> N ... 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O~ Cl =: 0. ~~ < ;; " ~~ trJ .., [;:J ~ ~ ("l i ES 9 ~ '" ~ ?' .... 0 0. 0 0 ~ ~ ("l .... trJ 0 ES ~, ~ < 3' '" .., ><: ~ t"< ''1 ~:J' ~"" C ~ ~ ~ ...~= --- 11[8 ... 1#' 4 .;-~~~ c ~ 0 : 3 ~~ ~ PtTfllEYBO\l"JtS ~ .z.\ !:::!,-, (C~." i . 02 1A $ 02.10 '" I\~' I. '/'.' . . 0004300317 JUN 1 0 2003 "-, r- .... . ~" MAlccD FROM ZIP CODE 19103 ~~~~ '" . . " .L :"'-'"" o>z ...."",., "'''''3 ~ ~ tt ""'" ,., '" '" = ., "" I 'C0t,j ='=trJ :: ftl c: ~~trj~ ~= "g.= F'Q~ ~aRo >~~ ~~= """,trJ <:>=~ w~~ <::1' ,., .? '" S. ib "" ... <:> <:> '.>iiIJ'-lI!liliiIo~"~~l'i;IIo&W4-l;I:1.M<iIl!l$'i'''*'t;iF~'l;,!",~,,,,,,-,,,,".;,,_,Jt"''"1.~,,",:~.w&M~ ,,,- ~_l '~mH.liL At., , _~L~. ^:.- . ,,_"_~.'''''' ~HL '" ~. "... '" '~ ' ~., J,~." ~ .:i&MM~itl (') r:; <: "'0('( me' ;-::: ;.:" Lr~ UJ; -<-' r- < ~f-~ ..:'::'" '."'j -.:; ~ ~-, ,~ ~,,~,~.~~ ''-, " C) 0) ~ ~-) o -n -"j (..~, ;T' ~-, '-~J -:,:) ~.? ...::,--i -~.~ (') :-~)iTi .-<... f';':) -:'.'l (,n ::::~ 5:) ,< Li " COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 00 - 3'11/ I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Maged Abdelmalik & Hanan Awadalla is the grantee the same having been sold to said grantee on the 29th day of ~ A.D., 2004, under and by virtue of a writ Execution issued on the 10th day of March, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2000 Number 3476. at the suit ofU S Bank Tr against Malinda S Meehan Jka Malinda S Rasmussen & Charles Meehan is duly recorded in Sheriffs Deed Book No. 266, Page 988. IN TESTIMONY WHEREOF, I have hereunto set my hand 1rJ-ti: and seal of said office this 71~ , A.D200 day of ... Recorder of Deeds EJ~~~==& +~. ~ ,,,,,J i _ ~'" , ,F US Bank National Association, as Trustee In The Court of Common Pleas of Under the Pooling and Servicing Agree- Cumberland County, Pennsylvania Ment, dated as of May 1,2000, among Writ No. 2000-3476 Civil Term Financial Asset Securities Corp., as Depositor, Greenwich Capital Financial Products, Inc., as a Seller, Litton Loan Servicing LP, as Servicer, and US Bank National Association, as Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000- I VS Malinda S. Meehan flk/a Malinda S, Rasmussen and Charles Meehan Ron Kerr, Deputy Sheriff, who being duly sworn according to law, states that on May 5, 2004 at 8:51 o'clock AM, 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: MaJ.inda S. Meehan f/k/a Malinda S. Rasmussen, by making known unto Malinda S, Meehan, personally, at The Mechanicsburg Post Office, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said 1:rUe and correct copy of the same. CpI. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on May 6, 2004 at 4:35 o'clock PM, 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: Charles Meehan, by making known unto Charles Meehan, personally, at 6280 Carlisle Pike, Lot 503, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on April 16,2004 at 3:56 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Malinda S. Meehan f/k/a Malinda S. Rasmussen and Charles Meehan located at 517 North Hanover St., Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Malinda S. Meehan flk/a Malinda S, Rasmussen, by regular mail to her last known address of 519 Hamilton Street, Carlisle, P A 17013. This letter was mailed under the date of May 6, 2004 and never retumed to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Charles Meehan, by regular mail to his last known address of 6280 Carlisle Pike, Lot 503, Mechanicsburg, PA 17055, This letter was mailed under the date of May 6, 2004 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 8, 2004 at 10:00 o'clock A.M. He s,old the same for .' "" the sum of$80,000.00 to Maged Abdelmalik and Hanan Awadalla. It being the highest bid and best price received for the same, Maged Abdelmalik and Hanan Awadalla of 1010 Tunbridge Lane, Mechanicsburg, P A 17050, being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of $8,000.00. On September,.24, 2004 the buyers in this execution did not comply with the Sheriff s terms of sale and pay the balance due to the Sheriff. Therefore, the Sheriff exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 29,2004 at 10:00 o'clock A.M. He sold the same for the sum of $62,000.00 to Maged Abdelmalik and Hanan Awadalla. It being the highest bid and best price received for the same, Maged Abdelmalik and Hanan Awadalla of 1010 Tunbridge Lane, Mechanicsburg, P A 17050, being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of $66,058.50. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Levy Postpone Sale Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $30.00 2,840.00 15.00 15.00 30.00 10.00 1.00 17.25 15.00 20.00 30.00 316.55 251.74 29.26 25.00 39.50 $ 3,685.30 Sworn and subscribed to before me So Answers: This 18 day of ~......;~ ~~ l-t:~ q R. Thomas Kline, Sheriff 2004, A.D. :f'- Q. fu,/tJf~'-'I1'r j ~ r - . d r thonotary BY \. _0 _~; , Real Estat eputy ~~ ,J{),oV l.rfD iA'-'-/7r03 Eu--. I ~ ! 0(,'/ -c.. ~. _l_ . SCHEDULE OF DISTRIBUTION SALE NO. 82 Date Filed: October 29,2004 Writ No. 2000-3476 Civil Term US Bank National Association, as Trustee Under the Pooling and Servicing Agreement, Dated as of May I, 2000 Among Financial Asset Securities Corp., as Depositor, Greenwich Capital Financial Products, Inc., as Seller, Litton Loan Servicing LP, as Servicer, and US Bank National Association, as Trustee, Soundview Home Equity Loan Asset Backed Certificates, Series 2000-1 VS Malinda S. Meehan f/k/a Malinda S. Rasmussen and Charles Meehan 517 North Hanover Street Carlisle, PA 17013 Sale Date: Buyer: Bid Price: September 29, 2004 Maged Abdelmalik and Hanan Awadalla $62,000.00 Real Debt: Interest: Attorney Costs: $96,020.81 22,407.60 2,149.53 Total: $120,577.94 DISTRIBUTION: Receipts: Cash on account (03/11104): $ Cash on account (09/08/04): Cash on account (09/29/04): Cash on account (10/06/04): 1,500.00 8,000.00 6,200.00 59,858.50 Total Receipts: $75,558.50 Disbursements: Sheriffs Costs Legal Search State Transfer Tax Local Transfer Tax Carlisle Borough (Lien 01-4387MLD) Attorney Frank Federman US Bank National Association et al Total Disbursements: Balance for distribution: So Answers: r~~-# R. Thomas Kline Sheriff ~ I $ 3,685.30 200.00 1,309.25 1,309.25 1,415.90 1,500.00 66,138.80 ($75,558.50) 0.00 ;...- " "'% TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 82 Held Wednesday, September 29, 2004 Advertised for June Sheriff Sale Date: September 29, 2004 TAXES: Receipts for all taxes for the years 2001 to 2003 inclusive. Taxes for the current year 2004. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to / dated, 2004, and recorded , 2004, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Raymond E. Diehl and Genevieve A. Diehl, his wife, by deed dated June 30, 1998 and recorded July 17, 1998 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle Pennsylvania, in Deed Book 181, Page 706, granted and conveyed to Malinda S. Meehan, formerly known as Malinda S. Rasmussen. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose, 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbeds of North Hanover Street and Specks Avenue, t.....-;.~., 6. Mortgage in the amount of $87,500.00 given Malinda S. Meehan formerly known as Malinda S. Rasmussen to ContiMortgage Corporation dated June 7, 1999 and recorded June 28, 1999 in Mortgage Book 1553, Page 209. Said mortgage was assigned to Credit Based Asset Servicing and Securitization, LLC, by instrument recorded November 6, 2000 in Miscellaneous Record Book 659 Page 536. Said mortgage was further assigned to US Bank National Association, Trustee under Pulling and Servicing Agreement of May 11, 2000 by instrument recorded October 21,2003 in Miscellaneous Record Book 703, Page 557. Complaint in mortgage fOIecIosure filed by Credit Based Asset Servicing and Securitization, LLC, as Plaintiff, against Malinda S. Meehan, formerly known as Malinda S. Rasmussen, and Charles Meehan, as Defendants, on June 8, 2000 in the Office of the Prothonotary of Cumberland County to File No. 2000-3476. Judgment in the amount of $96,020.81 entered July 20, 2000. Order reassessing damages in the amount of $128,515.43 entered Apri130, 2004. 7. Municipal lien in the amount of $882.00 entered by the Borough of Carlisle as Plaintiff against Malinda S. Meehan as Defendant on July 19,2001 in the Office of the Prothonotary of Cumberland County to File No. 2001-4387. 8. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 13. Real estate taxes accruing on and after January 1, 2005 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. ~~ Robert G. Frey, Agent Note: This Title Report shall not be valid or bindi until countersigned by an authorized signatory, .-...l~ ,- . REAL ESTATE SALE NO. 82 Writ No, 2000-3476 Civil US Bank National Association, as Trustee Under the Pooling and Servicing Agreement, dated as of May 1. 2000. among Financial Asset Securities Corp. as Depositor, Greenwich Capital Financial Products. Inc.. as a Seller. Litton Loan Servicing LP. as Servicer, and US Bank National Association, as Trustee, Soundview Home Equity Loan Asset-Backed Certificates, Series 2000-1 vs. " Malinda S. Meehan f/k/a Malinda S. Rasmussen and Charles Meehan. Atty.: Frank Federman ALL THAT CERTAIN lot of ground with the improvements thereon erected Situate in Carlisle Borough, Cumberland County. Pennsylvania. bounded and descrJbed as follows: BEGINNING at the Northeast comer of lot formerly of Fillmore Mause. on North Hanover Street; thence in a Northeasterly direction I along said North Hanover Street. 75 feet 10 inches to lot now or formerly of Lawrence L. Shenk and MaJjorie L. Shenk. his wife; thence 1n a South- easterly direction along said last mentioned lot. 150 feet; thence in a Northeasterly direction along same, 9 feet; thence in a Southeasterly direction along same, 53 feet to a public alley; thence along said alley in a Southwesterly direction. 103 feet to lot now or formerly of Mrs. Mowery; thence in a Northwesterly direction along said lot and other lots fronting on- McBride Avenue, and said lot now or formerly of Fillmore Maust. 220 feet to North Hanover Street. the place of the be- ginning. and known as 517 North Hanover Street. Carlisle, Pennsyl- vania. Together with any improvements thereon erected. being known as 517 North Hanover Street. Carlisle. Pa 17013 TITLE TO SAID PREMISES IS VESTED IN Malinda S, Meehan. for- merly Malinda S. Rasmussen. mar- ried woman by Deed from Raymond E. Dteh! and GeneVieve A. Dteh!. husband and wife dated 6/30/98. recorded 7/17/98. in Deed Book 181. Page 706. Tax Parcel #02-20-1800-075. ~~J."~_..."....... ~ ~,< , ' I US BANK NATIONAL ASSOCIATION; AS TRUSTEE UNDER THE POOUNG AND ' . SERVICING AGREEMENT, DATED AS OF MAY 1,2000, AMONG FINANCIAL ASSET SECURITIES CORP., AS DEPOSITOR, GREENWICH CAPITAL FINANCIAL PRODUCTS, INC., AS AS SELLER, UTTON LOAN SERVICING LP, AS SERVICER, AND US BANK NATIONAL ASSOCIATION, AS TRUSTEE, SOUNDVIEW HOME EQUITY LOAN ASSET- BACKED CERTIFICATES, SERIES 2000-1 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVll. DIVISION NO.00-3476-CIVIL Plaintiff, v. MALINDA S. MEEHAN F/KIA MALINDA S. RASMUSSEN CHARLES MEEHAN Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) US BANK NATIONAL ASSOCIATION. AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT. DATED AS OF MAY 1.2000. AMONG FINANCIAL ASSET SECURITIES CORP.. AS DEPOSITOR. GREENWICH CAPITAL FINANCIAL PRODUCTS. INC.. AS AS SELLER. LITTON LOAN SERVICING LP. AS SERVICER. AND US BANK NATIONAL ASSOCIATION. AS TRUSTEE. SOUNDVIEW HOME EQUITY LOAN ASSET- BACKED CERTIFICATES. SERIES 2000-1, 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. 517 NORTH HANOVER STREET. CARLISLE. PA 17013. 1. Name and address of Owner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MALINDA S. MEEHAN F/KfA MALINDA 519 HAMILTON STREET S. RASMUSSEN CARLISLE, P A 17013 CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real ;~ c "....", t property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PENNSYL VANIA POWER & LIGHT CO. 827 HAUSMAN ROAD ALENTOWN, PA 18104 CLINE'S PLUMBING & HEATING 2103 NEWVILLE ROAD CARLISLE, P A 17013 RAYMOND E. DIEHL & GENEVIEVE A. DIEHL 401 MYERS ROAD CARLISLE, P A 17013 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please 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 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 indicate) BOROUGH OF CARLISLE 53 W. SOUTH STREET CARLISLE, P A 17013 7. Name and address of every other person of 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 indicate) Tenant/Occupant 517 NORTH HANOVER STREET CARLISLE, P A 17013 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 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. March 9, 2004 DATE -~ Dst~rlJJ\~ FRANK. FEDERMAN, ESQUIRE Attorney for Plaintiff . I. ~'~'Ic. ',' us BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT, DATED AS OF MAY 1, 2000, AMONG FINANCIAL ASSET SECURITIES CORP" AS DEPOSITOR, GREENWICH CAPITAL FINANCIAL PRODUCTS, INC., AS AS SELLER, LITTON LOAN SERVICING LP, AS SERVICER, AND US BANK NATIONAL ASSOCIATION, AS TRUSTEE, SOUNDVIEW HOME EQUlTYLOAN ASSET-BACKED CERTIFICATES, SERIES 2000-1 Plaintiff, CUMBERLAND COUNTY No. 00-3476-CIVIL v. MALINDA S, MEEHAN FfKJA MALINDA S. RASMUSSEN CHARLES MEEIIAN Defendant(s). March 9, 2004 TO: MALINDA S. MEEHAN FIKiA MALINDA S. RASMUSSEN 519 HAMILTON STREET CARLISLE, P A 17013 CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, P A 17013 "THIS FIRM IS A DEBT COLLECTOR AITEMPTING 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 AITEMPT TO COllECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at, 517 NORTH HANOVER STREET, CARLISLE, P A 17013, is scheduled to be sold at the Sheriffs Sale on JUNE 9, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 596,020.81 obtained by US BANK NATIONAL ASSOCIATION. AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT, DATED AS OF MAY 1. 2000, AMONG FINANCIAL ASSET SECURITIES CORP., AS DEPOSITOR. GREENWICH CAPITAL FINANCIAL PRODUCTS, INC.. AS AS SELLER. LITTON LOAN SERVICING LP, AS SERVICER, AND US BANK NATIONAL ASSOCIATION, AS TRUSTEE, SOUNDVlEW HOME EOUITY LOAN ASSET-BACKED CERTIFICATES, SERIES 2000-1 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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. 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 fOI 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. -. L~~ ........."" " 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 M '._ ~"' . -^~"'L " . ALL THA T CERTAIN lot of ground with the improvements thereon erected Situate in Carlisle Borough, Cumberland County, Pennsylvania, bounded and described as follows: ' BEGINNING at the NorthellSt comer of lot formerly of Fillmore Mause, on North Hanover Street; thence in a Northeasterly direction along said North Hanover Street, 75 feet 10 inches to lot now or formerly of Lawrence L. Shenk and Marjorie L. Shenk, his wife; thence in a Southeasterly direction along said last mentioned lot, 150 feet; thence in a Northeasterly direction along same, 9 feet; thence in a Sontheasterly direction along same, 53 feet to a public alley; thence along said alley in a Southwesterly direction, 103 feet to lot now or formerly of Mrs. Mowery; thence in a Northwesterly direction along said lot and other lots fronting on McBride A venue, and said lot now or formerly of Fillmore Maust, 220 feet to North Hanover Street, the place of the beginning, and known as 517 North Hanover Street, Carlisle, PeImsylvania. Together with any improvements thereon erected, being known as 517 North HanOver Street, Carlisle, Pa 17013 .. TITLE TO SAID PREMISES IS VESTED IN Malinda S. Meehan. formerly Malinda S. Rasmussen, married woman by Deed from Raymond E. Diehl and Genevieve A. Diehl, husband and wife dated 6/30/98, recorded 7/17/98, in Deed Book 181, Page 706. TrotParcel # 02-20-1800-075 ~"~. lld.li.l!Ii-..-""" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) . , NO 00-3476 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfY the debt, interest and costs due US BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER TH POOLING AND SERVCING AGREEMENT, DATED AS OF 511/00, AMONG FINANCIAL ASSET SECURITIES CORP., AS DEPOSITOR, GREENWICH CAPITAL FINANCIAL PRODUCTS, INC., AS A SELLER, LITTON LOAN SERVICING LP, AS SERVICER, AND US BANK NATIONAL ASSOCIATION, AS TRUSTEE, SOUNDVIEW HOME EQIDTY LOAN ASSET-BACKED CERTIFICATES, SERIES 2000-1 Plaintiff (s) From MALINDA S. MEEHAN f/kla MALINDA S. RASMUSSEN and CHARLES MEEHAN, 519 HAMILTON ST., CARLISLE PA 17013. (i) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 517NORTHHANOVERST"CARLISLE PA 17013 (SEE LEGALDESCRIPTION) . (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 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) Ifproperty of the defendant(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 himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $96,020.81 L.L. Interest 7/21/00 TO 6/9/04 @ $15.78 per diem = $22,407.60 Arty's COnTIn % Due Prothy $1.00 Arty Paid $2,149.53 Other Costs Plaintiff Paid Date: MARCH 10, 2004 (Seal) By: REQUESTING PARTY: Name FRANK FEDERMAN, ESQ. Address: ONE PENN CENTER@SUBURBANSTATION 1617 JFKBLVD., SIDTE 1400 PHILADELPIDA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215)563-7000 -- ~ >---,~,- '~~: ~~_illI!!ltll!jielij}",'",.>.!;H,,,,-.,,";r,",iii"""'4<;',,-<,",_;Y~-"",-,,,,">'>J;f--",,,,,jl.)i ~_"~.;."[,a"'i,-,,...~....~ili~,~~..l ,,-~~~~ ~1idIlHlIlilIi ~ - ~,i Real Estate Sale #82 On March 11, 2004 the sherifflevied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, P A Known and numbered as 517 North Hanover Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 11,2004 By: J~^A-l.t-t Real Estate~~~-' @#j, ~~~ '-" ::" j d '.'i i_, ., Z 0\ ~~!,l '1d?i,I":- . ~~~f~{;::~'I';:' , ..:+>> c.:,';;~iG " -- ".. "~a'-~r3:~l!;""'i"~r1<'o,n."-~~,u !l.inS' rot" '~~[l!f ~~?:g lIT ~l'i1,l~ ,,'~iii t~: ~ii II lL ~.. ,"!i~~~~a!lni~tfri!l~h:h!i~i~h; ;; 'zlj<~aJ~~f ~~~l~1f. S' S':J JfJlrJ';.! ;lt~ [. 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',~: ~-;~-,-_.: .:.~..; -:"'-;:0"" '- --- ~~~~~tiJ-;:~"'-!#- - -Wz ~ ~!!tb ';:~::;Ie:! - ~ ;:.c:: a:l> iii":J -! :I>~ n i en' ~ ~mm m~_0~mo~ _~~ > ~~aE:"~ - ~g&'cfi.!!~r&CJ~> ::Sr- .. a- mm~~i=moma>c~ ~m l~[1 !.~~2g.;:.JmifDi~ .~~mm<miom~~a;~.i~=sp~ ~mm~0N~3gm~~~=39~g~~m ms::uS: cnm..:; a:=oi:gClllCirmfD:cCl) ~@=m ~~~=cf~onm~~>3~~ ~~3~ -$c~W~~~o~~om :m im=! n..~2mn?o~g:~~=~ ~z := OJ . m -- Dl & m... 0 ....0 ,::r r,n- "S'~it:l::JID't:J1D Q.tQ..:: . CllI (ROCD::lI;"(Qrs;:;:rn2:omm CltJ ~..~::r _.. ~.." ~m_!!.. _ _!!-tD a. I'\) ..~~.- ,',' -"',,';':'" -~ . ,,~:: - . -~ _::;~,~;~:~,f < , .--.c>~>-_.-- .-- - - .----- rflEALEST1.:iE SALE No. 82 ~. wntNQ.2000-3416 ~_ cClvllTerm .1' ~~~J>.- --' _ _ _ J?,~\ng and ".'!"t, dated O' of ,!'nto09. F\nanc1!;\t _ _ ....{!.<>iIlUJllles COrp. .' _DellO.llor, Greenwich capl\!d ~n~_nc\a\_PjOdUGl$I.lnC'1 a9 a ~1~rJ,Il.tqJL L<:>,On3eI"M1PSII,P, ~ -!'i'seN\cer, and US sank :::. NatiQnJJ\ ASsoc., as Trustee, ~~9P)/);Ifflll9Il\!!.~qu!tYL<!..n ~~-sse't_~aCk~ certiflcatas, ~~ series 2000-1 ~ ..::---~V'~-~ ~~MiIlnda S._han .,,_.~ fil<<a Ma\\nd.B S_,,- Rasmussen ~~~J.\.~Ii""- .." ~~~ttY, I'rao","FQ<jeTman ~EiCRip.rIClN " ~~CERTAlNlot'fgro,rolWI\hthe ~\S'\he1&""",cted"","'int"\lsl' Jl<i"'u&Jl. cumbed>nd Coun\Y. _'jl""" ~."rd&9bed",fOl\aW" -?~Gat=,~~~~5~d()OOt- ~)jl~JiI"'~'''' NorthH-" ~]l\ell'" at a N","-,,,,,,,Ij &<ecMu ",01 J1ill~.j,J~Jee.Jllllt@e.S\!)\ot ;W:Jl<.'~,w-;:;jf"Wili"" L. Shenk ",d " ~one 1,. Sbe~_~_<wif~~~w:.RC~ ijl. a ~_,"j~"""""gs1lid\"t",Oti"".d ~'I50 f~, 'W"\.in-,.~"'~~"" ~. 9 fee" thellC'_in.;,Jpl\!!""",lj ~c\iOn lllong l)aD1e, 53 feet to ~ pUblic al1ey~ ~ce al.Ol1.8. saW a1tey in a SO\l\:hVJeste!ly ~n, 1q~ ~;tYJJo1.IlQ~ pi (ooP~1Y_~UUS' ~~_ tbence _In._ a NcM~tetlY direCtion ~,lgL!!,.qtheLj<>)l!!""~",,.~rl" " J-11<I ,~~ \q\O'l'(l9't~j oiJut- !,ei",N~rtl1\lal;<'",S11"'-\lJei"", ". . ~,glnlli'K, and """" ~ ,\1 ",Prtb 'Sf{rowverstreet,Cailiste,.PenllSY1'l'ania. .:~-.:.,'IOG~ wlth any lmpro'o'ements lheroon ~p, .being 'known as 517 Nooh Hanover ~Cllli>;l<.~I>Jl0tL .,' ~Ji~.'!'O _~~~~J i" vested in ,~~ !,,,,,,Iy M>Jinda S, ~un,_ roani.ed wClJltm, by need from .;;}l>jlU,"Lj\..n;e1JLand Ge",,",'/" ~ ~and wile::d>~6fJ08B. ,-led ;:r1tll9~.i!i ]).<e!l.B90.\SJ.~a&' 106, r~RAR~"'P,@"2Q,l!i1O./l15, -'-~- --~--_.----====--- ~ ~ .' ~, I 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 Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller 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 Sundav Patriot-News newspapers of general circulation, printed and published a1 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 27th day(s) of April and the 4th and 11 th day(s) of May 2004, 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 the office for the Recording of Deeds in and for said County Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #82 NOlARlAI. SEAl Terry L Russen, Notary PUbli Oly of Harrisburg, Dauphin Counly My Commission expires June 6, 200 Member, P,nnsylvanlaAllodallonof NDlarl8s NARY PUBLIC commission expires June 6, 2006 , ~, 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 251.74 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.........,.""",.,.,.,.,.,.,.,.,.,.,.,.,.,.,.,.,.,.,.,.,.,."".,. ~" REAL ESTATE SALE NO. 82 Writ No. 2000-3476 Civil US Bank. National Association, as Trustee Under the Pooling and Servicing Agreement. dated as of May 1.2000. among Financial Asset Securtties Corp. as Depositor, GreenWich Capital F1nanc1al Products. Inc., as a Seller, Litton Loan Servicing LP. as Servicer, and US Bank National Association, as Trustee, SoundView Home Equ11;y Loan Asset-Backed Certificates, SeI1es 2000~ 1 va, Malinda S. Meehan f/k/a Malinda S. Rasmussen and Charles Meehan. Atty.: Frank Federman ALL THAT CERTAIN lot of ground With the improvements thereon erected Situate in Carlisle Borough, I Cumberland Coun1;y, Pennsylvania, I bounded and descr.lbed as follows: BEGINNING at the Northeast comer of lot formerly of Fillmore Mause, on North Hanover Street; thence in a Northeasterly direction along said North Hanover Street, 75 feet 10 inches to lot now or formeTly .of Lawrence L. Shenk and MaIjorie L. Shenk, his wife; thence in a SouthM easterly direction along said last mentioned lot. 150 feet; thence in a Northeasterly direction along same, 9 feet; thence in a Southeasterly direction along same, 53 feet to a public alley; thence along said alley in a Southwesterly direction. 103 feet to lot now or formerly of Mrs. Mowery; thence in a Northwesterly direction along said lot and other lots fronting on McBrtde Avenue, and said lot now or formerly of Ftllmore Maust, 220 feet to North Hanover Street, the place of the be- ginning, and known as 517 North Hanover Street, Carlisle, Pennsyl~ vania. Together with any improvements thereon erected. being known as 517 North Hanover Street. Carlisle, Pa 17013 TITLE TO SAID PREMISES IS VESTED IN Malinda S. Meehan. for- merly Malinda S. Rasmussen, mar~ ned woman by Deed from Raymond E. Diehl and Genevieve A. Diehl, husband and wife dated 6/30/98, recorded 7/17/98, in Deed Book 181, Page 706. Tax Parcel #02-20-1800~075. \ . l"'--A~' \ . MAiL Ill&T'A'I'E seE M. Il2 WIlt No. 2000,3476 Civil US Bank National Association, as Trustee Under the Pooling and Servicing Agreement. dated as of May 1, 2000. among Financial Asset Securities Corp. as Depositor. Greenwich Capital Financial Products, Inc., as a Seller. Litton Loan Servicing LP, as Servicer, and US Bank National Association, as Trustee, Soundview Home Equity Loan Asset-Backed Certificates. Sertes 2000-1 vs, Malinda S, Meehan f/k/ a Malinda S. Rasmussen and Charles Meehan. Atty.: Frank Federman ALL THAT CERTAlN lot of ground with the improvements thereon erected Situate in Carlisle Borough, Cumberland County, Pennsylvania, bounded and described as follows: BEGiNNING at the Northeast comer Df lot formerly of Fillmore Mause, on North Hanover Street: thence in a Northeasterly direction along said North Hanover Street, 75 feet 10 inches to lot now or formerly of Lavrrence L. Shenk and MazjOIie L. Shenk, his wife; thence in a South- easterly direction along said last mentioned lot, 150 feet; thence in a Northeasterly direction along same, 9 feet; thence in a Southeasterly direction along same, 53 feet to a puhlic alley; thence along said alley in a Southwesterly direction, 103 feet to lot now or formerly of Mrs. Mowery; thence in a Northwesterly direction along said lot and other lots fronting on McBride Avenue, and said lot now or formerly of Flllmore Maust. 220 feet to North Hanover Str"i:et. t"te place of the be- ginning, and kp,own as 517 North Hanover Street, Carlisle, Pennsyl- vania. Together with any improvements thereon erected, be1ng known as 517 North Hanover Street, Carlisle, Pa 17013 TITLE TO SAlD PREMISES IS VESTED IN Malinda S, Meehan, for- merly Malinda S. Rasmussen, mar- lied woman by Deed from Raymond E. Diehl and Genevieve A. Diehl. husband and wife dated 6/30/98, recorded 7/17/98, in Deed Book 181. Page 706, Tax Parcel #02-20-1800-075, ~ .. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATE OF PENNSYL VANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the COlUlty 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 Joumal on the following dates, VIZ: APRIL 16,23,30,2004 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. ~ SWO 0 AND SUBSCRIBED before me this 30 day of APRIL 2004 SEAL LOIS E. SNYDER. Notary Public Carlisle BOlO, Cumbe~and County My Commission Expires March 5.2005 ~{)(j(j - 347" All -A1;"js prtt11' -1-0 11-/7-(J~ h.tuJ L. b e..~1\ fII\ t c,r" OPr IIt\ e.. J.. . A- off , ~ ,,"V'r+ .fo~A..&. t ^ ~(;O J.. -A II,.. J S i (Vtls!a.j,dl e.cJ.. .fllh'(J' J)afuJ.. II-jJ'-,).OO:l.,. . -- .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: CREDIT BASED ASSEST SERVICING AND SECURITIZATION, LLC ) CIVIL ACTION ) vs. MALINDA S. MEEHAN, F/KlA MELINDA S. RASMUSSEN CHARLES MEEHAN ) ) CIVIL DIVISION NO. .Q82-3476-CIVIL 00 - AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for CREDIT BASED ASSEST SERVICING AND SECURITIZATION, LLC hereby verify that on 8/27/02 & 11/4/02 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 8/27/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: November 12. 2002 ? - ~ ----- __ --c-..:::... ~_,____,__- ")-~" ____ _.::::r FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff c:l~~ .... 0. lllI r./l0.'S c. !'II .... !'II ;:$ ~ lllI ~ ~"';:$ N - .... 0. J:>- v> Cf'- IJl 1 ....- rfl -.1 ....- ....- ....- '-C - ....- v> N ....- 0 IJl J:>- ... ~Z~ ... ~%-~ ... ... .. '" '" ... ~ .. ~ t'!1 t'!1 S $!. ~ t'!1 ~ - ~ ~ ~ ~ .. .. " ... " " ~ ~ ,,: :<' 'i. g · "Cd,,~~,,~~,,~?~~~~~:ll~~~~9"~ ~ ~ O~~Z~~~~~~~":Z~:ll~~:ll~~d~~ ~ ~%~~%~~\\~\~\\~~\~~\t~~~~ \ ~~Q~~~~~~d~~i~~~;~\!~~~~i~ ~ " 'i 'il ~ <:; ~ ,. ~ '" '" .. " ,. ~ '" :ll ~ '" '" ,. ",'" r ~o~~~o~~~~~~~~~~o~;!i~~~~ ~= ~ c ...~<z~ ~cO~"d ~'" ~~,.~ ",0 ~ t:. " '0 ~ '" ... ~ ". t:. ~ 9!> ... ~ '" ",?' ~ ~ '" i z" ~ ,,:. ~... ...~ ...; 0 .. ~ d '" 9!> 't, ~Z ~ g ~ ~ ~". ,. ~~ 'i: "", ~ 2 ~ ~ <;; <:;... '" ~:ll 'il" ~ ~ ~ ... ~,. ~ '" " d ~ ~ ~ 9 ~,. ~?" . d ~ ~ ,,~ ~ ~? ~ ~ ~ .. Z <.'3 pos,.. ~ -,'?-' "Q oC/J ~'!'.Y' !~ OJ (;J.{:;';;"'" ~ . ~ ,~~ ",tNt' "",oNf,S ",^ .. $ 02.400 vi. \.~ 0004~003" . -." MPoI\.2.0 f\'~OM ZIP COOe. \.. . ~o~ ='Z~ ~~d ~i\ ~ 'Z 'JI-. ~(":I'Z $~~ _'Z~ !" .,.., % ~~~ ~,..r .-.~'JI- ~'C'"'Z 6'J1- ~toO OC~ .-.~ J:>-~ ~ ~ ... J:>- e:> e:> .' , :!;, !g - '" ~z N -= ~3 aQ" ,. Q"~ '-<! co ~... .. " c. ~ f;' ~ !!. !: ~ z .. c.= . 3 ~ "'Q" ~.. o ., ~co ~ 0:; Si ~ ~ a ~ ~~ :1 = ':I~ =-= '-<! . g =- _It :c ~ ,. ., - z . = ,. co ... f ~- ., :i" lJQ i'i~~3'" Sl~a!-=; I!S;C:;.S' ;;-=gg== ""S..=Sc. ;;o=l"S-~ ::c...,:aiO :...~=-......, ~-,".,Sl. llI:.s,""s- a~"S~= !..i~i-=2. ~'-<! i ~ ~ ., !!;.S....~ ~=;r-g.S!:; ~ ~al:.:;i. -",ft:sQ'"'t ""NS",~" 100.;; ..Y'::J=~i ~ ag~~":; ~ =':1 ~ i a ~ S'~ ~. co co "",,".fII:I= S'.ig;~~!!. -'l5.ft==- -oec2~c.. i~=C$g.e ;:;: ;; ~':I " .. . C,,-= "' C =- Cl:",.,~...- co-a':l"" =...!:".;-g: =.",~::=c. sa!:!'i. ~! =.S!:=~ ~~:;~i; ~ a.:;~= ..g..cog.~ ~i.". g-==::;- ~i:iiJ: _......::s r;;- ~t:!,;:-li =g"'=" ~.iaa ~..,e:,~i ~;gtJ::: ~. l~.., .,..=- 1:: ,. I' ~~~' ~j '""'--- - - - = '-0 QO .... "" ~ "" Ul N .. .. .. .. I"'lUl= >""0 ~~= _/'OlO ~~c ~..,~ !'~= ~S~ ::i=1"'l =~> -..,= ""~C ~~ ..,f; "z> : = ::t .. S - Q"!l .. .. ., 1"" S' .. !,>z ~c... ..C.3 = ~ "' c..... ~ '" ::I Cl. . "f- :; .. co .... > c. Cl. ., i .!t ~ i r- ~..,~ =.~~ iOOt::l c.~~ l!.l:" 'l:l,,:... ='I"'l~ P,.> ~=z >~Ro :c;~ --= =..~ Nt~ ~ > ~z .. '-0 g .. " Cl. ': ~ o :3 .. It > Cl. C. ., a .. . . ./ r 7160 3901 9844 9257 6001 TO: CHARLES MEEHAN 519 HAMILTON STREET CARLISLE, PA 17013 SENDER: KMD REFERENCE: SALES ..,..'C ~ l.~ ~ 1 ~J-';. J"NjI) .;J ;...., ~- I PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service POS ~ R DATE Receipt for Certified Mail ~ ~J . ... "-'~< -/' ./...../:~~ No Insurance Coverage Provided Do Not Use for International Mail '~~ . · Vel"" ~ 7160 3901 9844 9257 5998 TO: MALI~DA S. MEEHAN, F/KJA MELINDA S. RASMUSSEN 519 HAMILTON STREET CAP.LISLE, PA 17013 SENDER: KMD REFERENCE: SALES 1 TEAM-a, -] I ' ' PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail , ...1 ~ t___~_:~!.~=~~::~~~~:?_____ _____.__._______.____________.___.________________. -~ t"',l -::J 1H