HomeMy WebLinkAbout01-2391 FX
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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, FA
7105 CORPORATE DRIVE PTX-B35,
PLANO, TX 72024
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
Plaintiff
v.
NO, 01 - ~19J
Gut ~
mbITH N. STUM
100 ONEIDA ROAD,
. CAMP HILL, PA 17011
CUMBERLAND COUNTY
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Defendant( s)
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVlOUSL Y
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 obj ections 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 COUNlY
CUMBERLAND COUNlY BAR ASSOCIATION
2 LIBERlY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Loan #: 9160979
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1. Plaintiff is:
WASHINGTON MUTUAL BANK, FA
7105 CORPORATE DRIVE PTX-B35,
PLANO, TX 72024
2, The name(s) and last known addressees) of the Defendant(s) are:
JUDITHN. STUM
100 ONEIDA ROAD,
CAMP HILL, PA 17011
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 5/24/99 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to AMRESCO RESIDENTIAL MORTGAGE CORPORATION
which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in
Mortgage Book No, 1545, Page 138. By Assignment of Mortgage Recorded 9/20/99 the
mortgage was assigned to COUNTRYWIDE HOME LOANS, INe which Assignment is
recorded in Assignment of Mortgage Book No. 625, Page 235, PLAINTIFF is now the
legal owner of the mortgage and is in the process of fonnalizing 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 1111100 and each month thereafter are due and unpaid, and by the tenns 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 nA!'
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6. The following amounts are dne on the mortgage:
Principal Balance
Interest
10/1/00 through 2/1/01
(Per Diem $14.42)
Attorney's Fees
Cumulative Late Charges
5/24/99 to 2/1/0 I
Cost of Suit and Title Search
Subtotal
$65,928.30
1,788.08
3,296.00
203.78
550.00
$71,766.16
Escrow
Credit
Deficit
Subtotal
0.00
803.85
$ 803.85
TOTAL
$72,570.01
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. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. S 1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in 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 rem Judgment against the Defendant(s) in the sum of
$72,570.01, together with interest from 2/1/01 at the rate of$14.42 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.
7:~rm~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
DATE: Ma.rch 13, 2001 FORECLOSURE
TO: Judith N. Sturn
100 Oneida Road
Camp Hill, PA 17011
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 HA VE 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 home is in default and the lender intends to foreclosure.
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
your home. This Notice explains how the pro.e:ram works.
To see ifHEMAP can helo. vou must MlJET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet the
Counseling Agencv.
The name. address and ohone number of Consumer Credit Counseling Agencies serving vour Countv 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 find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUEDE AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAM A
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SAL V AR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
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STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): Judith N. Sturn
PROPERTY ADDRESS: 100 Oneida Road - Camp Hill, PA 17011
LOAN ACCT. NO.: 9160979
ORIGINAL LENDER: Amresco Residential Mortgage Corporation
CURRENT LENDERlSERVICER: Countrywide Home Loans, Inc.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAlGE 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 YOURDEl'AULT 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
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of
foreclosure on yom 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 DEl' AUL T" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-Ifvou meet with one ofthe consumer credit
counseling agencies listed at the end of this notice the lender mav NOT take action against vou for thirtv
(30) davs after the date ofthis meeting. The names, addresses and teleohone numbers of designated
consumer credit counseling agencies for the county in which the orooertv 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 ASSIST ANCE- Y our 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 file 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.
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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
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,
f ou have filed bankru tc ou can still a I for Emer enc Mort a e Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it uo to date).
NATURE OF THE DEF AUL T -The MORTGAGE debt held by the above lender on your property located
at: 100 Oneida Road - Camp Hill, PA 17011 IS SERIOUSLY IN DEFAULT 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 3/1/01 at $1,403.00 per month.
Monthly Payments Plus Late Charges Accrued $7,218.48
NSF: $0.00
Inspections: $107.00
Other: $500.00
(Suspense): $0.00
Total amount to cure default $7,825.48
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use ifnot 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 $7,825.48,
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 payable and'sent to: FEDERMAN AND PHELAN, One Penn Center at
Suburban Station, 1617 John F. Kennedy Boulevard, Suite 1400, Philadelphia, P A 19103-1814,
attention: Reinstatement 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 aoplicable.) 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. The 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 insttuct its attorney to start legal action to
foreclosure upon your morte-aE:e propertv.
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, if legal proceedings are started against you. you
will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed 550.00.
Any attorney's fees will be added to the amount to the lender, which may also include other reasonable
costs. Ifvou cure the default within the THIRTY (30) DAY oeriod. vou will not be required to pay
attornev's fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
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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 ri2ht to
cure the default and orevent the sale at anv time un to one hour before the Sheriffs Sale. You mav do so
bv oavin2 the total amount then oast due. olus anv late or other char2es then due. reasonable attornev's fees
and costs connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as
soecified in writing bv the lender and bv oerforming anv other reauirements under the mortgage. 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 Sheriffs Sale will be sent to you before the sale. Of course,
the amount needed to cure the default will increase the longer you wait. You may find out at any time
exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER: Attorney Representing Lender:
FEDERMAN AND PHELAN
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Ste.1400
Philadelphia, P A 19103-1814
Contact Person: Phyllis Levin, Reinstatement Dept.
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriffs 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 PAY OFF 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 DEF AUL T. (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 MA Y HAVE TO SUCH ACTION BY
THE LENDER
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
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Very truly yours,
FEDERMAN AND PHELAN, LLP
Cc: Countrywide Homre Loans, Inc.
Ann: Nancy Gray
Account No.: 9160979
Mailed hy 1" Class mail and by certitied Mail No:
Certified Article Number
7106 4575 1294 2930 2881
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SENDERS RECORD
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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 Slreet P.O. Box 1328
Williamsport. PA L 7703
(570) 326-0587 FAX (570) 322-2197
CCCS of Northeastern P A
1631 South Athenan St, Suite 100
SlaleCollege. PA 16801
(8t4) 238-3668 FAX (814) 238-3669
CCCS of Northeastern PA
201 Basin Street
Williamsport. P A 17703
(570)323-6627 FAX (570) 323-6626
COLUMBIA COUNTY
1400 Abington Executive Park:
Suite 1
Clarks Summit PA 18411
(570) 587.9163 or (800) 922-9537
FAX (570) 587-9134.9135
31 W. Market Street
POB 1127
Wilkes-Barre. PA 18702
(570) 821-0837 or (800) 922-9537
FAX (570) 82[,(785
Commission on Economics Opportunity of Luzeme County
163 Amber Lane
Wilkes-Barre, PA 18702
(570) 826-0510 or (800) 822-0359
FAX (570) 829. I 6<55-(Call Before Faxing)
(570) 455-4994 Hazeltowo
FAX (570) 455-5631-(Call Before Faxing)
(570) 836-4090 Tunkhannock
CRAWFORD COUNTY
Booker T. Washington Center
1720 Holland Cent!:r
Erie, P A 16503
(814) 453-5744 FAX (814) 5749
Greater Erie Community Action Committee
18 West 9lh Street
Erie. PA 16501
(814) 459-4581 FAX (814) 456-0161
John F. Kennedy Center, Inc.
2021 East 20. SIr"'t
Erie,'PA 16510
(814) 898-0400
FAX (814) 898-1243
Shenango VaIley Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
(412)981-5310
CUMBERLAND COUNTY
Financial Counseling Services of Franklin
31 West3~Street':"
Waynesboro, PA 17268
(717) 762-3285
cecs of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-L757
Urban League of Metropolitan Harrisburg
N. 6111 Street
Harrisburg, PA 17101
(717) 234-5925 FAX (717) 234-9459
YWCA of Carlisle
30 I "0" Street
Carlisle, P A 17013 .
(717)243-3818 FAX(717f731-9589
Community Action Comm of the Capital Region
IS 14 Derry Street
Harrisburg, PA 17104
(717)232-9757 FAX (717) 234-2227
Adams County Housing Authority
139-143 Carlisle St
Gettysburg, PA 17325
(717)334-1518 FAX 334-8326
PENNSYLVANIA BULLETIN, VOL. 29, NO. 23, JUNE 5, t999
IIItI8fTA
ALL TaAT CERTAIN p~ece or parce~ of ~and w~th the bui~dings and .
~mprovement5 thereon er$cted s~tuated Ln the Lower Al~en Township,
Cumberland County, Commonwea~th o~ Pennsylvania, more_part~cu~arly
bounded and descr~bed .5 fo~~ows, to wit:
BEGINNING at ~ poLnt on the southerly ~ine or Oneida Road wh~ch point
is 85 ~eet West of the southwesterly corner of Oneida Road and St.
John's church Road and at d~v~d~ns line between Lots Nos. 7 and 6 on
the hereinafter mentioned plan of lots; thence al~9 same South 36
degrees East 85 fee~ to a paint at div~ding lLne between ~ots Nos. 7
and 9 on said p~an; thence along same South 01 deqree_37 mLnutes Wast
65 feet to a poLnt; thence South S7 degrees 55 minutes West 20.38 feet
to-a point at d~vidLnq line between Lots 6 and 7 on 3a~d p~an; thence
aLong same North 36 degrQQs West 135.10 feet to a po~nt on the
southerly lLne o~ Oneida Road aroresaidr thence alons same North 54
degrees East 60 feet to a paint the place of BEGINNING.
BE~NG Lot No_ 7 on Plan oE Lata known as Orch&rd H~l~s and havLn~
t4~reon erQcte~ a one and on$-hal~ story brick and frame dwel~Lng
known as ~OO One~da Road:
BEING the same premises which RolAnd L. Guard and Genevieve Guard,
husband and wi~a, by tha~r deed d4ted Apri~ 25, 1959, ~d recorded Lfi
Cumberland County DeGd Book C, Volume 19, Page 298, granted and
conveyed unto CHARLES F. MULLIGAN and ALW~LDA S_ MULLIGAN, husband and
wifeA The said Charles F. Mull~9an died September B, 1990, whereupon
tLt~e vested ~n A~w~lda s. MUlligan, the decedent, by operation of
L4W.
TOGETRER w~th al~ and singular the build~ngs, improvements, ways,
streets, alleys I pa$aages, waters, water-courses, r~ghts, libe~ties,
privi1eges, heredLt4ments and appu=tenances whatsoever, thereunto
belonging or in any W~3e apperta~ning and the r~vers~on5 and
rema~ndQr3, rents, ~Bsues and prori~s thereof, and al~ the estate,
r~9ht, tit2e, interest, property, claim and demand whatsoever of her,
the sai.d_ -ALWILDA S.. MULLIGAN, a.t and i.nuned.i.a.tQ~Y before: the ti.me of
her decease, Ln law, equ~t~, or otherwi~e howsoever, ~f, in, to or out
of=the same_
~a HAVE AND ~O HOLD the 6a~d lot o~ piece of ground above
described, with the bu~lq~n9s and impro~emQnts thereon erected,
hered~taments and premises hereby granted or mentioned, and Lntended
so to be, with the appurtenances unto the sa~d Grantee, to and for the
only proper U~e and behoof of _the said Gr~tee, forever.
And the said Grantors, for themselves and their ~espective h~L=s,
eXQ~utors acd administrators, do oovenant, promLse and agree to and
wi.th the 5a..i.d G.rantee, her hei.rs and Assi.gnsl that they, the sa.i.d
Grantors, have not heretofore done or committed any act, matter or
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th~ng whatsoever whereby the premLses hereby granted, or any part
thereo:, is, are, shal~ or mAY be impeached, charged, or encumbered in
title, charge, estate or otherwLse howsoever.
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VERIFICATION
BRANDON SCIUMBATO hereby states that he is VICE PRESIDENT of
COUNTRYWIDE HOME LOANS, INC. mortgage servicing agent for Plaintiff in this matter, that he
is authorized to take this Verification, and that the statements made in the foregoing Civil Action in
Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The
undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904
relating to unsworn falsification to authorities.
DATE:
'1/1 rjo I
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FEDERMAN AND PHELAN
By: FRANKFEDERMAN
Identification No. 12248
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Attorney for Plaintiff
i
W ASINGTON MUTUAL BANK, FA
7105 CORPORATE DRIVE PTX-B35
PLANO, TX 72024
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff
: CIVIL DIVISION
vs.
: NO. 01-2391
JUDITH N. STUM
100 ONEIDA ROAD
CAMP IDLL, P A 17011
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 JUDITH N. STUM,
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 2/1/01-6/8/01
$72,570.01
$1,845.76
TOTAL
$74,415.77
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.
.~~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATEJtl Jil 0 '4 ;:)(Xj \ (JJ div6
~V0.
p. PR BY
"THIS FIRM IS A DEBT COLLECfOR 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, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATtEMPT TO COLLECf
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
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FEDERMAN AND PHELAN, L.L.P.
Frank Federman, Esquire
Identification No. 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
1
WASHINGTON MUTUAL BANK,
FA
COURT OF COMMON PLEAS
CIVIL DIVISION
vs.
JUDITH N. STUM
CUMBERLAND COUNTY
NO. 01-2391
Defendant(s)
TO: JUDITH N. STUN
100 ONEIDA ROAD
CAMP HILL,PA17011
FILE COpy
DATE OF NOTICE: MAY 23.2001
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
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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
W ASINGTON MUTUAL BANK, FA
: CUMBERLAND COUNTY
Plaintiff
: Court of Common Pleas
vs.
: CIVIL DIVISION
JUDITH N. STUM
: NO. 01-2391
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) islare 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 JUDITH N. STUM is over 18 years of age and resides at 100
ONEIDA ROAD, CAMP HILL, P A 17011.
This staternent is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
~~
FRANK FEDERMAN
Attorney for Plaintiff
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(Rule of Civil Procedure No. 236 - Revised)
W ASINGTON MUTUAL BANK, FA
: CUMBERLAND COUNTY
Plaiutiff
: Court of Common Pleas
vs.
: CIVIL DIVISION
JUDITH N. STUM
: NO. 01-2391
Defendant(s)
Notice is given that a Judgment in the above captioned matter has been entered against you on
JUNE ,2000.
By
DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESOUIRE
Attorney fOf Filing Party
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
-*TffiS 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. **
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
WASHINGTON MUTUAL BANK, FA
Plaintiff,
CUMBERLAND COUNTY
v,
No. 01-2391 CIVIL TERM
JUDITH N. STUM
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$74,415.77
Interest from 6/8/01 to 915/01
(per diem - $12.23)
$1,088.47and Costs
TOTAL
$75,504.24
F FEDE , ESQUIRE
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 TaAT CERTAIN piece or parce~ of Land with ~he ~uiLd~n9s and
Lmprovemene5 thereon e~~ceed sLt~ated L~ the Lowe: Alke~ ~ownsh~p,
C~erLand CQU~ty~ Commonwea~th o~ ,Pennsy2van~a~ more pa~t~cu~a:ly
bot.:.nded and. aescJ:'i.l:led' '.as fol.~ow:a; to w.it;:
BEGINNING at a point On the southerLy Line of Oneida Road which point
~s 85 ~eet West of the southwester~y corner of One~da ~oad and S~.
~ohn's Church Road and at dividing Line between Lots Nos. 7 and a on
the hereinafter mentioned pLan of Lots; thence aL~g same South 36
degrees East 85 reee to a point at dividing Line between Lots Nos. 7
and 9 on said pLan; thencea~ong same South 01 degree 37 minutes west
65 feet to a point; thence South 57 degrees 55 minutes West 20.38 feet
to a point at dividing Line between Lots 6 and 7 on said pLan; thence
a~ong same North 36 degrees West L35.10 feet to a point on the
,"outher1.y Line of Oneid.a Road a~Qresaid; thence aLong same North 5.4
degrees East 60 feet to a point the pLace of BEGI~NING.
aEING Lot No. 7 on PLan of Lots known as Orchard Hi1.Ls and having,
ehereon erected a one and one-haL~ story brick and ~rame dweL~ing
known as 100 Oneiaa Road.
BEING KNOWN AS: 100 ONEIDA ROAD
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WASHINGTON MUTUAL BANK, FA
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
JUDITH N. STUM
CIVIL DIVISION
Defendant(s).
NO. 01-2391 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
WASHINGTON MUTUAL BANK. FA, 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 100 ONEIDA ROADCAMP HILL, PA
17011
1. Name and address ofOwner(s) orreputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
JUDITH N. STUM
100 ONEIDA ROAD
CAMP HILL, P A 17011
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.)
None
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4. Name and address of the last recorded holder of every mortgage of record:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
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 rnay 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
100 ONEIDA ROAD
CAMP HILL, P A 17011
Domestic Relations of Cumberland
County
13 North Hanover Street
Carlisle, PA 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, P A 171 05
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to aut rities.
June 11. 200 I
DATE
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FEDE~ANandPHELAN
By: FRANK FEDE~AN
Identification No. 12248
Suite 1400
One Penn Center at Suburban Station
Philadelphia, PA 19103
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK, FA
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
JUDITHN.STUM
NO. 01-2391 CIVIL TERM
Defendant(s).
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned rnatter, 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:~ /
RANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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WASHINGTON MUTUAL BANK, FA
Plaintiff,
CUMBERLAND COUNTY
v.
No. 01-2391 CIVIL TERM
JUDITH N. STUM
Defendant(s).
June 11,2001
TO: JUDITH N. STUM
100 ONEIDA ROAD
CAMP HILL, PA 17011
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at 100 ONEIDA ROAD CAMP HILL, PA 17011is 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, PA 17013, to enforce the court judgment obtained by
WASHINGTON MUTUAL BANK. FA (the mortgagee) against you. If the Sheriffs 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 rnust 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 irnproperly 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.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate cornpared 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 rnay call (717) 240-6390.
4. If the amount due frorn 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 rnoney 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 ofthe sale. This
schedule will state who will be receiving that money. The rnoney 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 (IO) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your horne 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 LffiERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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~ THAT C~aTA~N p~ece or parce~ of ~and w~th the bu~~d~ngs and
i~provemen~= t~ereon e:dc~ed sLtuated L~ the Lo~Q~ Al~e~ Townsh~p,
C~er.l.and CQUnty; COamlonweal.t:.h ot! .pennsy1van.:ia., more pa.:::':t:.icu2a=~y
ba...nded and ciesc:.:-i.bedas fol.l.ows,' to "'it, . .
BEGINNING at a po~nt on the aoutherl.y l.ine of One~dA Road wh~ch point
i~ as ~eet West of the southwesterl.y corner of One~da Road and St.
~ohn's Church Road and at ~viding ~i~e between Lots Nos. 7 and a on
the hereLna~ter mentioned pl.an of l.ots; thence al.~g same South 36
degrees East as feet to a point at dividing l.ine between Lots Nos. 7
and 9 on said pl.an; thence al.ong sa=e South 01 degree 37 minutes West
65 feet to a point; thence South 57 degrees S5 minutes West 20.38 feet
to a point at dividinq l.ine bet~een Lots 6 and 7 on said pl.an; thence
a~ong same No:.:-th 36 degrees West l.J5.10 feet to a point on the
southerl.y l.Lne of Oneida Road a~oresaid; thence a~onq same North S4
desreea East 60 feet to a point the pl.ace of BEG~~NING.
BEING Lo~ No. 7 on Pl.an 0: Lots known as Orchard Hi~l.s and .hav~~q.
th~reQn ereeted a one and on.-ha~~ story br~ck and frame dwe~~~nq
known as 100 One~da Road.
BEING KNOWN AS: 100 ONEIDA ROAD
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AFFIDAVIT OF SERVICE
PLAINTIFF
WASHINGTON MUTUAL BANK, FA
JUDITH N. STUM
CUMBERLAND COUNTY
No.01-2391 CIVIL TERM
DEFENDANT(S)
SERVE JUDITH N. STUM AT
815 Al'l!,LF}11RJi:E. LANE
MECHANICSBURG, P A 17050
Type of Action
- Notice of Sheriff's Sale
Sale Date: SEPTEMBER 5, 2001
SERVED
Served and made known to J a tJ rrH S-TU WI , Defendant, on the IIf l1.t.-
at 'J:</.4 ,0'clocklLm.,at fir M/~~r: (A,Jc Mec"'..wr.c.rL]"'tt.~
,
dayof .1,,1..'1
,
, 200 L.
, Commonwealth
of Pennsylvania, in the manner described below:
Defendant personally served. C I... )
)GAdult family member with whom Defendant( s) resider s). Relationship is Pi It>""'" t:. hllJ4 u ,u iO y
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place oflodging in which Defendant(s) residers).
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, 7Co ~ A, )Art! . 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.
NOTARIAL SEAL
Sworn to and subscribed GRACE E. SPITAL, Notary Public
befOrj me this L!L- day Susquehanna Twp., Dauphin County
of I u\ '3 ,2001-, My Commission Expires May 2
NOtary(bC!!lC-'t.. e Sf" .~(fer, Pennsyi~ Association
F'-"-1 NOT SERVED
a~'
On the day of
.200_, at
o'clock _.m., Defendant NOT FOUND because:
Moved Unknown
No Answer
Vacant
Other:
Sworn to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire - I.D. No. 12248
One Penn Center Suburban Station, Snite 1400
Philadelphia, PA 19103
(215) 563-7000
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REAL _TAm SALE NO. 43
Writ No. 2001-2391 Civil
Washington Mutual Bank. FA
vs.
Judith N. Sturn
At1y.: Frank Federman
ALL TIlAT CERTAIN piece or par-
cel of land with the buildings and
improvements thereon erected situ-
ated in the Lower Allen Township.
Cumberland County, Commonwealth
of Pennsylvania. more particularly
bounded and described as follows.
10 wit:
BEGINNING at a point on the
southerly line of Oneida Road which
point is 85 feet West of the South-
westerly comer of Oneida Road and
St. John's Church Road and at dt-
viding line between Lots Nos. 7 and
8 on the hereinafter mentioned plan
oflots; thence along same Soiith'36
degrees East 85 feet to a point at
dividing line between Lots Nos. 7
and 9 on said plan; thence along
same South 01 degree 37 minutes
West 65 feet to a point; thence Sou1h
57 degrees 55 minutes West 20.38
feet to a point at dividing line be-
tween Lots 6 and 7 on said Plan;
thence along same North 36 degrees
West 135.10 feet to a point on the
southerly line of Oneida Road afore-
said; thence along same North 54
degrees East 60 feet to a point the
place of BEGINNING.
BEING Lot. No. 7 on Plan of Lots
known as Orchard Hills and having
thereon erected a one and one-half
story brick and frame dwelling
known as 100 Oneida Road.
BEING KNOWN AS: 100 ONEIDA
ROAD.
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Washington Mutual Bank, FA
VS
Judith N. Sturn
In The Court of Common Pleas of
Cwnberland County, Pennsylvania
Writ No. 2001-2391 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Frank Federman.
Sheriff's Costs:
Docketing
Surcharge
Posting Handbills
Law Library
Prothonotary
Share of Bills
Mileage
Levy
Advertising
Certified Mail
Poundage
Postpone Sale
Law Journal
Patriot News
30.00
20.00
15.00
.50
1.00
25.66
16.25
15.00
15.00
1.38
264.60
242.15
206.94
$853.48 paid by attorney
8/31/01
Sworn and subscribed to before rne So Answers:
This /o<t::.dayof lnr;: t<.~ ?"'~t:::. :eot: ~~
n ' R. Thomas Kline, SHeriff
2001, A.D. '- It'. a. ftu.uh))~ d. . r --4-1
BY q{) -'It \Jrn I .ill
Prothonotary Real Est e Deputy
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WASHINGTON MUTUAL BANK, FA
,
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
JUDITH N. STIJM
CIVIL DIVISION
Defendant(s).
NO. 01-2391 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
WASHINGTON MUTUAL BANK. FA, 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 100 ONEIDA ROADCAMP HILL. PA
17011
1. Name and address ofOwner(s) orreputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
JUDITH N. STUM
100 ONEIDA ROAD
CAMP HILL, PA 17011
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.)
None
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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 rnay 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 whorn the plaintiff has knowledge who has any interest
in the property, which rnay be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
100 ONEIDA ROAD
CAMP HILL, P A 17011
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 staternents herein are made subject to the
penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to au rities.
June 11. 200 I
DATE
RANK F DE
Attorney for Plaintiff
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WASHINGTON MUTUAL BANK, FA
Plaintiff,
CUMBERLAND COUNTY
v,
No. 01-2391 CIVIL TERM
JUDITH N. STUM
Defendant(s).
June 11, 2001
TO: JUDITH N. STUM
100 ONEIDA ROAD
CAMP HILL, PA 17011
**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 RECElVED A DISCHARGE IN
BANKRUPTCY AND THlS 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 100 ONEIDA ROADCAMP HILL, PA 17011is 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, PA 17013, to enforce the court judgment obtained by
WASHINGTON MUTUAL BANK. FA (the mortgagee) against you. If the Sheriffs sale is
postponed, the property will be relisted for the DECEMBER 5, 2001 Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
L 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 rnuch you rnust 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 rnore 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You rnay
fmd out the price bid by calling (215) 563-7000.
2. You rnay 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 rnay 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 rnoney 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 horne back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
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ALL ~BAT CERTAIN piece or parce~ of Land with the bui~di~gs and
~mprovemen~~ thereon e=~ceed s~tuated L~ the Lowe: AlLe~ Townsh~p,
C~.rLand CQU~ty, 'Commcnwea~~h o~ ,Pennsy~vania, more, pa=t~~~2&=~y
bo~nded and cesc~~bed, as tQL~ows, to w~t: . .
BEGINNING at a point on the .Outhe=~y ~ine of OneidA Road which point
is as ~eet West of the southwesterLy corner of Oneida Road and S~.
~ohn's Church Road and at ~vidin~ ~ine between Lots Nos. 7 and 6 on
the hereinafter mentioned p~an o~ ~ots; thence a~~g same South 36
degrees East a5 feet to a point at dividing ~ine between Lots Nos. 7
and 9 on said plan; thence a~ong sa~e South 01 degree 37 minutes West
6S feet to a poin~; thence South 57 degrees 55 ~nutes West 20.36 feet
to a point at dividing ~ine between Lots 6 and 7 on said p~an; thence
a~ong sarne Morth 36 degrees West L35.10 feet to a point on the
southerly ~ine of Oneida Road a~oresaid; thence a~ong same Noreh 54
degrees East 60 feet to a point the p~ace of SEGI~NING.
BE~NG Lot No. 7 on P~an of Lots known as Orchard Hills and .hav~~g.
th~re~n ere~ted a one and one-ha~~ story br~ck and frame dwe~2~ng
known as ~OO Oneida Road.
BEING KNOWN AS: 100 ONEIDA ROAD
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WI;IIT OFE~I;~UTION and/or ATTACHMENT
. ,
COMMONWEAL1'H. Of, PENNSYLVANIA)
, ~ ,-" :. '.
COUNTY OF CUMBERLAND)
NO.
01-2391 CIVIL 19
CIVIL ACTION - LAW
TO THE SHERIFF OF
Cumberland
COUNTY:
To satisfy the debt, interest and costs due
Washington Mutual Bank, FA
PLAINTlFF(S)
lrom Judith N. sturn
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
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GARNISHEE(S) as follows:
;"ft
and to notny the garnishee(s) that: (a) an attachment has been issued; (Ii) the 1j'arnishee(k) '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 ofthe delendant(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 agarnishea and is enjoined as above
stated.
Interest
574.415.77
from 6/8/01 to 9/5/01 (per diem-
$1? ?~) $' ORR 47 nnrl c.o~t~
%
L.L.
Due Prothy
Other Costs
$.50
51. 00
Amount Due
Atty's Comm
Atty Paid
Plaintiff Paid
$108.06
Oate:
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June 13,. 2'001
Curtis R. Long
Prothonotary, Civil Division
by:
'i?J~
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. Deputy
REQUESTING PARTY:
Name
Address:
Frank Federman. Esa.
AnA PAnn CAntAr nt:. Suburban station Suite 1400
phil~nAlphjn_ PA 19103
Attorney for: pl ,Ii nr; ff
Telephone: (215) 563-7000
Supreme Court lD No. 1 ~04e
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REAL ESTATE SALE No.. L/~.
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Int8I88t In the real property situated in rI tfIJJ{!A. (JlOI2"l~
8umberland County, Pa.. known and numbered as: /00 ()~ R~
{JQ/Yl.P ~ and more fully described on Exhibit "A" filed wit~
this writ and by tlDs reference Incorporated herein.
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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 PENNSYL VANIA :
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,
VIZ:
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
staternents as to time, place and character of publication are true.
r~onu
Roger . Morgenthal, Editor
~
SWORN TO AND SUBSCRIBED before me this
3 day of AUGUST. 2001
'NOTARIAIJ .
LOISE.~NlIIc
Cerl8leIloro, Cum . ColIlIY
My Col",~ ExpIres March 5, 2005
,. ,..
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
James L. Clark being duly sworn according to law, deposes and says:
C."'- ~ SALE No. 43
",-O~ ".writ No. 2001-2391
Civil Term
~ashjngton Mutual
Bank, FA
~~-vs
'~"'7-->i",Judlth N. ~\um
_'.'---=-,~ ~: Fran~ F~rm8n
DESCRIPTION
That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing
under the laws of the Commonwealth of Pennsyivanla, 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 ~
Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published
ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 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 facts aforesaid and Is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin iliscellaneous Book "M",
V;I~::I~:~~~;' .... ......u.....,...........<J......n~........n..n.....n......, ........................
COpy subscribed befOrjl~iS 21st d of A t 2001 A.D.
SA L E #43 Notarial Seal .
Tony l.. Russell, Notary Publlo t
HotrI!l>utg, Dauphin COunty /
My CommlsslO7l Expires June 6. 2012
Menltler, Pennsyrvanla Associa.Uon of Notan..
TARY PUBLIC
My commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFRCE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
~'m TH~T', CERTA IN piocc or parc:e1 of
-, land with lhc building and improvt.:'mcnt"
thcreon c:roctcd situated in thl; Lol,l,l'f Allen
row'n-~fiTP, Cumberland CounfY,
~ OS'.Plinon\Walth of Pcnn~ylvania, more
~Iar'-y . bounded and de~ribcd a~
~dnlt:
~~O al a point on the 'lOOthcrty
f'il'iiC .of Orielda Road which poinl j... R-C; feet
~~, .of llil:~ :,(J/lthW1::.tcrly comer of Dodda
~ana~, ,John\ Church Road and al
~~ ,@S ~l.....ecn. !-.ots N~. 7 and 8 .on
~ ,~~ )'ll..'n;~fil..'r lTk'nllonca, plan of IOh;
! ,t~n~ alo~ !kJm~ .5?u.ch 3? degrees Ea.'ot R5
"! ~co a P;Otnl at dl\'ldmg hne bctl,\.ecn LOb
'~j 1 .an4,--9 on ~id plan; thence along
.:Sam~ SoutILOI degrt:C 37 minutc~ WC~l 65
~. " "~.EQfnt; thence &-luth .<\7 dl'&D.'~~5_i5 ,
~. WC_M 203R, fect tv il IX'im ,II
~:~g ~, bctw~n LO{~ 6 and 1 on said
~.~pran; thelJO:, along ~mc North 36 dcgrce~
~l35.ru:fuct.lO a 'point on the ,\rOuthcrt)'
.'ine of C>rk;.;ga "Road afvre,~ilid; lht:rn.:c along
__"-5m~C Noren 5.J degrees EasI 60 feet ta a
point thl' pla.:c of BEGINNING.
~ BU'\lG 1,0( No.7 on Plan .of Lot~ knawn a..
Orcl1ard HUh. and ha\ 109 thereon erectoo a
-.-ene- -and onc..half ~Iory brick and fram..:
;' 4wcmng ~own a... 100 Oneida Raad.
;. ~EING KNO\VN a~: tOO_OneIda Road,
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
205.44
1.50
206.94
Publisher's Receipt for Advertising Cost
., publisher of The Patriot-News and The Sundav Patriot. News. newspapers of general
je receipt of the aforesaid notice and publication costs and certifies that the S8me have
By........ ............................................................
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
WASHINGTON MUTUAL BANK, FA
7105 CORPORATE DRIVE PTX-B35
PLANO, TX 72024
No.: 01-2391 CNIL TERM
vs.
JUDITH N. STUM
100 ONEIDA ROAD
CAMPHILL,PA 17011
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY
Kindly mark the judgment that was entered in the above captioned matter on
JUNE 6. 2001 vacated upon payment of your costs only.
fJft1M Ji._ i= o.A P f11>1/1 /1 '"
Fr Federrnan,Esqurre ~
Attorney for Plaintiff
August 6, 2001
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02391 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK FA
VS
STUM JUDITH N
RICHARD E. SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
STUM JUDITH N
the
DEFENDANT
, at 1118:00 HOURS, on the 2nd day of May
, 2001
at 100 ONEIDA ROAD
CAMP HILL, PA 17011
by handing to
JUDITH STUM
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
8.06
.00
10.00
.00
36.06
So Answers :../?/ ~. .
..r'",W;-~"t:.-F~
R. Thomas Kline
05/02/2001
FEDERMAN &
Sworn and Subscribed to before By:
me this ,;/ 3d day of
~ fkvl A.D.
QT' a /h,!p,< Aptnt
P othonotary