The URL can be used to link to this page

Home My WebLink About01-03375 '11;; "_"~, ~ . FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF.KENNEDYBOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATIORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION WASHINGTON MUTUT AL HOME LOANS, INe. 539 SOUTH 4TH AVENUE LOUISVILLE, KY 40202 Plaintiff TERM NO. ljl- .J3'iS Gl)~ l~ J~ v. CUMBERLAND COUNTY SCOTI R. KUHN 708 CONKLIN STREET MECHANICSBURG, PA 17055 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are wamed that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE 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 #; 0094435368 .iRl "I - _' r, ~"- -~~. " '\'''4':;II!~ "~ -","~"1"" IF TillS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. . I ' ~ ~,~ ~,' 1; 1. Plaintiff is WASHINGTON MUTUTAL HOME LOANS, INC, 539 SOUTH 4TH AVENUE LOUISVILLE, KY 40202 2. The name(s) and last known addressees) of the Defendant(s) are: SCOTT R. KUHN 708 CONKLIN STREET MECHANICSBURG, P A 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3, On 7/14/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FIRST KEYSTONE FEDERAL SAVINGS BANK which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No, 1558, Page 818. By Assignment of Mortgage Recorded 10111/00 the mortgage was assigned to STATE STREET BANK AND TRUST COMPANY which Assignment is recorded in Assignment of Mortgage Book No. 657, Page 1. PLAINTIFF is now the legal owner ofthe 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 2/1101 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." --"'7 ~~,,' , ' '-.', "'~" 'tl ,-",., ^ - '.>," . --,'1 _W i ,t -,. -~ . 6, The following amounts are due on the mortgage: Principal Balance Interest 11110 I through 5/1101 (Per Diem $36.87) Attorney's Fees Cumulative Late Charges 7/14/99 to 5/1101 Cost of Suit and Title Search Subtotal $143,535.98 4,461.27 4,000.00 241.04 550.00 $152,788,29 Escrow Credit Deficit Subtotal 0.00 0.00 $ 0,00 TOTAL $152,788.29 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. ~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 $152,788,29, together with interest from 5/1101 at the rate of$36,87 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. :;-~~i2~( Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff , ~.._- ~. , ." -~...~. , ~- " , " ~ -. ZZ11.9 BS701-C1st April 08, 2001 Scott R Kuhn 708 Conklin Street Mechanicsburg PA 17055 RE: LOAN NUMBER: 0094435368 PROPERTY ADDRESS: 708 Conklin Street Mechanicsburg PA 17055 Current Servicer: Washington Mutual 539 S 4th Avenue Louisville, KY 40202 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 PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance. ) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) . NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 708 Conklin Street Mechanicsburg PA 17055 IS SERIOUSLY IN DEFAULT because: AS of 04-04-01 YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are past due: Payments from 02-01-01 through 04-04-01 * PAYMENT AMOUNT 1,205.21 * PAYMENTS NOW DUE 3 * LATE CHARGES 120.52 * RETURN CHECK CHARGE .00 * OTHER FEES .00 * LESS UNAPPLIED FUNDS .00 TOTAL AMOUNT PAST DUE: 3,736.15 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 $ 3,736.15, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Washington Mutual Home Loan,Inc. ATTN: Cash Services Dept, 75 N Fairway Drive, Vernon Hills, IL 60061. I,EXHIBIT ~~k "',. 1,- ,~-"',~, ''''''''"'1'''''''- - r I "C'- - :~;, - ,"< .. ~. BS203 BS206 BS210 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM -FORECLOSURE The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program rnay be able to help you. Read the attached notice to find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at 1(800)342-2397 LANOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA. PUBS AFECTA SU DERECHO A CONTUNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION llvIMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMANDO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUBDE SAL V AR SD CASA DE LA PERDIDA DEL DERECHO A REDIMIR SD HIPOTECA. ACT91 INSERT PA9 ,1)(H'Brr~R ," -., _..~: ,,'---" " , --,_"! - - ~ - , " ., BS203 BS206 BS210 lfyou have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for fmancial assistance frorn the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may be proceeded against your home immediately. - Available funds for emergency homeowner mortgage assistance are very lirnited. They will be disbursed by the agency under the eligibility criteria established by the act. It is extremely important that your application is accurate and cornplete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have rnet the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. 717-780-3800 or 1-800-342- 2397(toll free number). Persons with impaired hearing can call (717) 780-1869. In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice ofIntention to Foreclosure". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, PNC Mortgage Corp of America Customer Service Department PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, YOU ARE ADVISED THAT WE ARE DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .EXNIB'T ,'!A-- .~" - ~, "." ~--,' - '-I 't, -, -, . 0d ':J CJ.... - /f'Ul Ql'Y1wrtl..of ~t.s C;~ T .,$VttsvJVl ~ '1l'lQ &!.6~~ uh CS"'v; dtK c c..) f\IJ\- MCLkir\ WN\ CRW'\} . $Cw-w-n b1A ~S n.oJvu, ~ ~ _ ... cwtnbu-hr'VV\ lA..,'(j.D 06V\l2 ih (\;"'--Q.J'\G,~ ~ {Ju )V-~1~ tru- ~li\ou.~ '\r'.Ju if\9-: cJ4. " \. \. PENNSYLVANIA HOUSING FINA.!'1CE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) Lycoming..clinton Counties Commision for Community Action (STEP) 2138 Lincoln Street P_O. Box 1328 Williamsport, P A 17703 (570) 326-0587 FAX (570) 322-2197 CLINTON COUNTY CCCS ofNonheastem PA 1631 South Atherton St, Suite 100 State College. PA 16801 (814) 238-3668 FAX (814) 238-3669 CCCS ofNonheostml P A 201 BlI$in Street Williarnsport, P A 17703 (570) 323-6627 FAX (570) 323-6626 31 W_ Market Street POB 1127 Wilkes-Barre. P A 18702- (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 COLUMBIA COUNTY 1400 Abington Executive Park: . Suite 1 C1arks Summit PA 18411 (570) 587-9163 or (800) 922-9537- FA-X (570) 587-9134-9135 Commission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Barre. PA 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665-(Cal1 Before Faxing) (570) 455-4994 HazellOwn FAX (570) 455-5631-(Call Before Faxing) (570) 836-4090 Tunkhannock Booker T. WashingtOn Center 1720 Holland Center Erie, PA 16503 (814) 453-5744 FAX (814) 5749 CRAWFORD COUNTY Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 John F. Kennedy Center, Inc. 2021 East 20LA Street Erie. PA 16510 (814) 898-0400 FAX (814) 898-1243 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412)981-5310 CUMBERLAND COUNTY Financial Counseling Services ofFranldin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 cecs lJfWestem Pennsylvania. Inc. 2000 Linglestown Road HarrisbUrg, PA 17102 (717) 541-1757 Urban league of Metropolitan Harrisburg N.6"Street - Harrisburg, P A 171 0 I (717) 234-5925 FAX (717) 234-9459 YWCA of Carlisle 30 I "G" Street Carlisle, PA 17013 . (717)243-3818 FAX (717) 731-9589 Commtmity Action Comm of the Capital Region 1514 Deny Street Harrisburg, PA 17104 (717)232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle Sl Gettysburg, P A 17325 (717) 334-1518 FAX 334-8326 PENNSYLVANIA BULLETIN, VOL. 29, NO. 23. JUNE 5, 1999 EXHIBn~,"p,: -';.""" ....~., -, :'-'~-~'> " ~. ," .-' ", " " \e -----,-_...- ALL thai certain piece or parcel or land siluate in the Borough of Mechani.csburg:, COUdty of Cumberland and State of Pennsylvania, bounded Rnd desenbed as fonows: BE~NING _t a point on the so..thern line of Cocklin Street, said- point being at the dividing Iide between Lots Nos. 97 and 98 on the hereinafter mentioned Plan or Lots. theace continuing along the southern line or Cockli.. Street Od a curve to the righ: having a radius of 175 reet. all arc length of 112..30 feet to a poidt; thence aloag the same South 70 degrees 2.8 ndnuta .East, two and eighteen hundredths (2..18) reet to a poine; thence along the same on a curve to the Jeft having a radius of 225 feet. an arc: Jedgtb of' 164.::8 feet to a poillt; thence along the same Nortb 6"1 degrees 42 minules :east, five and nioety bUlldredths (5.90) feet to a poidt; thence along tbe same on a c.urve to the right having a radius of 17 reet, sn are length of 26..45 feet to a polnt 011 the western liRe of ADeadale Road; thence cODI.inuil'lg aJong the .westa:n line or ABend.le Road south 23 deg.-ees to minutes East tcn and nU:let)"-s.~ hundredths (10.96) (eet to a point; thence along tbe fine of laud now o~ formcrl?" of Shelley South 6S degrees Z4 minutes West, two bundred seventy-sa And ..s.ty hundredths (276.60) reet to a point at the dividing line between Lo~ Nos.. 97 and 98 011 said plan; tb.eDce along said dividing line Nortb 22 degrees 09.Mldutes West. one hundred rorty-one and orty-rour hundredths (141.54) feet to a pOlnt on the soutbern line or Coddin Street. the place of BEGINNING. HAVING thereon erected a single brick and aluminum rapch-type dwelling with one-car garage. known and numbered as 708 Cocklin Street. Pan:e11117-:z4-0789-199 Being the same premises which William F. Swain and ,J'eallne ~ Swain, his wife, by Deed Dated Junc 23, 1981, and recorded in the Office ror the Rec:order or Deeds in and for Cumberland County, Pennsyl1,ania ill Deed Book 'M"~ Volume 29, Page 4&7,. granted and COllveyed unto Joseph G. Catalano and Ann M. Catalano. his wife,. in ree, the-Granton herein. Together -wi t.h all and $lingulaII:' the buildings and -improve~eats. wayS. strec:tS, ~1l8)'S, driveways, passaps. waters., waur-counrcs, rights, liberties, pmnleges" hereditaments and appurtalances., Whatsoever unto the hereby granted premises belonging, or in anywise appertaining.. arid the t8VersiOn5 and remainders, rentS, issues, and profits tbcreol; and all the estate. righ~ title. interest. property~ claim and demand whatsOever of thent, the $aid gr;utlots, as well at law as in equity. of, in and to the same. . To have and to hold the said lot or piece of ground described above, wi<h the builcUnllS and impl'Ovemcnts thereon erected. hereditaments and premises hereby granted, or mentioned and intended $0 to be. with the appurtenances, Wlto the said Grantee. heirs and assigns. to and fur the only proper use and behoot"'of" the said Orantee, heirs and assigns, f'arevcr. And the said GnmtOrs, fur themselves and their heirs, exoeut.OB and administrators, do, by these prese:nts~ covenant, grant and agtee. to and with the said Gnmtee, heirs and assigns. that they. the said Onmtors, ~d their heirs. all and singuJar the hereditanlents and premises heroin describ.ed and gmnte<l, or mentioned and intended so to be. with the appurtenarlces. tmto the said Grantee. belts and assigns. against them. the said Grantors, and their heirs. and against all and every other person and pemons wbOS04Ver lawfully claiminS or to claim the same or any part thereof: by, !tom at 'UIlder him., her~ it. or any of them. sh:aU and will .., --.,.'-.,-_._, -<,' '.' , ~._, ,," - . , " VERIFICATION ADAM STYERS hereby states that he is ASSIST ANT VICE PRESIDENT of WASHINGTON MUTUAL HOME LOANS, INe. 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, infonnation and belief, The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec, 4904 relating to unsworn falsification to authorities, DATE: ,/J.<i/ol c~ ADAM s1'YBB.S ASGT. VICE PREtUDENl' ~;:[f!ffl!lffl --I . . '" - - "~_ = "" MO_ .. ,( (') c::. 0 ~ -n .P "OJ t_ ,-I P ~ O)rn c= 'r ~ Z fj-~:TI zi; -,- i ~ , ::ciP3 ~ ~:2' 06 W ~ <0 "'0 '4_. e ~8 :x ::r: -+l .......... 00 9 ~ 0 "l 5>c: ~ 2m ~,,~lj j."-'t ..' ....... ~ :;H( 1I?11l!' ' i '_f~. J.J () 0 ~ s:- ~ .~"", '"' w :d ..,. , .~~;': (f' I ~ f' r r ~ i; ji ~I I! Ii f.' tP~ ,_>'"<J" : '!"""~!~~- ""' J ll!,l'jiI~~JII o .'<'l'1"'''.' 1~if!i"':"~-"!"l"~Hih''"i,i"',,,,\;o;'j,1'W''';>,,'''lj!'''''~'1:P~'!lif,,f'j.'''iW'lW,"li.a:l;l':!i!i'~r~ ~~'~~ JJ FEDERMAN AND PHELAN, L.L.P. BY: FRANK FEDERMAN, ESQUIRE Identification NO. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd. Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION WASHINGTON MUTUAL HOME LOANS, INC. 539 SOUTH 4TH AVENUE LOUISVILLE, KY 40202 TERM: NO: 01-3375 CUMBERLAND COUNTY Plaintiff vs. SCOTT R. KUHN 708 CONKLIN STREET MECHANICSBURG, PA 17055 Defendants(s) SUGGESTION OF RECORD CHANGE DEFENDANT'S ADDRESS TO THE PROTHONOTARY: FRANK FEDERMAN, ESQUIRE, attorney for the Plaintiff, hereby certifies that, to the best of his knowledge, information and belief the address of the mortgaged premises was erroneously listed as: 708 CONKLIN STREET MECHANICSBURG, PA 17055 The correct address for the mortgaged premises is: 708 COCKLIN STREET MECHANICSBURG, PA 17055 Kindly change the information on the docket. June 28, 2001 ~ rl~~ Frank Federman, Esquire Attorney for Plaintiff ,~-.., ~< -",' - ~.- -"~ , " ~~ ,. ~. ,I ,.. ~~liM~~i1l<l!l1lJffi!Ii?i~ "_""'0 '--r "-'." - '~. -,. S-::2 ~:-:.,: -T":, to" (i.:; ~~- ..'/ ,f. ,- ~.~? t~::: -. ~r;'~,. -- '. L",' " ,~. c;~ - , J!i___!",.!lIi!IlWl~~"fl~1;iF'iW;;:"""-fti'1GnV-"\;ej""!":',"j_""jl:!{;7H~;1<~.~!'ij;i1'I'#i'Ij-;'Wf*}";"")j-i'1.~~~n'i"hf,'ij0H'W~\'i?I~:;j*~ SHERIFF'S RETURN - REGULAR CASE NO: 2001-03375 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHNIGTON MUTUAL HOME LOANS VS KUHN SCOTT R BRYAN D WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KUHN SCOTT R the DEFENDANT , at 1400:00 HOURS, on the 27th day of June 2001 at 708 CONKLIN STREET MECHANICSBURG, PA 17055 by handing to SCOTT R KUHN 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 6.82 .00 10.00 .00 34.82 ~~. -~~ R. Thomas Kline 06/28/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: D~er~ 0~) me this I r~ day of A.D. /~'hon ;' 'il#-'1::l_, ~, "'1~ ~._,'!iI'1IIll<! _,_ ,~-~ ~ !II" . FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Atty. I.D. No.: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff WASHINGTON MUTUAL HOME LOANS, INC. Plaintiff Court of Common Pleas CUMBERLAND County No. Ol-3375-CIVIL TERM Vs. SCOTT R. KUHN Defendant(s) PRAECIPE TO WITIIDRA W COMPLAINT. WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly withdraw the cornplaint filed in the instant rnatter, without prejudice, upon payrnent of your costs only. A Chapter 13 bankruptcy was filed on APRIL 18, 2001, which invalidated the cornplaint. 1<3 ;. !Y2 Date '1rfLO...f}( ~ -1--f? Av7./W A1i/'}V Frank Federman Attorney for Plaintiff ",- ''''''~ ~,~,' ~, - ~ ,~'" w " ;,;, - - ~~ ~_, ,,_.~''''''''n"-'- _lDllfilr '- n .~ -,. ~.~ ~~..~-- () C :s.~ ~"- .....v_., 92~n zr- ~:r: r::::c, ~E~ c z :~ ~l r"q CD I (J" ~; ,--:- :~';'0 ,-'J" ;~j 5:; .-< . ~~) ".,....~_ J ,"W>"'WI~:jl,)j'iOOJWt>'iWF"KP,,:-,c,,;<W'-*""W./l"\-~q~_'1i'ItJ;~!~1Wf"1\1i~W4!!iI~"~~~l~N~ \...0 ~Jl c,,::t-