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FEDERMAN AND PHELAN, LLP
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
WASHINGTON MUTUAL BANK
505 SOUTH MAIN STREET, SUITE 6000
ORANGE, CA 92868-4509
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
Plaintiff
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NO. 01- 17l/{ twJ
v.
CUMBERLAND COUNTY
LUEL YN M. CARCHIDI
203 WIDDERS DRIVE
MECHANICSBURG, PA 17055
Defendant(s)
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
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 warned that if you fail to
do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013.
(717) 249-3166
Loan #: 0017917436
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1. Plaintiff is
WASHINGTON MUTUAL BANK
505 SOUTH MAIN STREET, SUITE 6000
ORANGE, CA 92868-4509
2. The name(s) and last known address(es) of the Defendant(s) are:
LUEL YN M. CARCHIDI
203 WlDDERS DRIVE
MECHANICSBURG, PA 17055
who is/are the mortgagor(s) and real owner(s) ofthe property hereinafter described.
3. On 8/24/00 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to AMERIQUEST MORTGAGE COMPANY which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 1636, Page 521. PLAINTIFF is now the legal owner of the mortgage and is in the
process of formalizing an assignment of same.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 11/1/00 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith. A copy of such notice is attached as Exhibit "A."
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6. The following amounts are due on the mortgage:
Principal Balance
Interest
10/1/00 through 3/1/01
(Per Diem $31.92)
Attorney's Fees
Cumulative Late Charges
8/24/00 to 3/1/01
Cost of Suit and Title Search
Subtotal
$104,213.03
4,851.84
4,000.00
298.45
550.00
$113,913.32
Escrow
Credit
Deficit
Subtotal
0.00
0.00
$ 0.00
TOTAL
$113,913.32
7. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. !l1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiff s written Notice to Defendants,
a true and correct copy of which is attached hereto as Exhibit "A"; or
(ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
WHEREFORE, PLAINTIFF demands an in!!lli! Judgment against the Defendant(s) in the sum of
$113,913.32, together with interest from 3/1/01 at the rate of$31.92 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale ofthe mortgaged property.
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/ s/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
DATE: January 23, 20n FORECLOSURE
TO:
Luelyn M. Carchidi
203 Widders Drive
Mechanicsburg, PA 17055-5777
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.
This is an official notice that the mortgage on vour borne is in default and the lender intends to foreclose.
Soecific information about the nature of the default is orovided in the attached oages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to helo to save
vour home. This Notice exolains how the orogram works.
To see ifHEMAP can helo. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when Vou meet the
Counseline: Ae.encv.
The name. address and ohone number of Consumer Credit Counseling Agencies serving vour County are
listed at the end of this Notice. Ifvou have anv auestions. vou mav call the Pennsvlvania Housing Finance
Agencv toll free at 1-800-342-2397. (Persons with imoaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you fmd a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTlNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIT AMENTE LLAMANDO EST A
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRA.:Y[A
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CliAL
PUEDE SAL V AR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
EXH\B\T A
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STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): Luelyn M. Carchidi
PROPERTY ADDRESS: 203 Widders Dr.-Mechanicsburg, PA 17055
LOAN ACCT. NO.: 0017917436
ORIGINAL LENDER: Ameriquest Mortgage Company
CURRENT LENDER/SERVICER: Ameriquest Mortgage Company
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE.
. IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
. IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
. IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYL V ANlA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must
arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-Ifvou meet with one of the consumer credit
counseling agencies listed at the end of this notice the lender mav NOT take action against vou for thirtY
(30) davs after the date of this meeting. The names. addresses and telephone numbers of designated
consumer credit counseling agencies for the county in which the propertY is located are set forth at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv
of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in a default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default.) If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and me a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in submitting a complete
application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
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Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
If ou have filed bankrn te ou can still a I for Emer ene Mort a e Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to date).
NATURE OF THE DEF AUL T -The MORTGAGE debt held by the above lender on your property located
at: 203 Widders Dr.-Meehaniesburg, P A 17055 IS SERIOUSLY IN DEF AUL T because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due: Start/End: 11/1/00 thru 1/1/01 at $994.77 per month.
Monthly Payments Plus Late Charges Accrued $3,223.07
NSF: $0.00
Inspections: $0.00
Other: $0.00
(Suspense): $0.00
Total amount to cure default $3,223.07
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable): N/ A
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,223.07,
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
THE THIRTY (30) DAY PERIOD. Payments must be made either bv cash. cashier's check. certified
check or monev order made pavable and sent to: AMERIQUEST MORTGAGE COMPANY, 505
South Main Street, 6th Floor, Orange, CA 92868, Attention:Collections Department.
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter. (Do not use if not applicable.) N/ A.
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means
that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to
foreclose UDon your mortlZalZe oroDertv,
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay
off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's
fees that were actually incurred, up to $50.00. However, iflegal proceedings are started against you, you
will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00.
Any attorney's fees will be added to the amount you owe lender, which may also include other reasonable
costs. Ifvou cure the default within the THIRTY (30) DAY period. vou will not be required to pav
attorney's fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default
WIthin the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to
EXHIBIT A
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cure the default and orevent the sale at any time uo to one hour before the Sheritrs Sale. You may do so
bv oavin2 the total amount then oast due. Dins any late or other char2es then due. reasonable attorney's fees
and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as
soecified in writin2 bv the lender and bv oerformin2 any other requirements under the mort2a2e. Curing
your default in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriffs
Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of
this Notice. A notice of the actual date of the Sheritrs Sale will be sent to you before the sale. Of course,
the amount needed to cure the default will increase the longer you wait. You may fmd out at any time
exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
AMERlQUEST MORTGAGE COMPANY
505 South Main Street, 6th Floor
Orange, CA 92868
Tel:(800) 430-5262
Attention: Collections Department
EFFECT OF SHERIFF'S SALE-You should realize that a Sheritrs Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE-You may or_X_may not (CHECK ONE) sell or transfer
your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost are paid prior to or at the sale and that the other requirements
of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
. TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT.
. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
. TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
Very truly yours,
Attn: Collections Department
AMERIQUEST MORTGAGE COMPANY
Account No.: 0017917436
Mailed by 1" Class mail/Certificate of Mailing and Certified Mail No:
, Certified Article Number" . c-
710b ~575 12"14 ]'''lD0 6553
. 'SENDEEtSRECORO' '.
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PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
(REV. 8/00)
CLINTON COUNTY
Lycoming-Clinton Counties Commision for
Community Action (STEP)
2138 Lincoln Street P.O. Box 1328
Williamsport, PA 17703
(570) 326-0587 FAX (570) 322-2197
CCCS of Northeastern PA
20 I Basin Street
Williamsport, PA 17703
(570) 323-6627 FAX (570) 323-6626
31 W, Market Street
POB 1127
Wilkes-Barre, PAl 8702
(570) 821-0837 0' (800) 922-9537
FAX (570) 821-1785
Commission on Economics Opportunity ofLuzerne County
163 Ambo< Lane
Wilkes-Barre, PAl 8702
(570) 826-0510 0' (800) 822-0359
FAX (570) 829-1 665--{Call Befo" Faxing)
(570) 455-4994 Hazeltown
FAX (570) 455-5631--{Call Before Faxing)
(570)836-4090 Tunkhannock
Booker 1. Washington Center
1720 Holland Center
E,ie, PAl 6503
(814) 453-5744 FAX (814) 5749
John F. Kennedy Center, Inc.
2021 East 20th Street
Erie, PA 16510
(814) 898-0400
FAX (814) 898-1243
CCCS of West em Pennsylvania, Inc.
2000 LingJestown Road
Harrisbu,g, P A 17102
(717) 541-1757
Urban League of Metropolitan Harrisburg
N, 6th Street
Harrisburg, PA 17101
(717) 234-5925 FAX (717) 234-9459
Community Action Corom of the Capital Region
1514 Derry Street
Harrisbu'g, PAl 71 04
(717) 232-9757 FAX (717) 234-2227
CCCS of Northeastern P A
1631 South Athenan St., Suite 100
State College, P A 1680 I
(814) 238-3668 FAX (814) 238-3669
COLUMBIA COUNTY
1400 Abington Executive Park
Suite 1
Chucks SummiL PAl 84 I I
(570) 587-9163 or (800) 922-9537
FAX (570) 587-9134-9135
CRAWFORD COUNTY
Greater Erie Community Action Committee
18 West 9th Street
Erie, PA 16501
(814) 459-4581 FAX (814) 456-0161
Shenango VaHey Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
(412) 981-5310
CUMBERLAND COUNTY
Financial Counselin~ Services of Franklin
31 West 3rd Street "
Waynesboro, PA 17268
(717) 762-3285
YWCA of Cadisle
301 "G" Street
Carlisle, PA 17013 e
(717) 243-3818 FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St.
Gettysbu'g, PA 17325
(717)334-1518 FAX334-8326
PENNSYL VANIA BULLETIN, VOL. 29, NO. 23, JUNE 5, 1999
EXHIBIT A
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ALL THAT Cl!RTAIN tr""t of land situate in MantOe Townsbil'. CUmbe:land County.
Pennsylvania, being mote particularly bounded and described os follows, '0 wit:
BEGINNING at a POiD' 00 the eastm1 sidc of Widdem Drivc, a fifty (50) fool wide stre..;
lIumce aloog lands now or formerfy of Uoyd B. Widdo<s. North sixlY-seven (67) de_
cisJlteez> (18) minutes sixteen (16) seconds East,. DOC hundta4 nlae<een BOd fiftY-two Inm<h<odths
(119.52) fcet lO a point at Lot No. 24; t&eace along Lo. No. 24, Sooth eighteezs (18) degrees twO
(2) mbwle$ .wenty-slx (26) seconds East, 00' hundr<:d cleven and slXly-six hUJ:ldredrhs (111.66)
fee. '0 a point a. Lot No. 23; lh_ along Lot No. 23. South Ihirty (30) degJl!eS flIty-onc (51)
minutes fotty-eisJl. (48) secoztds East, twenty-nine and twCttty-.wo hundredths (29.22.) feet 10 .
p_t a' Lo. No. 30; thence al~ Lo. No. 30. South alxlY-sevOl1 (67) degrees 101gb...... (la)
mlnutes si:lc"'en (16) seconds West. ODC hun_ fourteen and si:lcty-ducc hun_cbs (114.63)
feet to a point on the castent side of Wlddem Drive; thence along the eastem aide of Wlddcn;
Drive. North .wenty-two (22) degrees, fony-ODe (41) minutes forty-four (44) seconds West, on"
hundred forty (140) feet to a point on the castem side of Widdcrs Drive.., and the place of
BEGINNING.
BEma Lot No~ 29 of Monroe Acres, as shown on Section Bt i.a accordance With a survoy of
Larsen and Brilhart.. Inc., Re&istere.d Survc:yors~ dated June 18, 1970, and I'c:corded in Plan Book
22. at page 1.
RA VlNG THEREON ~ a modified spill-level brick and aluminum sieling dwelling
Ilumbcte<! 203 Wldders Drive.
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VERIFICATION
Priscilla Clark hereby states that he/she is Foreclosure Specialist of
mortgage servicing agent for Plaintiff in this matter, that he/she is
authorized to take this Verification, and that the statements made in
the foregoing Civil Action in Mortgage Foreclosure are true and correct
to the best of his/her knowledge, information and belief. The
undersigned understands that this statement is made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to
authorities.
DATE: '3\(0\0\
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priscilla Clark, Foreclosure Specialist
q;j~~"~j~li!i1O~i\fii,tm~~~!~II#!t$IWllJl.i~~H'i!t'k!lt,,-,,,-.lj~;';,t~"""""'''-<Ml&i';~lli'-ij"~.~-,""_. ~""-'''''"--","' ~~
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~EDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
One Penn Center at Snbnrban Station
Snite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Attorney for Plaintiff
t
WASHINGTON MUTUAL BANK
505 SOUTH MAIN STREET, SUITE
6000
ORANGE, CA 92868-4509
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff
: CIVIL DIVISION
vs.
: NO. 01-1745
LUELYN M. CARCHIDI
203 WIDDERS DRIVE
MECHANICSBURG, P A 17055
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 LUEL YN M.
CARCHIDI, Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days
from service thereof and for foreclosure and sale ofthe mortgaged premises, and assess Plaintiff's
damages as follows:
As set forth in Complaint
Interest 3/1/01-5/21/01
$113,913.32
$2,617.44
TOTAL
$116,530.76
I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above,
and (2) notice has been given in accordance with Rille 237.1, copy attached.
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FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~
DATE: fYl~d} .;2.1 .;).O<J \ ~j/J)';' J 12.
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"TillS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS DEBT WAS
NOT REAFFIRMED, TillS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLEcr
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. "
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FEDERMAN AND PHELAN, L.L.P.
trank Federman, Esquire
Identification No. 12248
'One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
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WASHINGTON
MUTUAL
BANK
COURT OF COMMON PLEAS
CIVIL DIVISION
vs.
LUELYN M. CARCHIDI
CUMBERLAND COUNTY
NO. 01-1745
Defendant(s)
TO: LUELYN M. CARCHIDI
203 SOUTH MAIN STREET, SUITE 6000
MECHANICSBURG,PA17055
FILE COpy
DATE OF NOTICE: MAY 10.2001
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 COUNfY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
One Penn Center at Snburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Attorney for Plaintiff
W ASIDNGTON MUTUAL BANK
: CUMBERLAND COUNTY
Plaintiff
: Court of Common Pleas
vs.
: CML DIVISION
LUELYN M. CARCHIDI
: NO. 01-1745
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the
following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act
of Congress of 1940, as amended
(b) that defendant LUELYN M. CARCHIDI is over 18 years of age and resides at
203 WIDDERS DRIVE, MECHANICSBURG, P A 17055.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
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FRANK FEDERMAN
Attorney for Plaintiff
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(Rule of Civil Procedure No. 236 - Revised)
W ASIDNGTON MUTUAL BANK
: CUMBERLAND COUNTY
Plaintiff
: Court of Commou Pleas
vs.
: CIVIL DIVISION
LUELYN M. CARCHIDI
: NO. 01-1745
Defendant(s)
Notice is given that a Judgment in the above captioned matter has been entered against you on
MAY r;} 3 .2000.
~y 40". "'---,P. ~~ J'"i)EPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESOUIRE
Attorney for Filing Party
One Penn Center at Snburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
**TIDS Ji1RM 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. **
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-01745 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK
VS
CARCHIDI LUELYN M
STEVEN M. WHISTLER
, Sheriff or Deputy Sheriff of
Cumberland county,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
CARCHIDI LUELYN M
the
DEFENDANT.
, at 1708:00 HOURS, on the 3rd day of April
, 2001
at 203 WIDDERS DRIVE
MECHANICSBURG, PA 17055
by handing to
LUELYN M. CARCHIDI
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
5.58
.00
10.00
.00
33.58
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R. Thomas Kline
04/04/2001
FEDERMAN & PHELAN
me this /Il::::..-
day of
By~1Jt,4J~
Deputy Sheriff
Sworn and Subscribed to before
GN :uo I A.D.
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P othonotary
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
WASHINGTON MUTUAL BANK
Plaintiff,
CUMBERLAND COUNTY
v.
No. 01-1745
LUEL YN M. CARCHIDI
Defendant{s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$116,530.76
Interest from 5/21/01 to 9/5/01
(per diem - $19.16)
$2,049.66 and Costs
TOTAL
$118,580.42
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ONE PENN CENTER at SUBURBAN STATION
SUITE 1400
PHILADELPHIA, PA 19103
Attorney for Plaintiff
Note: Please attach description of property.No.
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ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County,
Pennsylvania, being more particularly bounded and described as follows, to wit:
BEGINNING at a point on the eastern side of Widders Drive, a fifty (50) foot wide street; thence
along lands now or formerly of Lloyd B. Widders, North sixty-seven (67) degrees eighteen (18)
minutes sixteen (16) seconds East, one hundred nineteen and fifty-two hundredths (119.52) feet to a
point at Lot No. 24; thence along Lot No. 24, South eighteen (18) degrees two (2) minutes twenty-
six (26) seconds East, one hundred eleven and sixty-six hundredths (111.66) feet to a point at Lot
No. 23; thence along Lot No. 23, South thirty (30) degrees fifty-one (51) minutes forty-eight (48)
seconds East, twenty nine and twenty-two hundredths (29.22) feet to a point at Lot No. 30; thence .
along Lot No. 30, South sixty-seven (67) degrees eighteen (18) minutes sixteen (16) seconds West,..:.
one hundred founeen and sixty-three hundredths (114.63) feet to a point on the eastern side of
Widders Drive; thence along the eastern side of Widders Drive, Nom twenty-two (22) degrees,
forry one (41) minutes forry-four (44) seconds West, one hundred forry (140) feet to a point on the
eastern side of Widders Drive, and the place of BEGINNING.
BEING Lot No. 29 of Monroe Acres, 'as shown on Section B, in accordance with a survey of
Larsen and BriIhart, Inc., registered Surveyors, dated June 18, 1970, and recorded in Plan Book 22,
at page 1.
HAVING THEREON ERECTED a modified split-level brick and aluminum siding dwelling
numbered 203 Widders Dtive.
TAX PARCEL #22-29-2463-081
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TITLE TO SAID PREMISES IS VESTED IN Luelyn M. Carchidi, widow by Deed from Luelyn
M. Carchidi, widow dated 8/24/00 and recorded 8/31/00 in Record Book 228 Page 387.
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AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No.1)
WASHINGTON MUTUAL BANK, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 203 WIDDERS
DRIVEMECHANICSBURG. P A 17055
1. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
i reasonably ascertained, please so indicate.)
LUELYNM.
CARCHIDI
203 WIDDERS DRIVE
MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
GREENWOOD TRUST
COMPANY
C/O EDWARD STOCK 18TH FLR.
1608 WALNUT STREET
PHILADELPHIA, PA 19103
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4. Name and address ofthe last recorded holder of every mortgage of record:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
5. Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
203 WIDDERS DRIVE
MECHANICSBURG, PA 17055
Domestic Relations of Cumberland
County
13 North Hanover Street
Carlisle, P A 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Mav 25,2001 4-- - A j.tJ ~
DATE ~~~~,ESQUIRE
Attorney for Plaintiff
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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
WASHINGTON MUTUAL BANK
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
LUELYN M. CARCHIDI
NO. 01-1745
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.
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FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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WASHINGTON MUTUAL BANK
Plaintiff,
CUMBERLAND COUNTY
v.
No. 01-1745
LUELYN M. CARCHlDI
Defendant(s).
May 25, 2001
TO: LUEL YN M. CARCHIDI
203 WIDDERS DRIVE
MECHANICSBURG, P A 17055
""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 203 WIDDERS DRIVEMECHANICSBURG, PA 17055is_.
scheduled to be sold at the Sheriff's 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 WASHINGTON MUTUAL BANK (the mortgagee) against you. If the Sheriffs sale is postponed,
the property will be relisted for the Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, ifthe judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
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You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution 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 LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAwYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County,
Pennsylvania, being more particularly bounded and described as follows, to wit:
BEGINNING at a point on the eastern side of Widders Drive, a frfty (50) foot wide street; thence
along lands now or formerly of Lloyd B. Widders, North sixty-seven (67) degrees eighteen (18)
minutes sixteen (16) seconds East, one hundred nineteen and fifty-two hundredths (119.52) feet to a
point at Lot No. 24; thence along Lot No. 24, South eighteen (18) degrees two (2) minutes twenty-
six (26) seconds East, one hundred eleven and sixty-six hundredths (111.66) feet to a point at Lot
No. 23; thence along Lor No. 23. South thirty (30) degrees fifty-one (51) minutes forry-eight (48)
seconds East, twenry nine and twenry-two hundredths (29.22) feet to a point at Lot No. 30; thence.
along Lot No. 30, South sixry-seven (67) degrees eighteen (18) minutes sixteen (16) seconds West,.,.
one hundred founeen and sixry-three hundredths (114.63) feet to a point on the eastern side of
Widders Drive: thence along the eastern side of Widders Drive, Nonh .twenry-two (22) degrees,
fony one (41) minutes forry-four (44) seconds West, one hundred fony (140) feet to a point on the
eastern side of Widders Drive, and the place of BEGINNING.
BEING Lot No. 29 of Monroe Acres,.as shown on Section B, in accordance with a survey of
Larsen and Brilhart, Inc., registered Surveyors, dated June 18, 1970, and recorded-in Plan Book 22,
at page 1.
HA VING THEREON ERECTED a modified split-level brick and aluminum siding dwelling
numbered 203 Widders Drive.
TAX PARCEL #22-29-2463-081
TITLE TO SAID PREWSES IS VESTED IN Luelyn M. Carchidi, widow by Deed from Luelyn
M. Carchidi, widow dated 8/24/00 and recorded 8/31100 in Record Book 228 Page 387.
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Law Offites - f "" ,
FEDERMAN AND PHELAN
One Penn Center at Suburban Station
1617 JohnF. Kennedy Blvd., Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Fax: (215) 563-5534
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Leo Magee
Foreclosure Department
Representing Lenders in
Pennsylvania and New Jersey
July 9,2001
Office ofthe Prothonotary
Cumberland County Courthouse
South Hanover Street
Carlisle, P A 17013
Re: WASHINGTON MUTUAL BANK
v. LUELYNM. CARCHIDI
Nd.01-1745
Premises: 203 WIDDERS DRNE, MECHANICSBURG, P A 17055
Dear Sir/Madam:
Enclo~e.p for filing and transmittal to the assigned Civil Si<ming Judge for execution. please find
Plain~trsPetition for Service of the Notice of sale Pursuant to Special Order of Court and
propo$ed Order.
Kindly return a time-stamped copy in the enclosed self-addressed stamped envelope.
Also, find attached a copy of the Order granting alternative service which should be signed by
the Judge. Please return this signed Order in the attached stamped self-addressed envelope.
Very trul:/rurs,
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Leo Magee for
Federman and Phelan
/leo
enclosures
cc: AMERIQUEST MORTGAGE COMPANY
Attention: Foreclosure Department
File #0017917436
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
WASHINGTON MUTUAL BANK
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
vs.
No.: 01-1745
LUEL YN M. CARCHIDI
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
LUEL YN M. CARCHIDI on 07/24/01 at 203 WIDDERS DRIVE, MECHANICSBURG, P A
17055, in accordance with the Order of Court dated 07/16/01.
The undersigned understands that this statement is made subject to the penalties of 18 P A
C.S. s 4904 relating to unsworn falsification to authorities.
1-/lAMk 9-~
FRANK FEDERMAN, ESQUIRE
Date: Ju1v 25. 2001
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SENDER:
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REFERENCE: .... SALES
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK
Plaintiff
CIVIL DIVISION
vs.
No. 01-1745
LUEL YN M. CARCHIDI
Defendants
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
SS:
CUMBERLAND COUNTY
I, FRANK FEDERMAN, ESQ., attorney for WASHINGTON MUTUAL
BANK, hereby verify that on JUNE 6. 2001, true and correct copies of the Notice of
Sheriff's Sale were served by certificate of mailing to the recorded lienholder(s), and any
known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was
sent to defendant(s) on JUNE 6. 2001 and JULY 24,2001 by first class mail and
certified mail return receipt requested, see Exhibit "B" attached hereto.
Date: Auqust 10, 2001
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK
Plaintiff
CIVIL DIVISION
vs.
FILE Copy
No. 01-1745
LUEL YN M. CARCHIDI
Defendants
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
. SS:
CUMBERLAND COUNTY
I, FRANK FEDERMAN, ESQ., attorney for WASHINGTON MUTUAL
BANK, hereby verify that on JUNE 6. 2001, true and correct copies of the Notice of
Sheriff's Sale were selVed ~y certificate of mailing to the recorded Iienholder(s), and any
known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was
sent to defendant(s) on JUNE 6. 2001 and JULY 24. 2001 by first class mail and
certified mail return receipt requested, see Exhibit "B" attached hereto.
Date: Auoust 10. 2001
~tt."'PflIILI
. ~f'r:J:'t'6~
Ptlt'l'4'r r .
.
. -
STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55.
Robert P Ziegler
I, ---_________________________________________________~________________________Ilecorderof
Deeds in and for said County and State do 'hereby certify that the Sheriffs Deed in wbich ________________
Wahsington Mutual Bank .
-------~-------------------------------------------------___________________________ 6 thegr.onWe
5th
the same having been sold to said gr.ontee on the ------________u_____uu__u__________________ day of
u____~:R.J:.~~.?_':.'::_u_u_u_________u___ A. D.,; 01 n___' under and by virtue of a wriL_____________
Execution . 8th
_______________________________u__________u___lSSued on the __________________u__u____u_______
June
clay of __________________________ A. D.,
Civil
__________________________u__... __ ___ u_____ u_ __ __ _______ u_ _______h_____ _______ Term, :
01 .
__u_> out of the Court of Cornman Pleas of said County as of
01
. 1745 . Washington Mutual Bank
Number --------------, at the su.t of -~----------_____u__________________u_u____u________u_____
Lue1yn M Carchidi
-------------------------______ -_ __ against_ ___ ___________ ________ ____________ __ ____ ___________ is
248 3926
duly recorded in Sheriffs Deed Book No. ____________, Page _____________
IN TESTIMONY WHEIlEOF, I have hereunto
-;7f;
set my hand and seal of said office this J'-__h___ day
......,ellleedt. ~Co\III\J.CaI\iSIe.1'A
.., Q,mllliltlll"EIIlli* IIIe rlllllllllldl1 aI aa.-
Washington Mutual Bank
VS
Luelyn M. Carchidi
" ~
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,_;.,d _ -<.<
I J __');!
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-1745 Civil Term
Bryan Ward, Deputy Sheriff, who being du1y sworn according to law, says
on Ju1y 25, 2001 at 8:33 o'clock PM EDST, he served a true copy of Real Estate Writ,
Notice and Description in the above entitled action upon one of the within named
defendants to wit: Luelyn M. Carchidi, by making known unto Luelyn Carchidi, at 419
Fairview Ave., Enola, Cumberland County, Pennsylvania, its contents and at the same
time handing to her personally the said true and attested copies of the same.
Dawn Kell, Deputy Sheriff, who being du1y sworn according to law, states on
Ju1y 2, 2001 at 10:00 0' clock A.M., EDST, she posted a true copy of the within Real
Estate Writ, Notice, Poster and Description upon the property of Luelyn M. Carchidi
located at 203 Widders Drive, Mechanicsburg, P A 17055, according to law.
R. Thomas Kline, Sheriff, who being du1y sworn according to law, states that he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a pendency ofthe action to one of the within named
defendants, to wit: Luelyn M. Carchidi, by regular mail to her last known address of203
Widders Drive, Mechanicsburg, P A 17055. This letter was mailed under the date of Ju1y
26,2001 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being du1y sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on September 5, 2001 at 10:00 o'clock A.M., E.D.S.T., and sold the same
for the sum of $1.00 to Attorney Dale Shughart (for Attorney Frank Federman) for
Washington Mutual Bank. It being the highest bid and best price received for the same,
Washington Mutual Bank of 505 South Main Street, Suite 6000, Orange, CA 92868-
4509, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of
$812.39, it being costs.
Sheriffs Costs:
Docketing
Poundage
Advertising
Posting Handbills
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Law Journal
$30.00
15.93
15.00
15.00
30.00
10.00
.50
1.00
15.60
1.71
15.00
20.00
321.20
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
244.29
25.66
25.00
2Q..iQ
$812.39 paid by attorney
10-03-01
Sworn and subscribed to before me
" ,
so~
n ~.,,- -,.....<'~-<'"
R. Thomas Kline, Sheriff
This ~ day of rJ~ .
2001, A.D. t}p(,-, 0 Ih,/Ih 1~'
rothonotary
By q()~ SM-L~
Real Estate Deputy
~
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f2u-" )1f1J 't ')..-
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"
WASHINGTON MUTUAL BANK
.
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
LUEL YN M. CARCHIDI
CIVIL DIVISION
Defendant(s).
NO. 01-1745
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No.1)
WASHINGTON MUTUAL BANK, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 203 WIDDERS
DRIVEMECHANICSBURG, PA 17055
1. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
LUELYNM.
CARCHIDI
203 WIDDERS DRIVE
MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
GREENWOOD TRUST
COMPANY
C/O EDWARD STOCK 18TH FLR.
1608 WALNUT STREET
PHILADELPHIA, PA 19103
. ,
L.~ ~~~j~
4., Name and address of the last recorded holder of every mortgage of record:
..
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
5. Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
203 WIDDERS DRIVE
MECHANICSBURG, P A 17055
Domestic Relations of Cumberland
County
13 North Hanover Street
Carlisle, PA 17013
Commonwealtll1 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.
Mav 25. 2001 4- - A j,tJ ~
DATE ~~M::
Attorney for Plaintiff
Ir ...
-J
":'i
WASffiNGTON MUTUAL BANK
Plaintiff,
CUMBERLAND COUNTY
v.
No. 01-1745
LUELYN M. CARCffim
Defendant(s).
May 25,2001
TO: LUEL YN M. CARCHIDI
203 WIDDERS DRIVE
MECHANICSBURG, P A 17055
"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 203 WIDDERS DRIVEMECHANICSBURG, P A 17055is_
scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a.m. in the Curnberland
County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained
by WASHINGTON MUTUAL BANK (the mortgagee) against you. If the Sheriffs sale is postponed,
the property will be relisted for the Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
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You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
yOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale neverhappened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7 . You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
(
ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County,
Pennsylvania, being more particularly bounded and described as follows, to wit:
BEGINNING at a point on the eastern side of Widders Drive, a fifty (50) foot wide street; thence
along lands now or formerly of Lloyd B. Widders, North sUlly-seven (67) degrees eighteen (18)
minutes sixteen (16) seconds East, one hundred nineteen and fifty-two hundredths (119.52) feet to a
point at Lot No. 24; thence along Lot No. 24, South eighteen (18) degrees two (2) minutes twenty-
six (26) seconds East, one hundred eleven and sixty-six hundredths (111.66) feet to a point at Lot
No. 23; thence along Lot No. 23, South thirty (30) degrees fifty-one (51) minutes forty-eight (48)
seconds East, twenty nine and twenty-two hundredths (29.22) feet to a point at Lot No. 30; thence
along Lot No. 30, South sixty-seven (67) degrees eighteen (18) minutes sixteen (16) seconds West, _..
one hundred fourteen and sixty-three hundredths (114.63) feet to a point on the eastern side of
Widders Drive; thence along the eastern side of Widders Drive, North twenty-two (22) degrees,
forty one (41) minutes forty-four (44) seconds West, one hundred forty (140) feet to a point on the
eastern side of Widders Drive, and the place of BEGINNING.
BEING Lot No. 29 of Monroe Acres, as shown on Section B, in accordance with a survey of
Larsen and Brilhart, Inc., registered Surveyors, dated June 18, 1970, and recorded in Plan Book 22,
at page 1.
HAVING THEREON ERECTED a modified split-level brick and aluminum siding dwelling
numbered 203 Widders Drive.
TAX PARCEL #22-29-2463-081
TITLE TO SAID PREMISES IS VESTED IN Luelyn M. Carchidi, widow by Deed from Luelyn
M. Carchidi, widow dated 8/24/00 and recorded 8/31/00 in Record Book 228 Page 387.
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~WRf'T'GF(EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 01-1745 CIVIL 19X TERM
CIVIL ACTION - LAW
TO THE SHERJFF OF
Cumberland
COUNTY:
To satis.fy the debt, interest and costs due Washnigton Mutual Bank
PLAINTIFF(S)
trom Luelyn M. Carchidi, 203 Widders Drive, MeChanicsburg. PA 17055
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 detendanl(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the detendant(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/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $116,530.76 L.L.
from 5/21/01 to 9/5/01
Interest (per diwl $1 q 1 h 1 $?n4CJ "" "nn Costs Due Prothy
Atty's Comm % Other Costs
$.50
$1.00
Atty Paid
Plainfiff Paid
S105.58
Date: June 8, 2001
Curtis R. Long
Prothonotary, Civil Division
bye 4-0-""1' [) 71fJ7/lAY')
Deputy
REQUESTING PARTY:
Address:
Frank Fedennan, Esq.
One Penn Center at Suburban Station, Suite 1400
Philadelphia, PA 19103
Attorney for: Plaintiff
Telephone: 215-563-7000
Supreme Court ID No. 12248
Name
;t~d6\!~~mil~~~"'{"~I~,"i~"".;I,"'l1.;s...~illi;;;;",,'_,f!.,_~,~!.C-"'L,Q,.
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U~llillili!ll!.~
REAL ESTATE SALE No.13
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on J ~ J L/ I 2..00 f the sheriff levied upon the lleteoolam;
Interest In the real property situated in -r1 (ll/l.,Irf. I ~~ .....
Oumberland County, Pa., known and numbered as: JI) 3 ~lddoAA)[)/i(1/e
171'ci.Iu1'i:-b1xvr.j and more fully described on Exhibit "A" filed wlU,!
this writ and by this reference incorporated herein.
1Jate:-J"~ 1<1, ODD! By: (~C/..A..
[)-e~k ~~
Y\""'I'l<CI.1h!3d
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
SS.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
V1Z:
JULY 20, 27, AUGUST 3, 2001
Affiant further deposes that he is authorized to verifY this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
j
Roger M. Morgenthal, Editor
--..
SWORN TO AND SUBSCRIBED before me this
3 day of AUGUST. 2001
~~~A. ~nv
nt::1nr
, N01ARrAUEAL
LOIS E. SNYDER, Nol8ryPubllc
CarlisIeBoro, CUmberland County
My CoIRlIileaIon Expires MaR:h 5. 2005
:REAL ESTA.TE SAm NO. 33
-
Writ No. 2001-1745 CMl
Washington Mutual Bank
Vs.
Luelyn 111. Carch.idi
Ajjy.: Frank Fedennan
ALL THAT CERTAIN tract of land
situate in Monroe TO'WD.ship. Cum-
berland County. PennsylvanJa. being
more Particularly bOunded and de-
scribed as fellows. to Wit:
BEGINNlNG at a point on the
eas~ side ofWidders Drive. a fifty
(50) foot \Vide street; thence along
lands now or formerly of Lloyd B.
Widders. North sixty-seven (67) de-
grees eighteen (18) minutes sixteen
(16) seconds East, one hundred nine-
teen and :fifty-two hundredths (119-
.52) feet to a pomt at Lot No. 24:
thence along Lot No. 24. South 18
(18) degrees two (2) minutes twenty-
sIx (26) seconds East one hundred
eleven and six'ty-six one hundredths
(11 1.66) feet to a point at Lot. No.
23; thence along Lot No. 23. South
tb1rty (30) degrees :fifty-one (51) min-
utes forty-eight (48) seconds East,
twenj:y-nine and twen",-two hun-
dredths (29.22) feet to a point at
Lot No. 30; thence along Lot No. 30.
South sixty-seven (67) degrees eight-
een (18) minutes sixteen (l6) seconds
West. one hundred fourteen and
sixty-three hundredths (114.63) feet
to a point on the eastern. side of
\Vidders Drive: thence along the
eastern Side of 'W1dders Dtive. North
'ttven:ty-two (22) degrees. forty one
i41} minutes forty-four (44) seconds
West. one hundred forty (140) feet
to a point on the eastern side of
'\iVidde:rs Drive. and the Place of BE-
GINNING. -
BEING Lot No. 29 of Monroe
Acres. as shown on Section B. in ac-
COrdance With a sUIV'ey of Larsen .and
B:dlhart. me.. registered Sl.UVeyors.
dated June 18. 1970. and recorded
m Plan &ok 22. at page 1.
HAVING THEREON ERECTED a
modified split-leVel blick and alu-
minum siding dwelling numbered
203 Widders Drive.
TAX PARCEL #22.29-2463-081.
TInE TO SAID PREMISES IS
VESTED IN Luelyn M. Carchidi.
Widow by Deed from Luelyn M.
Carchid.i, "Widow dated 8/24/00
and recorded 8/31/00 in Record
Book 228 Page 387.
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing
under the laws of the Commonw@alth of Pennsylvania, with its principal office and place of business at 812 to 818
Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of IJ1g
Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published
ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular dally and/or Sunday/ Metro editions which appeared on the 24th and 31 st day(s} of July and the 7th
day(s) of August 2001. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the filCts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Misrneous Book "M",
V;I~:Lll~:~~~:' ......................................fi................... ...............................
COpy . me is 21s day ugust 2001 A.D.
_Seal
S ALE #33 rerry L RUSS8II, NoIary P
Harrisburg, Dauphin
My Co\lIfnI..1on expires June
Member, Pennsylvania Assoelatlon 01 NolanD My commission expires June. 6, 2002
\
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
!~
,
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
herelo on the above stated dates $
Probating same Notary Fee(s) $
Total $
242.79
1.50
244.29
Publisher's Receipt for Advertising Cost
The Patriot News Co., poblisher of The Patriot-News and The Sunday Patriot-News, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
By....................................................................
ilEAl. eSTAlE SAtEN~-:a~
il'rl!NO: 2001-1745 ..
'''"::''''':ct!WJTernf' -,
WashiNStoo Mutual BanI(
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~'"'l\in M.Cai6/iidi
Aity: Prankfcilermiln .
DESCRIPTION
.. AlL TRAi",CER'rAL.'1 troc! or J:lnd, Silll<lle lIJ
MUnrO!: .. Tw.~Jl,~.l:iip., .. ~m~rl~tl({ ('GUM).
p{'1JJl.~)!fvaQi;I,... P<'lllg" .!i!9f9 P<m/cularl): h?ul1dt.'(j
:a'ndi:kii'Crfflc~;ra~'lhJ,~~~\IOWlt '," ..
.. 13f.01NNJNG~':;~ ~c,fki!r1i .em lht'"J:.JsrCffi Md<: llt
Wldd!:n Dri\e; .a,.Wly (SQ}.P'JOt \\.')Jq SlItt'l,
then(\> <1long /,'lnds' now ',{I( formerly of Ulya B.
\Vi?uen:, NOi"'l1i'~IXIY:~i!?~'l'! (61j<4'gr~'i;'f€hlC$.1l
""(!8j-nJhl'li[L'S"':Si;liJCc':n.. (J6} ,~~s' .Ea'ii; <me
..hlln<:/red 1lJI1IOtcen.', am1:, Ii{i}'~i;\'t) fllmdr<.'rirn\
O!9.52J fecI !o,';r,POin(af +.{r!-..k~\ 3Ji {iJrrJi:t'
.,a/PIII; Lvt No. 24, Squ& l."lj!h(ec!:I W'O dc~n::~\<
!WQ m miiusn:s f\l,em~:..'i'iX'(?f:>),\~.lltid.\ l-::N,
{)he",hl)lidrcd ckl-eil miJ ;1~1\~~1:\,..1Jlll1&cdl~'.)
{JJ U,6j' f\.'~(. to,11 poinf .at Lci Nit '2J; li'lI;q.:c:
wt)np Lol No, ~J, lXIU(O (nil1,Y 13m ~l::~J'ift5.-
",''m'';'',Sl) iliiflUli.:'S, ~l.litj.-t~t,gnt (,-i..~l :-i";<;ilJds r~,'>l:;
" ,[\\>i:'l1lY'm'n~";fiJtf tWClltj,.tWl,) hUi1frl'dal.~ C!:rI,:2)
i~r:t l!i ;i Po:i}n ~_l( {,pt Noc JO: ,thfric\:' :ll(\~g ,Lvi
~'i:-;, '31L,Soiuh,ShlY_~'~Vi;I? ,16:7tdeCr:ct"!i !:Whl~~
'J8)' u,ii'Rltl.'i; ',iJ\teen /161 Sccnl1d~ l,i.b,l> 'alii:
hundred fOllrkt'1l and, \i,;;rY:ihl\:e,'" il.4l1!JfcJilh
n J-l.bJ) fl.'-i,.t'to a point on (he 'casteni -'>1de, of
Wid4cr.(Dri~e; J!1cilce aloile,-'lht' ~~'tern M<k of
Widib"; fin\e; .N(~ ,1w..'1ItY;I,W<l (lZi &.'tn-'C1;.,
" fqtty 1101:,/-l,1) mmqli:s'foriifour (.:i.n SCcol:l.ds
Wl;.\f. tine handfed fon}' f H(,!'. fci.:t iq ,(pollJ( Ofl
,t1k:J;'a.'4l% ~fli'- 91' Wlddt,rs Dnv\.'; 'and the- pl~ce
<1fHEV/NN1NG. .. ... . .
R!:L\iti p,i Nit :itl, bi' Mon(fA~:At~, a~ ,snO\\ n
'Qi;"'5.C(<[jOJi'f:1; In :l{.cprcmnce ~l':ilh'iUl!n'~)' of
' IArscn 'ilnd 13rilha'r4 IiIe:, n:W~lered SlJr~}Of'i.-
([~((,.'il.Jtin{ 18. /970, ,mu n..'CO~d 1Il Pf;m Book
..:p;j( PJj;i;). , , , ." _" ,~,
'HAVTNa THEREON ERECTED a /7l<li:Jified
~Plh'.It::\dlj'ri~k;lnd 31umiimm ,,j,ll.1illg,dwdlillg
IlJliJ10ClVd 1tJ3 'Wii1i)<.:f"; Drh",: ',' <:,,:
i.4XPARCEL,!J::1'J9':,~'-!f>3.:,IJ.8I' ""
"!iTI.t,,'TO,,$/~l{) .Pf.i;m,\: r;; ,'V~,~ m: l.Od$'h
Rr.: Caii;n-iJi, t>!~i1dW" oJ;: Pi:i!q (rQflY ifkl,l-h ,M.
-Cnrchitlf, "tiif&xy. .d41t,<J. 8/24/1)1), '~~"t1l"('9.)n:k'd (il
j 1/0(fii1"Retoro .&Xil,2,..itpij~j87" " ,
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
COURT OF COMMON PLEAS
CIVIL DIVISION
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
vs.
No.: 01-1745
LUEL YN M. CARCHIDI
ORDER
AND NOW, this /~ ~y Of~, 2001, upon consideration of Plaintiffs
Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED
that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s),
LUELYN M. CARCHIDI, by mailing a true and correct copy of the Notice of Sale by certified
mail and regular mail to Defendant's last known address and the mortgaged premises.
Service of the aforementioned mailings is effective upon the date of mailing and is to be
done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service.
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
COURT OF COMMON PLEAS
CNIL DNISION
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
vs.
No.: 01-1745
LUELYNM. CARCHIDI
MOTION FOR SERVICE PURSUANT TO
SPECIAL ORDER OF COURT
Plaintiff, by its counsel, Frank Federman, Esquire, moves this Honorable Court for an
Order directing service of the Notice of Sale upon the above captioned Defendant(s) by certified
mail and regular mail to Defendant's last known address.
1. Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated
by the Affidavit of Service attached hereto as Exhibit "A."
2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith
effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific
inquiries made and the results therefrom is attached hereto as Exhibit "B."
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order
pursuant to Pennsylvania Rule of Civil Procedure 430 directing service ofthe Notice of Sale by
certified mail and regular mail to Defendant's last known address.
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FEDERMAN, ESQUIRE
ATTORNEY FOR PLAINTIFF
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AFFIDAVIT OF SERVICE
PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
No.01-1745
DEFENDANT(S)
LUEL YN M. CARCHIDI
SERVE LUEL YN M. CARCHIDI AT
203 WIDDERS DRIVE
MECHANICSBURG, PA 17055
Type of Action
- Notice of Sheriff's Sale
Sale Date: SEPTEMBER 5, 2001
SERVED
Served and made known to
, Defendant, on the
day of
,200_,
at
, o'clock_.m, at
, Commonwealth
of Pennsylvania, in the manner described below:
Defendant personally served.
Adult family member with whom Defendant(s) reside(s). Relationship is
Adult in charge of Defendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place oflodging in which Defendant(s) reside(s).
Agent or person in charge of Defendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Other:
Description:
Age_
Height _
Weight _ Race
Sex
Other
I, , a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated above.
Sworn to and subscribed
before me this _ day
of ,200_.
Notary:
By:
A 11ft -:JVN ~
On the -4- day of
i Moved Unknown
NOT SERVED
,200-1, at ~ o'clock ~.m., Defendant NOT FOUND because:
No Answer
Vacant
Other: ~Ov(.~ *,0 E~oli3-, fA 0l<'Z~p... "'f(!<PC
~~~~~:~:~b~~y ~ N~'h\o~O(\S.' 1~9
of '",llilli , 200 1~
Notary: By: /
Attorn f r lint
Frank Fe erman, Esquire - l.D. No. 12248
One Penn Center Suburban Station, Suite 1400
Philadelphia, PA19103
(215) 563-7000
1. We~J<-
"')o}
:;?CCO"'~"N:J
Notanal Sea'
Stacy L Heefner, Notary Public
Chambersburg Bora. Franklin County
My Commission Expires Aug. 5. 2002
Member, ,..ennsylvanla ASSOCiation ot Notaries
EXHIBIT A
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PLAYERS NATIONAL LOCATOR
AFFIDAVIT OF GOOD FAITH INVESTIGATION
Loan Number: 01-1745
Attorney Firm: TRACK STARS
Case Number:
Subject: LUEL YN M CARCHIDI
AKA.: None
Last Known Address: 203 WIDDERS DRIVE
MECHANICS BURG, PA 17055
Last Known Number: ( ) -
Michael K Gross, being duly sworn according to law, deposes and says:
1. I am employed in the capacity of President for Players National Locator.
2. On 07/05/2001, I conducted an investigation into the whereabouts of the above named
defendant(s). The results of my investigation are as follows:
CREDIT INFORMATION -
A. SOCIAL SECURITY NUMBER:208-42-7165
B. EMPLOYMENT SEARCH:
Unable to locate a good employer for Luelyn.
C. INQUIRY OF CREDITORS:
The creditors indicated that Luelyn is living at 203 Widders Drive, Mechanicsburg, Pa. 17055 with
no valid home phone number. Luelyn filed chapter 7 bankruptcy in April 1998 with attorney Keith
Dearmond. Case # 98-01674 with a release date of July 1998.
INQUIRY OF TELEPHONE COMPANY -
A. DIRECTORY ASSISTANCE SEARCH:
The directory assistance has no listing for Luelyn Carchidi.
INQUIRY OF NEIGHBORS -
Contacted 717-790-9103 registered at 205 Widders Drive and spoke with a neighbor who stated
Luelyn Carchidi is living at the last known address.
INQUIRY OF POST OFFICE -
A. NATIONAL ADDRESS UPDATE:
As of June 27, 2001 the National Change of Address (NCOA) has no change for Luelyn from last
known address.
MOTOR VEHICLE REGISTRATION-
A. MOTOR VEHICLE & DMV OFFICE:
The Pennsylvania Department of Drivers Licensing has Luelyn listed at last known address.
OTHER INQUIRIES -
A. DEATH RECORDS:
As of June 27, 2001 the Social Security Administration has no death record on file for Luelyn M
Carchidi under her social security number.
EXHiBiT "B"
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B. PUBLIC LICENSES (PilOT, REAL ESTATE,'ETC. ):'
'None Found, .
C. COUNTY VOTER REGISTRATION:
The Cumberland County Voters Registration Office has Luelyn listed at the last known address.
ADDITIONAL INFORMATION ON SUBJECT-
A. DATE OF BIRTH:
08/51
AFFIANT
"NOTARY SEAL".
Kristine M. Scott, Nolary Public .
51. louis countY'ESlate OI9M/~lsig8~1
My Commission xpnes
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Players National Locator 113 Old State Road, Suite 104 St. Louis, MO 63021
Phone: (636) 230-9922 Fax: (636) 230-0558
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FEDERMAN AND PHELAN
By: BRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
WASHINGTON MUTUAL BANK
No.: 01-1745
vs.
LUEL YN M. CARCHIDI
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430(a) specifically provides:
(a) If service cannot be made under the applicable rule, the plaintiff may move the Court
for a special order directing the method of service. The Motion shall be accompanied by an
Affidavitstating the nature and extent of the investigation which has been made to determine the
whereabouts of the Defendant and the reasons why service cannot be made.
Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without
leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis,
238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known
address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa.
165,360 A.2d 603 (1976).
An illustration of good faith effort to locate the defendant includes (1) inquires of postal
authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265,
(2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations
oflocal telephone directories, voter registration records, local tax records, and motor vehicle
records.
As indicated by the attached Affidavit of Service, marked hereto as Exhibit "A", the
Sheriff has been unable to serve the Notice of Sale. A good faith effort to discover the
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whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good
Faith Investigation, marked Exhibit "B."
WHEREFORE, Plaintiff respectfully requests service of the Notice of Sale by certified
mail and regular mail to Defendant's last known address.
Respectfully submitted:
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FRANK FEDE , ESQUIRE -
ATTORNEY FOR PLAINTIFF
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VERIFICATION
FRANK FEDERMAN, ESQUIRE, hereby states that he is the Attorney for the Plaintiff
in this action, that he is authorized to take this Affidavit, and that the statements made in the
foregoing MOTION FOR SERVICE OF THE NOTICE OF SALE PURSUANT TO
SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information
and belief.
The undersigned understands that this statement herein is made subject to the penalties of
18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
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FRAJiKFEDERMAN,ESQUlRE
ATTORNEY FOR PLAINTIFF
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA,PA 19103-1814 COURT OF COMMON PLEAS
(215) 563-7000 CIVIL DIVISION
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
vs.
No.: 01-1745
LUEL YN M. CARCHIDI
CERTIFICATION OF SERVICE
I, FRANK FEDERMAN, ESQUIRE, hereby certify that a copy of the Motion for Service
Pursuant to Special Order of Court has been sent to the individuals indicated below on
July 9, 2001.
LUELYNM. CARCHIDI
203 WIDDERS DRIVE
MECHANICSBURG, P A 17055
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FRANK FEDERMAN, SQUIRE
Attorney for Plaintiff
Date: July 9,2001
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Law Offices ,
FEDERMAN AND PHELAN
One Penn Center at Suburban Station
1617 JohnF. Kennedy Blvd., Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Fax: (215) 563-5534
Leo Magee
Foreclosure Department
Representing Lenders in
Pennsylvania and New Jersey
July 9,2001
Office of the Prothonotary
Cumberland County Courthouse
South Hanover Street
Carlisle, P A 17013
SHERIFF'S
COpy
Re: WASHINGTON MUTUAL BANK.
v. LUELYNM. CARCHIDI
No. 01-1745
Premises: 203 WIDDERS DRIVE, MECHANICSBURG, PA 17055
Dear Sir/Madam:
Enclosed for filing and transmittal to the assigned Civil Signing Judge for execution, please find
Plaintiffs Petition for Service of the Notice of sale Pursuant to Special Order of Court and
proposed Order.
Kindly return a time-stamped copy in the enclosed self-addressed stamped envelope.
Also, find attached a copy of the Order granting alternative service which should be signed by
the Judge. Please return this signed Order in the attached stamped self-addressed envelope.
Very truly~yours,
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Leo Magee for
Federman and Phelan
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enclosures
cc: AMERIQUEST MORTGAGE COMPANY
Attention: Foreclosure Department
File #0017917436
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
COURT.OF COMMON PLEAS
CIVIL DIVISION
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
vs.
No.: 01-1745
LUELYNM. CARCHIDI
ORDER
AND NOW, this _ day of
,2001, upon consideration of Plaintiffs
Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED
that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant( s),
LUELYN M. CARCHIDI, by mailing a true and correct copy of the Notice of Sale by certified
mail and regular mail to Defendant's last known address and the mortgaged premises.
Service of the aforementioned mailings is effective upon the date of mailing and is to be
done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service.
BY THE COURT:
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FEDERMAN AND PHELAN
By: FRANKFEDERMAN,ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
COURT OF COMMON PLEAS
CNIL DNISION
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
vs.
No.: 01-1745
LUELYNM. CARCHIDI
MOTION FOR SERVICE PURSUANT TO
SPECIAL ORDER OF COURT
Plaintiff, by its counsel, Frank Federman, Esquire, moves this Honorable Court for an
Order directing service of the Notice of Sale upon the above captioned Defendant(s) by certified
mail and regular mail to Defendant's last known address.
1. Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated
by the Affidavit of Service attached hereto as Exhibit "A."
2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiffhas made a good faith
effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific
inquiries made and the results therefrom is attached hereto as Exhibit "B."
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order
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pursuant to Pennsylvania Rule of Civil Procedure 430 directing service ofthe Notice of Sale by
certified mail and regular mail to Defendant's last known address.
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FEDE , ESQUIRE
ATTORNEY FOR PLAINTIFF
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AFFIDAVIT OF SERVICE
PLAINTIFF
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
No.01-1745
DEFENDANT(S)
SERVE L UEL YN M. CARCHIDI AT
203 WIDDERS DRIVE
MECHANICSBURG, PA 17055
LUELYNM. CARCHIDI
Type of Action
- Notice of Sherifrs Sale
Sale Date: SEPTEMBER 5, 2001
SERVED
Served and made known to
, Defendant, on the
day of
,200_,
at
, o'clock _.In., at
, Commonwealth
of Pennsylvania, in the manner described below:
Defendant personally served.
Adult family member with whom Defendant(s) reside(s). Relationship is
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place oflodging in which Defendant(s) reside(s).
Agent or person in charge ofDefendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Other:
Description:
Age_
Height_ Weight_ Race
Sex
Other
I, , a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated above.
Sworn to and subscribed
before me this _ day
of .200_.
Notary:
By:
NOT SERVED
A 11ft ::JVN~
On the ~ day of
-X- Moved _ Unknown~ Nb'Answer
, 200J., at ~ o'clock 4.m., Defendant NOT FOUND because:
Vacant
Other: >>.0-1 ~ ~ ~o E )Uo!o- , FA OI~ ~ p.. '" f'f(E:p{, 1. \.>Jt"<..f
~:r~: :ea::~b~~y ~ N~ ~h 00 (\/;".' f! ~P-
of IJltlli ,200 l~ /;) iJ ,
Notary: By ~
Attorn 'f r lint
Frank Fe erman, Esquire - 1.D. No. 12248
One Penn Center Suburban Station, Suite 1400
Philadelphia, P A 19103
(215) 563-7000
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Notarial Seal
Stacy L. Heefner, Notary Public
Chambersburg Bora. Franklin County
My Commission Expires Aug. 5, 2002
Member, Pennsylvania ASSOCisuon of Notaries
EXHIBIT A
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PLAYERS NATIONAL LOCATOR
AFFIDAVIT OF GOOD FAITH INVESTIGATION
Loan Number: 01-1745
Attorney Firm: TRACK STARS
Case Number:
Subject: LUEL YN M CARCHIDI
AKA.: None
Last Known Address: 203 WIDDERS DRIVE
MECHANICSBURG, PA 17055
Last Known Number: ( ) -
Michael K Gross, being duly sworn according to law, deposes and says:
1. I am employed in the capacity of President for Players National Locator.
2. On 07/05/2001, I conducted an investigation into the whereabouts of the above named
defendant(s). The results of my investigation are as follows:
CREDIT INFORMATION-
A. SOCIAL SECURITY NUMBER:208-42-7165
B. EMPLOYMENT SEARCH:
Unable to locate a good employer for Luelyn.
C. INQUIRY OF CREDITORS:
The creditors indicated that Luelyn is living at 203 Widders Drive, Mechanicsburg, Pa. 17055 with
no valid home phone number. Luelyn filed chapter 7 bankruptcy in April 1998 with attorney Keith
Dearmond. Case # 98-01674 with a release date of July 1998.
INQUIRY OF TELEPHONE COMPANY -
A. DIRECTORY ASSISTANCE SEARCH:
The directory assistance has no listing for Luelyn Carchidi.
INQUIRY OF NEIGHBORS - . ,...
Contacted 717-790-91'03 registered at 205 Widders Drive and spoke with a neighbor who stated
Luelyn Carchidi is living at the last known address.
INQUIRY OF POST OFFICE -
A. NATIONAL ADDRESS UPDATE:
As of June 27, 2001 the National Change of Address (NCOA) has no change for L.uelyn from last
known address.
MOTOR VEHICLE REGISTRATION-
A. MOTOR VEHICLE & DMV OFFICE:
The Pennsylvania Department of Drivers Licensing has Luelyn listed at last known address.
O-rHER INQUIRIES -
A. DEATH RECORDS:
As of June 27, 2001 the Social Security Administration has no death record on file for Luelyn M
Carchidi under her social security number.
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. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.):
None.Found . .
.
C. COUNTY VOTER REGISTRATION:
The Cumberland County Voters Ri!!iisWHion Offil:i! hllll LiJelyn listed at the last known address.
ADDITIONAL INFORMATION ON SUBJECT-
A. DATE OF BIRTH:
08/51
AFFIANT
" NOTARY SEAL".
Kristine M. Scott, NolalyPubUc .
51. Louis Gounty, Slate of MISSOUri
My Commission txpll6S 91212002
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Players National Locator 113 Old State Road, Suite 104 Sf. Louis, MO 63021
Phone: (636) 230-9922 Fax: (636) 230-0558
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
COURT OF COMMON PLEAS
CNIL DNISION
CUMBERLAND COUNTY
WASHINGTON MUTUAL BANK.
No.: 01-1745
vs.
LUELYNM. CARCHIDI
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430(a) specifically provides:
(a) If service cannot be made under the applicable rule, the plaintiff may move the Court
for a special order directing the method of service. The Motion shall be accompanied by an
Affidavit stating the nature and extent ofthe investigation which has been made to determine the
whereabouts of the Defendant and the reasons why service cannot be made.
Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without
leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis,
238 Pa. Super. 362,357 A.2d 580 (1976). "Notice of intended adoption mailed to last known
address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa.
165,360 A.2d 603 (1976).
An illustration of good faith effort to locate the defendant includes (1) inquires of postal
authorities including inquiries pursuant to the Freedom oflnformation 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;~6ter registration records, local tax records, and motor vehicle
records.
As indicated by the attached Affidavit of Service, marked hereto as Exhibit" A", the
Sheriff has been unable to serve the Notice of Sale. A good faith effort to discover the
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.
.
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.
.
.
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whereabouts of the Defendant has been rnaqe as evidenced by the attached Affidavit of Good
Faith Investigation, rnarked Exhibit "B."
WHEREFORE, Plaintiff respectfully requests service of the Notice of Sale by certified
mail and regular mail to Defendant's last known address.
Respectfully submitted:
1A~~lA~
FRANK FEDE , ESQUIRE -
ATTORNEY FOR PLAINTIFF
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VERI.FIC A TION
FRANK FEDERMAN, ESQillRE, hereby states that he is the Attorney for the Plaintiff
in this action, that he is authorized to take this Affidavit, and that the statements made in the
, '
foregoing MOTION FOR SERVICE OF THE NOTICE OF SALE PURSUANT TO
SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information
and belief.
The undersigned understands that this statement herein is made subject to the penalties of
18 Pa. C.S. Sec. 4904 relating to nnsworn falsification to authorities.
~~-~~
FRANK FEDERMAN, ESQUIRE
ATTORNEY FOR PLAINTIFF
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814 COURT OF COMMON PLEAS
(215) 563-7000 CNILDNISlON
WASHINGTON MUTUAL BANK
CUMBERLAND COUNTY
vs.
No.: 01-1745
LUEL YN M. CARCHIDI
CERTIFICATION OF SERVICE
I, FRANK FEDERMAN, ESQUIRE, hereby certifY that a copy of the Motion for Service
Pursuant to Special Order of Court has been sent to the individuals indicated below on
July 9, 2001.
LUELYNM. CARCHIDI
203 WIDDERS DRIVE
MECHANICSBURG, P A 17055
C;-~k ~
FRANK FEDERMAN, SQUIRE
Attorney for Plaintiff
Date: July 9,2001
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