HomeMy WebLinkAbout02-6076FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQ., Id. No. 12248
LAWRENCE T. PHELAN, ESQ., Id. No. 32227
FRANCIS S. HALLINAN, ESQ., Id. No. 62695
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
215 563-7000
CENDANT MORTGAGE CORPORATION
FIXIA PHH US MORTGAGE SERVICE CORPORATION
6000 ATRIUM WAY
MT. LAUREL, NJ 08054
Plaintiff
V.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. U.;Z -- (00 ?L ou L' C?
SCOTT B. SINGISER CUMBERLAND COUNTY
718 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
Defendant(s)
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS 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, PA 17013
Loan #: 0002014686 (717) 249-3166
IF THIS IS THE FIRST NOTICE THAT YOU HAVE
RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. IF
DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO
BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
SEND DEFENDANT(S) THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT
FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT
UNTIL THE END OF THE THIRTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH
YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES
THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY
(20) DAYS, YOU MAY OBTAIN AN EXTENSION OF
THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY
(30) DAYS AFTER YOU HAVE RECEIVED THIS
COMPLAINT. HOWEVER, IF YOU REQUEST
PROOF OF THE DEBT OR THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS
UPON YOUR RECEIPT OF THIS COMPLAINT,
THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR
OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY
FOR ADVICE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
Plaintiff is
CENDANT MORTGAGE CORPORATION
F/K/A PHH US MORTGAGE SERVICE CORPORATION
6000 ATRIUM WAY
MT. LAUREL, NJ 08054
2. The name(s) and last known address(es) of the Defendant(s) are:
SCOTT B. SINGISER
718 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
On 2/1/99 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to MEMBERS FIRST FEDERAL CREDIT UNION which
mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in
Mortgage Book No. 1518, Page 282. By Assignment of Mortgage recorded 2/5/99 the
mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of
Mortgage Book No. 602, Page 1001.
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 06/01/2002 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.
6. The following amounts are due on the mortgage:
Principal Balance $121,758.76
Interest 4,925.62
05/01/2002 through 12/19/2002
(Per Diem $21.14)
Attorney's Fees 1,225.00
Cumulative Late Charges 234.18
06/01/2002 to 12/01/2002
Cost of Suit and Title Search $ 550.00
Subtotal $ 128,693.56
Escrow
Credit 0.00
Deficit 1,809.63
Subtotal $ 1.809.63
TOTAL $ 130,503.19
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. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or
Notice of Default as required by the mortgage document, as applicable, have been sent to
the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by
said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff
or an authorized consumer credit counseling agency, or has/have been denied assistance
by the Pennsylvania Housing Finance Agency.
9. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$ 130,503.19, together with interest from 12/19/2002 at the rate of $21.14 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
FEDE AN AND PHELA LP
By: ?(?+? s/
FRANK FEDERMAN, ESQUIRE
LAWRENCE T. PHELAN, ESQUIRE
FRANCIS S. HALLINAN, ESQUIRE
Attorneys for Plaintiff
All 1? THAT CERTAIN Cract or parcel of land and premises, situate,
lying and being in the Borough of Mechanicsburg, in the County of
Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING ac a stake on the building line of said South Market
Street at line of lands formerly of Ralph D. Mumma, now or late of
Raymond H. Green and Janith L. Green, his wire; thence westwardly
along the line zf said land, one hundred eighty (180) feet to a
point at line of other land formerly of Frank S. Mumma and
Katharine R. Mumma, his wife; thence northwardly along the line of
said last manti:pned land fifty-rive (55) feet, more or less, to
line of land focmerly of J. Heiks Paul, now or late of Elmer Lee
Ritter, Jr. and Gladys Ritter, his wife; thence eastwardly along
the line of sail last mentioned land, one hundred eighty (180) feet
to the said building line on South Market Street; thence
southwardly along said building line tifcy-five (55) teat, more or
less, to the plica of BEGINNING.
HAVING THER?ON erected a two story frame dwelling house known
and numbered as 71a South Market Street, Mechanicsburg, Pennsylvania.
BEING THE S.1ME PREMISES which Drew W. Murphy and Maria P.
Murphy, husband and wife, conveyed unto Scott B. Singiser and
Patricia A. Sin,3iser, husband and wife, by deed dated June 9, 1995
and recorded Jude 12, 1995 in the Recorders Office in and for
Cumberland Counl:y, Pa. in Record Book 123, Page 482.
VERIFICATION
MARC J. HINKLE hereby states that he is V.P. of CENDANT MORTGAGE
SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this
Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true
and correct to the best of his knowledge, information and belief. The undersigned understands that this
statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to
authorities.
DATE: /;? l l ? (J19-
r ? V?
`' ,
C
_ '?
? 5
V
n
W ? ? .?
'
?y?
f:.
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-06076 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CENDANT MORTGAGE CORPORATI
VS
SINGISER SCOTT B
CPL. MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
SINGISER SCOTT B
was served upon
DEFENDANT
the
, at 2043:00 HOURS, on the 8th day of January , 2003
at 701 LINDHAM COURT
MECHANICSBURG, PA 17055
SCOTT B SINGISER
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
8.97
/i'r?
.00
10.00 R. Thomas Kline
.00
36.97 01/09/2003 ???
FEDERMAN & PHELAI fi
Sworn and Subscribed to before BY:
me this 13`& day of
iAA•
g/ Kth- / Proonotary'
Deputy-Sheri
FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN
Identification No. 12248
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(2151 563-7000
CENDANT MORTGAGE CORPORATION F/K/A
PHH US MORTGAGE SERVICE CORPORATION
6000 ATRIUM WAY
MT. LAUREL, NJ 08054
V.
Plaintiff,
SCOTT B. SINGISER
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 02-6076
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against SCOTT B. SINGISER, 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 from 12/20/02 to 2/11/03
TOTAL
$ 130,503.19
$ 1,141.56
$ 131,644.75
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and
(2) that notice has been given in accordance with Rule 237.1, copy attached.
/i a-?Xk A /VYt CY
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDIC
DATE: as
22?. PRO PROTHY
FEDERMAN AND PHELAN
BY: FRANK FEDERMAN, ESQUIRE
Identification No. 12248
1617 John F. Kennedy Boulevard Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7800
CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE SERVICE
CORPORATION
Plaintiff
vs.
SCOTT B. SINGISER
Defendant(s)
TO: SCOTT B. SINGISER
1001 LINDHAM COURT, APT #701
MECHANICSBURG, PA 17055
DATE OF NOTICE: JANUARY 29, 2003
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 to 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
Attorney for Plaintiff
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: CUMBERLAND COUNTY
: NO. 02-6076
C Lx ?( LsZ J
5
Frank Federman, Esquire
Attorney for Plaintiff
i
S
V
'
`
r
t ''1 -
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
CENDANT MORTGAGE CORPORATION F/YJA .
PHH US MORTGAGE SERVICE CORPORATION :
Plaintiff,
V. No. 02-6076
SCOTT B. SINGISER
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest from 2/12/03 to 6/11/03
(per diem -$21.64)
$ 131,644.75
$ 2,596.80 and Costs
TOTAL
$ 134,241.55
C.
' .UVL
FEDE AN, 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.
d
OW O
W > F rj ?
w?
°?- 1:60 O C7 ? 0-0
u Grr c
O
" ? Ud.,
W C7 F 0.4 F L
OUz
w? goo 3 c
O o
w F7_, d U
FA A?
0-.4
U
w ?
o a
p
r, ,
0
-o ? -o
w
v
ti
? M
r
ALL THAT CERTAIN tract or parcel of land and premises, situate,
lying and being in the Borough of Mechanicsburg, in the County of
Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a stake on the building line of said South Market
Street at line of lands formerly of Ralph D. Mumma, now or late of
Raymond H. Green and Janith L. Green, his wife; thence westwardly
along the line of said land, one.hundred eighty (180) feet to a point
at line of other land formerly of Frank B. Mumma and Katharine R.
Mumma, his wife; thence nouthwardly along the line of said last
mentioned land fifty-five (55) feet, more or less, to line of land
formerly of J. Heiks Paul, now or late of Elmer Lee Ritter, Jr. and
Gladys Ritter, his wife; thence eastwardly along the line of said last
mentioned land, one hundred eighty (180) feet to the said building
line on South Market Street; thence southwardly along said building
line fifty-five (55) feet, more or less, to the place of BEGINNING.
TAX PARCEL# 16-24-0787-115
PREMISES BEING KNOWN AS: 718 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
TITLE TO SAID PREMISES IS VESTED IN Scott B. Singiser by Deed
from Scott B. Singiser and Patricia A. Singiser, his wife, dated 2/1/1999
and recorded 2/5/1999 in Record Book 193, Page 1024.
r
V 77i?
nV-
1
(T1
N
V1 e
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-6076 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CENDANI MORTGAGE CORPORATION, f/Wa PHH
US MORTGAGE SERVICE CORPORATION Plaintiff (s)
From SCOTT B. SINGISER, 1001 LINDHAM COURT, APT #701, MECHANICSBURG PA
17055.
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 718 S. MARKET ST., MECHANICSBURG PA 17055 (SEE ATTACHED
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) 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $131,644.75
Interest 2/12/03 TO 6/11/03 @ $21.64 per diem
Atty's Comm %
Arty Paid $118.97
L.L. $.50
Due Prothy $1.00
Other Costs
Plaintiff Paid
Date: FEBRUARY 13, 2003
(Seal)
REQUESTING PARTY:
CURTIS R. LONG
Protho tary
By:
D putt'
Name FRANK FEDERMAN, ESQ.
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JFK BLVD., SUITE 1400
PHILADELPHHIA PA 19103-1814
Attorney for: PLAINTIFF
Telephone: (215) 563-7000
Supreme Court ID No. 12248
FEDERMAN and PHELAN, LLP
By: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
CENDANT MORTGAGE CORPORATION F/K/A
PHH US MORTGAGE SERVICE CORPORATION :
6000 ATRIUM WAY
Plaintiff,
V.
SCOTT B. SINGISER
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 02-6076
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 SCOTT B. SINGISER is over 18 years of age and resides at , 1001
LINDHAM COURT, APT #701, MECHANICSBURG, PA 17055.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unworn falsification to authorities.
FEDE AN, ESQUIRE
Attorney for Plaintiff
?, -
E__
_?
r---?
(,
? ? -
f
,
t ?'
FEDERMAN and PHELAN, LLP
By: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
CENDANT MORTGAGE CORPORATION F/K/A
PHH US MORTGAGE SERVICE CORPORATION
V.
Plaintiff,
SCOTT B. SINGISER
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 02-6076
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 unworn
falsification to authorities.
C
F FEDERMAN, ESQUIRE
Attorney for Plaintiff
?. -
c-
_..?
??
CENDANT MORTGAGE CORPORATION F/K/A
PHH US MORTGAGE SERVICE CORPORATION :
V.
SCOTT B. SINGISER
Plaintiff,
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 02-6076
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
ivJlqJ]K I GAGE SERVICE
Plaintiff in the above action, by its attorney, FRANK FEDERMAN, SQUIRE, sets
forth as of the date the Praecipe for the Writ of Execution was filed the following information
concerning the real property located at, 718 SOUTH MARKET STREET MECHANICSBURG PA
17055.
1. Name and address of Owner(s) or reputed Owner(s):
Name
SCOTT B. SINGISER
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
1001 LINDHAM COURT, APT #701
MECHANICSBURG, PA 17055
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)
None
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)
MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS INC. P.O. BOX 2026
FLINT, MI 48501-2026
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
None
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
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
Tenant/Occupant
Domestic Relations of Cumberland County
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
718 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
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 of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
February 10, 2003
DATE
?&'K L
an?
FEDE AN, ESQUIRE
Attorney for Plaintiff
r,j
,
f
'
CENDANT MORTGAGE CORPORATION FWA
PHH US MORTGAGE SERVICE CORPORATION
Plaintiff,
V.
SCOTT B. SINGISER
Defendant(s).
CUMBERLAND COUNTY
No. 02-6076
February 10, 2003
TO: SCOTT B. SINGISER
1001 LINDHAM COURT, APT #701
MECHANICSBURG, PA 17055
* *THIS FIRMIS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANYINFORMATION
OBTAINED WILL BE USED FOR THATPURPOSE. IF YOUHAVEPREVIOUSLYRECEIVED A DISCHARGEIN
BANKRUPTCYAND THIS DEBT WAS NOTREAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
ANATTEMPTTO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINSTPROPERTY. **
Your house (real estate) at 718 SOUTH MARKET STREET MECHANICSBURG PA
17055, is scheduled to be sold at the Sheriffs Sale on JUNE 11.2003 at 10:00 a.m. in the Cumberland
County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of
$131_,645 obtained by CENDANT MORTGAGE CORPORATION F/K/A PHH US
MORTGAGE SERVICE CORPORATION (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:
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.)
Y V U 1V1H 1 V A xLL aia. -?-- -
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
56
find out the price bid by calling 51563-7000.
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, PA 17013
(717) 249-3166
(800) 990-9108
ALL THAT CERTAIN tract or parcel of land and premises, situate,
lying and being in the Borough of Mechanicsburg, in the County of
Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a stake on the building line of said South Market
Street at line of lands formerly of Ralph D. Mumma, now or late of
Raymond H. Green and Janith L. Green, his wife; thence westwardly
along the line of said land, one.hundred eighty (180) feet to a point
at line of other land formerly of Frank B. Mumma and Katharine R.
;Mumma, his wife; thence northwardly along the line.of said last
mentioned land fifty-five (55) feet, more or less to line of land
formerly of J. Heiks Paul, now or late of Elmer Lee Ritter, Jr. and
Gladys Ritter, his wife; thence eastwardly along the line of said last
mentioned land, one hundred eighty (180) feet to the said building
line on South Market Street; thence southwardly along said building
line fifty-five (55) feet, more or less, to the place of BEGINNING.
TAX PARCEL# 16-24-0787-115
PREMISES BEING KNOWN AS: 718 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
TITLE TO SAID PREMISES IS VESTED IN Scott B. Singiser by Deed
from Scott B. Singiser and Patricia A. Singiser, his wife, dated 2/1/1999
and recorded 2/5/1999 in Record Book 193, Page 1024.
("1 -.
?.. <.
`? ;'
f - '
?" " ..
? J.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RTGAGE
RE: CENDANT MORTGAGE CORPORATION F/K/ CIVIL ACTION
SERVICE CORPORATION j
VS.
SCOTT B. SINGISER
CIVIL DIVISION
NO. 02-6076
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA ) SS:
COUNTY OF CUMBERLAND )
I, FRANK FEDERMAN, ESQUIRE attorney for CENDANT MORTGAGE
CORPORATION F/K/A PHH US MORTGAGE SERVICE CORPORATION
hereby verify that on 2/12103 & 4/22/03 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: May 8, 2003 FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
rl
A i-V -3 uj
o o A . r .r r~ ~O oo J rn
H E ~ .• W N
4 at
W <D
m
a Z
C
3
Q
W
x -?
1z O
0 "
No
oro CO)
m
a
0
N
& O
o ? A
?ro
O
S.
oc
?g "k.9V
0
6+ c`i w
N ? M O b
n ? 8 ° N
O ? C
a•w? °'a
0
? ? O 8
7 d
F4 v
43 .0 00
0
Wv
c 5-, -
u.
y
0
E7, ?' 7
d 7
o E:?a
0
w_ ? 8 w
f0? c
G
0
L
G
e
'oyG?n v'nx0
c?
n v' ?d ? 'd ? H
t
n o
n
e
i
ti
A
a
CL
a
C) a?
? d
o cu ?
Fd? ? n
W ? d
0 0
r
?C
?aa r
d r-•
O
C O
O
t ? ? d Y $?wES Q
$ o0. 203
g12
?gR?4JiZIP?`'De y;y3
16
DJI?1Lc'D
?•'°°?SdSq\
r EI
GUU4 4 i 9g]
vs;
a?
a?
m
y
a
1
go
(z
it
. ?d
s?
N
N
d?
or
?y
a N
'a
P U
C
r
Cr
ro
r
?x
0
O
c?
?
c ?' ;
`_
?
??: ?
,_
c : .. _ -.
r-=
.? { - - -,
--- -
AFFIDAVIT OF SERVICE
PLAINTIFF CENDANT MORTGAGE CORPORATION
F/K/A PHH US MORTGAGE SERVICE
CORPORATION
DEFENDANT(S) SCOTT B. SINGISER
SERVE SCOTT B. SINGISER AT
1001 LINDHAM COURT, APT #701
MECHANICSBURG, PA 17055
Served and made known to !5,r,4 e, at It, V,o'clock 'l,,.m., at
001
CUMBERLAND COUNTY
KMD
No. 02-6076
ACCT. #0002014686
Type of Action
- Notice of Sheriffs Sale
Sale Date: JUNE 11, 2003
Defendant, on the S? day of 2003
?? / r
Ck( ? 70 ( W? e CU aOl ?, Commonwealth
of Pennsylvania, in the manner described below:
Defendant personally served. ( ? 7 -? v ? rQ
Adult family member with whom Defendant(s) reside(s). Relationship is d
Adult in charge of Defendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place of lodging in which Defendant(s) reside(s).
Agent or person in charge of Defendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Other: -'
I If
r I , ?0? OJ ?-
Description: Age Height JrC? Weight ? Race LL Sex Other w
ici. v c M OL L ? R.. a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of tliNotice 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. NOTMKWAL
ELIZABETH M. JOHAKWM, Nfty pft
Sworn to and subsc ed Greene T"x FtBnlalff Co ft
befor, a this IN- y 9l?
of IM kL , 200
No By:
PLE ATTEMPT SERVICE AT LEAST 3 TIMES. I ICATE D ES TIMES OF SERVICE ATTEMPTED.
NOT SERVED
On the day of , 200_, at o'clock _.m., Defendant NOT FOUND because:
Moved Unknown No Answer Vacant
1St Attempt: Time: 2°d Attempt: Time:
3rd Attempt: / / Time:
Sworn to and subscribed
before me this day
of , 200
Notary: By:
SERVED
Attorney for Plaintiff
Frank Federman, Esquire - I.D. No. 12248
F '
-
T) ?.
i
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND I SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Federal Home Loan Mtg Corp is the grantee the same having been sold to
said grantee on the 11th day of June A.D., 2003, under and by virtue of a writ Execution issued on the
13th day of Feb, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Tenn, 2002
Number 6076, at the suit of Cendant Mtg Corp against Scott B Singiser is duly recorded in Sheriff's
Deed Book No. 257, Page 4770.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this 3 day of
, A.D. 2003
R?a?Iy 1 R corde of Deeds
ft, mbedww Cafte, PA
MY con m uion Expirea? the FFiM . of JnL 2006
Cendant Mortgage corporation Fk/a In The Court of Common Pleas of
PHH US Mortgage Service Corporation Cumberland County, Pennsylvania
VS Writ No. 2002-6076 Civil Term
Scott B. Singiser
Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states
that on March 31, 2003 at 6:28 o'clock PM, she 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: Scott B. Singiser, by making known unto Scott B. Singiser, personally,
at 1001 Lindham Court, Apt. #701, Mechanicsburg, Cumberland County, Pennsylvania,
its contents and at the same time handing to him personally the said true and correct copy
of the same.
Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states
that on April 07, 2003 at 2:36 o'clock P.M., she posted a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Scott B. Singiser located at 718 South Market Street, Mechanicsburg,
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 one of the within
named defendants, to wit: Scott B. Singiser, by regular mail to his last known address of
1001 Lindham Court, Apt. #701, Mechanicsburg, PA 17055. This letter was mailed
under the date of April 07, 2003 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 June 11, 2003 at 10:00 o'clock A.M. He sold the same for the
sum of $1.00 to Attorney Frank Federman for Federal Home Loan Mortgage
Corporation. It being the highest bid and best price received for the same, Federal Home
Loan Mortgage Corporation of Foreclosure Unit, Mail Stop 61, P.O. Box 5000, Vienna
VA 22183-5000, being the buyer in this execution, paid to Sheriff R. Thomas Kline the
sum of $710.02.
Sheriffs Costs
Docketing $30.00
Poundage 13.92
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 15.87
Certified Mail
Levy 15.00
Surcharge 20.00
Law Journal 246.80
Patriot News 207.19
Share of Bills 25.24
Distribution of Proceeds 25.00
Sheriffs Deed 39.50
$ 710.02
Sworn and subscribed to before me
This q`=' day of
2003, A.D. C
Prothonotary
So w
R. Thomas Kline, Sheriff
' BY JbcJ ?M.J.T.?^?
Real Estate eputy
30 ' a
C?
7
Cn
pt", 13 9P
Real Estate Sale # 65
On March 14, 2003 the sheriff levied upon the
defendant's interest in the real property situated in
Mechanicsburg Borough, Cumberland County, PA
known and numbered as 718 South Market Street,
Mechanicsburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: March 14, 2003 By: Jodi{
Real Estate Deputy
D?
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
JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. Commonwealt Controller of The Patriot News Co., a corpo of business at 812 existing 818dMarketlaws
Street inethe C ty of Harrisburg,
Pennsylvania, with its principal office and place
County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September
18th, 1949, respectively, and all have been continuously published ever since; and
ished That the printed notice or publication which is securely tonhthe 22nd and 29th day(s)rlof April andblhe 6thln
their regular daily and/or Sunday/ Metro editions which appeared
to time, place and character of publication notice or
day(s) of May 2003. That neither he nor oflthis ostatement lase the
advertising, and that all of the allegations
true; and verify That he has personal knowledge of athe facts aforesaid and is duly foresaid by virtue and pursuantauthorized
resolut on unan'mouslyt pa sed ands
statement on behalf of The Patriot News C
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
ffie for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
the o c
Volume 14, Page 317.
PUBLICATION
COPY
S A L E #65
REAL ESTATE SALE No. 65
Writ No. 2002-6076
Civil Term
Cendpant Mortgage
Cor PHH US tMortg ge
Service Corp.
Scott B. Singiser
VS
Atty: Frank Federman
DESCRIPTION
ALL THAT CERTAIN tract or parcel of land
and premises, situate, ifing and being in the
Borough of Mechanicsburg, to the County of
Cumberland and Commonwealth of
Pennsylvania, more particularly described as
follows:
BEGINNING at a stake on the building line of
said South Market Street at line of lands formerly
of Ralph D. Mumma, now or late of Raymond H.
Green and Janith L. Green, his wife; thence
westwardly along the line of said land, one
hundred eighty (180) feet to a point at line of
other land formerly of Frank B. Mumma and
M his wife; thence
...............
....
.. ......
Sworn to and su sc bed before rpe t is 14th day o kfAay 200 D.
I Notarial Seal
Fussell, Notary Publ1
Ay +arrsr.: rg, )auphinCounry N rARY PUBLIC
nv " SrYrrs?:.. txptresJune6,2006
fvlember. Pennsylvania Association Ot Nota ' y 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 205.44
hereto on the above stated dates $ 1 .75
Probating same Notary Fee(s) $
Total $ 207.19
Katharine R. umma, publisher's Receipt for Advertising Cost
northwardly alone the line of said last mentioned
The Patriot News Co., publisher of The Patriot-News and The Sunday 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. land fifty-five (55) feet, more or less, to line of
land formerly of J. Heiks Paul, now or late of
Elmer Lee Ritter, Jr. and Gladys Ritter, his wife;
thence eastwardly along the line of said last
mentioned land, one hundred eighty (180) feet to
the said building line on South Market Street;
thence southwardly along said building line fifty-
five (55) feet, more or less, to the place of
BEGINNING.
TAX PARCEL NO.: 16-24- 0787-115.
PREMISES BEING KNOWN AS: 718 South
Market Street, Mechanicsburg, PA 17055.
TITLE TO SAID PREMISES is vested in Scott
B. Singiser by Deed from Scott B. Singiser and
Patricia A. Singiser, his wife, dated 2/1/1999 and
recorded 2/511999 in Record Book 193, Page
1024.
By .....................................
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
APRIL 25, MAY 2, 9, 2003
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.
RL+'AL ESTATE SALE NO. 65
Writ No. 2002-6076 Civil
Cendant Mortgage Corporation,
f/k/a PHH US Mortgage
Service Corporation
vs.
Scott B. Singiser
Atty.: Frank Federman
ALL THAT CERTAIN tract or par-
cel of land and premises, situate,
lying and being in the Borough of
Mechanicsburg, in the County of
Cumberland and Commonwealth of
Pennsylvania, more particularly de-
scribed as follows:
BEGINNING at a stake on the
building line of said South Market
Street at line of lands formerly of
Ralph D. Mumma, now or late of
Raymond H. Green and Janith L.
Green. his wife: thence westwardly
along the line of said land, one hun-
dred eighty (180) feet to a point at
line of other land formerly of Frank
B. Mumma and Katharine R. Mum-
Lis Mariee Coyne ditor
SW TO AND SUBSCRIBED before me this
9 day of MAY, 2003
j
C 3n 2005
3
_
ma, his wife; thence northwardly
along the line of said last mentioned
land fifty-five (55) feet, more or less,
to line of land formerly of J. Heiks
Paul, now or late of Elmer Lee Ritter.
Jr. and Gladys Ritter, his wife: thence
eastwardly along the line of said last
mentioned land, one hundred eighty
(180) feet to the said building line on
south Market Street: thence south-
wardly along said building line
fifty-five (55) feet, more or less, to
the place of BEGINNING.
TAX PARCEL # 16-24-0787-115.
PREMISES BEING KNOWN AS:
718 SOUTH MARKET STREET,
MECHANICSBURG, PA 17055.
TITLE TO SAID PREMISES IS
VESTED IN Scott B. Singiser by Deed
from Scott B. Singiser and Patricia
A. Singiser, his wife, dated 2 / 1 / 1999
and recorded 2/5/1999 in Record
Book 193, Page 1024.
Lawrence J. Neary, Esquire
108-112 Walnut Street
Harrisburg, PA 17101-1609
(717) 238-4798
(717) 238-4793 - Fax
Email: Ijnearyesq@aol.com
KAREN J. CHASE, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2003-6076
DUSTIN R. RADER, CIVIL ACTION - LAW
Defendant
JURY TRIAL DEMANDED
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please mark the above captioned action ended, settled and discontinued and all
costs have been paid.
Respectfully Submitted,
C
Date: it
Lavyf ce J. N a , Esqu
Attey for PI i iff
108 - 112 Wal t Street
Harrisburg PA 17101-1
(717) 238-4798
(717) 238-4793 - Fax
Pa. I.D. No. 25827
ii
CERTIFICATE OF SERVICE
I, Lawrence J. Neary, Esquire, attorney for the Plaintiff, hereby certify that I have on
the date shown below served a copy of the foregoing Praecipe to Discontinue to the
person and in the manner indicated below:
UNITED STATES FIRST CLASS MAIL, POSTAGE PREPAID
Jefferson J. Shipman, Esquire
Johnson, Duffie, Stewart and Weidner, P.C.
301 Market Street
Lemoyne, PA 17043
Date: y1 I
Respectfully Submitted,
Lawre ce J. Ne , Esquire
Attey for Plai iff
108-112 Walnut Street
Harrisburg PA 17101-16 9
(717)238-4798
(717)238-4793 - Fax
PA I.D. No. 25827