HomeMy WebLinkAbout00-03507
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~REDIT BASED ASSET SERVICING AND
SECURITIZATION
CUMBERLAND COUNTY
Plaintiff,
COURT OF COMMON PLEAS
v.
CIVIL DMSION
MALINDA S. MEEHAN, F/KIA MALINDA S.
RASMUSSEN
CHARLES MEEHAN
NO. 00-3507 CIVIL
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No.1)
CREDIT BASED ASSET SERVICING AND SECURITIZATION, 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 .519
HAMILTON STREET. CARLISLE. PA 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 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:
MALINDA S. MEEHAN,
F/K/AMALINDA S. RASMUSSEN
519 HAMILTON STREET
CARLISLE, PA 17013
CHARLES MEEHAN
.519 HAMILTON STREET
CARLISLE, PA 17013
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
827 HAUSMAN ROAD
ALLENTOWN, PA 18104
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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)
AMERICAN GENERAL FINANCE
6S.HANOVERSTREET
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)
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)
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
PO BOX 2675
HARRlSBURG,PA 17105
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
13 NORTH HANOVER STREET
CARLISLE, P A 17013
TENANT/OCCUPANT
519 HAMILTON STREET
CARLISLE, PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
March 11. 2002
DATE
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Attorney for Plaintiff
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CREDIT BASED ASSET SERVICING AND
SECURITIZATION
CUMBERLAND COUNTY
Plaintiff,
No. 00-3507 CIVIL
v.
MALINDA S. MEEHAN, F/K/A MALINDA S.
RASMUSSEN
CHARLES MEEHAN
Defendant(s).
March 11, 2002
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 A TTEMPTING 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. 519 HAMILTON STREET. CARLISLE. PA 17013. is scheduled
to be sold at the Sheriffs Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 75.621. 70 obtained by
CREDIT BASED ASSET SERVICING ANDSECURITIZATION (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, ifthe 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 chalIce
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
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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 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 (0 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 ifthe sale never happened.
5, You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
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DES CRlPTIO "i
ALL THAT CERT.\I"i :rac: siruated in the Borough of Carlisle. Cumberland Coumy. Pennsylvania.
as follows:
ON the "iorth by Hamilton Street; on the East by lot now or formerly or' Laura Wert: on 'he Somh
by :m llley: on the West by lOt Jawor formerly of John Bender: Comaining 28 feet in ,'rom on
said Hamilton Street :llld extending in depth 120 fee: to said llley: and having erected thereon l tWO
lnd one-half story frame dweiling house. known lnd numbered as 519 Hamilton Scree:.
BEI"iG P:lreel i"06-20-1 SOO-061.
TITl.E TO S.-\[o PRE::vUSES IS VESTED I"i Charles :vleehan :md \',~iinda S \,[eeh:ln. husband
::Ind wife. by Deed from :vIalinda S R::Ismusse:l :;. i-,:, a :vIalinda S. :v[eehan and Charles :v[eehan dated
115,1906 reclJrdeJ Ii 26,]996 in Deed Book 1-"9 page -:"73
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
CREDIT BASED ASSET SERVICING AND
SECURITIZATION
Plaintiff,
v.
No. 00-3507 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
$75,621.70
Interest from 8/21/00 to 6/5/02
(per diem -12.43)
$8,116.79 and Costs
TOTAL
$83,738.49
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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.
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UNITED STATES BANKRUPTCY COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
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IN RE: Malinda S. Rasmussen
a.k.a. Malinda S. Meehan
Debtor
: CHAPTER 13
: BANKRUPTCY NO.00-05305 RJW
ORDER MODIFYING SECTION 362 AUTOMATIC STAY
AND NOW, this !h~~y of 9'~ 2002, upon Motion of Litton Loan Servicing, Inc.
(Movant), and after notice of default and the filing of a Certification of Default, it is
ORDERED AND DECREED THAT: The Automatic stay of all proceedings, as provided
by 11 U.S.C. 362 is modified with respect to premises, 519 Hamilton Street, Carlisle, PA
17013, as to allow the Movant to foreclose on its mortgage and allow the purchaser of
said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for
enforcement of its right to possession of said premises; and it is further
ORDERED AND DECREED THAT: Rule 4001 (a)(3) is not applicable and Litton Loan
Servicing, Inc. may immediately enforce and implement this order granting Relief from the
Automatic Stay.
(J?o-t~~~~
Robert J. Woodside, Bankruptcy Judge .
cc: Judith T. Romano, Esquire
Autherine B. Smith, Esquire
Jay B. Jones, Esquire
LeeAne O. Huggins, Esquire
Suite 1400/ One Penn Center at Suburban Station
Philadelphia, PA 19103-1814
Charles J. Dehart, III, Esquire (Trustee)
P.O. Box410
Hummelstown, PA 17036
JAN 1 6 2002
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?Irvine Row
Carlisle, PA 17013-3019
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DESCRIPTION
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ALL TH.-\T CERT.\IN tract situated in the Borough of Carlisle, Cumberland Count'j, Pennsylvania,
as follows;
ON the Nonh- bv Hamilton Street; on the East bv lor now or formerlv of Laura Wen; on the South
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by an alley; on the West by lor now or formerly of John Bender: Comaining 28 feet in from on
said Hamilton Street and extending in depth 120 feet to said alley; and having erected thereon a two
and one-half story frame dwelling house, known and numbered as 519 Hamilton Screet.
BEING Parcel #06-20-1800-061.
TITLE TO SAID PREMISES [S VESTED IN Charles y[eehan and \l:ilinda S. :'vleehan. husband
and wife. by Deed from !vlalinda S. Rasmussen :J..h:,a Malinda S. .'vleehan and Charles Meehan dated
11;5,1996 recorded 1126i!996 in Deed Book 1.+9 page 773.
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FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN
Identification No. 12248
Suite 1400
One Penn Center at Suburban Station
Philadelphia, PA 19103
(215) 563-7000
ATTORNEY FOR PLAINTIFF
CREDIT BASED ASSET SERVICING AND
SECURITIZATION
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
v.
CIVIL DIVISION
MALINDA S. MEEHAN, FIKlA MALINDA S.
RASMUSSEN
CHARLES MEEHAN
NO. 00-3507 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. e.s. Section 4904 relating to unsworn
falsification to authorities.
~EZ-~ffiE
Attorney for Plaintiff
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
Attorney for Plaintiff
CREDIT BASED ASSET SERVICING AND
SECURITIZATION
5373 WEST ALABAMA, SUITE 600
HOUSTON, TX 77056
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff
: CIVIL DIVISION
vs.
: NO. 00-3507-CIVIL
MALINDA S. MEEHAN,
F/K/A MALINDA S. RASMUSSEN
CHARLES MEEHAN
519 HAMILTON STREET
CARLISLE,PA 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/KIA MALINDA S. RASMUSSEN and CHARLES MEEHAN, Defendant(s), for
failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for
foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows:
As set forth in Complaint
Interest 5/1/00 TO 8/21/00
$73,622.73
$1.998.97
TOTAL
$75,621.70
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.
~fUlk. ~am
FRANK FEDE , ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED. /). ~.
DATE: IJ'-'9 .:2~".)CVD t;l:k4-b..; f)__
I PRO PROT
"THIS FIRM IS A DEBT COLLECTOR ATI'EMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISOIARGE IN BANKRUPTCY AND THIS DEBT WAS
NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATI'EMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ..
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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. 00-3507-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 ASSOCIA TlON
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
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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. 00-3507-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 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, P A 17013
(717)249-3166
Frank Federman, Esquire
Attorney for Plaintiff
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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
: CUMBERLAND COUNTY
: Court of Common Pleas
Plaintiff
: CIVIL DIVISION
vs.
: NO. 00-3507-CIVIL
MALINDA S. MEEHAN,
F/KIA 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, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act
of Congress of 1940, as amended
(b) that defendant MALINDA S. MEEHAN, F/KIA MALINDA S.
RASMUSSEN is over 18 years of age and resides at 519 HAMILTON STREET, CARLISLE,
PA 17013.
(c) that defendant CHARLES MEEHAN is over 18 years of age, and resides at
519 HAMILTON STREET, CARLISLE, P A 17013.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
F~E~/WntwL-
Attorney for Plaintiff
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(Rule of Civil Procedure No. 236 - Revised)
CREDIT BASED ASSET SERVICING
AND SECURITIZATION
: CUMBERLAND COUNTY
: Court of Common Pleas
Plaintiff
: CIVIL DIVISION
vs.
: NO. 00-3507-CML
MALINDA S. MEEHAN,
FfKJA MALINDA S. RASMUSSEN
CHARLES MEEHAN
Defendant(s)
Notice is given that a Judgment in the above captioned matter has been entered against you on
AUGUST:::2~ ,2000. .
,
___By ~tJAJI. .P ~~.fDEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESOUIRE
Attorney for Filing Party
SUITE 900
TWO PENN CENTER PLAZA
PHILADELPHIA. PA 19102
(215) 563-7000
**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. **
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-03507 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CREDIT BASED ASSET SERVICESING
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 0019:00 HOURS, on the 12th day of June
, 2000
at 519 HAMILTON ST
CARLISLE, PA 17013
by handing to
MALINDA 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
So Answers:
18.00
3.10
.00
10.00
.00
31. 10
~~"<4?~
R,.Thornas Kline
06/13/2000
FEDERMAN & PHELAN
Sworn and Subscribed to before By:
me this '7!5- day of
(J~ ~61tiJ A. D.
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rothonotary
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2000-03507 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CREDIT BASED ASSET SERVICESING
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 0019:00 HOURS, on the 12th day of June
, 2000
at 519 HAMILTON ST
CARLISLE, PA 17013
by handing to
MALINDA 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
6.00
.00
.00
10.00
.00
16.00
So ;~~I
R. Thomas Kline
06/13/2000
FEDERMAN & PHELAN
me
Sworn and Subscribed to before By:
this '7iz::- day of
~ a2ov-<J A.D.
~ (( /h,Pft:.; ~
~honotary
.
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FEDERMAN AND PHELAN
, By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PillLADELPHIA, PA 19102
(215) 563-7000
ATTORNEY FOR PLAlNTWF
COURT OF COMMON PLEAS
CIVIL DIVISION
CREDIT BASED ASSET SERVICING
AND SECURITIZATION
5373 WEST ALABAMA, SUITE 600
HOUSTON, TX 77056
Plaintiff
TERM
NO. ()J- 3507 -&v.J
v.
CUMBERLAND COUNTY
MALINDA S. MEEHAN,
F/K/A MALINDA S. RASMUSSEN
CHARLES MEEHAN
519 HAMILTON STREET
CARLISLE, P A 17013
Defendant( s)
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
**THIS FIRM [S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
I!'iFORMATlO:" 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 A TTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against 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 oumay lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, P A 17013
(717) 249-3166
Loan #: 8089823
-"
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1. Plaintiff is
CREDIT BASED ASSET SERVICING
AND SECURITIZATION
5373 WEST ALABAMA, SUITE 600
HOUSTON, TX 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
519 HAMILTON STREET
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 6/7/99 mortgagor(s) made, executed and delivered a mortgage npon the premises
hereinafter described to CONTIMORTGAGE CORPORATION which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 1550, Page 894. PLAINTIFF is now the legal owner of the mortgage and is in the
process of formalizing an assignment of same.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 2/11/00 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 dne thereon
are collectible forthwith. A copy of such notice is attached as Exhibit "A."
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6. The following amounts are due on the mortgage:
Principal Balance
Interest
1/11/00 through 5/1/00
(per Diem $17.69)
Attorney's Fees
Cumulative Late Charges
6/7/99 to 5/1/00
Cost of Suit and Title Search
Subtotal
$67,755.17
1,981.28
3,387.75
85.02
550.00
73,759.22
Escrow
Credit
Deficit
Subtotal
136.49
0.00
136.49
TOTAL
$73,622.73
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.
9. The CDmbined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. *1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accDrdance with Plaintiff's written Notice to Defendants,
a true and correct copy of which is attached hereto as Exhibit "A"; Dr
(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
$73,622.73, together with interest from 5/1/00 at the rate of$17.69 per diem to the date of
Judgment, and other costs and charges cDllectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
~,r~
/s/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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APPE:-'TIIX A
Page lof5
APPENDIX A
Date: 4/17/00
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE*
This is an official notice tnat.tbe..mortf!:a!!e on Your home is in default. and the lender intends to
foreclose. Soecific information. aho.u.t th,e..nature of the defauJtis orovided in the :-ttached oaf!:es.
The HOMEOWNER'S MORTG_<H~F." ASSISTANCE PROGRAM (REMAP) mav be able to
helD to save "our home. This Notice exnla.ins how to oro!!ram works.
To see if HEMAl' 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 vou meet with the Counseline: Af!'encv.
The name. address and chone number of Consumer Credit Counselinl! Al!encies sen.'in!! vour
Count", are listed at the end of the Notic.e.1f vou have any auestions~ YOU may call the Pennsylvania
"cusin!! Finance A!!ency toll fre.e_ _a.L_l:-800-342-2397 .fPersons with imoaired hearinl! can call
(717)780-1869.
'This :N"otice contains important legal information. If you have any questions, representath"es a1 the
Consumer Credit Counseling Agency may be able to help explain it. You may also ,",,"ant to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTlFCACION EN ADJUN1'O ES"DE SUMA IMPORTANCIA, PUES AFECTA SU DERECItO A
CONTlNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENlDO DE ESTA
NOTlFICACION OBTENGA UNA TRADUC:CION INMEDITAMENTE LLAMANDO ESTA AGENCIA
(PEN1IiSYL VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIO:'\ADO ARRIBA.
PUEDES SER ELEGIBLE PARA "UNPRESTAi\io poll. EL PROGRAMA "LLA.'I'lADO ~ItO~lEOWNER'S
El\1ERGE;';CY l\IORTGAGE:-ASSiSTANCt-PROGRAl\f" ELCUAL PlJEDE SALVAK SU CAS'"' DE LA
PERDlDA DEL DERECHO A REDiMJR SIf HTi>OTEC-A. - - ---
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No Insurance covera9tional Mail See reverse
_ 00 not use for lntema
sent\a
HO~(EOWNER'S NAME(S): Malinda Meehan
Charles Meehan
~IAILlNG ADDRESS:
519 Hamilto.u_Street_
Carlisle, PA 17013
PROPERTY ADDRESS:519 Hamilton Stnel
CarlisI.. PA 17013
LOAN ACCT. NO.:
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APPE)lDIX A
Page 2 of5
CL'RRE:-<T LENDER/SERVICE:
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SA VE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTAi'iCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTAl'OCE:
IF YOUR DEFAULT HAS BEEN CAUSED BV CIRCUMSTANCES
BEVOND YOUR CONTROL,
IF VOU HAVE A REASO:-iABLE PROSPECT OF BEING ABLE TO
PAY YOUR MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELEGIBILlTV REQUIREMENTS
ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TK\lPORARY 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
MUST 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.
CO:-\SUMER 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 telenhone numbers of
desi!mated consumer credit counse1in2: aQencies for the county in which the orouertv is located are set
forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your
lender immediatelv of your intentions.
APPLICATION FOR MORTGAGE ASISTANCE-Your mortgage is in default for the reasons
set forth later in this Notice (see following pages for specific information about the nature of your
default.) If you have tried and are unable to resolve this problem with the lender, you have the right to
apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To
do so, you must fill out, sign and me a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling agencies listed at the end of this
Kotice. 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 posnnarked within thirty (30) days of your face-to-face meeting.
YOl' "L'ST FILE YOUR APPLICATIO:-i PROMPTLY. IF YOU FAIL TO DO SO Ok IF yot; DO :-iOT
FOLLOWTHE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGEl'ICY ACTION - Available funds for emergency mortgage assistance are very limited. They
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lu'PENDIX A
Page 3 of5
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 aboye. 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 FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have tiled bankruptcy you can-still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOL'R MORTGAGE DEFAULT (Brim! it un to da).ti,
:\"A TURE OF THE DEF AUL T - The MORTGAGE debt held by the above lender on your property
located at: 519 Hamilton Street
IS SERlOCSL Y IN DEF AUL T because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following
months and the following amounts are now past due:
2/1 1/00 through April 2000 totaling $2,062.38
Other charges
Late Charges $ 0
Deferred late charges $ 131.7
TOTAL AMOUNT PAST DUE S2,062.38
B. YOU 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 TIIE TOTAL MOUNT PAST DUE TO THE LENDER,
WHICH IS $$2,062.38_, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavrr.'nts must be made
either bv cash, cashier's check. certified check or monev order made oavable and sent to:
Litton Loan Servicine LP. 5373 West Alabama. Suite 600. Houston. Texas 77056.
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date
of this leller: (Do not use if not 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 ri.-hls to accelerate
the morteaee 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
l;;;;~ftllJ/'r
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APPENDIX A
Page 4 of 5
to instruct its attorneys to start legal action to foreclose uPon vour mortl!al!ed propertv.
IF THE :\IORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by Ihe
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, if 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 550.00. Any attorney's fees will be added to the amount you owe the
lender, which may also include other reasonable cost. If von cure the default within the THIRTY
(30\ DAY oeriod. vou will not be reQuired to nav attornev's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have
the ri.ht to cure the default and mevent the sale at anv time UD to one hour before the Sheriff's Sale.
You mav do so bv Davin. the total amount then Dast due Dlus anv late or other char.es then due.
reasonable attornev's fees and costs connected with the foreclosure sale and anY other costs connected
with the Sheriff's Sale as sDecified in writin. bv the lender and bv Derforrnin. anv other requirements
under the mort!?:311e. 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 date of the Sheriffs Sale wiIl be sent to
you before the sale. Of course, the amount needed to cure the default will incre...e the longer you
wait. You may frod 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.
ASSIDIPTION OF MORTGAGE - You _ mayor _ may not (CHECK ONE) sell or
cransfer 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 mongage are satisfied.
EXHIBIT A
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APPENDIX A
Page 5 0[5
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 OCCURRED, 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.
CONSVMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
(Fill in a list of all Counselin!! A!!encies listed in Aooendix C. FOR THE COUNTY in which the
prooert\' is located. usinl! additional Dal!es if necessary).
CumberlaodCountv
CCCS of , Vest ern Pennsvlvania. Inc.
2000 Lin!!lestown Road
Harrisbur!!. P A 171 02
(717(541-1757
Financial Counselin!! Services of Franklin
31 West 3rd Street
Wavnesboro. P A 17268
(717\762-3285
Urban Lea!!ue of MetroDolitan Harrisbur!!
N. 6th Street
Harrisbur!!. P A 171 01
(71 n234-5925
F A."X(717\234-9459
YWCA of Carlisle
3001 G Street
Carlisle. P A 17013
(71 n243-3818
FAX(71 n731-9589
EXHIBIT A
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Communitv Action Comm of the CaDitat
R..non
1514 DerTY Street
Harrisbur\!. P A 171 04
(717)232-9757
F~"(717)234-2221
Adams CounlY Housin\! Authoritv
139-143 Carlisle St
Geltvsburl!. P A 17325
(717)334-1518
FAX(717)334-8326
EXHIBIT A
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ALL THAT CERTAIN tract situated in the Borough of Carlisle, Cumberland County, Pennsylvania, as follows:
ON the north by Hamilton Street; on the east by lot now or formerly of Laura West; on the south by an alley; on
the west by lot now or fo(ll1erly of John Bender; Containing 28 feet in front on said Hamilton Street and
extending in depth 120 feet to said alley; and having erected thereon a two and one-half story frame dwelling
house, known and numbered as 519 Hamilton Street
Being the same premises which became vested in Malinda S. Rasmussen by deed from Robert H. Rasmussen
and Frances A, RasmuS$Eln dated October 7, 1994 and recorded October 7,1994 in Record Book 113, page 60.
Parcel #0612011800/061
Premium Amount $604.60.
Endorsement $150.00. {3f!
~
PREMISES: 519 HAMILTON STREET
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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, infonnation
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: &/lf~t
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CREDIT BASED ASSET
SERVICING AND SECURITIZATION
Plaintiff
CIVIL DIVISION
vs.
No. 00-3507 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, hereby verify that on SEPTEMBER 15, 2000,
true and correct copies of the Notice of Sheriffs Sale were served by certificate of
mailing to the recorded Iienholder(s), and any known interested party, see Exhibit "A"
attached hereto, and the Notice of Sale was sent to defendant(s) on SEPTEMBER 15,
2000 by first class mail and certified mail return receipt requested, see Exhibit "B"
attached hereto.
Date: November 1, 2000
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MALINDA S. MEEHAN, FfK/A MALINDA S.
RASMUSSEN
519 HAMILTON STREET
CARLISLE, PA 17013
TO:.
SENDER:
REFERENCE:
DMK
SALES
PS FORM 3800 SEPrEMBER 1995
-
Certified Fee
RETURN
RECEIPT
SERVICE
Return ReceIpt Fee
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Total Poalageaod Fees
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Receipt for
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No Insurance Coverage Provided
Do not use for International Mail
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REFERENCE:
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PS FORM 3800 SEPTEMBER 1995
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RETURN
RECEIPT
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RestrIcted Dellvery
ToIaIPostageandFee$
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Receipt for
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Credit Based Asset Servicing and
Securitization,LLC
-vs-
Melinda S. Meehan F fK/ A Malinda S
Rasmussen and Charles Meehan
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 2000-3507 Civil
R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ
is returned STAYED.
Sheriff's Costs:
Docketing
Poundage
Advertising
Posting Bills
Law Library
County
Mileage
Certified Mail
Levy
Postpone Sale
Surcharge
Law Journal
Patriot News
Share of Bills
30.00
9.13
15.00
15.00
.50
1.00
6.20
.69
15.00
20.00
30.00
191.00
109.15
23.15
$ 465.82 by atty
12/07/00
Sworn and subscribed to before me
S(J.~." ,;/ii'!...:
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R. Thomas Kline, Sleriff
This .2 /....r day of ~
2000, A.D. ~a~-
P 0 onotary
B'(~, JJ,"fr
Real Estate Deputy
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CREDIT BASED ASSET SERVICING AND
SECURITIZATION
CUMBERLAND COUNTY
Plaintiff,
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
MALINDA S. MEEHAN,
F/K/A MALINDA S. RASMUSSEN
CHARLES MEEHAN
NO. 00-3507 CIVIL
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
CREDIT BASED ASSET SERVICING AND SECURITIZATION, 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 519 HAMILTON
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/K/A MALINDA S.
RASMUSSEN
519 HAMILTON STREET
CARLISLE, PA 17013
CHARLES MEEHAN
519 HAMILTON 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
827 Hausman Road
Allentown, PA 18104
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4. Name and address of the last recorded holder of every mortgage of record:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
American General
Finance
6 South Hanover Street
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 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.)
T enantlOccupant
519 HAMILTON 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
September 8. 2000
DATE
~~.~
F FEDE ,ESQUIRE---'
Attorney for Plai tiff
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CREDIT BASED ASSET SERVICING
AND SECURITIZATION
Plaintiff,
CUMBERLAND COUNTY
No. 00-3507 CML
v.
MALINDA S. MEEHAN,
FIK/A MALINDA S. RASMUSSEN
CHARLES MEEHAN
Defendant(s).
September 8, 2000
TO: MALINDA S. MEEHAN, FIK/A MALINDA S. RASMUSSEN
CHARLES MEEHAN
519 HAMILTON 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
BANKRUfTCY ANp :rJUS 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.""
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Your house (n;al estate) at 519 HAMILTON 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, Carlisle, P A 17013, to enforce the court judgment obtained by
CREDIT BASED ASSET SERVICING AND SECURITIZATION (the mortgagee) against you. If
the Sheriffs sale is postponed, the property will be relisted for the March 7, 2001 Sheriff's Sale.
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NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
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. You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
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.
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 TmS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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DESCRlPfION
ALL THAT CERTAIN tract siruated in the Borough of Carlisle. Cumberland County, Pennsylvania,
as follows:
ON the North by Hamilton Street; on the East by lot now or formerly of Laura Wert: on the South
by an alley: on the West by lot now or formerly of John Bender: Containing 28 feet in front on
said Hamilton Street and extending in depth 120 feet to said alley; and having erected thereon a two
and one-half story frame dwelling house. known and numbered as 519 Hamilton Street.
BEING Parcel #06-20-1800-061.
TITLE TO SAID PREMISES IS VESTED IN Charles yIeehan and Malinda S. Meehan, husband
and wife, by Deed from Malinda S. Rasmussen n.k;a Malinda S. Meehan and Charles Meehan dated
11/5/1996 recorded 11/2611996 in Deed Book 1-1-9 page 773.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 00-3507 CIVIL 19
CIVIL ACTION - LAW
TO THE SHERIFF OF
CUMBERLAND
COUNTY:
CREDIT BASED ASSET SERVICING AND
To satisfy the debt, interest and costs due
SECURITIZATION
PLAINTIFF(S)
MALINDA S. RASMUSSEN AND CHARLES MEEHAN, 519
fmm MALINDA S. MEEHAN flkla
HAMILTON ST., CARLISLE PA
17013.
i
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE LOCATED
AT 519 HAMILTON ST., CARLISLE PA 17013. (SEE ATTACHED LEGAL
DESCRIPTION. )
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(2) You are also directed to attach the property of the detendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) islareenjoine\il trompaying any
debIto or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) It property of the detendant(s) not levied upon an subject to attachment is found in the possession of anyone other
than a named garnishee, you are directed to notffy him/her that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $ 7 5,621. 70
Interest 8/21/00 - 12/6/00
($12.43/diem)
Atty's Comm
Atty Paid
L.L.
$.50
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$1, 330.01
Due Prothy
$1. 00
%
Other Costs
$119.10
Plaintiff Paid
Date:
September 12. 2000
CURTIS R. LONG
Pr honotary, Civil Division
Deputy
by: ~.
REQUESTING PARTY:
Name
Address:
Frank Federman, Esquire
Two Penn Center Plaza, Ste. 900
TRUE COPY FROM REeOHD
In Testimony WilllWQf, I !lere l.mto Slit my hand
and the seal of ~id Co a.t CaiUsla, Pel.
Thi -e:: ay ,;lb1Jl)
Philadelphia PA 19102
Attorney for: Plaint iff
Telephone: (215) 5637000
Supreme Court 10 No. 12248
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REAL EST A IE SALE No. ~
On ~i1t;".I,l. 5JA ~ the sneriff levied upon the d&lendantF
Interest in the real property situated in r;". itA a An___/-
C:umberland County, Pa., knoWiljnd numbered as: S;., ~.-.: /JI....JI
CluL.().L- and more 1l,'fld on Exhibit "A" filed witt
this writ and by this reference iH ~HT)orated herein.
rJate:,J~A1- .1... ~o.~ By;;2t";...- -dfL~
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AFFIDAVIT OF SERVICE
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CUMBERLAND COUNTY
PLAINTIFF
CREDIT BASED ASSET SERVICING AND
SECURITIZATION
No. 00-3507 CIVIL
DEFENDANT(S)
MALINDA S. MEEHAN,
FIKIA MALINDA S. RASMUSSEN
CHARLES MEEHAN
ACCT. #8089823
Type of Action
- Notice of Sheriff's Sale
SERVE MALINDA S. MEEHAN, FIKIA MALINDA S.
RASMUSSEN AT
519 HAMILTON STREET
CARLISLE, P A 17013
Sale Date: JUNE 5, 2002
~h SERVED rfh
Served and made known to ( 'N da 5'. If1, e '1...-k~tJ , Defendant, on the :2 f
at 5:;{.O , o'cloCk-fm., at-.5l9 It....) /rht-J /&vfL->) CA<<. \." k
day of /A?'-({, L \.. ,200.2.
, Commonwealth
ofPelll1sylvania, in the manner described below:
)< Defendant personally served.
__Adult family member with whom Defendant(s) residers). Relationship is
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place oflodging in which Defendant( s) resider s).
Agent or person in charge ofDefendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Other:
Description: Age~ Height_ Weight_ Race Sex Other
I, ~~I/Ic..- ;-I, (!OJ\.-fy , 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 Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated above.
"1"-'\1'" N~SEAI.
S d bib d EUlABETHM.JOHANSSON,NoI8IyNlo
worn to an su scr~ e ""GIll8Il8Twp,. FllII1k1in ~
befoI~ me \his ~ day!'; "" (iomIiilsslon ExpII!I8 Pee. 19. 2006
of jVJi,}~c.1.-. , 200~ .--fI ~
NotarY~1'h.~~By: ~ '
PLEA~ ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED.
NOT SERVED
On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because:
Moved Unknown No Answer Vacant
1 st Attempt: I I Time: 2nd Attempt: I I Time:
3rd Attempt: I I Time:
Sworn to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire - J.D. No. 12248
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AFFIDAVIT OF SERVICE
l'LAINTIFF
CU!vrBr:RLA~D COUNTY
CREDIT BASED ASSET SERVICING AND
SECURITIZATION
No. 00-3507 CIVIL
DEFENDANT(S)
MALINDA S. MEEHAN,
FIKIA MALINDA S. RASMUSSEN
CHARLES MEEHAN
ACCT. #8089823
---'"
Type of Action
- Notice of Sheriff's Sale
SERVE CHARLES MEEHAN AT
519 HAMILTON STREET
CARLISLE, PA 17013
Sale Date: JUNE 5, 2002
Served and made known to d9r\ I t-5' ~ eoektJ
at ,5':10 ,0'clockf-m.,at,571 i!a.1jU,,/defJ
SERVED ,~,
, Defe~r th\ df day of 140rcrcl , 200~
51-: / \ 5 e.- , Commonwealth
of Pennsylvania, in the manner described below:
Defendant personally served. ( _ \, ' . ,
X Adult family member with whom Defendant( s) reside( s). Relationship is'~ If'~'
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place of lodging inwh'ich DefendantCs) reside(s).
~'\g~nt or person in charg~ of Defclldant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
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Description: Age4IL- Heightf!i Weight.!Ji2. Race~SexL-- Other Me~. 1\
I, Lu:~' tie..- J-J. C[Lrj~ ' a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the ohce of Shenffs Sale I .. er as set forth herem, Issued m the captlOned case on the date and at
the address indicated above.
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M~~8t-!
Other:
Sworn to and su~d
bef~ me this day
of "y{C~ , 200';"
Notary:<-~, '1'Y\~~BY: '
PLEA~E ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED.
""." . NOTARIAL SEAL
EIJZ'ABE11:IM.~, N_Publlc
" ~T".. FllUIklln CountY
r:: _~QIl~'18SDec.19.2006
NOT SERVED
On the day of
,200_, at
o'clock _.m., Defendant NOT FOUND because:
Moved Unknown
No Answer
Vacant
IS1
Attempt:
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Time:
2nd Attempt:
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3rd Attempt:
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Sworn to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Attornev for Plaintiff
Frank Federman. Esquire - I.D. No. 12248
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CREDIT BASED ASSET SERVICING AND
SECURITIZATION
CUMBERLAND COUNTY
Plaintiff,
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
MALINDA S. MEEIIAN, FIK/A MALINDA S.
RASMUSSEN
CIIARLES MEEIIAN
NO. 00-3507 CIVIL
Defendant(s).
AMENDED AFFIDAVIT PURSUANT TO RULE 3129
(Mfidavit No. I)
CREDIT BASED ASSET SERVICING AND SECURITIZATION, 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 .519
HAMILTON STREET, CARLISLE, PA 17013 .
1. Name and address ofOwner(s) orreputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
519 HAMILTON STREET
CARLISLE, P A 17013
MALINDA S. MEEHAN,
FfK/A MALINDA S. RASMUSSEN
CHARLES MEEHAN 519 HAMILTON STREET
CARLISLE, P A 17013
2. Name and address of Defendant(s) in the judgment:
MALINDA S. MEEHAN, 519 HAMILTON STREET
FfK/A MALINDA S. RASMUSSEN CARLISLE, PA 17013
519 HAMILTON STREET
CARLISLE, PA 17013
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
CHARLES MEEHAN
Last Known Address (if address cannot be reasonably
ascertained, please indicate)
PENNSYL V ANlA POWER & LIGHT
827 HAUSMAN ROAD
ALLENTOWN, PA 18104
RAYMOND E. DIEHL, GENIEVE DIEHL
& MALINDA RASMUSSEN
401 MYERS ROAD
BOILING SPRINGS, P A 17007
4409 N. FRONT STREET
HARRISBURG,PA 17110
KEITH KENDALL PC
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4. Name and address oflast recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be reasonably
ascertained, please indicate)
AMERICAN GENERAL FINANCE
6S.HANOVERSTREET
CARUSLE,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)
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)
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
PO BOX 2675
HARRISBURG, PA 17105
TENANT/OCCUP ANT
13 NORTH HANOVER STREET
CARLISLE, P A 17013
519 HAMILTON STREET
CARLISLE, PA 17013
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
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.
MAY 28. 2002
DATE
~cf '" /IAN. ~ AA/Vt;7A/\.
FRANK FEDE , ESQUIRE
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE:
U.S 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 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,
WITHOUT RECOURSE
)CIVIL ACTION
)
vs.
MALINDA S. MEEHAN F/K/A
MALINDA S. RASMUSSEN
CHARLES MEEHAN
)
)
CIVIL DIVISION
NO. 00-3507 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
)
)
SS:
I, FRANK FEDERMAN, ESQUIRE attorney for U.SBANKNATIONAL
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 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, WITHOUT RECOURSE hereby verify that on 3/13/02 & 5/28/02 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. Notice of Sale was sent to the Defendant(s) on 3/13/02 by
certified mail return receipt requested see Exhibit "B" attached hereto.
DATE: June 5. 2002
~./AMJ/ ~~~
F NK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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71bO 3901 9844 7042 3013
MALINDA S, MEEHAN,
FIK/A MALINDA S. RA:SMUSSEN
519 HAMILTON STREET
CARLISLE, PA 17013
SENDER:
TEAM 5/IM
REFERENCE: MEEHAN, MALINDA
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71bO 3901 9844 7042 300b
CHARLES MEEHAN
519 HAMILTON STRIiET
CARLISLE, Pi\: 17013
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PS Fonn 3800 June 2000
RETURN Postage
RECEIPT Certified fee
SERVICE
Retum Receipt Fee
Restricted Delivery
Total postage & Fees
.34
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.7.14
US Postal Service
Receipt for
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SENDER:
TEAM 5/IM
REFERENCE: MEEHAN, MALINDA
PS Form 3800 June 2000
RETURN Postage
RECEIPT
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- 1 Total Postage & Fees
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FEDERMAN AND PHELAN, L.L.P.
BY: FRANK FEDERMAN, ESQUIRE
ATTORNEY !.D. NO. 12248
ONE PENN CENTER AT SUBURBAN
STATION, SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAmTWF
COURT OF COMMON PLEAS
CIVIL DIVISION
NO: 00-3507 CIVIL
CREDIT BASED ASSET SERVICING AND SECURITIZATION
v.
MALINDA S. MEEHAN FfK/A MALINDA S. RASMUSSEN
CHARLES MEEHAN
CUMBERLAND COUNTY
PRAECIPE TO MARK JUDGMENT TO USE OF PLAINTIFF
TO THE PROTHONOTARY:
Please mark the judgment in the amount of$75,621.70 in the above captioned
matter to the use ofU;S BANK N;'\TIONAL ASSOCIATION, AS TRUSTEE
UNDER THE POOLINGAN]) 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 SERVICER AND U.S. BANK NATIONAL
ASSOCIATION A-S'TRUSTEE,,SOUNDVIEW HOME EQUITY LOAN ASSET-
BACKED CERTIFICATES, SERIES 2000-1, WITHOUT RECOURSE, 180 EAST
5TH STREET, ST. PAUL,MN 55101. ~
PA/\^J./~
F FEDE , ESQUIRE
Attorney for Plaintiff
DATE: June 5. 2002
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf ofU.S 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 SELLER LITTON LOAN SERVICING LP AS SERVICER
AND U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE, SOUNDVlEW
HOME EQUITY LOAN ASSET-BACKED CERTIFICATES, SERIES 2000-1,
WITHOUT RECOURSE, 180 EAST 5TH STREET, ST. PAUL, MN 55101.
DATE: June 5. 2002
~'"~~~V"'-
F FEDERMAN,ESQUIRE
Attorney for Plaintiff
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.l 0lJ - 3507 ~
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND } SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriffs Deed in which US Bank N A Tr etal is the grantee the same having been sold to said
grantee on the 4th day of Sept A.D., 2002, under and by virtue of a writ Execution issued on the 13th
day of March, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2000
Number 3507, at the suit of Credit Based Asset Servicing & Securitization against Malinda S Meehan
fka Malinda S Rasmussen & Charles Meehan is duly recorded in Sheriff's Deed Book No. 254, Page
420.
IN TESTIMONY WHEREOF, I have hereunto set my hand
/p--ti
and seal of said office this
~
day of
,A.D. 2002
Recorder of Deeds
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Credit Based Asset Servicing and
Securitization
VS
Malinda S. Meehan fi'k/a Malinda S.
Rasmussen and Charles Meehan
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2000-3507 Civil Term
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states
that on April 10, 2002 at 8:10 o'clock PM, EDST, 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: Malinda S. Meehan fi'k/a Malinda S. Rasmussen, by making
known unto Malinda S. Meehan personally, at 519 Hamilton Street, Carlisle, Cumberland
County, Peunsylvania, its contents and at the same time handing to her personally the
said true and correct copy of the same.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, ~tates
that on Aprill 0, 2002 at 8: 10 o'clock PM, EDST, 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 Malinda S. Meehan,
wife of defendant, at 519 Hamilton Street, Carlisle, Cumberland County, Pennsylvania,
its contents and at the same time handing to her personally the said true and correct copy
of the same.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states
that on April 10, 2002 at 8:10 o'clock P.M., EDST, 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 fi'k/a Malinda S. Rasmussen and Charles Meehan located
at 519 Hamilton Street, Carlisle, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Malinda S. Meehan, fi'k/a Malinda S. Rasmussen, by regular mail to
herlast known address of519 Hamilton Street, Carlisle, PA 17013. This letter was
mailed under the date of April 15, 2002 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Charles Meehan, by regular mail to his last known address of 519
Hamilton Street, Carlisle, PA 17013. This letter was mailed under the date of April 15,
2002 and never returned to the Sheriff s 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, exposed the within described
premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County,
Pennsylvania, on September 4, 2002 at 10:00 o'clock AM. He sold the same for the sum
of $1.00 to Attorney Frank Federman for U.S. 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 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, without
.,L
..._"
recourse. It being the highest bid and best price received for the same, U.S. 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 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, without recourse of 4828 Loop Central Drive, Houston, TX
77056, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of
$617.76, it being costs.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Postpone Sale
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
$30.00
12.11
15.00
15.00
30.00
10.00
1.00
3.45
.85
15.00
30.00
20.00
200.30
155.35
25.20
25.00
29.50
$617.76 paid by attorney
9/30102
Swoffiand subscribed to before me
~~
.
This J1 ~ day of (Pc:a.........
2002, A.D. CJt. () tu_ I)"~I j~
Prothonotary
R. Thomas Kline, Sheriff
BUcLy~
Real Estate Deputy
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WRIT OF EXECUTION and/llr ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 00-3507 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CREDIT BASED ASSET SERVICING AND
SECURITIZATION PLANTIFF(S)
From MALINDA S.MEEHAN FIK/A MALINDA S. RASMUSSEN AND CHARLES MEEHAN
(I ) You are directed to levy upon the property of the defendant( s) and to sell SEE LEGAL
DESCRIPTION OF PROPERTY
(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 Due75,621.70
L.L.
Interest FROM 8/21/00 TO 6/5/02 (pER DIEM -12.43) $8,116.79 AND COSTS
Atty's Comm % Due Prothy $1.00
Atty Paid $597.42
Other Costs
Plaintiff Paid
Date:MARCIfI13,2002
CURTIS R. LONG
Prothonotary, Civil Division
~:
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REQUESTING PARTY:
Name FRANK FEDERMAN, ESQ.
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SillTE 1400
PIDLADELPIllA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ill No. 12248
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Real Estate Sale #60
On March 15, 2002 the sherifflevied upon the
defendant's interest in the real property situated in
Borough of Carlisle, Cumberland County, P A known
and numbered as 519 Hamilton Street, Carlisle
and more fully described on Exhibit "A" filed with
this writ and by this reference incorporated herein.
Date: March 15,2002
By: JcciLl S~
Real Estate Deputy
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CREDIT BASED ASSET SERVICING AND
SECURITIZATION
CUMBERLAND COUNTY
Plaintiff,
COURT OF COMMON PLEAS
,
,
1
v.
CIVIL DIVISION
MALlNDA S. MEEHAN, F/K/A MALlNDA S.
RASMUSSEN
CHARLES MEEHAN
NO. 00-3507 CIVIL
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3 I 29
(Affidavit No. I)
CREDIT BASED ASSET SERVICING AND SECURITIZATION, 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 ,519
HAMILTON 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/K/A MALINDA S. RASMUSSEN
519 HAMILTON STREET
CARLISLE, PA 17013
CHARLES MEEHAN
519 HAMILTON STREET
CARLISLE, PA 17013
2. Name and address of Defendant(s) in the judgment:
MALINDA S. MEEHAN,
F/K/A MALINDA S. RASMUSSEN
519 HAMILTON STREET
CARLISLE, PA 17013
CHARLES MEEHAN
519 HAMILTON STREET
CARLISLE, PA 17013
3. Name and last known address of every judgment creditor whose judgment is a record lien on the i'cal
property to be sold:
Name
Last Known Address (if address cannot be reasonably
ascertained, please indicate)
PENNSYLVANIA POWER & LIGHT
827 HAUSMAN ROAD
ALLENTOWN, PA 18104
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4. Name and address oflast recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be reasonably
ascertained, please indicate)
AMERICAN GENERAL FINANCE
6 S. HANOVER STREET
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)
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)
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
PO BOX 2675
HARRISBURG, PA 17105
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
13 NORTH HANOVER STREET
CARLISLE, P A 17013
TENANT/OCCUPANT
519 HAMILTON STREET
CARLISLE,PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
March 1 L 2002
DATE
~e7-~~ ?-~~/Vr--
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
_,,..J..
.>" .1
'llcl.,-
y CREDIT BASED ASSET SERVICING AND .
SECURITIZATION
CUMBERLAND COUNTY
,
Plaintiff,
No. 00-3507 CIVIL
v.
MALINDA S. MEEHAN, F/KIA MALINDA S.
RASMUSSEN
CHARLES MEEHAN
Defendant(s).
March 11,2002
TO: MALINDA S. MEEHAN,
FIK/A 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 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. 519 HAMILTON STREET. CARLISLE, PA 17013. is scheduled
to be sold at the Sheriff's Sale on JUNE 5. 2002 at 10:00 a.m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 75.621. 70 obtained by
CREDIT BASED ASSET SERVICING AND SECURITIZATION (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 Sheriff's Sale, you must take immediate action:
I. 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.)
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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. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened. ., .
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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DESCRIPTION
ALL THAT CERTAIN tract situated in the Borough of Carlisle. Cumberland County. Pennsylvania,
as follows:
ON the :'-iorth bv Hamilton Street; on the East bv lot now or formerlv of Laura Wert: on the South
, ~,
by an alley: on the West by lot now or formerly of John Bender: Comaining 28 feet in from on
said Hamilton Street and extending in depth 120 feet to said alley: and having erected thereon a cwo
and one-half story frame dwelling house. known and numbered as 519 Hamilton Street.
BEING Parcel /106-20-1800-061.
TITLE TO SAID PRE'vIISES IS VESTED IN Charles yleehan and \ialinda S. yleehan. husband
and wife bv Deed from ylalinda S. Rasmusse:J. :J.lca Malinda S. Meehan and Charles Meehan dated
. ,
1l!511996 recorded I l. 26/1996 in Deed Book 1-\.9 page Ti3.
C,_~,.,,,,,._,"___
_ BS<lWDE NII8 N0. lIll
Writ No. 2000-3507 CM!
Credit Based Asset Servicing
and Securitization
vs.
MalInda S. Meehan. flkl a
Malinda S. Rasmussen and
Charles Meehan
Atty.: Frank Federman
DESCRIPTION
ALL TIfAT CERTAIN tract situat-
ed in the Borough of Carlisle, Cum-
berland County, Pennsylvania, as
follows:
ON the North by Hamilton Street:
on the East by lot now or formerly
of Laura Wert: on the South by an
alley: on the West by lot now or for-
merly of John Bender: Containing
28 feet in front on said Hamilton
Street and extending in depth 120
feet to said alley; and having erected
thereon a two and one-half story
frame dwelling house, known and
numbered as 519 Hamilton Street,
BEING Parcel #06-20- 1800-061.
TITLE TO SAID PREMISES IS
VESTED IN Charles Meehan and
Malinda S. Meehan, husband and
wife, by Deed from MalInda S. Ras-
mussen. n/k/a Malinda S. Meehan
and Charles Meehan dated 11/51
1996 recorded II/26/1996 In
Deed Book 149 page 773.-
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. 1.1784
STATEOFPENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor ofthe Cumberland Law Journal, of the County
and State aforesaid, being du1y 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~or 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,
VIZ:
APRIL 26, MAY 3,10,2002
Affiant further deposes that he is authorized to verifY this statement by the Cumberland
Law Journal, a legal periodical of general circu1ation, 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
10 day of MAY. 2002
NOT.
LOIS E. SNYDER, Notary PublIc
ClirII8Ie ilom, Cumberfand County
My CommIs8Ion Expires Man:h 5, 2005
+ '........
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin} 55
Frank J. 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 continuousiy published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and pubiished in
their regular daily and/or Sunday! Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the
7th day(s) of May 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, piace 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 #60
worn tON%r.~ai'S'.!1.~cribed
Terry L. Russ~lI, Notary Publl
Harrisburg, Dauphin County
My Commission Expires June6, 2002 NOTARY PUBLIC
Memtler, PennsylVenla Ass_lion ot Nolaries My commission expires June 6, 2002
REAL ESTATE SALE No. 60
-',Writ No. 2000-3507
Civil Term
-" Cred. Based Asset
~rviclng and Securitization
-'. vs
~~Mallnda S. Meehan IMa
.~_"Mellnda S. Rasmussen
- - - and Charles, Meehan
... ,-Ally: Frank Federmsn
. DESCRIPT\ON
- ALLl'HATCERTAIN tract situated in the Borough
ofcarHs]e, Cumberland County, Pennsylvania, as
follows:
ON the North by Hamilton Street; on the East by Jot
now_or fonne.rly of Laura Wert; on the South by an
_ _alley; on the-West by lot now orfonnerly of John
Bender; Containing 28 feet in front on said Hamilton
Street and ex./cIding in depth 120 feet to said al!ey;
aoobaving ei~ted thereon a two and one-half story
fr~e.dweurnghouse, known and numbered as 519
HamiltQnStrect
, BElNGP""IJ\l6,20,ISIIO,061.
-UItE TO sAiD premises is vested in Charles
Meehan andM'aIindaS, Meehan, husband and wife,
by Deed frornMalinda S. Rasmussen a/kIa Malinda
S. Meehan arid Char]es Meehan dated 111511996
recorded llfZCl11990 in Deed Book 149 page 773.
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTI-lOUSE
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 $
153.60
1.75
155.35
Publisher's Receipt for Advertising Cost
)., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
ge receipt of the aforesaid notice and publication costs and certifies that the same have
By....................................................................