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Home My WebLink About00-07540 _~'~ ~ J .,1" "i'.?). SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-07540 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST UNION NATION BANK OF DEL VS MILLER SHEILA J ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT MILLER SHEILA J A/K/A BRUDOWSKY SHEILA J but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , MILLER SHEILA J A/K/A BRUDOWSKY SHEILA J RETURN NOT FOUND AS PER JASON RICCO ON 11/3/00, DEFT. NO LONGER RESIDES AT GIVEN ADDRESS.. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 9.92 5.00 10.00 .00 42.92 ~ R. Thomas~--' ~_/ Sheriff of Cumberland County FEDERMAN & PHELAN 11/06/2000 Sworn and subscribed to before me this ~~ day of~ :Ja-v-o A.D. Q,~(). ~ ~ P 0 honotary , ",'I FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 A TIORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION FIRST UNION NATIONAL BANK OF DELAWARE, F/KI A FIRST UNION HOME EQUITY BANK, N.A. 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607 TERM Plaintiff v. NO~- 7-5""1..(0 c(."I CUMBERLAND COUNTY SHEILA J. MILLER, AIKJ A SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, P A 17025 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against 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. We hereby certify the within to be a true and com'lct copy of the original filed of record FEDERMAN AND PHELAN CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 9794151 TRUE COpy FROM RECORD In Testl~Wh8I'8Of.lhere unto. my !lane and the _ of said Court at Cal'IlsIe._Pa, Th~)Uc4cL1Jm~_ N;( 1. Plaintiff is: FlRST UNION NATIONAL BANK OF DELAWARE, F/K/ A FlRST UNION HOME EQUITY BANK, N.A. 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607 2. The name(s) and last known addressees) of the Defendant(s) are: SHEILA J. MILLER, A/KJA SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 3/9/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1254, Page 815. 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 9115/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." '",I ~, ' ~ """i . 6. The following amounts are due on the mortgage: Principal Balance Interest 8/15/99 through 9/1/00 (Per Diem $7.53) Attorney's Fees Cumulative Late Charges 3/9/95 to 9/1/00 Cost of Suit and Title Search Subtotal $22,615.38 2,883.99 800.00 227.64 550.00 $27,077.01 Escrow Credit Deficit Subtotal 0.00 0.00 $ 0.00 TOTAL $27,077.01 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. Notice of Intention to Foreclose h~s been sent to Defendant(s) by Certified Mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania on the date(s) set forth in the true and correct copy(s) of such notice(s) attached hereto as Exhibit "A". 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "B"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $27,077.01, together with interest from 9/1/00 at the rate of$7.53 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. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff L~ L .- '...:.],; I~' ~' 'i, , FEDERMAN AND PHELAN, L.L.P. Suite 900 Two Penn Center Plaza Philadelphia, PA 19102-1799 215-241-1711 Fax: 215-568-7617 Representing Lenders in Pennsylvania and New Jersey September 19, 2000 CERTIFIED MAIL Sheila J. Miller, a!k!a Sheila J. Brudowsky 1044 Hemlock Lane Enola, PA 17025 Re: Loan No. :9794151 NOTICE OF INTENTION TO FORECLOSE We represent Fi~st Union MOrtgage Corporation, servicer for the holder of a mortgage on your prop'erty located at 1044 Hemlock Lane - Eno1a, PA 17025, which mortgage is in SERIOUS DEFAULT because you have not made the monthly payment of $299.88 for 9/15/99 through 9!15/00 and or because N/A. Late charges (and other charges) have also accrued in the amount of $258.39. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $4,156.83. 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 ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereOf; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, this firm will send you the name and address of the original creditor if different from above. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $4,156.83, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made in the form of certified check, cashier's check or money order, and made at Suite 900, Two Penn Center Plaza, Philadelphia, PA 19102. If you do not cure this default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly payments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a lawsuit to foreclose on your mortgaged property. G}{HtaiT A - 1 - . , I~ :~~ ~or~ga;e ~5 ~cr~c~csed, yc~~ mcr~;3ge~ ~r=~er:' ~'___ te s::d t. _ :t~~~~f :: ?aj Gf~ ~he rncr~gage debt. ~: yo~ cure ~~e cefa~~: te~8re ~e be~ - 2.ega.l proceedings agains'C you, you will st.ill na~le to pa:; tr.e reasonab e attorney's fees actually incurred up to $50.00. However, if legal proceedings are starLed against you, you will have to pay the reaso~able attor~ey's fees eve~ if r:--1ey are over SSO.OO. ?_.r:y attorney's fees wi=-2. De added t8 I,v'hat.ever Y01..: Gi-ie ~S/ wnich ma] also include our reasonable costs. ~: yo~ cure tjis defa~lt withi~ the thirty day period, you will not be required to pay the attorney's fees. YOU HAvE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDINGS THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAvE TO ACCELERATION AND FORECLOSURE. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total due, as well as ~he reasonable attorney's fees and costs incurred in connection with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's Sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at a.ny time exactly what the required payment will be by calling us at the following number: (215) 241-1711. This payment must be in the form of certified check, cashier's check or money order and made payable to us at the address stated above. You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's Sale, a lawsuit could be started to evict you. You have additional rights to help protect your interests in the property. YOU 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 OFF THIS DEBT (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED.) CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS MIGHT EXIST. YOU HAvE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure this default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Very truly yours, ::~E!f;.A:lL~ Fra~Federrnan FF: 11 cc: First Union Mortgage Attn:Kirn Johnson CERTIFIED MAIL NOS.: Corporation Loan No. :9794151 7099-3220-0011-0272-2537 - 2 - ll)(H1B\i A ~- , ~I,' '", I .'" ..., "~~i . ALL that e.r4al~ tr.e~ or parcel ot land and pre.i.eSr si~uat~, Iv!n, and be!n, i~ the lownship or East Pennsboro, County of CUlberlanrl, and COD.on..ellth of Penn.vIYlnia, 1I0re puUeularly detle..ibed a. tallow. I BEGINNING at I point on the .outh~rn ..i9"t of WIV line of H~aloek Lane I eo..on co..~.r at lot Not, 43 and land now a.. forll.l'ly af 8tln Hutlehln.onl thence 110ng .Iid ritht af VIY I1nl South 77 deg..I.. 22 1I1nutes EI.t 85.00 fe.t to I poi~t, co..on co..nlr at Lots No.. 4Z and 431 thene. Ilont laid Lot Ho. 42, South 12 de,r..s 38 .lnute. W..t, 120.00 fe.t to a point, at lands now 0.. torllerly of Stan HutlehlnlonJ t~.nee alont .aid lands North 77 dlgrel. ~2 Dlnute, WI.t, 89.65 re.t to a poln\, a cOII.on corne.. of Lot No. 43 Ind lands now or tOD..er1v at 1\ln Hutichinlonl thence along said lan~. North 14 dp.t...e. 51 IIlnutl' 14 .econd. EI.t IZO.09 teet to a point, the place at BEGINNING. CONTAIMING 10,479 aquare teet. 8EINe Lot No. 43 a. ahoun o~ Fi~al Subdivision Plln No. 5 af T"..Dont prepar.d by D. P. Raften.p.rg~r Alloclat.. at Caap Hill, dated August 25, 1997 a~d ..eco..ded In the Office of thp Reco..de.. ot D.lds In and tor CVDberland County .t Plan Baak 53, pa~. 1~9. PREMISES ON: 1044 HEMLOCK LANE, ENOLA, PA 17025 ;.m . ,'.~ '~,'il~" . VERIFICATION JOHN SCHWEPPE hereby states that he is LEAD SPECIALIST of FIRST UNIION MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this maller, that he is au.thorized to take this Verification, and that the statements made in the foregoing Civil Action in ;....lortgag~ Fo,ec1osure 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. CS. Sec. 4904 relating to unsworn falsification to authorities. /L-J;~~, DATE: /O/cRO/on f { ~~ ~;:,""';'~J'"."'~Ir."';"'~ 1M 'J!MR~lIi<' ~" ~'\ .. '~~i''''''''''imfi1 ';Jllit";';"""'-" c _~, . > ' ~~ ,'" ~ ~<,." ~ '~~"-'~ "', '-:'l I' , '_ ",_, u, I' I I I, ,. i ii I'; , " I:) ~@~It-\ :f~,,\~' .~~ "J~~.,.. ,," n " , I J . ~~~".~",,!!Ilr~" FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. !.D. #69849 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 7.1 ~) ~()1-7000 FIRST UNION NATIONAL BANK OF DELAWARE, F/K/A FIRST UNION HOME EQUITY BANK, N.A. ATTORNEY FORPLAmTITF COURT OF COMMON PLEAS CIVIL DIVISION Vs. CUMBERLAND COUNTY SHEILA J. MILLER NO. 2000-7540 CRRTTFTCATTON OF SRRVTCF, I, Michele M. Bradford, Esquire, herby certifY that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individual( s) as indicated below by first class mail, postage prepaid, on the date listed below. SHEILA 1. MILLER 1044 HEMLOCK LANE ENOLA, PA 17025 The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: Novemher 11 7000 , /}10c1Jt }J;. ~ Michele M. Bradford, Esquire Attorney for Plaintiff H:/Main Forms/rnotions/county.comp L, .~, ~"'~~"~ FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff FIRST UNION NATIONAL BANK OF DELAWARE, F/K/A FIRST UNION HOME EQUITY BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. SHEILA J. MILLER, A/K/A SHEILA J. BRUDOWSKY Cumberland County No. 2000-7540 Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ~ , ESQUIRE Plaintiff Date: December 5, 2000 i"'" '~," ~_' '~~'''.''~~~!:!im!iti!t'l~ii~~~_m~'llJlitjj(&.iM ,..[ ~ ,~ -~,,~ , '.,' (' ,,,..',_",v "h'" ,," ~ ~o", >''=''"''', -'." ~". L ~ II:IIlIIW'; ~i iii \-i: Ii: ~ j;! \'.11 iI " ,::1 j Iii ".'1 :1 fi, n "I :'1 'I III ','I " L ill "I Iii :11 " 'i I III 'I II I I I I I, I, 'I !I 0 co () c 0 -n ;;;: C) "Um i-'1 n1'.(:"n " ...- z-' -'-' ,1'",'j Z~ 0 (/) .' co -<2 ~~~:~) ~C-~ ~'O PC) ::a;: ~;~ z - >8 N ~ 'JI ~ ~7 0 "< ,;l .^ --- ..,~...".....,~ - '. --,I,: ~'; "~"" "II . ,-' .<.. '-, l FEDERMAN AND PHELAN BY: FRANKFEDERMAN,ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 161 7 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (? 1 'i) 'ilii-7000 Attorney for Plaintiff FIRST UNION NATIONAL BANK OF DELAWARE, FIK/A FIRST UNION HOME EQUITY BANK, N.A. : COURT OF COMMON PLEAS : CNIL DNISION Plaintiff vs. : CUMBERLAND COUNTY SHEILA J. MILLER, NKJA SHEILA 1. BRUDOWSKY : NO. 2000-7540 Defendant( s) AFFIDAVIT OF SERVICE OF COMPLAINT RV M i\lT. PTTRSTTi\NT TO COTTRT ORfiF,R I hereby certifY that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to SHEILA J. MILLER, AlKJ A SHEILA J. BRUDOWSKY at 1044 HEMLOCK LANE, ENOLA, P A 17025 on /'1-- ')')-. UO, in accordance with the Order of Court dated NOVEMBER 21, 2000. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: n"~"mh,,r?? ?OOO q-/lUIM 1:.- <;)~ ~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff "'~""'""",' . ~;!tJl~~Mli~4~1~_ur"".'~~lM;Mi~,\A;,)f,;,,,,~ob.O!W.;&WfjU~m'ij";"'m:' ..;'~".n' ,',.' ..'" ~:"'~'~~M ,-- ", -_. ''''''~''~ii!Il!l~1I "C", _ ,~"C' ,j..," '~'~1Si.l1iMlll tillUlI , , (") c:' ;".1 c 0 ~:: C1 uG ",'1 __e, fTJ'fT'; "- .' -- Z::r' N H ze -," 5!~ ~0 ...j ,<c ~ "~~ YC:: ~ .....,,~ Zo '-P. :>c:. CJ ---1 ~ W )> <0 32 ~ . ," '''", ,>~, ^"'?'.~, ~ - 1,1.- .1 --'-"'--C=~i,_ FEDERMAN AND PHELAN .... . By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff FIRST UNION NATIONAL BANK OF DELAWARE, FIK/A FIRST UNION HOME EQUITY BANK, N.A. 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607 Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION vs. : NO. 2000-7540 SHEILA J. MILLER, AIKIA SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, PA 17025 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 SHEILA J. MILLER. A/K1A SHEILA J. BRUDOWSKY, 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 9/1/00 to 1/30/01 $27,077.01 $1.144.56 TOTAL $28,221.57 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ~ J-dMJ4A.g RANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY AllSESSED All INDlCAlED. ~ DATE: _ h ).3/ ';,)1')01 (],~ ) I), - , PRO PRO **THlS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** -" _"j~-~, l_ ," ~ ." 'hm}lit, , FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire IO$ntification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF i. FIRST UNION NATIONAL BANK OF DELAWARE, F/K/A FIRST UNION HOME EQUITY BANK, N.A. COURT OF COMMON PLEAS ( CIVIL DIVISION Plaintiff CUMBERLAND COUNTY NO. 2000-7540 y f , vs. SHEILA J. MILLER, A/K/A SHEILA J. BRUDOWSKY , Defendant(s) II... .... ~- --&,./Y TO: SHEILA J. MILLER, A/K/A SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, PA 17025 DATE OF NOTICE: JANUARY 12. 2001 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 . '''-'.~',-\: , ,~' , . ---J. 1"';;'~.1_.......J~ < >~;Ijl)> . FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff FIRST UNION NATIONAL BANK OF DELAWARE, F/K1A FIRST UNION HOME EQUITY BANK, N.A. : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 2000-7540 SHEILA J. MILLER, A/K1A SHEILA J. BRUDOWSKY Defendant(s) VERIFICATION OF NONcMILITARY 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 ofthe 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 SHEILA J. MILLER, A/KIA SHEILA J. BRUDOWSKY is over 18 years of age and resides at PRESENT WHEREABOUTS UNKNOWN. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1A~ 7-~ FRANK FEDERMAN Attorney for Plaintiff " , ~- " .'-", ,', -!II,)" . (Rule of Civil Procedure No. 236 - Revised) FIRST UNION NATIONAL BANK OF DELAWARE, F/K1A FIRST UNION HOME EQUITY BANK, N.A. Plaintiff : CUMBERLAND COUNTY : Court of Common Pleas : CIVIL DIVISION vs. : NO. 2000-7540 SHEILA J. MILLER, AIKIA SHEILA J. BRUDOWSKY Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on FEBRtJMtY ~. J a.v~( ...3/, d-CO 1 ~y L p . 27t-;;u,-y, (DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 **TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ~~~~!f&M!;l~~f~~'*lN,_,~'t<Mdl!ijM!ft""",,".irn~;5!\'dill.~~l%"~ft<"";" ''" "O-~ ~~I ....~......' "~~, -<- -.;~ ~. , (:J ~ ~ ~ ....0 i & 0 c c .j C ,l s: '- -oc-o '"'" f mm ~~ i.-;-:1":: Z:x;; ~ ~ ........ U zr W -,-! :";"'1 (f))> ~- ........ -<~,:. i --J ~ p~ r<(.) r-, 1 "D 0 )>-rj 3: :<; =r: ~ Z..... ;;~~h~ -W' ---0 "- )>C '-,,/ ~~ t z "'" .....0>' ~ CO ::D -< --C" -. ^~,. '^' ~, ._,,,_~~ ._,_ or _ .~ r-' _,,' _ --~ ,'.~,,^,.~~ .. .___J. 1",,",",L",~.k.~ .'''~G..,,~_~ "~Rl('> FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 FIRST UNION NATIONAL BANK OF DELAWARE, FfKlA FIRST UNION HOME EQUITY BANK, N.A. 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607 ATTORNEY FOR PLAmTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. JeaJ-7S'/O c. 'i v,1 v. CUMBERLAND COUNTY SHEILA J. MILLER, A/KJA SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, P A 17025 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS 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 wamed that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. 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 (717) 249-3166 Loan #: 9794151 'c ," ~ 1. Plaintiff is: FIRST UNION NATIONAL BANK OF DELAWARE, F/KJA FIRST UNION HOME EQUITY BANK, N.A. 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607 2. The name(s) and last known addressees) of the Defendant(s) are: SHEILA J. MILLER, AIKIA SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 3/9/95 mortgagor( s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1254, Page 815. 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 9/15/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit" A." , / - ~ ''1 c~'t\:~,i J. I: ~', .1 ..~ ~ .ilh~,..j 6. The following amounts are due on the mortgage: Principal Balance Interest 8/15/99 thTough 9/1/00 (Per Diem $7.53) Attorney's Fees Cumulative Late Charges 3/9/95 to 9/1/00 Cost of Suit and Title Search Subtotal $22,615.38 2,883.99 800.00 227.64 550.00 $27,077.01 Escrow Credit Deficit Subtotal 0.00 0.00 $ 0.00 TOTAL $27,077.01 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose has been sent to Defendant(s) by Certified Mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania on the date(s) set forth in the true and correct copy(s) of such notice(s) attached hereto as Exhibit "A". 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "Boo; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $27,077.01, together with interest from 9/1/00 at the rate of$7.53 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. /l1rucFe /~ FRANK FEDE , ESQUIRE Attorney for Plaintiff r.1 .",,~ I ,-.".'_. J:,=,~,;_'_ .M:L~ FEDERMAN AND PHELAN, L.L.P. Suite 900 Two Penn Center Plaza Philadelphia, P A 191 02-1799 215-241-1711 Fax: 215-568-7617 Representing Lenders in Pennsylvania and New Jersey September 19, 2000 CERTIFIED MAIL Sheila J. Miller, a/k/a Sheila J. Brudowsky 1044 Hemlock Lane Enola, PA 17025 Re: Loan No.:9794l5l NOTICE OF INTENTION TO FORECLOSE We represent First Union MOrtg~ge Corporation, servicer for the holder of a mortgage on your property located at 1044 Hemlock Lane - Enola, PA 17025, which mortgage is in SERIOUS DEFAULT because you have not made the monthly payment of $299.88 for 9/15/99 through 9/15/00 and or because N/A. Late charges (and other charges) have also accrued in the amount of $258.39. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $4,156.83. 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 ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, this firm will send you the name and address of the original creditor if different from above. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $4,156.83, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made in the form of certified check, cashier's check or money order, and made at Suite 900, Two Penn Center Plaza, Philadelphia, PA 19102. If you do not cure this default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly payments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a lawsuit to foreclose on your mortgaged property. f!XHtBIT A - 1 - - . c, .",1,1,";'( ",I" ~ , c, '", ;;,- .-;, _~,' ,__ ".'.,r 'c';'" If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure this default within the thirty day period, you will not be required to pay the attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDINGS THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU ~Y HAVE TO ACCELERATION AND FORECLOSURE. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total due, as well as the reasonable attorney's fees and costs incurred in connection with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's Sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (215) 241-1711. This payment must be in the form of certified check, cashier's check or money order and made payable to uS at the address stated above. You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's Sale, a lawsuit could be started to evict you. You have additional rights to help protect your interests in the property. YOU 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 OFF THIS DEBT (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED.) CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure this default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Very truly yours, FEDE~A:JL~ By: A4J. ~ Frank Federman FF:ll cc: First Union Mortgage Attn:Kim Johnson CERTIFIED MAIL NOS.: Corporation Loan No.:9794151 7099-3220-0011-0272-2537 - 2 - r8tMle\T A ALL that cer~aln tr.~t or parcel of land Ih~ pre.t.es, situI'e. Iv!n, Ind betn, in the Township or EI.t Penn.boro. County of Cuaberlan~. Ind Co..onw'llth of P.nn.vlYanta. eor. plrticularlY de.erib.d I' tollowsl IEGINNING at . point on the .outh~rn ri9~t of WIY line 01' H..lock Lan. . CODaon Corner of Lot No.. 43 and land nON or tor..rly of Itan Hutiehln.on' thene. .lonl I.id rllh\ or WIY 11n. South 77 delreel ZZ einutes Ea.\ 85.00 1'..\ to a pOint. eO.llin corner 0,' Loti NOI. 42 and 43' th.nee a10nl said Lot No. 42. South 12 de.r... 38 .inute. W..t, 120.00 re.' to a point. at land. now or 'ore.rly of Stan Hu\lchln.on' thence alon, .ald lands North 77 d.,r...~% Ilnute. N.,t. .9.65 r.et to · point. a eOI.on earner of Lot No. 43 Ind lands now or tOlr.rlv of Itan Hutiehinsonf thenee alon, said 1.n~' North 14 d~tre.' 51 Itnute, 14 seeonds Ee.' 120.09 f.et to . point. the place or BEGINNING. CONTAINING 10,479 Iquare f..t, BEING Lot No. 43 a. Ihown on Final Subdlvi.lon Plan No. S 01' TrePlont prep#red bv O. P. Rlft.n,perl4r AI.oellte. of Ca.p Hill. dat.d AUlust 25. 1987 and recorded In the Office ot thp Reeord.r of D..ds In and for Cu.b~rl.nd Covntv It Pl.n Boo~ 53. plve 149. PREMISES ON: 1044 HEMLOCK LANE, ENOLA, PA 17025 ""-~ ~ 1.- ';t",< VERIFICA nON JOHN SCHWEPPE hereby states that he is LEAD SPECIALIST of FIRST UNIION MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoiug Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. jL./.y DATE: /O/cRO/on , { , . ' , ~~<liW~_ """"'~"~"~Im;ID\~~~",".Y_:<*,l,~~"li:,fi-~ . . ~~.. <. -. .. ~ ~ li ", i I' I,' I,: I;i if :i: :1, t I'ii.' i: ,;, II' 'Ii Iii 'i; !i , ,. , ( VI C; 0 C. ....r:: ] <::::\- ~ Ot ....c [1" ;, --, !') ~ ~ Y'> () .. ~ / ' '-".,) 0 U (' . va ~. 'C) --0 0 C~: ;..'~ ~'I", ~. < .' w ':S- ~ ';>''- ' , '"" :tF.o":: , ~ -t .D ,a. ~ /.~) "-. ~ 4 ..-:::'" ;',...! .J- -...j ':::> ~o ~ ;?1 -' (j'j , -< ~ ~ i '3d 0;;\ SS' ;> ~I~ .,,~~ . . ~:. ." ~z~ "}J' -I. oh... ;;tl~ -l ,'sm: ~~*-1 ~~~~,' ;0: tj: -< : i' ,-- ,--", _,~"~~'. ,-, "'..r, ".P . .,^,' '~',w__,_" "".^, H~'-""~'-_;"",~" .,..'C' ;; ''"'"'.''' "..<, ~ ," ',\ ".,~ , '.. ". ,,",: " ..","o!-'r.~~'l'.." " .0 - """."_~' ..~ ,=,_. ,'" ~~",,' "" ~~ .,,, :i "'-~" . ~ l ~I '-"':i!~7 , , ., FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. I.D. #69849 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (? 1 ~) ~h1-7000 ATTORNEY FORPLAINTITF FIRST UNION NATIONAL BANK OF DELAWARE, F/K/A FIRST UNION HOME EQUITY BANK, N.A. COURT OF COMMON PLEAS CIVIL DMSION vs. CUMBERLAND COUNTY SHElloA J. MILLER NO. 2000-7540 ,-;r- ORDER AND NOW, this;;; day of ~ ,2000, upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of Court and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), SHEILA J. MILLER, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the Defendant's last known 'address, and to the mortgaged premises located at 1044 HEMLOCK LANE, ENOLA, P A 17025. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. BY t~ 411 I J- :0..-00 RX~ H:lMain Forms/motions/county.comp ,~,'" ~'_' ~'~I\fiI;J~flmil!t<4I~JM:M~~*-.JiU""jlk.llvflH.H"'~,,*,i~-"'1~t~-=-- ~"'"- lri~ \iir,lVi\~}.,SNN:'3d }J 1\i'"'/",; -',', /-"t! 1""'-11'1'1'1'-'" IJ\I L: ' "', ".'.' :,:")/'d 1\,) "" ~,; lJ (,., leD / / 't.-'; Ab\'lC , ..^" ~~'^',,' ~."~. "I ~.^' ,^~ ".~,-^ ~, ~, iiIIIiilllll " ~, ~~ "''Ilbiii~'-- .~ ~ N >, 1 J8Ujjl['ili! ~ ~ ~:~., w, " c 'I, '. r,j"- 'F'" , . , ' FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. J.D. #69849 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 ? 1 'i) 'i1l1-7000 FIRST UNION NATIONAL BANK OF DELAWARE, FIK/A FIRST UNION HOME EQUITY BANK, NA ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY SHEILA 1. MILLER NO. 2000-7540 THIS FIRM IS A DEBT COLLECTORATTEMPTmG TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VB PREVIOUSLY RECEIVED A DISCHARGE m 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. MOTION FOR SERVICE PURSUANT TO SPF.CT A L ORDRR OF c:mrnT Plaintiff, by its counsel, Michele M. Bradford, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by Certified mail and regular mail to the Defendant's last known address and mortgaged premises located at 1044 HEMLOCK LANE, ENOLA, P A 17025 and in support thereof avers the following: 1. Attempts to serve Defendant( s) with the Complaint have been unsuccessful, as indicated by the Sheriffs Return of Service attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results is attached hereto as Exhibit "B". H:/Main Fonns/motions/county.comp "" ~ ,~ 'JOiiJ;~~%f,t~ , ' 3. Plaintiff submits that it has made a good faith effort to locate the defendants, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail. Michele M. Bradford, Esquire /fUt.dvJ} 171. H;/Maitl Forms/motions/county.comp , "II. ~ ~ ,"' , , ~". ~ L';': . 1'1." ." ~'J._ . . FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. J.D. #69849 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (? 1~) ~1i1-7000 FIRST UNION NATIONAL BANK OF DELAWARE, F/KIA FIRST UNION HOME EQillTY BANK, N.A. ATTORNEY FOR PLAINTITF vs. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 2000-7540 SHEILA 1. MILLER MF.MORANllTTM OF LA W Pennsylvania RuIe of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to detennine the whereabouts of the Defendant(s) and the reasons why service cannot be made. Note: A Sheriffs return of "Not Foundll or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evid~ce of concealment. r,.nn7~I~" V" Pnli" 238 Pa. Super. 362, 357 A2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address. II Arlnptinn nfWAlk~T 468 Pa. 165,360 A2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom oflnfonnation Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Sheriff's Return of Service, attached hereto and marked as Exhibit "A", the Sheriff has been unable to serve the Complaint. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit "B". WHEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and reguIar mail. Respectfully submitted: /fh1'rlv.t 7h ~ Michele M. Bradford, Esquire H:/Main Fonns/motions/county.comp ~~ ., C" ~~'~f.illl!&>irtw~,;" SHERIFF'S RETURN - NOT FOUND , . CASE NO: 2000-07540 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF fUMBERLAND 0{ FIRST UNION NATION BANK OF DEL VS MILLER SHEILA J ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT MILLER SHEILA J A/K/A BRUDOWSKY SHEILA J but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , MILLER SHEILAJ A/K/A BRUDOWSKY SHEILA J RETURN NOT FOUND AS PER JASON RICCO ON 11/3/00, DEFT. NO LONGER RESIDES AT GIVEN ADDRESS.. Sheriff's'Costs: Docketing, . Service NOT FOUND RETURN Surcharge 18.00 9.92 5.00 10.00 .00 42.92 ~~ R. Thomas K ' e Sheriff of Cumberland County FEDERMAN & PHELAN 11/06/2000 Sworn and subscribed to before me this day of A.D. Prothonotary ~)(,H\B\T ~ ~ - " .. ~I ..c," ',.' . '. "., '~. , ,,; . . ,.J EKL DATA, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: File Number: Attorney Finn: Federman & Phelan Subject: Sheila J. Miller Property Address: 1044 Hemlcock Lane Enola, PA 17025 Last Known Address: 1044 Hemlcock Lane Enola, PA 17025-2042 Current Address: 1044 Hemlcock Lane Enola, P A 17025-2042 Last Known Number: non-published George H. Lewis, Ill, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of President ofEKL DATA, INC. 2. On September 12, 2000, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: Credit Infonnation A. Social Security Number Sheila J. Miller: 204-50-8279 B. Emplo)'fl1ent Search: Could not locate any employment information for the above named subject at this time. C. Inquiry of Creditors: The creditors indicated that Sheila J. Miller resides at 1044 Hemlcock Lane, Enols, PA 17025-2042. II. Inquiry ofTe1ephone Company A. Directory Assistance Search: The Telephone Company has Sheila J. Brudowsky listed with an address of 1044 Hemlcock Lane, Enola, P A 17025-2042. The phone number is non-published. lll. Inquiry of Neighbors Contacted Mrs. Hofmann ofl042 Hemlock Lane, EnoIa, P A 17025-2042 and verified that Sheila J. Miller does indeed reside at 1044 Hemlcock Lane. IV Inquiry of Post Office A. National Address Update: As of September 12, 2000 the National Change of Address has no forwarding record for Sheila J. Miller listed at 1044 Hemlcock Lane, Enola, PA 17025-2042. V. Inquiry ofDMV The Pennsylvania Department of Motor Vehicles has Sheila J. Miller listed at 1044 HemIcock Lane, Enola, PA 17025-2042. EXHIBIT B - , ,,,""';;'; ~'~ ~; . , . ,; EKL DATA, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION VI. Other Inquiries A Death Records: As of September 12, 2000 the Social Security Death Index has no death record on file for Sheila J. Miller under her social security number. B. Public Licenses None found C. County Voter Registration: The county does have Sheila J. Miller listed as a registered voter with an address of 1044 Hemlcock Lane, Enola, PA 17025-2042. D. AKA: Sheila J. Brudowsky E. D.O.B.: Sheila J. Miller: 07-21-57 F. Miscellaneous Information None orge H Lewis ill Subscribed and sworn before me September 12,2000. ~(~ Notarial Seal Ellen K. lewis. Notary Public lower Merjon Twp., Montgomery County My Commission Expires Feb. 24, 2003 EKL DATA, INC. 19 1423 SUFFOLK LANE 19 WYNNEWOOD, PA 19096 Tel.: 1-888-829-576819 Fax: 610-649-263719 email: ekl-data@home.com EXHiB\T B -.-'11 ,1__. j,-- ." 1i~0~ '. . . VF,RTFTCATTON Michele M. Bradford, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: Nnvemher 11 7000 , ~cft~;uko ~ H:/Main Forms/motions/county.comp # -j. ~~,' . ..... PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 FIRST UNION BANK OF DELAWARE, FIK/A F1RST UNION HOME EQUITY BANK N.A. Plaintiff, CUMBERLAND COUNTY v. No. 2000-7540 SHEILA J. MILLER, AlK/A SHEILA J BRUDOWSKY Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $28.221.57 Interest from 1/30/01 - 6/6/01 $589.28 and Costs (per diem - $4.64) $28,810.85 TOTAL ~~~ FRANK FEDERMAN, ESQUIRE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property.No. to 4ft t;..(-eMlod< Levii-C ~ol.c.-- 'PA 17 ()~ ,:0"':';"" """"~~1P~iiI8.~!lf~.iri"0t;i"",-f!;Nt."""""''''~ti~~C;"~'~' ISiliIililiIi!l"~'- :........" " --.!i l tI" . . ~ m ~ 0 i::I ~ i:Q .... ~ -< ... m ..... ...;:$ ~ ~ "'" Z := O~ .~ 0 m i::I 0 ~ m> ~i:Q ..... ~~ ~ Eo< :;J "'m ~~ i:Q U J~ -ci i:l.Z -<..... .... ~'F <J) Zz ...:;J -< ~ l': ","0' "'" = "'""'ll'l <J) Q 0"," ... '" o"E ...~N '" ~~ i::I"'" ..... ... 0 <J) ~ ..."'" "'" 0<:: 'a ...U~ .n := - ~O"" ~ O~ '" I'l-< 0 O~ m Eo< ... 0 ~O< v, sa~ ... . ... -< a 0 uz -< 0.8 ....~i:l. N ...:;J ~:= . .. ~ ~~ ~ ZZ ;>-, -<"'"< ~ 00 < ~~ a ...:=... g. Eo<U i:Q0 ..... Z..... ~ Ot: ~ ",""l'0 Po f-< ~i::I OZ ... 0 :=~Z <J) ... :;J~ .....:;J "'" "'"6- m",,"," <J) 8~ ZEo< ... ~ ... i:l. :;J~ ..... u; ..... u ~ '" "'""'" fj;s ~ oi:j ~ <J) :=i:Q ...; ~ Eo<~ ~-< <J) - -< .~ Z:;J s~ ... i:l. j;l.; .....u ~ ..... "'" := m " _.0 " ~~~ . - .' ..~ >,~ . -. ~., ~",~' ,.~~_~ _.,".,_~".. ~_"""'" .<~,_I"->,'_ ""'" h~'.'>f ~ -,.. - . ..- ~ . . . " i'l h ,.,., -,."~,,, ~t' lilD). . .J1i". . .... DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of East Peimsboro, County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the southern right-of-way line of Hemlock Lane, a common corner of Lot Nos. 43 and land now or formerly of Stan Hutichinson; thence along said right-of-way line, South 77 degrees 22 minutes East, 85.0 feet to a point, common corner of Lots Nos. 42 and 43; thence along said Lot No. 42, South 12 degrees 38 minutes West, 120 feet to a point, at lands now or formerly of Stan Hutichinson; thence along said lands, North 77 degrees 22 minutes West, 89.65 feet to a point, a common corner of Lot No. 43 and lands now or formerly of Stan Hutichinson; thence along said lands, North 14 degrees 51 minutes 14 seconds East, 120.09 feet to a point, the Place of Beginning. CONTAINING 10,479 square feet. BEING known as 1044 Hemlock Lane, Enola, Pennsylvania. BEING Lot No. 43, as shown on final subdivision plan no. 5 of Treemont prepared by D.P. Raffensperger Associates of Camp Hill, dated August 25, 1987 and recorded in the Office of the Recorder of Deeds in and for Cumberland County at Plan Book 53, Page 149. Tax Parcel #09-13-0998-084 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Sheila J. Brudowsky by Deed from Stephen P. Brudowsky and Sheila J. Brudowsky dated 7120/1993, recorded 9/15/1993, in Deed Book "N", Volume 36, Page 466. - ?D f~ - +:- J \~ -- ;),-iJi~IIiH~~j,li'k~~;;,,~~~iIfliir~'o '"'i$'!ilfr~" ;l;l",,;. ~ ';'~~I.lliU:is~~~it!'.ililli!l: ~~ ::::>t:, -- -.~ ~~ -.t::: ~ ~ ~ .~ ~ ". - - .-1' . , , .P. ~.~""'" ^ _""'''T.,,<I,.,,,._<..,,-_.. .'.C"."",,". .=- , =..~ - ,_ _"_ ,_ ,,"~"'---' --. ~o~cl..oi'~ """ ~~'lIl>ll '" =~. "-1iiiIiI ~-\"'-' ~-i)~~cg- o ~ ~ c: Co.""", '" c_ I,. .r~ .0' -~, ,--,. l-'(lr::~' ~i~ Cf) ~--.: ~c. ,~'-:c :. ;:,';c: :.>~; ~, o ~, c r' " "'"i") r:;) "-.-; -', -< . . ~ .-! ", -- -.- --">'~'f,! II I' II II ',; " :j " Ii i I I I ,I , , I " II I i @ ,..h, =. ~ ~: ,.;,,,0'.1 "~Iitt . ). FIJl.ST UNION BANK OF DELAWARE, F/K/A FIJl.ST UNION HOME EQillTY BANK N.A. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION SHEILA J. MILLER, AlK/A SHEILA J BRUDOWSKY NO. 2000-7540 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) FIRST UNION BANK OF DELAWARE, F/K1A FIRST UNION HOME EOUITY BANK N.A., 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 1044 HEMLOCK LANE, ENOLA, PA 17025. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) SHEILA J. MILLER, AlK/A SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Fifty Third Mortgage Co. slb/m to Citifed Mortgage Corp. of America Assignee of Integra Mtg. 10908A 38 Fonntain Square Cincinnati, OH 45263 ( 744 Wertzville Road Laurel Hills Development Corp. Enola, P A 17025 ,.. .. J~ ~J ~i I. ~~j, . . \. 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.) Citifed Mortgage Corporation of America One Citizens Federal Center Dayton, OH 45402 Nations Credit Consumer Discount Company 3300 Hartzdale Drive, Ste 107 Camp Hill, P A 17011 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 1044 HEMLOCK LANE ENOLA, P A 17025 Domestic Relations of Cumberland County 13 North Hanoyer Street Carlisle, P A 17013 Commonwealth of Pennsylyania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 26.2001 DATE ~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~"<:,;~', d!:W 'l?!l~_~~~~I!!li!t"*,-!I1~~_<fu;"~.."-~!~:j)r.,,,,;;,;i;i4;ilii:~;,,,;;'i1.i '"'.m~llln T~'~ r~""~ ~,~ <.,' "'~''''''''' ~,~..~, .~, =- , ".. . , "",,' .~~, l_~. ~ ~ ",_'No,. .~ ~~" ,,,."'~ =.~ ^> . ,~,., - " lIilill/lIlIIII~-"""'" ~. - ~~. ,,- h'~~' .--", C'; c-.: -~~;: >,1\,'- ~~.-- ~~, Z>-::, jc;s L, -< .,-1 - ~dI;f~i ,.,. . c:..' -7;~ ::';_J c~ -T:: !-.,.) .'..~"" . "I ~" .',-- -"';,;,.-~'" FEDERMAN and PHELAN By: FRANKFEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF FIRST UNION BANK OF DELA WARE, F/KIA FIRST UNION HOME EQillTY BANK N.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION SHEILA J. MILLER, AIKIA SHEILA J BRUDOWSKY NO. 2000-7540 Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~~ Attorney for Plaintiff 'o<,JtJ :'-'-]ijJ]\~i~@~<tJ~1i~b"1;"~~~!0!tMt!:>lili1li";"Ii';;:&::f~6M,;;~fij~-'~"''''"'' '1' ;;; ,- 'e. ""~~~_ _,~, I. 0, ~~ ~.. ".," ",. " _"-,-"",.,.,,,,,.iy _>->.o~'_ .~.. ~ . ~ ~" 0 C) S~ :"---,. "- 9~~ " ::::::: t , U; " :....... -~:~ , ~':~ ,- ~? " ,.",- ~::::! ;..::: -'''l -,'''' -_I -~ -<. . ~ ~ ""'----IIMld ~ il ~ Ii ii !i " " ]' Ii ,j, "- .~ ',.' --'..~"",,,, t FIRST UNION BANK OF DELAWARE, F/KJA FIRST UNION HOME EQUITY BANK N.A. Plaintiff, CUMBERLAND COUNTY No.2000-7540'" v. SHEILA J. MILLER, A/KJA SHEILA J BRUDOWSKY Defendant(s). February 26,2001 TO: SHEILA J. MILLER, NKJA SHEILA J BRUDOWSKY 1044 HEMLOCK LANE ENOLA, P A 17025 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 1044 HEMLOCK LANE. ENOLA. PA 17025, is scheduled to be sold at the Sheriffs Sale on JUNE 6, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by FIRST UNION BANK OF DELAWARE. F/K1 A FIRST UNION HOME EOUITY BANK N.A. (the mortgagee) against you. Ifthe Sheriffs sale is postponed, the property will be relisted for the September 5.2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. .'~ - . _.._"';....,.ik. ,".1. ".,. ~~. "."'~"f"' t You may need an attorney to assert your rights. The sooner you contact one, the more chance you wiJI have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. rfthe 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 ifthe 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 ofthe 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 LA WYERAT ONCE. IF YOU DO NOT HAVE ALA WYEROR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 C_" "~ "" _" "'~*, I DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of East Pennsboro, County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the southern right-of-way line of Hemlock Lane, a common corner of Lot Nos. 43 and land now or formerly of Stan Hutichinson; thence along said right-of-way line, South 77 degrees 22 minutes East, 85.0 feet to a point, common corner of Lots Nos. 42 and 43; thence along said Lot No. 42, South 12 degrees 38 minutes West, 120 feet to a point, at lands now or formerly of Stan Hutichinson; thence along said lands, North 77 degrees 22 minutes West, 89.65 feet to a point, a common corner of Lot No. 43 and lands now or formerly of Stan Hutichinson; thence along said lands, North 14 degrees 51 minutes 14 seconds East, 120.09 feet to a point, the Place of Beginning. CONTAINING 10,479 square feet. BEING known as 1044 Hemlock Lane, Enola, Pennsylvania. BEING Lot No. 43, as shown on fmal subdivision plan no. 5 of Treemont prepared by D.P. Raffensperger Associates of Camp Hill, dated August 25, 1987 and recorded in the Office of the Recorder of Deeds in and for Cumberland County at Plan Book 53, Page 149. Tax Parcel #09-13-0998-084 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Sheila J. Brudowsky by Deed from Stephen P. Brudowsky and Sheila J. Brudowsky dated 7/20/1993, recorded 9/15/1993, in Deed Book "N", Volume 36, Page 466. J~l!'i\.~~~~_ilim<-~>fI:~~",;llJ"~;;;I;i!i.G"i.''-''I''Ni..~iib~ll-i~k,~~jl' ~ ,. ~~. ,.,- e'""",,"~",IiIii<JijjIllli.~"'''''''<~'~-''." w, ",.01 - 0 c:::. C :;-". rri c :'2; I _-'J ....,.. ,-- I (f) (T\ -< r- l. sS --0 ;~;-: C '1' > ~ r",,) =u -< --1 -< , .r ,"'.. illli'"' - - : , I ., ' ~"' 1 ._ " ~'* FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (? 1 'i) 'i1i1- 7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION FIRST UNION BANK OF DELAWARE, F/K/ A FIRST UNION HOME EQUITY BANK N.A. CUMBERLAND COUNTY No.: 2000-7540 vs. SHEILA J. MILLER, A1KJA SHEILA J BRUDOWSKY AFFIDAVIT I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to SHEILA J. MILLER, A/KJA SHEILA J BRUDOWSKY on MARr:H 'i" 7001 at 1044 HEMLOCK LANE, ENOLA, PA 17025, in accordance with the Order of Court dated NOVEMBER 21, 2000. The undersigued understands that this statement is made subject to the penalties of 18 P A C.S. s 4904 relating to unsworn falsification to authorities. ~~~LV~ Date: MBren?1i ?001 " , " ~ ~g n " n _ ~ z Cc: ~ 3 8.1f <7' '< 0 "'~ n " 0. n , ~CI g [ :;::' Z n c 0.3 ~<7 ...n o ' ~ 0 - ~ 0'" sir n n n ~ "'a' 3 ~ .., - -3 ~ " n ~ n [; -'" ... ~ j ~ o ~ ~ n s: " '" ,.... ,.... ,.... th "'" "" ~ '. ~ ~ ~ ~ ~ ~ ~ ~ ~ -. ,.... N ,.... ,.... ,.... o 1.0 ~ gj ::; a o tI1 ;::~. ~ ~ ,.... ~ "" ~ n "-- @ ,...~ e: :J F - o l' n N tI1 0 th;o ~ ~ ~ tl > ~. en ~ lii ~ ~ ~ t;O 8 o :E en .~ ~ ~1iiIoIIiol''''''''i' . 00 -..] 0\ th "'" n o .g ~ "" "" o o ::r: i a:. " tl ::1. <: S" en CD' ,.... o .;-J n ~ ::r: ~. ,.... r "" > "" n o ~ o ~ " ., - Er- o ...., "" " 5 '" 'So <: ~ ~. tl .g ~ a o ...., ~ ~ ." "" o t;O o ~ N 0\ -..] .th ::r: S. en (j' ~ "" > ,.... -..] ,.... o th ; ~ ; . , : > :: ,.... :ii: "'" ffi ~ 5 n ;r:: ~ ~. - ~ 0.. ~ o ::l- 0<> ~ " n o .a o ~ ~. o "' o ...., ~ " ::1. ('l l' ~ n ~. - ~. N " "' en "r1 " 0.. [ n " a .~ tl ~ o F o ::r: "'" th "'" o N ~ ~. -::p ll",<: "oSl ~-' ~. _ ~a '" 00 ~ >0 ""::l- 000<> "r1~ o " an ., 0 S'~ encr .gs- .a 0 nn _. ...... = ::to ~. ~ 5 0.. a~ ,:-' 0 g~ ""'" thn NO tI1 el ~"'. is '0 F ~ ;e ~ " ::1. ('l ., > en 00 ~. " o ...., ~ " %i tl " <: " .g- s 9 - n o jl -..] "'" ..,. :E ~ <: ~. - - " ~ F- ,.... -..] o N th N tl o S " 00 - (;. ~ - a g' 00 o ...., n ~ " :!. 8- n o 5 ~ ,.... "" ! ::r: ~ ~ en - @ " - n ~ ~. 00 - ." "" > - -..] o - "" < "~~ ',~~ ""'-','-.l ,.... >-i " "' ~ ('l ('l {j ~ .- ,.... " o 5. ..,. ... "'" 0 ::r: ~ tI1 S ~ ~ 5 ~ n ~ ;r:: ~ .~ ~ j: "" :> ,.... -..] o N th "~iJiliaL r- 5' n o > z .... Q. .. en Q. :3 " ., '" = III .. ~ '" = " Q. "'1. > " n' 1i' z c ~ ~ ;i!~[;l ==10 ., "'Il I:'l ~ ~"'~ 3 ,,= n ,.... = ~ ~'-e: Q ~ it pia.... 0. ",I<" g ~"'I "'= ~ > "'Il:r;: " ~;- ~ i ~~ ~ .- c::> '" Z N S. ~ '" ,., c c if ~ . ~ - J~ JJ,.,.,~--I '.... -< ..'~~,.. ~~~,:, 7106 4575 1294 1439' 3085 TO: SHEILA J. MILLER AlK/A SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, PA 17025 \ \ \ , SENDER: CMG REFERENCE: SALES PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Totaf Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail ';!f' , /' lc'f!;c~ .34 1.90 1.50 0.00 3.20 __M___~_____..__..~___~__._.._.______~__ ___'_~"'_.____._"",___'_'___._ , ,',. I .' 0_ ID.MI~ ~~I'~'E-1tj~-iI_~;~IillSli!;.~!\il-i>llii;m"iI&,>t"'lN"-{&."'''''~;!'W*",~~~ "~"-'i-i. - .",~r"'. .rl .~ _ _ ~.~, "' _~"f_, , ~ ,~ '., l 0-' 1ilIi/ililillil_RilIII!~ -~Hm 1 () c: V~:.~ rr-;':'," ~~,J.' cr) ) ~(. ',' :?c' ~C< ....:-~ ~ '--..">,,' ~0 , ,~ ~ '^'~ "" C2 <..- -o.J C~) l::!lII -~'J :">;;;J ! W -,..:.',"" ;;'- 'Y' -)~- -.; ~-~) <-'"J-d /;;1(;; ~ :D -< ).-::.,. --,"- ,~- "~-- " .:::il!lI!t..~, I II II II \1 ~. "IJ ~,'I "",o,~._~"_ _. ,~.~....~ \i- " First Union Bank of Delaware, F/K/A First Union Home Equity Bank, N.A. VS Sheila 1. Miller, AIK/ A Sheila 1. Brudowsky _ . II L.,- ~. ~~ -~-~ '~"]~", In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-7540 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law says this writ, is returned Stayed. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Law Library County Mileage Levy Certified Mail Surcharge Postpone Sale Law Journal Patriot News Share of Bills Sworn and Subscribed To Before Me This 6'lf;-' Day Of~ 2001 A.D. Q..u Q~ ~ Proth n6tary 30.00 12.29 15.00 15.00 .50 1.00 9.30 15.00 .89 10.00 20.00 209.60 262.95 25.09 626.62 paid by attorney 05-22-01 ~~ R. Thomas Kline, Sheriff By ~~e~ 'b I.:;' c.k- 3 .lSbl ~. //.;1'82- , i~ "-, ru. ~ - I I "~ -. '''''~,.,'~''' > , .. . t...... FIRST UNION BANK OF DELAWARE, FIKJA FIRST UNION HOME EQillTY BANK N.A. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION SHEILA J. MILLER, A/KJA SHEILA J BRUDOWSKY NO. 2000-7540 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) FIRST UNION BANK OF DELAWARE. F/K1A FIRST UNION HOME EOUITY BANK N.A., 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 1044 HEMLOCK LANE, ENOLA, PA 17025. 1. Name and address of Owner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) SHEILA J. MILLER, A/K1A SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Fifty Third Mortgage Co. s/b/m to Citifed Mortgage Corp. of America Assignee of Integra Mtg. 10908A 38 Fountain Square Cincinnati, OH 45263 744 Wertzville Road Laurel Hills Development Corp. Enola, P A 17025 . " "",.,..;~', . .... 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.) Citifed Mortgage Corporation of America One Citizens Federal Center Dayton, OH 45402 Nations Credit Consnmer Discount Company 3300 Hartzdale Drive, Ste 107 Camp Hill, PA 17011 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.) TenanUOccupant 1044 HEMLOCK LANE ENOLA, PA 17025 Domestic Relations of Cumberland Connty 13 North Hjlnover 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 26. 2001 DATE r?;:(~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff .~.~ '~t'" ~~~~~~~i'1ld;-'!Il,.iIiJl-:Jlti~"""~*"I!<!:-i.w;~'"",mc.~_liili il ~ o,,~ V\NV^lJ.,SIH13d 'J -I ,-. ; "" .. j ''''.. - .' ,--.':! ; '~-' ~ ~! 10. WJ ZS t 9 111M J..1NHC:J C~~~"!~~~~~l9Hn~ .:1:11113115 :Jfl1 ji) :a:ll.:UO __,<c_,^, , _,~ "~.~",, ,,>___~ ,,~ ~~ ~~" '0. ., "" " .~ 'i.-: ~ ~ .::r , I 'I "iWM~t;, , / FIRST UNION BANK OF DELA WARE, F/K1A FIRST UNION HOME EQillTY BANK N.A. Plaintiff, CUMBERLAND COUNTY No. 2000-7540 v. SHEILA J. MILLER, A/K1A SHEILA J BRUDOWSKY Defendant(s). February 26, 2001 TO: SHEILA J. MILLER, AlK/A SHEILA J BRUDOWSKY 1044 HEMLOCK LANE ENOLA, P A 17025 -'THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY-' Your house (real estate) at 1044 HEMLOCK LANE, ENOLA, P A 17025, is scheduled to be sold at the Sheriffs Sale on JUNE 6, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by FIRST UNION BANK OF DELAWARE. F/K1 A FIRST UNION HOME EOUITY BANK N.A. (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the September 5. 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ""","'- . . u,l. _I "."'''~L f You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE 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 . I I~, " -~,,, u;;;, . / DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of East Pennsboro, County of Cumberland, and Conunonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the southern right-of-way line of Hemlock Lane, a conunon corner of Lot Nos. 43 and land now or formerly of Stan Hutichinson; thence along said right-of-way line, South 77 degrees 22 minutes East, 85.0 feet to a point, conunon corner of Lots Nos. 42 and 43; thence along said Lot No. 42, South 12 degrees 38 minutes West, 120 feet to a point, at lands now or formerly of Stan Hutichinson; thence along said lands, North 77 degrees 22 minutes West, 89.65 feet to a point, a conunon comer of Lot No. 43 and lands now or formerly of Stan Hutichinson; thence along said lands, North 14 degrees 51 minutes 14 seconds East, 120.09 feet to a point, the Place of Beginning. CONTAINING 10,479 square feet. BEING known as 1044 Hemlock Lane, Enola, Pennsylvania. BEING Lot No. 43, as shown on fmal subdivision plan no. 5 of Treemont prepared by D.P. Raffensperger Associates of Camp Hill, dated August 25, 1987 and recorded in the Office of the Recorder of Deeds in and for Cumberland County at Plan Book 53, Page 149. Tax Parcel #09-13-0998-084 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Sheila J. Brudowsky by Deed from Stephen P. Brudowsky and Sheila J. Brudowsky dated 7/20/1993, recorded 9/15/1993, in Deed Book uN", Volume 36, Page 466. ; ~" 'L ~. , , ,.~-~ . . ;.', . ',./ . L,,j~:m!JW EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 00-7540 CIVIL lIP\. TERM COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due First Union Bank of Delaware, F /K/A First Union Home Equity Bank N.A. PLAINTIFF(Sj from Sheila J. Miller, A/K/A Sheila J. Brudowsky, 1044 Hemlock Lane, Enola, PA 17025 DEFENDANT(S) . (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession ot .,;~.~\ '.:d ~ ~'* i'il'~t'ltk,,\j "'~."'__. r -<II..., ~..........." . :,'/. I ". ,'.,nt~',. fH lj,jT'H~H;.- ~';! ;V:,~:~ }!.. ,t~';'l ,,?'t'\ ii !~"' ",n .... ~'(\r,.,,,;. ' h"',.....'~.~,:.-'--""~l'"_. ,"'o. WJfl;, '-^<" "'~m~(',~aHEE(S) as follows: '" and to notny the garnlStt4e~i:'f;\j a~e'\\t has' been issu~iJ;'{b)'I~IJI8aiMl'hee('$) is/:obi! linjtlined 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'" ''''Ii ........ ....... .'i....: I ~ftk;~ .'}\,;~~' "1 '.",'.f<~~;.:' aiwt! 1{ '.,.)!If.,,' ~rrfl'~ r, (3) If property of the defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other than a named garnishee, you are directedlO notify him/he.f\hat helshe has been added asa garnishee aRl!isEmjoined as above stated. . Amount Due $28,221.57 L.L. from 1/30/01 to 6/6/01 - Interest $Sg9.2g and Cm::ts (pAr iJiAJn - S4.64) Due Prothy Atty's Comm % Other Costs $.50 S1.00 Atty Paid Plaintiff Paid $114.92 Date: March 6, 2001 Curtis R. Long Prothonotary, Civil Division by.:. 4{)/F'?' 2. 71z~ r--- Deputy Name REQUESTING PARTY: Frank Fedennan, Esq. One Penn Center at Suburban Station SUlte 14UU PRilaQ~lPria. p~ 19103 Attorney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 Address: *~'ifL.",." ""l!lili"~" -lilllitc!.:iI~.lii~:t"""'liW''''':'';-'''i:l!-W'',~ill{'\::~WM:-~Wkf''~.~~1i(1''- IW ....... 'liiiI!iJi.' - j!j;.&;j (" . . , .' ." ( \ REAL t.S1All: ~i'\L.t.l~o. ,lID - fZ:::I f:!:, I!:!!::I c......) .f \:--,~; On fY/. ~ ~ J 00/ the sheriff levl8duponlledetendants Interest In the real property situated In t cud p.Q)l~ /O~ Cumberlilnd County, Pa., known and numbelldll: /044 IleflJ.MJz.i.u.A,L tna-& and more fuHy described on ExhIbIl"A"lI8dwlth tNs WItt and by 111II reftrtnce Incorporated .... DrI8: fl)cwH,;leD I By: ~~~ VI~,~,~,~~ SN N3d ~L) :",-:f !~,J\fJ WI J{d rs € 9 lI8J/j J~~'Qi;\l.,i"'f1""'''' -oiBD~~; ~" ',~. Tf~,vJ - ~ili :iilJ 3oJli:lfm; . =~."._~=..""~."^'~"'''~',,,'-,,, _~""',~' "..' .0 _,,~'_".-"~" ~, ..~NT ,~', ,. , >"'n._."" ~. <-,,?--,,""-,C", _,~, ' ~ ~ ' ".~. ~ ,'" "~".~ _ .,,,, -1 '"~"~ ...L _ ...... " ~;.~ - I PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P'R.C.P.3180-3183 FIRST UNION NATIONAL BANK OF DELAWARE, F/K/A FIRST UNION HOME EQIDTY BANK, N.A. Plaintiff, CUMBERLAND COUNTY No. 2000-7540 v. SHEILA J. MILLER AIKI A SHEILA J. BRUDOWSKY Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $28,221.57 Interest from 1/30/01 to 9/5/01 (per diem - $4.64) $1,011.34 and Costs TOTAL $29,232.91 ~~ ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property.No. ,'~ "~~''''~~~~1ii;.~-Itkl",~d!Jj'~-'f'.&J;'-'w,,,,,,,,'~Ll'-');(;''-;';;"4,,g'':i'''L''il~';'''lijCj~,I>;'';' ri~"~ < , '. BIil , ~tllfl ~"" Hun' . ~ ~< -&1 I I - I " I I I I I ~ 00 ~ 0 ~ ~ = ~ ...; < ...;:$ 00 ...1 ~ .... ~ ~ OZ 0 Z = 00< ...~ ~ 0 00 <... 00 ~ .... < ... . ;j ~ ~= ;;J ~~ ~9 . = U ~oo ~~ -d ZZ ...; ~'F Q) OZ =Z< < ~ = i:::: ~ c:i ~!5: :;j;;Ji ...1 .- ~...111l Q) ... ~ i:J ...1~"" <IJ < .... Q) ~ . Z"'~ ~ 0'"" 'Ol ...1U~ .rJ 0 O~ 8~~ = ... :: - ~O"" 0 00 ~ ~ 0 UZ .; i:a~ .... ....1 < S N ...;;J ~...= .. ~ <8 ....~~ 5" ~~ :>, <IJ 00 z~~ a <~< Ii) ...u < ~ ~ ==...1 g. z-..... o ell ... ~~ 0...;;J ~ ...~ -J~ ~""'o Q.. ;;JZ .... '0- ~ ~~ =~z ~ 0< ~~~ ...1 oo....~ u~ ...1 ~'-' ~ .... .... 0; ~~ ...~ ~ u ~ <IJ == ~< -i::i Q) ...~ .......1 ...; Q) .tJ ...~ < - ~ Z;;J .- ....u ~ ...1 ~ ~ .... ~ = 00 _~<~"^'.' ",,~_",k'~. ~,.".,~ - _~, >.,'_~ , ""f.'_' ~.. '" ,"._,~., "" 0, ,"~ -~ ' -~ , " -"~.~~...~.,""""-' ,~ , - ~ l<. .",--- ~..- ~ -'H ",.'" - ; DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of East Pennsboro, County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: -, BEGINNING at a point on the southern right-of-way line of Hemlock Lane, a common corner of Lot Nos. 43 and land now or formerly of Stan Hutichinson; thence along said right-of-way line, South 77 degrees 22 minutes East, 85.0 feet to a point, common corner of Lots Nos. 42 and 43; thence along said Lot No. 42, South 12 degrees 38 minutes West, 120 feet to a point, at lands now or formerly of Stan Hutichinson; thence along said lands, North 77 degrees 22 minutes West, 89.65 feet to a point, a common corner of Lot No. 43 and lands now or formerly of Stan Hutichinson; thence along said lands, North 14 degrees 51 minutes 14 seconds East, 120.09 feet to a point, the Place of Beginning._ CONTAINING 10,479 square feet. BEING known as 1044 Hemlock Lane, Enola, Pennsylvania. BEING Lot No. 43, as shown on final SUbdivision plan no, 5 ofTreemont prepared by D.P. Raffensperger Associates of Camp Hill, dated August 25, 1987 and recorded in the Office of the Recorder of Deeds in and for Cumberland County at Plan Book 53, Page 149. Tax Parcel #09-13-0998-084 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Sheila J. Brudowsky by Deed from Stephen P. Brudowsky and Sheila J. Brudowsky dated 7/20/1993, recorded 9/15/1993, in Deed Book uN", Volume 36, Page 466. ~bIJmllW~i;/Mi\..ljwL$k>E~",1.ili!f,l@i,~~;;-""--'l.J~'''&~;'J.0''<","",,,,,";;o;k'1i,,:!,,,4d''''i",*~,:hflOF,",.l~'" "",">~"...il~.;.,.," ':~~'\llb' ~~~Iiili ,~~." "'- ,!!iIiiil '. .... \ ~ ~ (U ~ ~ ...... "'" rr ~ ~ ~ f2 t ....... tt- >-- ...0 .~ .~ , 0 () 0 & 0 ,.. -() 8 ~ ...... D ~ 0 ~ ~ 0 0 I.v (') 10 c: -n r- "'D {f f I I ~p! s: t- :~J r- ~ -ow c:: ,-..." rnp: -- ;'np , z~; .... cr' , ::- , .~ I -""lrT1 ~ ... .... ... ~ ~~ ~-,JQ ... ... (X> C~6 ~ ;) !;2CJ ::::1 "I'; ..... , , :l> J.~-n ... " ~a ::ll: ()~ Zr' ~g '-R ~ ~ 0 ~ - "< ;<< ,--"~',I.." "'.. .., .,~, ,,.-"1 ," " -, ",,,~ " .".r ..,,- ",,',t:-o ",....;,_.. ..,.,",."",,. """ .,~" .....,.. ",""',,'.",''"''''1'' <"",-.' ._, "~~,, .. .". J, . F ORItNiAN AND PHELAN .,..........eY: Michele M. Bradford, Esq. Atty. LO. #69849 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (? I~) ~6,-1000 -, Nav 1 7 2000Jp FIRST UNION NATIONAL BANK OF DELAWARE, F/KJ A FIRST UNION HOME EQUITY BANK, NA COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY- SHEILA 1. MILLER NO. 2000-7540 AND NOW, this iF>} ORDER \ day of ~~, 2000, upon consideratio:~f Plaintiff's Motion for Service Pursuant to Special Order of Court and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), SHEILA J. MILLER, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the Defendant's last known address, and to the mortgaged premises located at 1044 HEMLOCK LANE, ENOLA, P A 17025. - Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. BY THE COURT: /5/ d1J~t. ..v-L,Jo , J. H:IMain Fonnslmotions/county.comp . ,~, iI' l -~f;o;t/iI ~~.L ._._. " , ~. '" ,-- :., ,~~-'~ ':', .,,- FIRST UNION NATIONAL BANK OF DELAWARE, , F/K/A FIRST UNION HOME EQIDTY BANK, N.A. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION SHEILA J. MILLER A!K/A SHEILA J. BRUDOWSKY NO. 2000-7540 Defendant( s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) FIRST UNION NATIONAL BANK OF DELAWARE. F/K1A FIRST UNION HOME EOUlTY BANK. N.A., 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 1044 HEMLOCKLANEENOLA, PA 17025 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) SHEILA J. MILLER AlKlA SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) FIFTY THIRD MORTGAGE CO. SIB/M TO CITIFIED MORTGAGE CORP. OF AMERICA ASSIGNEE OF INTEGRA MTG. 10908A38 FOUNTAIN SQUARE CINCINNATI, OH 45263 LAUREL HILLS DEVELOPMENT CORP. 744 WERTZVILLE ROAD ENOLA, PA 17025 " 1~1'h,,^;;~'~- "~~ 41. ,h or ~ I 'A..-l. ~~ir rt. :". 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) TenantlOccnpant 1044 HEMLOCK LANE ENOLA, PA 17025 Domestic Relations of Cumberland Connty 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisbnrg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~kt~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff June 5. 2001 DATE ~h.~~W!l;l!li~l6il,~'lI'*'~},h';'-'?i:""<f"",.,~;g~';';'~-;,-"-'i""'P'J'"~","~&'li.k'-'1,~",*~t~Jiliitillli!ll-"~~~ '- --^ ~,- -^ ,,,", ", ,. ~ ,~ ,-",-",-,",._- _ill ~ . ~i 1 .... 2 co 0 -n ~-: '- .-l -0 CD C ~~~~ rnrrl :z:. -'-lm Z:J:' I ze;o> ""'6 0:> (~'S- ~~~: ~. --< " 1:20 E:: -r'-rl 5:'3 ~- -- z:~ 0.., ;;;2 'Po 9t ~ 0 ~ - ~ .","",,1 ~. ..~ .' , _ ,I - i J .1 L .'" Ii -"~tYlr~' ; FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF FIRST UNION NATIONAL BANK OF DELAWARE, FIK/ A FIRST UNION HOME EQffiTY BANK, N.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION SHEILA J. MILLER AIK! A SHEILA J. BRUDOWSKY NO. 2000-7540 Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1::J1:~ Attorney for Plaintiff ;d,.~ ;iP'-~~!!i~","I&~ili'~;W;'b,,'NllJil~)i6,~dlo.j[61t';]l~ii;~l;t'M'it~',-~,,~,~ """'JKi"~tL-'IL~ml~~l- >~, 'Il"- - ~ .--l!i~Miii!IlI:' " '" " "-~_o<<.'>lil',ar-<J!;lli ~1IIiiI 0 0 ~ c: ? C- .~ .-l -om c:: ~:J] 52m :z ::0 ! " u.;c I -O-fTY -<."'7" 0:> t16 ~.. !;:C .~, ~o > ;:c:tj ::ll: 'Jo pO 'P. 2m 0 c: :is ~ 0 -< l ,",~4"""~~' ~__~ ~L "" ~"' l~ . I. 1 ., _illli " . . tl' . "\j~,( .. . FIRST UNION NATIONAL BANK OF DELAWARE, F/KJA FIRST UNION HOME EQillTY BANK, N.A. Plaintiff, CUMBERLAND COUNTY No. 2000-7540 v. SHEILA J. MILLER A!KI A SHEILA J. BRUDOWSKY Defendant(s). -., June 5, 2001 TO: SHEILA J. MILLER AlK/A SHEILA J. BRUDOWSKY 1044 HEMLOCK LANE ENOLA, P A 17025 ""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 1\ 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 1044 HEMLOCKLANEENOLA, PA 17025is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by FIRST UNION NATIONAL BANK OF DELAWARE, F/KJA FIRST UNION HOME EOUlTY BANK. N.A. (the mortgagee) against you. If the Sheriff s sale is postponed, the property will be relisted for the DECEMBER 5, 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ;. ;o";~_",,-__~~,,,"-.J,,~~,,,,, .., - 11- ~,.., ~,~I.- ~ . ,~ ,~. _~~ '_,1 1_ ." J.""",,, - o,,~~~-. ~"'i"; I You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. -'" 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened._ 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE 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 ASSOCIA'fION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 i";~_". ~ -~ . I I 1_ "~o& ,.. t DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of East Pennsboro, County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: -, -, BEGINNING at a point on the southern right-of-way line of Hemlock Lane, a common corner of Lot Nos. 43 and land now or formerly of Stan Hutichinson; thence along said right-of-way line, South 77 degrees 22 minutes East, 85.0 feet to a point, common corner of Lots Nos. 42 and 43 ; thence along said Lot No. 42, South 12 degrees 38 minutes West, 120 feet to a point, at lands now or formerly of Stan Hutichinson; thence along said lands, North 77 degrees 22 minutes West, 89.65 feet to a point, a common corner of Lot No. 43 and lands now or formerly of Stan Hutichinson; thence along said lands, North 14 degrees 51 minutes 14 seconds East, 120.09 feet to a point, the Place of Beginning.~- CONTAINING 10,479 square feet. BEING known as 1044 Hemlock Lane, Enola, Pennsylvania. BEING Lot No. 43, as shown on final subdivision plan no. 5 of Treemont prepared by D.P. Raffensperger Associates of Camp Hill, dated August 25, 1987 and recorded in the Office of the Recorder of Deeds in and for Cumberland County at Plan Book 53, Page 149. Tax Parcel #09-13-0998-084 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Sheila J. Brudowsky by Deed from Stephen P. Brudowsky and Sheila J. Brudowsky dated 7/20/1993, recorded 9/15/1993, in Deed Book "N", Volume 36, Page 466. ~1i...~~~!l!~.u"""'.i';;:~'''*'1?~~;''"'-Jt."j'''''&,,",;l''.'JA2;,''',"l3,t,'"tih'i&c.'Jo:,W"j"l\l'..,i~* '" ^ = lI~jjl"'ililO& ,LJ L . ..~ - ". >, .,>,. . ,~ >. "jh, - -"1 . .. () 0 0 c: -n ~ c.... :.:::1 -OW c:: F~'-::l;J] mf"n Z Z::V Z~c I -om en> CO ;S9 --<...r::: ~O ':::JO "'" *=r~ ~O :r:: ,J;:"; -0 'P. 2m PC: 0 Z ,::> ~ =<! -< , ^"~~~ , ."'".'~ ~~ '"'. I I ,~!;'" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-7540 CIVIL ~ TERM CIVIL ACTION - LAW - TO THE SHERIFF OF Cumberland COUNTY: First Union National Bank of Delaware F/K/A To satisfy the debt, interest and costs due l"ir"t- Tlni(')n Hrm.. Eqllity Bank. N.A. PLAINTIFF(S) from Sh..ila J. Mi Her. A/K/A Sheila J. Brudowsky, 1044 Hemlock Lane, Enola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell SP.e Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlherthal he/she has been added as a garnishee and is enjoined as above stated. Amount Due $28,221.57 from 1/30/01 to 9/5/01 Interest (p'T rJiPm - $4_64) $1.101.34 Atty's Comm % L.L. and costsDue Prothy Other Costs $1.00 Atty Paid Plaintiff Paid $754.04 Date: June 8, 2001 Curtis R. Long Prothonotary, Civil Division A~ - P 7t;~f}/U'}(J I '-8;t.:. Deputy REQUESTING PARTY: Name Frank Federman, Esq. Address: One Penn Center at Subruban Station, Suite Philadelphia, PA 19103 Attorney for: Plaintiff T I h 215-563-7000 e ep one: Supreme Court ID No. 12248 .., hind . PI. ." ,=."'-- - ..L. ~ , 0 J._ d" >~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-7540 CIVIL lfg. TERM CIVIL ACTION - LAW TO THE SHERIFF OF ~__ Cumberland COUNTY To satisfy the debt, interest and costs due First Union National Bank of Delaware F/K/A Fin;t l1r1ion Heme Fqility Bank. N.A. PLAINTIFF(S) from ShEena ,1. Miller. A!K/A Sheila J. Brudowsky, 1044 Hemlock Lane, Enola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the detendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and fo notify the garnishee(s) that: (a) an allachment has been issued; (b) fhe garnishee(s) is/are enjoined from paying any debt to or for fhe accounf of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereot; (3) If property of the defendant(s) notlevied uponan subject to attachment is found in the possessionot 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 $28,221.57 LL from 1/30/01 to 9/5/01 Interest ([""r rliPfT1 - $4.64) $1.101.34 and costsDue Prothy Ally's Comm % Other Costs $1.00 Atty Paid Plaintilf Paid $754.04 Date June 8, 2001 Curtis R. Long Prothonolary, Civil Division .A~"~ _ r /1nJA'V' / -~ Deputy REOUESTING PARTY: Name Frank Federman, Esq. Address: One Penn Center at Subruban Station, Suite philadelphia, PA 19103 Attorney for Plaintiff T I h 215-563-7000 e ep one: Supreme Court ID No. 1 ;>248 TRUE COPY FROM RECORD 1400 MT~wb6l'aef.ll1efel.into-lIlYhand ~"'~of saki~ CrilIe. PI. _ l~n~~~ _~:~~ ~" -~ <""'~ ~.I .Jitj !Il :~'i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-7540 CIVIL Jf9. TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY To satlsly the debt, interest and costs due First Union National Bank of Delaware F/K/A Fir"j- fJninn Hr.mp EqJlity Bank. N.A. PLAINTIFF(S) from Shfd1a J. Miller. AlK/A Sheila J. Brudowsky. 1044 Hemlock Lane, Enola, PA 17025 DEFENOANT(S) (1) You are directed to levy upon the property 01 the defendant(s) and to sell SPe Legal Description (2) You are also directed to attach the property of the delendant(s) not levied upon in the possession ot GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directedlo notify him/herthat he/she has been added as agarnishee and is enjoined as above stated. Amount Due $28.221. 57 L.L. from 1/30/01 to 9/5/01 Interest (p"'r riiPl'T1 $4.64) $1.101.34 and costsDue Prothy Atty's Comm % Other Costs Atty Paid $754.04 $1.00 Plaintiff Paid Date: June 8, 2001 Curtis R. Long Prothonotary. Civil Division AVr~ ~ r /-rJcj;/i~>n, / ( Deputy --9y.;. REQUESTING PARTY Name Frank Federman. Esq. Address: One Penn Center at Subruban Station. Suite philadelphia, PA 19103 Attorney lor: Plaintiff T I h 215-563-7000 e ep one: Supreme Court 10 No. 12248._ TRUE COP'{ FROM RECORD 1400 m T~Ii, ,,~ll$fOOf, lOO("u~t<l ~t ~h3nCl _ tile. Sliidl fji/ said c~;w[ at CMiSie. . 1* ~ay. ~J~.~~t~ '-- a --- - ~ r- -"'""" ~= " ~~t ; ",J .............""""'...~ t' I.J ti;;..i!i" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-7540 CIVIL ~ TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY To satisfy fhe debt, interest and costs due First Union National Bank of Delaware F/K/A F'ir,;t Oninn Hrmp EqJlity Bank. N.A. PLAINTIFF(S) from Shpila ,J. Miller. AlK/A Sheila J. Brudowsky, 1044 Hemlock Lane, Enola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Spe Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the delendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property 01 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 hlm/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $28.221.57 L.L. from 1/30/01 to 9/5/01 Interest (p<>r n;Pm - $4.64) $1.101.34 and costsDue Prothy Atty's Comm % Other Costs $1. 00 Atty Paid Plaintiff Paid $754.04 Date: June 8, 2001 Curtis R. Long Prothonotary, Civil Division J/JaYrJ! ~ r /?1:rM~'1(-, i- ~ Deputy REQUESTING PARTY Name Frank Federman. Esq. Address: One Penn Center at Subruban Station, Suite philadelphia, PA 19103 Attorney lor: Plaintiff T I h 215-563- 7000 e ep one: Supreme Court 10 No. 17/.48 TRUE COpy FROM RECORD 1400 ... r"'olr-"",.y "M""_,~ , ., ..~ ..............i, ''''M ~, ' ,lIBfiO' ijrlro Stt fflt' !land -. ~ llf ~ IA'li.j,t at~. PI. '- ~d~ ~~ A~<e~ "dll~~, ~ ~<<~<<~~' ~ "~ " ,. I.....' ;;!., WRIT OF EXECUTION and/or A IT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-7540 CIVIL lf9- TERM CIVIL ACTION - LAW TO THE SHERIFF OF ___Cumberland COUNTY To satisfy the debt. interest and costs due First Union National Bank of Delaware F/K/A FirRt Oninn Hrmee F.qJdty Bank, N.A. PLAINTIFF(S) from Shena-.J. Milleer. AlK/A Sheila J. Brudowsky, 1044 Hemlock Lane, mola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other 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 $28,221. 57 L.L. from 1/30/01 to 9/5/01 Interest (ppr r'HPm - $4 64) $] .101.34 and costsDue Prolhy $1.00 Atty's Comm Atty Paid Plaintiff Paid % Other Costs $754.04 Date: June 8, 2001 Curtis R. Long Prothonotary, Civil Division ~lhJL p ~10}/j",7(~ I --By.;. Deputy REQUESTING PARTY Name Frank Federman, Esq. Address: One Penn Center at Subruban Philadelphia, PA 19103 Attorney for: Plaintiff T I h 215-563- 7000 e ep one: Supreme Court ID No. ] 7.7.48. TRUE COpy FRv~ RECORD Station, Suite 1400 k'iT~.elly~i,:(I(ool, HilWinmwstlmyllancl i:~":~-#f' "--, <; ""-,, - f-:) I~ ~fe' - - , .. >J.' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-7540 CIVIL ~ TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY To satisfy the debt, Interest and costs due First Union National Bank of Delaware F/K/A F'in"T !Jninn Hrmp Eqllity Bank. N.A. PLAINTIFF(S) from Shpila J. Miller. AlK/A Sheila J. Brudowsky, 1044 Hemlock Lane, Enola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession ot GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other 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 $28,221.57 L.L. from 1/30/01 to 9/5/01 Interest (p"r r'li= - $4.64) $1.101.34 and costsDue Prothy Atty's Comm % Other Costs $1.00 Atty Paid Plaintiff Paid $754.04 Date: June 8, 2001 Curtis R. Long Prothonotary, Civil Division ~.f.Y"-€ _ r /-10J/?jJ( J / --by.;. Deputy REQUESTING PARTY Name Frank Federman, Esq. Address: One Penn Center at Subruban Station, Suite 1400 Philadelphia, PA 19103 Attorney for Plaintiff T I h 215-563-7000 e ep one: Supreme Court ID No. 12248. .~~I~~~O~ROM RECORD ~ 'i ~~Ht:~~~f. ~ j~WiO,S:~,i:m;'haOO - iIwI _ lii ~ Of -"j "-.l""I~ .... . :; <-,~~ ~~~ &~i r& 'I - - ,~ ~~ . ~'. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-7540 CIVIL lf9- TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY To satisfy the debt, interest and costs due First Union National Bank of Delaware F/K/A l'ir<:j- [Ininn Hrmp EqJliTy Bank, N.A. PLAINTIFF(S) from Sheila J. Miller. A/K/A Sheila J. Brudowsky, 1044 Hemlock Lane, mola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal 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 attachmenf has been issued: (b) the garnishee(s) is/are enjoined from paying any debt to or tor the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) II property of the defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other than a named garnishee, you are directed to notify himlherthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $28,221.57 LL from 1/30/01 to 9/5/01 Interest (p->r iliPll1 - $4.64) $1.101.34 and costsDue Prothy Atty's Comm % Other Costs $1.00 Atty Paid Plaintiff Paid $754.04 Date: June 8, 2001 Curtis R. Long Prothonotary, Civil Division AVrJL r /-YlOJ/M'>f> I ( Deputy --tl>f.:. REQUESTING PARTY: Name Frank Federman, Esq. Address: One Penn Center at Subruban Station, philadelphia, PA 19103 Attorney lor: Plaintiff T 'h 215-563-7000 e ep one: Supreme Court 10 No. 12248 Suite TRUE COPY FROM RECORD 1400 '" T~,y . li'iitr:Hw:a&lli mr!laM '- ~~~~:;~ I~Y -1-."' -- _...~ . ~~ ". ~ U~' '.. ~--f' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-7540 CIVIL ~ TERM CIVIL ACTION. LAW TO THE SHERIFF OF Cumberland _COUNTY To salisfy the debt, interest and costs due First Union National Bank of Delaware F/K/A F'ir<:T Ilninn HmlP Eqllity Bank. N.A. PLAINTIFF(S) from Sheila J. Miller. A/K/A Sheila J. Brudowsky, 1044 Hemlock Lane, Enola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as tollows: and to notily the garnishee(s) that: (a) an attachment has been issued: (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and trom delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not tevied upon an subject to attachment is found inthe possession of anyone other than a named garnishee, you are direcledto nomy himlherthat he/she has been added as a garnishee and is enjoined as above sfated. Amount Due $28,221.57 LL from 1/30/01 to 9/5/01 Interest (PPT' c1iPm - $4.64) $1.101.34 and costsDue Prothy Atty's Comm % Other Costs $1.00 Atty Paid Plaintiff Paid $754.04 Date: June 8, 2001 Curtis R. Long Prothonotary, Civil Division AfYM' _ r /-;J,j)/}~'}(-, I ( Deputy --bK REQUESTING PARTY Name Frank Federman. Esq. Address: One Penn Center at Subruban Station, Suite Philadelphia, PA 19103 Attorney for: Plaintiff T I h 215-563-7000 e ep one: Suprerne Court ID No. 12248 'TRUE 00'F'f m"JM R.ecoRD 1400~ l~ ',;;001'\101, I ,....;, ~lil~G t6t my Mad _ r;~~~~fg