HomeMy WebLinkAbout01-03821
-=....'..
J, ,_
,,"~j.; ~"' 1
""'""~"t~
~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, FIKlA PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
ISSUE NUMBER:
Plaintiff,
vs,
NO.: 01-3821
KIRAN KUMAR DANDAP AT
TYPE OF PLEADING:
Defendant.
Pac R.C.P. RULE 3129.2(c)(2)
PURSUANT TO RULE 3129.1
LIENHOLDER AFFIDAVIT OF
SERVICE
CODE-
FILED ON BEHALF OF PLAINTIFF:
Washington Mutual Home Loans, f/kla
PNC Mortgage Corp, of America
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M, Anthou, Esquire
Pa. J.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
9 West
Pittsburgh, PA 15222
(412) 281-7650
SALE DATE: March 5, 2003
'L
~ ' ',"
".. '~, ~" .~'I/!;-.1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, FIKlA PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
NO.: 01-3821
Plaintiff,
vs.
KlRAN KUMAR DANDAP AT
Defendant.
Pa. R.C.P. RULE3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Anthou, Attorney for Plaintiff, Washington Mutual Home Loans, f/kJa
PNC Mortgage Corp, of America, being duly sworn according to law, deposes and makes the
following Affidavit regarding service ofthe notice ofthe sale of real property on all persons
named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129,1 as follows:
1. By letters dated November 27, 2002, undersigned counsel served all persons
(other than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to
Rule 3129,1 with a notice of the sale of real property by ordinary mail at the respective addresses
set forth in the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit
Pursuant to Rule 3129,1 and Certificates of Mailing and any letters, if returned as of this date, are
marked Exhibit" A", attached hereto, and made a part hereof.
,
-
"
~ ~ I "J..:~
~~
,
"<-ii',
I verify that the facts contained in this Affidavit are true and correct based upon my
personal knowledge, information and belief.
GRENEN & BIRSIC, P,C,
BY:
/~.~d,u~~
Kristine M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Sworn to and subscribed before
me thisJ12!day of-:-y.,.<;i'\'"'1;3" c~2003,
~,;, '<l'~ l"'>.. -, ACh 0)1\ "",x::9
Notary Public
Notarial Seal .
Patricia A. Townsend, Notary Pubhc
City of Pittsburgh, ~lIegheny iO~~3
My Commission ExpIres June ,
Member, Pennsylvania Association at Notaries
"
] L
~; "",< l~~t'i
EXHIBIT A
,',1
"'~ --1Iill,~".
.
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f!k!aPNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO.:01-3821 Civil Term
vs.
KIRAN KOMAR DANDAPAT,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
)
) SS:
)
COUNTY OF ALLEGHENY
Washington Mutual Home Loans, f!k!a PNC Mortgage Corp. of
America, Plaintiff in the above action, sets forth as of the date the
praecipe for the Writ of Execution was filed the following information
concerning the real property of Kiran Kumar Dandapat, located at 852
Erford Road, East Pennsboro, Pennsylvania 17011, and is more fully
described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
L - _: ,
'~-.{4
.
.
1. The name and address of the owner or reputed owner:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
2. The name and address of the defendant in the judgment:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
3. The name.and last known address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Travelers Bank
11436 Cronhill Drive
Owings Mills, MD 21117-2285
PNC Mortgage Corp.
of America
539 South Fourth Street
Louisville, ICY 40202-253.1
East pennsboro Township
98 South Enola Drive
Enola, PA 17025-2796
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Dauphin Deposit Bank
and Trust Company
PO Box 4800
Harrisburg, PA 17111-0800
5. The name and address of every other person who has any record lien
on the property:
PA Dept. Of Revenue
Bureau of Individual
Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
Domestic Relations
Office
P. O. Box 320
Carlisle, PA 17013
Tax Assessment Office
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
Department of Welfare
Commonwealth of Pennsylvania
P.O. Box 2675
Harrisburg, PA 17105
L'
J"j'"
>IIillM~..,.:t,
.
.
6. The name and address
interest in the property
sale:
of every other person who has any record
and whose interest may be affected by the
None
7. The name and address of every
knowledge who has any interest in
by the sale:
other person whom the plaintiff has
the property which may be affected
Tenant (s) or
Current Occupant (s)
852 Erford Road
East Pennsboro, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to
authorities.
Dated:
///.t5""/o'/
r
BY:
{2;LLU~
SWORN to and subscribed before
me this ~day of }I..)pg ~",,^()<pl :),2002.
G~)\'i 0-:0 r-:\ A~ "Th..J::o~
Notary Public
,
Notarial r~otary Public
~trici; ~ts~;n....ilegheny ~~3
C.tYa,...mission axpires June .'
My lV3RiaASSOCiauonolN()UllIeS
Me1'llbel, panOS'l
,^" I" kL.jJ',..........iaIIl._...~4lIuiIlIl1lIlllioll--..._II~li..liMW~ijillll""-~" ".
;g~ c:
il' 0-< fn
,;"
2 om "
" me 0
. CJffi ~
~
~ ;00
a zCJ ,...
a l/!;o (J>
m
~:5 "
z" <
Om c;
~~ m
00
~~
"0
6;-
;;j~ 0
;o~ m
~
"l
5 :;;
~ ~
"
'" m
F 0
0
0 ."
m ;;:
" )>
z
~ ;=
Z
Gl
~
; 1>>,
, .J~
, 0
, .
i_-<
I~~
If
~
i>.,
1~
I~
I
I
,
,
I
I
I
I
,
,
!
.
.
q
"
(J>
3'
3
..
..
-
....
~
.
~
.J~
-"1
~
r
;g~
::0 0-< C
1lI Sm !:n
@ ~~ "1J
[ CJRf g
'Tl ;:00 :;;!
~.. zCJ r-
,~::o en
~c g:
zO <
0"
'Pm ~
.,,:!
00
"J~
~~
jij,jij 0
;0;0 m
~ ~
o :;;
~ ~
~ ;if
F 0
:5 ."
~ ~
o r-
"l Z
Gl
o
::J
CD
"'",
." ~
ar CD
:;: ::J
." ~
Qo
00
~o
...no
t:
.
J I
<.' 'Ill ,~u~"Ii',,',''" ,'l ....t;,;"",.-......=-'.~, I,'~j"--'''',:J
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTlC'AND INTERNATIONAl MAil, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Grenen & Birsic, P.C.
One Gateway Center, Nine West
Pittsburgh PA 15222
>=
'"
"
o
[Jl
~
Cl
rn
PS Fonn 3817. Janu~mN~
jJOS
u.s. POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From;
Grenen & Birsic PC
DnA r,~te"'ay Gel I '-v,"
." I 01, I neWest
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND' INTERNATIONAL MAil, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From;
{A
III
* II- JI- 11-..............
..-.l--.l-..............*
,.......................
o
" ~
"~-" ,~~i <,,~
'"" ~' " --~," "...~. ~ov~'''~';d,!
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Re""""'From' Grenen & Birsic, P.C.
One Gatewav Centp.(. ~ljlllllNest
Pittsburoh PA 1 'i<'22
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMEsne AND INTERNATIONAL MAIL, OOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Grenen & Birsic, P.C.
One Gateway Center, Nine West
Pittsburgh PA 15222
PS Fonn 3817, January 2001
-'1/,(3/
U.S. POSTAL SERVICE
CERTIFICATE OF.MAllING
MAY BE USED FOR DOMESTIC AND INTERNATIONAl MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received Frpm:
GrOAeA & Bil ~i(; P.G
n ' . .
n(' Giltll'''ay ee t /11'
. " ,f1 el, 1I1f;t ~VeSt
'\
One piece of ordinary man addressed 10:
- e; F7!'Jl1lt
PS Fo"" 3817. Janua~11J~
'Ili~.i\a;-*I!!l!i!'l.::lt\:;~ct ',e)..,!",'r'~;'i-{;b'6i1',"~'1.;,~.,;,j<_'-'!."0",""'~""
,_ ;.-~::, c_';'-;.," 0:',i,,,,,,,~,","",,->lliWkili&i<'..!I~I!IlI!!l!illa~ili:lI"~~"_~,Ill!ijdjiU.IJfdliiQlJllllil.ilY.--"""~~ + > fill'
!!jJL"HUUAU.Wl![lI A ,IlH!L,."".LJ%""",~._c",,,,,. ,=,,,
" ~,~
_~ ~ .m~_ ~,
c-'
,~'-~,
C!
:3
.~
~' 11IIlil_
.- ~-,
C,~'L
,....'}
:~'i'l
, "I~~
r'J
r:-
::::>
J -:-.::::.
:,:.-' <.'/
'::ll0"l
'5j
..<(
'"
'",
.'"
1- .....
,",'I
<, ,I " ~,-----
, " .-J-,;, ,
, "'1~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
)CIVIL DIVISION
)
) NO.: OI-3P~1
)
)
)TYPE OF PLEADING:
)
)CIVll ACTION - COMPLAINT IN
) MORTGAGE FOREClOSURE
)
)
TO, DEFENDANT )
YOU ARE HEREBY NOTiFIED TO PLEAD TO THE ENCLOSED ) FILED ON BEHALF OF PLAINTIFF:
COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE ) .
HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST
Y~U' ~~,.. )WASHINGTON MUTUAL HOME LOANS,
. ~ )INC, f/k/a PNC MORTGAGE CORP. OF
B . . )AMERICA,
A NE R PLAINTIFF )
)COUNSEL OF RECORD FOR THIS PARTY:
)
) Brian B. Dutton, Esquire
)Pa.I.D. #81953
)
)GRENEN & BIRSIC, P.c.
) One Gateway Center
) Nine West
) Pittsburgh, P A 15222
)(412) 28P650
)
)
)
)
)
)
)
)
WASHINGTOt'J MUTUAL HOME LOANS,
INC., f/kla PNC MORTGAGE CORP'r
OF AMERICA,
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS:
539 South 4" Street
Louisville, KY 40202-2531
AND THE DEFENDANT IS,
852 Erford Road
:ii;?~
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF THE REAL
ESTATE AFFECTED BY THIS LIEN IS:
TownshiD of East Penn,boro
(CITY, BORO OR TOWNSHIP)
(WARD)
~//J.'h/-
BY: ?LJ~
ATTORNEY FOR PLAINTIFF
CUll y~
',-P-'
~' ,
.
bw ,,'~
""lllbIilJbiill"\l,-,c;J'
.,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
INC., f/k/a PNC MORTGAGE CORP. OF
AMERICA,
Plaintiff,
)CIVIL DIVISION
)
)NO.:
)
)
)
)
)
)
)
)
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
NOTICE TO DEFEND
You have been slled in court. If you wish to defend against the claim 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 SHOULD
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.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717)249-3166
(800)990-9108
,~--,
~.
'..
, ' ...~,
, " "',- ~: i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
INC., f/k/a PNC MORTGAGE CORP. OF
AMERICA, f/k/a
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
)CIVIL DIVISION
)
)NO.:
)
)
)
)
)
)
)
)
)
)
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage Corp. of America, by its
attorneys, Grenen & Birsic, P.c., files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is, Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage Corp.
of America, which has its principal place of business at 539 South 4th Avenue, Louisville, KY
40202-2531, and is authorized to do business in the Commonwealth of Pennsylvania.
2. The Defendant, Kiran Kumar Dandapat, is an individual residing within the
Commonwealth of Pennsylvania, whose last known address is 852 Erford Road, East
Pennsboro, PA 17011.
3. On or about March 29,1996 Defendant executed and delivered a Note in favor
of Plaintiff in the original principal amount of $57,950.00.
'''' ,~-
~~ ~
,1
~~
"' """""'"''''''~~~~':I
, .
4. On or about March 29, 1996, as security for payment of the aforesaid Note,
Defendant executed and delivered in favor of Plaintiff, a Mortgage in the original principal
amount of $57,950.00 on the premises hereinafter described, said Mortgage being recorded
in the Office of the Recorder of Deeds of Cumberland County on April 1 , 1996, in Mortgage
Book Volume 1310, Page 1068. A true and correct copy of the description of the premises
subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof.
5. Defendant is the record and real owner of the aforesaid mortgaged premises.
6. Defendant is in default under the terms of the aforesaid Mortgage and Note, for
inter alia, failure to pay the monthly installments of principal and interest when due.
Defendant is due for the January, 2001 payment.
7. On or about March 12, 2001, Defendant was mailed combined Act 91 and Act 6
Notices, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of
1983 and Act 6 of 1974, 41 P.S. 9101, et seq.
8. The amount due and owing Plaintiff by Defendant is as follows:
i"~;;~'~';~~'I..m............mm..mmmmmmmm.............m.mm'rm"$~~'~~~~:~~"j
!....~..........................................................................................:....................................!
! Interest to 05/22/01 i $2,269.97 :
;.....:.........................................................................................1....................................j
j Late Charges to OS/22/01 ! $67.62 j
i...............................................................................................:....................................!
! Escrow Deficiency to OS/22/01 : $224.47 !
i...............................................................................................:....................................!
! Attorneys' Fees ! $800.00 !
~...............................................................................................:....................................:
! Title Search, Foreclosure and Execution! $2,500.00 !
! Costs i:
i..............,................................................................................:....................................!
L!?!.~.L.......m.mmm....mmm..mm...mmm..m..m........mmLm..~.!~!.!.!.~:.l.~..I
.<
{"--
j'" <'". ~~",.~:I'_,.-;
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure forthe amount
due of$70,770.14 with interest thereon atthe rate of$13.11 per diem from May 22, 2001, and
additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged
premises.
BY:
GRd:R~ ~
Brian B. Dutton, Esquire
Pa. 1.0. #81953
Attorneys for Plai ntiff
One Gateway Center
Nine West
Pittsburgh, PA 15222
(412) 281-7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
EXHIBIT "A"
c
"
-'. - ~'~
C',\.' '"
,jj
Ij
..
.,
-
.
,.,
-I"
-"..:::!'
ALL THAT CERTAIN !rael 01 land sllua'e In I/Ie Township 01 EllSl Pannsboro. Cumberland County,
Pennsyl\lanla, mora particularly bounCled llIld described 8ll follows, 10 wII:
BEGINNING ul u point on Erford Road8llhe <!Ivldlng line belween
Lois Nos. 16 and le{o) On Iha herelnaller menUonud Plan 01 lois;
thence along saki "rlord Road Soul/l Bfl degraes 50 mlnules e881
37.5108110 a point at Ihe Ilna dlvldlng La'" Nos. 18(K) and 17;
Ihenco along ""Id dlvldlng line South 0 degrees 10 mlnul"" Wesl
150 laello e polnl; thonco North Bfl degraaa SO m/nuIaa WBlII 37.5
'''''0 IhO line dividing Lar. Noe. lli(a) ancl16; thence along
said divIding line North 0 dag.....s 10 mlnutee easl150 laallo
Ihe polnl 01 BEGINNING.
BEING Lol No. 16(0) on Plan No. 19 01 flldley Perk as recorded In the Cumberland County Recordsr's 01llc8
In Plan lIPok 22, Pege 64.
HAVING Ihereon ereeled a dwelling house known and numbered as 852 Erlord Road.
UNDER AND SUBJECT 10 the easement of B sanitary ..we, Une as shown on the aforesaid plan.
BEING THE SAME PREMISES which QuI Ngoe Truong and Anh Dang Truong, by Doed dated Murch 13, 1989
and recorded March 16, 1989, In Iho omce ollho Reco.der 01 Deede In and lor Cumberlsnd County,
PonnsyMlnla, In Deed Book "V", Volume 33, Page 740, granled and conveyed unlo Pin Hul Kuo and Kuel
Y1ng Kuo, his wife.
. .
. ~
VERIFICATION
The undersigned, and duly authorized representative of Plaintiff, deposes and says
subject to the penalties of18 Pa. C.S.A. 94904 relating to unsworn falsification to authorities
that the facts set forth in the foregoing Complaint are true and correct to his information and
belief.
~~
" /' ~
. ADAM. TYERS
ASST. VICE PRESIDENT
1..
~!
,.;,.".~ "'L~~l'
-"/',',)"'",,,-
. ,
x",;,'<',
-'.': ",,,--,~ "',
4,.f~~~;;;;''*'''''lk''''~Ii-<iltll~Ht~""jj:",:,,,,,,~,,,,[,,;,,/,;'--,,"~~d>1/i<~il~iii'
IO~
~ f..
~~
-<::
~
jJ 1 flU -,:~m"VU,,:JJ7 nU,l: .JL ,~L l.J..~~"M,!JUL '~ ly_ '_ ,,,,j~L"'"',,'1''''t;fl';!?'("''' ' ""',~,"
,
"'6<,. ig.
~ ~~
B 8 V)
[0-
~~
~'t
'-C,
I
,_"~,, "~; ,"" ,""'>,""~' ,~^"_,__'^,,,,'" ,~A_~ ,"' ~ -,
(')
c
-~
<.
"\Jl:;"
n-,.-r.
~~~
)';:,.. -,
-7' ./
~.::.(~)
Pf~
::3
-,
u. ~
~.
L_
G
".)
i'')
',:-:->
OJ
(
,,\
~. S~
r "
. .
'. '~.~"iL,~"' ~''''~~'"'~~<''''''''~
SHERIFF'S RETURN - NOT FOUND
~
CASE NO: 2001-03821 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL HOME LOANS
VS
DANDAPAT KIRAN KUMAR
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
DANDAPAT KIRAN KUMAR
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, DANDAPAT KIRAN KUMAR
PROPERTY HAS BEEN DECLARED UNSAFE DUE
TO FIRE. NO FORWARDING ADDRESS.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
18.00
9.75
5.00
10.00
.00
42.75
S~
R.Thom~ KI:ne "-
Sheriff of Cumberland County
GRENEN & BIRSIC
07/11/2001
Sworn and subscribed to before me
this
J. .3 .-vI.
day of ~
d.819( A.D.
~-,-"a ~/;,.,~
Pr t onotary I
'"'.~
.
'"
" ,
.J'
,',-
~~~"'~:t~"1~:1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
) CIVI L DIVISION
)
) NO.: 01- ..3f.;t1
)
)
)TYPE OF PLEADING:
)
)CIVIL ACTION - COMPLAINT IN
) MORTGAGE FORECLOSURE
)
)
TO: DEFENDANT )
YOUAREHEREBYNOTlFIEDTOP,EADTOTHEENCLOSED )FILED ON BEHALF OF PLAINTIFF:
COMPLAINT WITHIN 1WENTY (20) DAYS FROM SERVICE )
~b~OF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST ) WASHINGTON MUTUAL HOME LOANS,
~~V' /7 .~ ) INC, f/k/a PNC MORTGAGE CORP. OF
B_ _~ )AMERICA,
A NE R PLAINTIFF )
)COUNSEL OF RECORD FOR THIS PARTY:
)
) Brian B. Dutton, Esquire
)Pa. I.D. #81953
)
) GRENEN & BIRSIC, P.c.
) One Gateway Center
) Nine West
) Pittsburgh, PA 15222
)(412) 281-7650
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF THE REAL )
ESTATE AFFECTED BY THIS LIEN IS:-', )
T ownshiD of East Pennsboro ")
(CITY, BORO OR TOWNSHIP) (WARD)
) TRUE COPY FROM RECORD
~ .11I Tlltf'"19llY..... I Mr8 unto .. .., IlIfllII
) - "'. . .. fiI sali :1:. CarIleIe. '. Pa..
)__T*~~~.~/'~~
WASHINGTON MUTUAL HOME LOANS,
INC., flk/a PNC MORTGAGE CORP.,
OF AMERICA,
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS:
539 South 4fu Street
Louisville, KY 40202.2531
AND THE DEFENDANT IS:
852 E,ford Road
:ZJ~
. ATTORNEY FOR PLAINTIFF
~ //J.~/-
BY: ?L)~
ATTORNEY FOR PLAINTIFF
CUlt~~
~,~-~ > -
. I
-, ~ - ',d
""'__..",1
-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS
,
INC., f/k/a PNC MORTGAGE CORP. OF
AMERICA,
Plaintiff,
)CIVIL DIVISION
)
)NO.:
)
)
)
)
)
)
)
)
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim 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 SHOULD
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.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717)249-3166
(800)990-9108
,'~~- ,~
.
d" ,,,~"
_o1fu>.'J~_
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
INC., f/k/a PNC MORTGAGE CORP. OF
AMERICA, f/k/a
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
)CIVIL DIVISION
)
)NO.:
)
)
)
)
)
)
)
)
)
)
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage Corp. of Arnerica, by its
attorneys, Grenen & Birsic, P.c., files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is, Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage Corp.
of America, which has its principal place of business at 539 South 4th Avenue, Louisville, KY
40202-2531, and is authorized to do business in the Commonwealth of Pennsylvania.
2. The Defendant, Kiran Kumar Dandapat, is an individual residing within the
Commonwealth of Pennsylvania, whose last known address is 852 Erford Road, East
Pennsboro, PA 17011.
3. On or about March 29, 1996 Defendant executed and delivered a Note in favor
of Plaintiff in the original principal amount of $57,950.00.
-
,," ,~
,
'" L"
"0 "-;'.L.I
"
4. On or about March 29, 1996, as security for payment of the aforesaid Note,
Defendant executed and delivered in favor of Plaintiff, a Mortgage in the original principal
amount of $57,950.00 on the premises hereinafter described, said Mortgage being recorded
in the Office of the Recorder of Deeds of Cumberland County on April 1, 1996, in Mortgage
Book Volume 1310, Page 1068. A true and correct copy of the description of the premises
subject to said Mortgage is marked Exhibit "An, attached hereto and made a part hereof.
5. Defendant is the record and real owner of the aforesaid mortgaged premises.
6. Defendant is in default under the terms of the aforesaid Mortgage and Note, for
inter alia, failure to pay the monthly installments of principal and interest when due.
Defendant is due for the January, 2001 payment.
7. On or about March 12,2001, Defendant was mailed combined Act 91 and Act 6
Notices, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of
1983 and Act 6 of 1974,41 P.S. 9101, et seq.
8. The amount due and owing Plaintiff by Defendant is as follows:
r'~~'i'~'~;'~'~inn.......n..nn...nn..................nnn........n"""'''''''Tn.....$'~~';~~~':~~"i
;....;..........................................................................................1....................................:
! Interest to OS/22/01 : $2,269.97 :
~...............................................................................................~..............................n....!
: late Charges to OS/22/01 : $67.62 :
;.....-..........................................................................................:....................................!
: Escrow Deficiency to OS/22/01 i $224.47 j
;...............................................................................................;....................................!
: Attorneys' Fees : $800.00 :
~...............................................................................................:....................................!
: Title Search, Foreclosure and Execution: $2,500.00 :
i Costs i i
~...............................................................................................:....................................!
i TOTAL . .m...Lun..~!..~!.!.!..~.:.~.~nj
........................................................................................
--~.
" J.
',I,
.: -
, . .. llil;lllil!ll1ii!t.li,~J'i
.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount
due of $70,770.14 with interest thereon at the rate of $13.11 per diem from May 22,2001, and
additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged
premises.
BY:
GR~R~~.
Brian B. Dutton, Esquire
Pa. 1.0. #81953
Attorneys for Plaintiff
One Gateway Center
Nine West
Pittsburgh, PA 15222
(412) 281-7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
.
EXHIBIT "A"
"I
_L,';_
,
"1-..
"c" ~ O~
'"f'<'~_'1iu,,:i;,
"'>"'''~
..
<
,"', .J ~,,"
ii<~>""'-"",::
ALL THAT CERTAIN tract 01 land allualeln !he Towneltlp 01 Easl Pennsboro, Cumberlancl County,
Pennsylvania, more pertlcularly bounCled and descrlbtld 88 lollows, to wilt
BEGINNING al 8 point on Erford Road aI Ihe dividing IIna belween
Lois Nos. le alld 16(1) On Ihe hereinafter menlloned Plan of Lola;
lhenoe elong saId Erlord Road South B9 degrees 50 mlnules East
37.5 faelle> a point at Ihe Ilna dividing Lots NOB. 1800 Bnd 17;
Ihence elong said dlvldlng line Soulb 0 degreea 10 mlnul8ll W8lI1
150 leel to a polnl; thence North B9 degrees SO tnInu1es WBSl37,5
f88110 Ihe llno divIding Lola Noe. 16(s) and 16; thance along
saId eIIvldl"glln. North 0 d.g.....s 10 tnInule. Ea.1150 leellO
Ihe pohll of BEGINNING.
IlEING Lol No. 18(x) on Plan No. 19 01 Ridley Park as record&d In Ihe Cumberland County Recorder's Offlco
In Plan Book 22. pege 64.
II'" VING Ihereon "recl&d a dwelling houa" known and nulnb.red 8s 852 &lord Road.
UNDER ANIl SUBJECT 10 Ihe Easemonl 01 a sanllary .ewer line as shown on the aforeoald plan.
BEING ntE SAME PREMISES which Qui Ngoe Truong and Anh Dang Truong, by DelKl dBled Malch 13, 1989
and recorded March 16. 1989, In Ihe Office ollhe Record8l' 01 Deed. In and lor Cumberland County,
PennayJvanla, In Deed Book "V", Volume 33, Page 740, granled end conveyed unlo PIn Hul Kuo and Kuel
Y1ng Kuo, hla wife.
-
-
"
" ~
"
,
VERIFICATION
The undersigned, and duly authorized representative of Plaintiff, deposes and says
subject to the penalties of18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities
that the facts set forth in the foregoing Complaint are true and correct to his information and
belief.
~ ~
ADAM. ~Y~RS
A3ST. VICE PRESIDENT
, .'
iIf.j~H
~"'!
<.,. "<<"" '.' ... 0"" ,",=.,0" "-'-"'--'~"~1~jrlil[lflllil_ .iI!l!1lI.1T~lr,'wwp"'li'
OfP;:::C iF
Ctr", - 0 E ,:~:,jt~ii~F
JUII Zl
3 '?" !
rL
'<,I/'.
~JUfM~~
w
~'
~~
~
~
i
""
~:.i. =, _ ,~J'~~I!rn;r&"'W'1'1i"""'''I''~\'?1t,~~*~~J~~~1'1ffilI*!i'W~~!il;:~~''~j:t'''<',y:''':''$""',",',">'"""cr'n'''''
_ T,'
~ ",' L
~:
""'~ ,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS
,
INC, flk/a PNC MORTGAGE CORP. OF
AMERICA,
CIVIL DIVISION
No.: 01-3821 Civil Term
Plai ntiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
ORDER OF COURT
AND NOW, to wit, this
day of
, 2001, upon
consideration of the within Motion for Service of the Complaint in Mortgage Foreclosure
Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that
the Sheriff of Cumberland County is hereby directed to serve Defendant, Kiran Kumar
Dandapat with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure by
posting the property at 852 Erford Road, East Pennsboro, PA 17011 and Plaintiff is permitted
to serve Defendant, Kiran Kumar Dandapat, by Certified Mail, return receipt requested and
First Class U.S. Mail, postage pre-paid at 852 Erford Road, East Pennsboro, PA 17011. Service
on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing
by the Plaintiff.
BY THE COURT:
I.
==~'~
1 '.
-.~" - ,
'. '~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
INC, f/k/a PNC MORTGAGE CORP, OF
AMERICA,
Plai ntif(
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
) CIVIL DIVISION
)
) No.: 01-3821 Civil Term
)
)
) ISSUE NUMBER:
)
) TYPE OF PLEADING:
)
) MOTION FOR SERVICE OF COMPLAINT
) IN MORTGAGE FORECLOSURE
) PURSUANT TO SPECIAL ORDER
) OF COURT
)
) CODE-
)
) FILED ON BEHALF OF PLAINTIFF:
) WASHINGTON MUTUAL HOME LOANS,
) INC., f/k/a PNC MORTGAGE CORP. OF
) AMERICA
)
) COUNSEL OF RECORD FOR THIS
) PARTY:
)
) Brian B. Dutton, Esquire
) Pa. 1.0. #81953
)
) GRENEN & BIRSIC, P.c.
) One Gateway Center, Nine West
) Pittsburgh, PA 15222
) (412) 281-7650
)
)
)
)
",,-.
, -"'-~"";
'l~h' ,,'~ '~:Jol1jll.'"""w"'l
, .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
,
WASHINGTON MUTUAL HOME LOANS,
INC, f/k/a PNC MORTGAGE CORP. OF
AMERICA,
CIVIL DIVISION
No.: 01-3821 Civil Term
Plai ntiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
MOTION FOR SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE
PURSUANT TO SPECIAL ORDER OF COURT
AND NOW, comes the Plaintiff, Washington Mutual Home Loans, Inc., f/k/a PNC
Mortgage Corp. of America by and through its attorneys, GRENEN & BIRSIC, P.c., and files
the within Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order
of Court under Pennsylvania Rule of Civil Procedure 430 as follows:
1. On or about June 21, 2001, Plaintiff filed a Complaint in Mortgage
Foreclosure against the Defendant, Kiran Kumar Dandapat, at the above-captioned number
and term.
2. On or about June 21,2001, Plaintiff delivered to the Sheriff of Cumberland
County a copy of the Civil Action - Complaint in Mortgage Foreclosure filed by Plaintiff at the
above-captioned number and term along with a direction sheet requesting that the Defendant
be served a copy of the Complaint at his last known address being 852 Erford Road, East
Pennsboro, PA 17011.
3. On or about July 18, 2001, Plaintiff received Notice from the Cumberland
County Sheriff's Office indicating that they attempted to serve Defendant, Kiran Kumar
'1
,,!"~
~-
, "-'";',
'~~I
, .
Dandapat with a copy of the Complaint at his last known address being 852 Erford Road, East
pennsboro, PA 17011 but Defendant was not served, as per Sheriff's return of service
"Property has been declared unsafe due to fire. No forwarding address". A true and correct
copy of the Sheriff's Return is marked Exhibit "A", attached hereto and made a part hereof.
4. An Affidavit of the Plaintiff stating the nature and extent of the investigation
which has been made to determine the whereabouts of Defendant and the reasons why
service of the Complaint in Mortgage Foreclosure cannot be made, is marked Exhibit "B",
attached hereto and made a part hereof.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court direct the
Sheriff of Cumberland County to serve Defendant, Kiran Kumar Dandapat with the Complaint
in Mortgage Foreclosure by posting a copy of the Complaint on the property at 852 Erford
Road, East Pennsboro, PA 17011 and permit the Plaintiff to serve Defendant, Kiran Kumar
Dandapat by mailing a true and correct copy of the Complaint in Mortgage Foreclosure by
Certified Mail, return receipt requested and by First Class U.S. Mail, postage pre-paid to 852
Erford Road, East Pennsboro, PA 17011. Service of the Complaint shall be deemed complete
and valid upon posting by the Sheriff and mailing by the Plaintiff.
GRENEN & BIRSIC, P.c.
BY:
fi;5~
Brian B. Dutton, Esquire
Attorneys for Plaintiff
One Gateway Center-Nine West
Pittsburgh, PA 15222
(412) 281-7650
'~ ~
k~
EXHIBIT "A"
~","j
r'
~ , '
'~.' "~ - - ~ '''\-)1
SHERIFF'S RETURN - NOT
CASE NO: 2001-03821~
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FOUND
.
WASHINGTON MUTUAL HOME LOANS
VS
DANDAPAT JURAN KUMAR
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
DANDAPAT JURAN KUMAR
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, DANDAPAT KIRAN KUMAR
PROPERTY HAS BEEN DECLARED UNSAFE DUE
TO FIRE. NO FORWARDING ADDRESS.
Sheriff's Costs:
Docketing
Service
Not Founo.
Surcharge
18.00
9.75
5.00
10.00
.00
42.75
so~. "'-''''. ....---:::.~
..... ~~--
...-'-.~" "'~
..,........-: -::,"'~_~' c....
R.,(Thomas Kline
Sheriff of Cumberland County
GRENEN & BIRSIC
07/11/2001
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
. ,
EXHIBIT "B"
".
'--1
--<
,--
" " '~,~ ~-""""-"'!
"
J , , ' ~l"iM"'.lil.""H'
. .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS
,
INC, f/k/a PNC MORTGAGE CORP. OF
AMERICA,
CIVIL DIVISION
No.: 01-3821 Civil Term
Plai ntiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT PURSUANT TO PA. R.C.P. 430
COUNTY OF ALLEGHENY )
) SS
COMMONWEALTH OF PENNSYLVANIA )
Before me, a notary public, in and for the foregoing county and commonwealth,
personally appeared Brian B. Dutton, of GRENEN & BIRSIC, P.c. attorneys for Plaintiff and
deposes and says that the following accurately reflects efforts made to ascertain the exact
whereabouts of the Defendant, Kiran Kumar Dandapat, named in the above-captioned matter:
a. On July 18, 2001, Plaintiff mailed to the United States Postmaster at East
Pennsboro, PA 17011, a request to be furnished with a forwarding address
of Defendant, Kiran Kumar Dandapat.
b. On July 26, 2001, Plaintiff received a response from the United States
Postmaster indicating that the Defendant is "Not know at address given". A
true and correct copy of that response is marked as Attachment "A", attached
hereto and made a part hereof,
,
',1
'...~~,,,,:
. .
c. Examinations were made of the Greater East Pennsboro Telephone Directory;
which indicates that there is no listing for the Defendant,
d. Examinations were made of the Cumberland County Voter Registration
Records; which indicates that Defendant resides at 852 Erford Road, East
Pennsboro, PA 17011,
e. A computer records search of a nationwide database indicates that Defendant
resides at 852 Erford Road, East Pennsboro, PA 17011,
Finally, affiant deposes and says that after the foregoing investigation, Plaintiff
believes and therefore avers that Defendant, Kiran Kumar Dandapat whereabouts remain
unknown.
GRENEN & BIRSIC, P.c.
BY:
Br. an B. Dutton, Esquire
PA ID# 81953
Attorneys for Plaintiff
One Gateway Center-Nine West
Pittsburgh, PA 15222
(412) 281-7650
Sworn to and subscribed before
me this ~ day OC6H ~ l~ -k- ,2001.
ac\\i~(\'\O>JO~o'm~
Notary Public
Notarial Saal
Patricia A Townsend, Notary Public
Pittsburgh. AlleQheny County
My Commission Expires June 2. 2003
Member, Pennsylvania AssoCfanon of Notanes
J, '~-'<>......~:~,J
. .
A TT ACHMENT "A"
,
,
Postmaster
East Pennsboro, P A 17011
City, State, ZIP Code
Date July 18, 2001
Request for Change of Address or Boxholder
Information Needed for Service of Legal Process
Please furnish the new ,address or the name and street address (if a box holder) for the following:
Name: Kiran KUI\1ar D~ndapat
Address: 852 Erf#rd 'Road, East Pennsboro, P A 17011
NOTE: The name ahd last known address are required for change of address information. The name, if known, and
post office box addiiess! are required for boxholder information.
The following infoijuation is provided in accordance with 39 CFR 165.6(d)(8)(ii). There is no fee for providing
boxholder information.: The fee for providing change of address information is waived in accordance with 39 CFR
265 ,6( d)(1) and (2}and corresponding Administrative Support Manual 352.44a and b,
I. Capacity of reqUester (e,g., process server, attorney, party representing himselt):Paralegal
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party
acting pro se - exce.pt a:' corporation acting pro se must cite
statute): N/A
3. The names of all known parties to the litigation: Washington Mutnal Home Loans, Inc., flkla PNC Mortgage
Corp. of America"vs. Kiran Knmar Dandapat
4. The court in which the case has been or will be heard: Common Pleas of Cumberland County, Pennsylvania
5. The docket or other identifying number if one has been issued:01-3821 Civil Term
6. The capacity in which this individual is to be served (e.g" defendant or witness): Defendant
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS
INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF
LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN
CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID
PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS,
OR BOTH (TITLE 18 U.S.C SECTION 1001).
I certifY that the above information is true and that the address information is needed and will be used solely for
s ice of legal process i onnection with actual or prospective litigation.
I
Il
Ja es E. Ashbaugh
rinted Name
Grenen & Birsic, P.C., One Gateway Center, Nine West, Pittsbnrgh, PA 15222 (412) 281-7650
FOR POST OFFICE USE ONLY
No change of address order on file.
7 Not known at address given,
_ Moved, left no forwarding address
No such address.
POS1MARK
NEW ADDRESS OR BOXHOLDER'S
NAME and STREET ADDRESS
.,....-----.
...~ h, "
" t ____. ~
..' .. '\ \,
r.l~ _\\
,~ ::::s' '"~ lP' i..~, ~
I."'
"""~~"""'Ji~I~
- ),
> :;
~_,.",,,>c,'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
INC, flkla PNC MORTGAGE CORP. OF
AMERICA,
CIVIL DIVISION
No.: 01-3821 Civil Term
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
ORDER OF COURT
AND NOW, to wit, this
day of
, 2001, upon
consideration of the within Motion for Service of the Complaint in Mortgage Foreclosure
Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that
the Sheriff of Cumberland County is hereby directed to serve Defendant, Kiran Kumar
Dandapat with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure by
posting the property at 852 Erford Road, East Pennsboro, PA 17011 and Plaintiff is permitted
to serve Defendant, Kiran Kumar Dandapat, by Certified Mail, return receipt requested and
First Class U.S. Mail, postage preopaid at 852 Erford Road, East Pennsboro, PA 17011. Service
on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing
by the Plaintiff.
BY THE COURT:
I.
" ~
- --
. ,
..
"
, .l" , ~,"~ ~ _
, ~,~..,,\
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the within Motion
for Service of the Complaint in Mortgage Foreclosure Pursuant to Special Order of Court was
mailed to the following on this (p"'h day of //t.lbvsr
, 2001, by First Class,
U.S. Mail, postage pre-paid:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
GRENEN & BIRSIC, P.c.
BY:
Brian B. Dutton, Esquire
Attorneys for Plaintiff
One Gateway Center-Nine West
Pittsburgh, PA 15222
(412) 281-7650
:i~1l1liM'/;?J.iM.',J";J"',,,';~'iO,~;" :"',,",' "';!,:r.,;,rh:o.".'''"''-1~'~.-~"" ;".'02."
.iI~I! ITml~IH. . III!!IIUIJLIL..""",~O'""',,,,,"",,~,,,,,,.,,",,, ".......
;;_~"N__j:,"i,h,iA',',-!;~1!l!lIlil~~~~ji~"-"'I~illUml!M.~~~~~i
o
S
-c.1n;
1T;r;-;
2>
21-
en -,,-
~iS
-=!:-.." C--""
ZC<
5>c:~~
.2:
_,'_" '~"',~""c~', ,>' ,.c ~^
,. ~
=<
J'"
o
o
'q
-I
",.
(;)
I
\,.0
J:-?
s'~
)::,;
:.J:J
-<
-'.,)
co
, ,<
,,",,~ ,
',,~ i
- .~" ~'~~j'l:
AUG 1 3 2~1
I 1
{
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
INC, f/k/a PNC MORTGAGE CORP. OF
AMERICA,
CIVIL DIVISION
No.: 01-3821 Civil Term
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
ORDER OF COURT
v1r,uJ ,--
, 2001, upon
AND NOW, to wit, this------t2..-day of
consideration of the within Motion for Service of the Complaint in Mortgage Foreclosure
Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that
the Sheriff of Cumberland County is hereby directed to serve Defendant, Kiran Kumar
Dandapat with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure by
posting the property at 852 Erford Road, East Pennsboro, PA 17011 and Plaintiff is permitted
to serve Defendant, Kiran Kumar Dandapat, by Certified Mail, return receipt requested and
First Class U.S. Mail, postage pre-paid at 852 Erford Road, East Pennsboro, PA 17011. Service
on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing
by the Plaintiff.
~"',"''', :"N~ ;"';\;:;-,~;ri-*~ifil~II:~~~,"l>l~~I",,,sM!!tl~.i~~ ""~ !IIlI~
~_~~'<MAAkm~:fi.W,t""Th"'.",h ,Oo "-,,,,: ih';>J-"""<0,~~:;;Jl\.;lLU,,-;J4,,.b-L~Hi--" 1;1' <.^';,\",J:l,
~
./
\")
''0:;~:
0;:.,:
c,,- \.
CEl."
t',....-
-Ul1 ~'
^IUI...~J1U
-,
\.Ie-
;j'"'\
'~
~.6'~
'~10,
";,,,,)-:2:.
~~ ~)?:\
" -'~~.'~~~
r.'" <' I
. ';,~'~.t0
';f:.{''>#'
/
<-"
'2
;c:.
/,
?"
-'<
:6
f-/7-ol
~'"
)JA.ui.u.-.{ ~
_ ~ ~,~~ ~, ~= "-,"-=, ~, ,~ _ '--', <'""""" "
fc..
~, "~C, ".";,' __ ,~', " ^,
~",~- ,
~~'~IUll'-"-~
l~.,
~_.
:if
~~
, ,..;. ...
< ".,~, L.'; " ,
" 1;)'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
flk/a PNC MORTGAGE CORP. OF
AMERICA,
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
)C1VIL DIVISION
)
) NO.: 01-3821 Civil Term
)
)
)TYPE OF PLEADING:
)
) PRAECIPE TO REINSTATE CIVIL ACTlON-
) COMPLAINT IN MORTGAGE
) FOREClOSURE
)
)
)
) FILED ON BEHALF OF PLAINTIFF:
)
)WASHINGTON MUTUAL HOME LOANS,
)INe., flk/a PNC MORTGAGE CORP. OF
) AMERICA,
)
)COUNSEL OF RECORD FOR THIS PARTY:
)
) Brian B. Dutton, Esquire
) Pa. I.D. #81953
)
)GRENEN & BIRSIC, P.e.
) One Gateway Center
) Nine West
) Pittsburgh, PA 15222
)(412) 281-7650
)
)
)
)
"
~~,~
'"" ""'-' ''''~ ....,"
, ...~ ' ~"
,
, ,
"<J~~",,,;
- .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
flk/a PNC MORTGAGE CORP. OF
AMERICA,
Plai ntiff,
)CIVIL DIVISION
)
) NO.: 01-3821 Civil Term
)
)
)
)
)
)
)
Ys.
KIRAN KUMAR DANDAPAT,
Defendant.
PRAECIPE TO REINSTATE CIVIL ACTlON-
COMPLAINT IN MORTGAGE FORECLOSURE
TO: PROTHONOTARY
SIR/MADAM:
Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with
respect to the above-referenced matter and mark the docket accordingly.
GRENEN & BIRSIC, P.c.
BY:
~If~
Brian B. Dutton, Esquire
PA ID# 81953
Attorney for Plai ntiff
'~fiI!Mi!.j^'t!t",l\i,1'iI:~"'$I"';0"-"",I\;L'iiHi<,,,Jif&,f;;J~~-i'.;,,,""''<-''''-\'J.-.,iJ;,:r,-h' ;,;", -,", """00;""',"'" ;''''~;;',",,'''",'fu;lMMi!~~~~~lliir';;:V--^,-,,;w<;l~lT~~''~ ~U'
'",;I",J~",,~u~~;~t .LJJL,__r,..!JLI{.'L~,:~,L~n,:~~~__ < ,~,~""',.. ',', "_I.~ ~~~~,~~~" " ~_",,,,,,,_,<', c ~_ ~".", >",," ~~ <",',
litililUlfUU
0 C)
c:
s: ~
-n t,,-,
Ii1f': ~-;-)
~ -'.,
Z ~;~ N
U) .--i
-< C~
r:: ~T)
C--
"'>- C..'
-C...
/.:.- (=1
:r; '---. ~:
'7 ,>
::? :0
.-1 0<
.
~~-
...
if]
..~
o
"
''"~'''li/V.,',I
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-03821 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL HOME LOANS
VS
DANDAPAT KIRAN KUMAR
BRYAN 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
DANDAPAT KIRAN KUMAR
the
DEFENDANT
, at 1107:00 HOURS, on the 30th day of Auqust
, 2001
at 852 ERFORD ROAD
EAST PBNNSBORO, PA 17011 by handing to
SERVED BY POSTING PROPERTY AT ADDRESS STATED
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
Posting
Surcharge
So Answers:
18.00
9.75
6.00
10.00
.00
43.75
r~~~~~
R. Thomas Kline
Sworn and Subscribed to before
08/31/2001
GRENEN & BIRSIC
By ~ ~l
Deput Sheriff
me this JJ~ day of
~~<Lt... .2ccf A. D .
Ch4LJ a 7u~ ~
Prothonotary
0; ,1
~ .""""-~"" " , "","~=>L-._'<'_'"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE CORP.
OF AMERICA,
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
) CIVIL DIVISION
)
) NO.: 01-3821 Civil Term
)
)
)
) TYPE OF PLEADING:
) AFFIDAVIT OF SERVICE OF DEFENDANT
) PER ORDER OF COURT
)
)
) FILED ON BEHALF OF PLAINTIFF:
)
) WASHINGTON MUTUAL HOME LOANS,
) f/k/a PNC MORTGAGE CORP. OF AMERICA
)
) COUNSEL OF RECORD FOR THIS
) PARTY:
)
) Brian B. Dutton, Esquire
) Pa. I.D. #81953
)
) GRENEN & BIRSIC, P.c.
) One Gateway Center
) Nine West
) Pittsburgh, PA 15222
) (412) 281-7650
)
)
)
)
)
)
)
.:.~
~~'"-:";""_""'''''''''iJ"i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME ) CIVIL DIVISION
LOANS, f/k/a PNC MORTGAGE CORP. )
OF AMERICA, ) NO.: 01-3821 Civil Term
)
Plai ntiff, )
~. )
)
KIRAN KUMAR DANDAPAT, )
)
Defendant. )
AFFIDAVIT OF SERVICE OF DEFENDANTS PER ORDER OF COURT
Brian B. Dutton, Esquire, Attorney for Plaintiff, Washington Mutual Home Loans, f/k/a
PNC Mortgage Corp. of America being duly sworn according to law deposes and makes the
following Affidavit regarding service of Plaintiff's Complaint in Mortgage Foreclosure in this
matter on Defendant, Kiran Kumar Dandapat as follows:
1. On or about June 21, 2001, Plaintiff filed a Complaint in Mortgage Foreclosure
against the Defendant, Kiran Kumar Dandapat, at the above-captioned number and term.
2. On August 17, 2001, this Court entered an Order authorizing Plaintiff to serve
Defendant by posting the mortgaged premises and serving the Defendant by certified mail
return receipt requested and first class mail to the address set forth in the Order, with service
to be valid upon posting and mailing. A true and correct copy of the Order is marked as
Exhibit "A" attached hereto and made a part hereof.
3. Pursuant to the Order, on August 29, 2001, the undersigned counsel served
Defendant, Kiran Kumar Dandapat, with a true and correct copy of Plaintiff's Complaint in
,
" ,'~-, '~Jii.-"k'>.1"''''''~,
Mortgage Foreclosure by certified mail, return receipt requested, and regular U.s. mail postage
prepaid, addressed to Kiran Kumar Dandapat at 852 Erford Road, East Pennsboro, PA 17011.
A true and correct copy of the U.s. Postal Service form 3800, Article Numbers 7001 0360
000254190493, and the Certificate of Mailing, evidencing service by certified mail and first
class mail on the identified Defendant, are marked Exhibit "B", attached hereto and made a
part hereof.
4. On August 30, 2001, the Cumberland County Sheriff's Office posted the property
located at 852 Erford Road, East pennsboro, PA 17011. A true and correct copy of the Sheriff's
return of Service is marked Exhibit "C", attached hereto and made a part hereof.
I verify that the facts contained in this Affidavit are true and correct based upon my
personal knowledge, information, and belief.
GRENEN & BIRSIC, P.c.
~!f~
BY:
Brian B. Dutton, Esquire
PA ID# 81953
Attorneys for Plai ntiff
Nine West, One Gateway Center
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS~AY OF~~N"'C'..Cl'9\. ') ,2001.
Q.q'\itr-~~ACb.~~
Notary Public
Notarial Seal .
Patricia A. Townsend, Notary Pubhc
Pittsburgh. Allegheny County
I My Commission Expires June 2. 2003
Member, pennsylvama Association of Notanes
EXHIBIT "A"
.,
'~
-""
.:.' ,
;,
~""-
--~";
'^ ,< , L'
", <,,~
~ '~J
.
1\\)(; 1.001
"'1'/\
(\(,
, I
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
INC, flk/a PNC MORTGAGE CORP. OF
AMERICA,
CIVIL DIVISION
No.: 01-3821 Civil Term
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant
ORDER OF COURT
AND NOW, to wit, this /1 T!::
day of
(}ur..J-
, 2001, upon
consideration of the within Motion for Service of the Complaint in Mortgage Foreclosure
Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that
the Sheriff of Cumberland County is hereby directed to serve Defendant, Kiran Kumar
Dandapat with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure by
posting the property at 852 Erford Road, East Pennsboro, PA 17011 and Plaintiff is permitted
to serve Defendant, Kiran Kumar Dandapat, by Certified Mail, return receipt requested and
First Class U.S. Mail, postage pre-paid at 852 Elford Road, East Pennsboro, PA 17011. Service
on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing
by the Plaintiff.
fRUE COpy FROM RECORD
In Testimony whereof, I here unto set my hand
end the seal of said Court at Carlisle. Pa.
fhis i1 \ day of D~ :J;;
( -:;11-' () ,
I .
Prottronotar;
BY THE COURT:
.ls/ !:ir 13. ~hr.
I.
.
,,', -{;:' ;;,=~,;.-==--;,~"_._--" -'----
_'0_';;',>",'",
-" ,-,., ..
". r' ..' __ _ ~ ",' ~
. " . ' " -
"
~,~ ~JLt~'h..b" - -,l"~, 1- ~qr~""j
EXHIBIT "B"
."
_ 'i
,',
="""I!I!ItI;l~&'
U.S. Postal Service
CERTIFIED MAIL RECEIPT
(Domestic Mail Only; No Insurance Coverage ProvIded)
rrI
IT"
::r
Cl
IT" Postage $ . 'i1()
r"l
::r Certified Fee
Lf1
Postmark
I1J Return Receipt Fee ~ lzc/7o I
Cl (Endorsement Requiredj
Cl Restricted Detivery Fee
Cl (Endorsement Required)
Cl Total Postage & Fees $ .t./D
"\ ...D
rrI Sent To
I:J
r"l siree-t~-Apt:'No:j- Kiran Kumar Dandapat
Cl or PO Box No. 852 Erford Road
Cl uuunn.n*_n...
ro- City, State, ZIP+ ' East Pennsboro, PA 17011
:11
/"
JC:::..
U,S, POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DoMESTIC AND INTERNATIONAL MAil, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
GRENEN & BiRSiC, re.
NiNE WEST
I >:;C}')"
One piece of ordinary mail addressed to:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, P A 17011
~i
:r;:
~,
j.,J'
n..
L.rl
; ,
; i
~ I
~ j
! ~ 1
~ ,; ~ . " " " , . " ~ .
PS Form 3817. Mar. 1989 7/- f3i "2JflJPtiffi'r
"0
EXHIBIT "C"
,
, "- '~., ",---;. .' ~,,'- -iJ
"~
~ ,-', ~' .
0"",-'--.,,,-.
-~ ',,"
SHERIFF'S RETURN
REGULAR
CASE NO: 2001-03821 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL HOME LOANS
VS
DANDAPAT KIRAN KUMAR
BRYAN 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
DANDAPAT KIRAN KUMAR
the
DEFENDANT
, at 1107:00 HOURS, on the 30th day of August
, 2001
at 852 ERFORD ROAD
EAST PENNSBORO, PA 17011 by handing to
SERVED BY POSTING PROPERTY AT ADDRESS STATED
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
Posting
Surcharge
18.00
9.75
6.00
10.00
.00
43.75
So Answers:
~~~,,<=~
R. Thomas Kline
Sworn and Subscribed to before
08/31/2001
GRENEN & BIRSIC
By: ):S_ c:J~ 1
Deput~heriff
me this
day of
A.D.
Prothonotary
\iii>jt~@,jlliMWi~'W~'i'~~iillL!,bifu!t_ljji,ililliia1!i2:j""M:j;im,;j~"',,"~;'; n"" "'-
'hl~;"-,,,Y,:;",''''
.',:,,-,j"-'!:dt~",,_ii.!."""""-"'''--'~~~i1kilJl~'lWI'.k. -
...
-~,
r. C) C~
. J
C "T]
~
'-'. C> u
'\J el, 1
rn f '4
--';;'
".,
L:: I
(/)
-',
C::: C-; -...-,
j;.';: C)
L:
):; () (,)
C ;1
---:.::"-
:':1 f'0
-< en =<
,JL,Xi"l\!~fI,.II:,l\';;!~iJJIUl_~~IlI,J0>_"n,l.LrJ:JJ~.,",.,%, . '''' ,...,' ....'J...
...,< -~,'_',1_'",,_,,~_ "~. hN_, _"""n,.w..,_=r_~_,__," ~. ,,~. ,,< ."'_
J[
I
. -', '~ ...........;.;AI>
'''''_'~J'!
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE CORP.
OF AMERICA,
vs.
Plaintiff,
KIRAN KUMAR DANDAPAT,
Defendant.
I hereby certify that the address of the
Plaintiff is:
9451 Corbin Avenue
Northridge, CA 91324
the last known address of Defendant is:
852 Erford Road
East Pennsboro, PA 17011
;Z7~
Attorneys for Plai ntiff
) CIVIL DIVISION
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
NO.: 01-3821 Civil Term
TYPE OF PLEADING:
PRAECIPE FOR DEFAULT JUDGMENT
(Mortgage Foreclosure)
FILED ON BEHALF OF PLAINTIFF:
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE CORP.
OF AMERICA
COUNSEL OF RECORD FOR THIS
PARTY:
Brian B. Dutton, Esquire
Pa. I.D. #81953
GRENEN & BIRSIC, P.c.
1 Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
.' ~.~" ",.
.,'=;:- ,^"'.~ -"
{,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
,
WASHINGTON MUTUAL HOME LOANS, CIVIL DIVISION
f/k/a PNC MORTGAGE CORP. OF
AMERICA, NO.: 01-3821 Civil Term
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
PRAECIPE FOR DEFAULT IUDGMENT
TO: PROTHONOTARY
SIR:
Please enter a default judgment in the above-captioned case in favor of Plai ntiff and
against Defendant, in the amount of $73,592.67, which is itemized as follows:
Principal $ 64,908.08
Interest to 10/17/01 $ 4,210.25
Late Charges to 10/1 7/00 $ 180.32
Escrow Deficiency to 10/17/01 $ 994.02
Attorney Fees $ 800.00
Title Search, Foreclosure and
Execution Costs $ 2.500.00
TOTAL $ 73,592.67
with interest on the Principal sum at the rate of $13.11 per diem from October 17, 2001, and
additional late charges, plus costs (including increases in escrow deficiency) and for
foreclosure and sale of the mortgaged premises.
BY:
GRENEN & BIRSIC, P.c.
4?f~'
Brian B. Dutton, Esquire
P.A. ID# 81953
" '-'
-, - .,
~~1MiI~--'1:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
,
WASHINGTON MUTUAL HOME lOANS, CIVIL DIVISION
f/k/a PNC MORTGAGE CORP. OF
AMERICA, NO.: 01-3821 Civil Term
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT IUDGMENT
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Brian B. Dutton, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendant is not in the military service of the United States of America to the best of his
knowledge, information and belief and certifies that the Notice of Intent to take Default
Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copy.
~~~
Sworn to and subscribed before me
this nNay~~'.
~_,,~~tM
otary Public
Notarial Seal ,
Joanne M, Wehner, Notary PublIc
City of Pll\sbUrgh, Allegheny County
My Commission Expires June 19. 2005
Member, pennsytvamaAsSOClationolNotanes
,"","",", "
',<,,,,,-".. ;;,,""c'
'~ ~-. ~d
IN'THE COURT OF COdl)N PLEAS OF CUMBERLAND C<8-TY, PENNSYL VANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE CORP.
OF AMERICA,
Defendant.
) CNIL DNISION
)
) NO.: 01-3821 Civil Term
)
)
)
)
)
)
)
Plaintiff,
vs.
KlRAN KUMAR DANDAP AT,
TO: Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, P A 17011
DATE OF NOTICE: September 28,2001
IMPORTANT NOTICE
YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN DA YS 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
LA WYERAT ONCE. IF YOU DO NOTHA VEALA WYER, OR CANNOT AFFORD ONE, GO
TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET
LEGAL HELP:
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
1-800-990-9108
By:
GRENEN & BIRSIC, P.C.
~1tJ:tV
Pa. I.D. # 81953
Attorneys for Plaintiff
One Gateway Center
Nine West
Pittsburgh, P A 15222
(412) 281-7650
FIRST CLASS MAIL, POST AGE PREP AID
~','i.
'-' '~i!<J.
IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY, PENNSYLVANIA
PNC BANK,
N.A.,
CIVIL DIVISION
Plaintiff,
No.: 01-06-0493
vs.
THERESA M. MCHENRY and
MICHAEL S. HUNT,
Defendants.
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: MICHAEL S. HUNT
4222 Salmon Street
Philadelphia, PA19137
( )
(XXX)
( )
Plaintiff
Defendant
Additional Defenda~t
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on
~~c...
1/ 1. ('y) (
A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows:$65,483.22
with interest on the Principal sum at the rate of $11.66 per diem and
additional late charges, plus costs (including increases in escrow
deficiency) and for foreclosure and sale of the mortgaged premises.
--
~D/T-~ -[1 77?'fM~r
Deputy
i~1i<ik"'.~'~Ofl'AAit";91I!!lik.~,~;~Im:'lij;;;l""",..,!ili_W".f;".'<,U'd"!-!'
. :'_",",~)'~:,s,<c'",i.'.<'-"~_;;&~-!.1I#Ui<~jl.H/r8i'~~"'1B:il_tii:M~H"';~_~~'.It<iJW__~_
"~""Jj:)l!",o,I!J"!.UIII~,oh,,,.IlI!lIl!I1!:ll,,,,m,j.,,,..,,,.,,~,,,,,,,,,,I,l'W,' """. '..'.,
~ ~ ~ ~
..0
~
r '- ~
--....
'-() R r (j C.:' "
~;:~ \1
~ f'" " ~
tJ G n;iL;--; ,~T1 -I"
[U' '.-'-)
"'-....
~ ,,~L
~ J U)
-, ----,~)
c::::
,- ~~~~ ,
~;~~ ...--
(,")
is ' '"
, ,
,~ .=,
'-'J?
,~ r:- "
._.4 :0
,..( en -<
."..~O"~;',",<;, ,,'
''''_t,'..e.-"'~, '_~~~'~'_ ",'_"~. -.,... ~_"~~ " <.c.... ,~.._. _"""",,c. .,.. ',", ,"~ _~,,'~~,~ _ .~~=
__ .. r
--',
/,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO. :01-3821 civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
TYPE OF PLEADING
Praecipe for
Writ of Execution
{Mortgage Foreclosure}
FILED ON BEHALF
OF PLAINTIFF;
Washington Mutual
Home Loans, et al.
COUNSEL OF RECORD
FOR THIS PARTY:
Brian B. Dutton, Esquire
Pa LD. #81953
GRENEN & BIRSIC, P.C.
One Gateway Center
Nine West
Pittsburgh, PA 15222
(412) 281-7650
.,
~\d
">"""
"- ,
.~~, '.~ ;[.!
r, ....
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Washingtonn Mutual Home Loans, f/k/a
PNC Mortgage Corp. of America
Kiran Kumar DandapatVs.
( ) Confessed Judgment
( ) Other
File No. 01-3821 Civil Term
Amount Due $73,592.67
Interest 2,695.11
Atty's Comm
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumber land County
for debt, interest and costs, upon the fOIlGwing described property of the defendant(s)
852 Erford Road, East Pennsbot~, PA 17011
County,
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date
/J..-7-0{
Signature:
Print Name:
Address:
~I!~
Brian B. Dutton
Attorney for:
Telephone:
One Gateway Center, Nine West
Pittsburgh, PA 15222
Plaintiff
(412) 281-7650
Supreme Court ID No.: 81953
(over)
,~l>~illi.jill;";;\~;i<l~~iMIIl~i''<tiii4c,"'''"IL'H)'~t'u;.i~JI-'-kla",~;.;!''1 ,,-_" 'f,_ "'-'~'~''''-''o".:..:,<ol"":e,-,"_~,.(~,''ffi'l.t:..,illili'ali>Jill~~l<liill~,,,t.'Wc~1iIIJ
.,>' ,'\
Notes: If real property, supply six copies of description including improvements and an original and copy of
affidavit of ownership (PaR.C.P. No. 3129),
If lengthy personalty list, supply four copies of list
To index writ, file separate praecipe with writ
~ '-
t:::J CIl .p; it ~
It- ~ {Q ~ ~ ~
~ 2 & !i1
~ ~ () '-1 c; ~ 8
...., ~ C 0 ~
.......
..() I I 0 CI (::"'J
~' I I c= -T\
~ lJ . a
p -ot[~; i'1
v ;e mn
......~ r ;:::::1'.' (-)
... Zt-
, ... ... ~ ... ~ ~:;
, , ~ ~
~C) ~,
, ~~ 4J ~~~ ~,
, ~
~ 0
2~ r.
==< ...J .-<
~11l_ ',] e_;_~'-""~o> ,_~ ."" ~..,".~~ ~Jk, '~<""_",t',~",~ ~"~,,, '" ,>> _~~._"'" ,,~_~..'V'_,_ ",".,_"~,,,_""__,_ .,_ ~__' ~-,~.,," ._, ,-'
H ,,_,
__.".n.'
,,"~C.,,'~ ~= ~_ ~.~ ,"_~. .,.~
"
, "". , , _li~4,i.
c ...
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO.:01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
)
) SS:
)
COUNTY OF ALLEGHENY
Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of
America, Plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information
concerning the real property of Kiran Kumar Dandapat, located at 852
Erford Road, East Pennsboro, Pennsylvania 17011, and is more fully
described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY.
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
-
. .
,.~- ." t
~-~-~-~0
r
1. The name and address of the owner or reputed owner:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
2. The name and address of the defendant in the judgment:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
3. The name and last known address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Travelers Bank
11436 Cronhill Drive
Owings Mills, MD 21117-2285
PNC Mortgage Corp.
of America
539 South Fourth Street
Louisville, KY 40202-2531
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025-2796
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Dauphin Deposit Bank
and Trust Company
PO Box 4800
Harrisburg, PA 17111-0800
5. The name and address of every other person who has any record lien
on the property:
PA Dept. Of Revenue
Bureau of Individual
Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
Domestic Relations
Office
P. O. Box 320
Carlisle, PA 17013
Tax Assessment Office
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
'*' ~' ~
,~~., l.:_
- ~' ~ . ,;i-
. , ...
6. The name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
None
7. The name and address of every
knowledge who has any interest in
by the sale:
other person whom the plaintiff has
the property which may be affected
Tenant (s) or
Current Occupant (s)
852 Erford Road
East Pennsboro, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to
authorities.
Dated:
/),.-7-0/
~b~~
BY:
Brian B. Dutton, Esquire
Attorney for Plaintiff
SWORN to and subscribed before .
~ "'0)(/1-;;', of ~L
~>7 <P '/;?;U
~otary Public
Notarial Seal
CJoanfne, M. Wehner, Notary Public
,tv 0 P.itIS.burgh, Allegheny Counly
My CommIssIon Expires June 19, 2005
Member, PennsylvaniaAssoclationofNolaries
~iH~~Mliiii&lili~r:illlt~2bi,aMi.\l,,~,2:';;;_,;-'n, ,.".,_,:,,;,~_,^"~-,,-:,,-~,;:.\'i:hi,,*_d\i!;lfl~
,~,J.,.JJJ'n"!t"l! JTn~.lfMU!llJ 1:.._",."""".",,,,"~,,",, ,~~,="~,~,."""..:_,~"_,,,=,';Y". ''', .'-,",' ~~,f,,~~."'>' ,'" ,,__-';"",,~ -".,
-'""~""JllIir~_"'i'<mI!l.ii;,~"~. ~.~--
.~ ,,0. ~" ,'~,
,,..
'.
~~2 (7) i~
~-
z.'" a
-0 ,- [7l
nl ~-") ,
'7
<--
/::
UJ
-< u
r'- ,
<: s: iiO';
~~ 25 l:,:J
&- ~
--' ::XJ
-< ...j -<
,,"."
... .~_~. ~, _,,_,"~ ~~",' =~~ n',,~ . ,
_1 ';""'f'"It<,,:
(
'II
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO. :01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: KIRAN KUMAR DANDAPAT
852 Erford Road
East Pennsboro, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued
out of the Court of Common Pleas of Cumberland County, Pennsylvania,
and to the Sheriff of Cumberland County, directed, there will be
exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COMMISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17103
on March 06, 2002, at 10:00 A.M., the following described real estate,
of which Kiran Kumar Dandapat is the owner or reputed owner:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
.... ~ ~ - ,- < ,
, '" ~ '~
'~>>"t
1
The said Writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
at Execution Number 01-3821 Civil Term in the amount of $76,287.78.
Claims against the property must be filed with the Sheriff before
the above sale date.
Claims to proceeds must be made with the Office of the Sheriff
before distribution.
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a petition to Set Aside the Sale must
be filed with the Office of the Sheriff no later than ten (10) days from
the date when Schedule of Distribution is filed in the Office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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
ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717)249-3166
(800)990-9108
> M.
"'~',d-
.
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after servic,e of the Complaint for Mortoaoe Foreclosure and Notice to
Defend, you may have the right to have the judgment opened if you
promptly fil1e a petition with the Court alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE
ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
~~~.
By:
Brian B. Dutton, Esquire
Attorney for Plaintiff
"~il>'l!~(i1.~~IllU#,,>jillJful!Il:iHtliBj~'H;;.!"''1i1:i:ai:~'"ot1:'~''l'''''~i,*(''' b,--"
.",,,,,,_~,_,,.~.~.~,rr(.'ild<>iJ~:<lii!;J'{~~~__~'li"""""" ~~~~_I<
,;,,,J c"h,!!!!1~"lR!~lJ!..1..LL1,~L!mk.J,.,LJ\"Lk-,:J,l,,,I,,~L, ""',.' "",,,,, .., "
~ ",'~_ ,y,~ _ -1_"'" ..' ~ ~.,~" ..~_u
.~"',"'"
~-
--
4
0 C) ,~
~=
'. 0
"U ,-, i'l
IT) 17 , '
z " ~
Z ;<
en '. ~
-<'~
r- c.=.:.
:C"; -T'--;.~
,'~ .. ,
,C_ ~. .,'
)0- ~. ,.! 2) :_~)
c:::
:;:~ c:-
--j :n
-<: .-J ..<:
,-..~' "
~. M ,>-.~.JF~
.-, ",,' ,h' "'n ~
.. .,-,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO.:Ol-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro,
Cumberland County, Pennsylvania, more particularly bounded and described
as follows, to wit:
BEGINNING at a point on Erford Road at the dividing line between Lots
Nos. 16 and 16(x) on the hereinafter mentioned Plan of Lots; thence along
said Erford Road South 89 degrees 50 minutes East 37.5 feet to a point
at the line dividing Lots Nos. 16(x) and 17; thence along said dividing
line South 0 degrees 10 minutes West 150 feet to a point; thence North
89 degrees 50 minutes West 37.5 feet to a point; thence North 89 degrees
50 minutes West 37.5 feet to the line dividing Lots Nos. 16(s) and 16;
thence along said dividing line North 0 degrees 10 minutes East 150 feet
to the point of BEGINNING.
BEING Lot No. 16(x) on Plan No. 19 of Ridley Park as recorded in the
Cumberland County Recorder's Office in Plan Book 22, Page 64.
HAVING thereon erected a dwelling house known and numbered as 852 Erford
Road.
UNDER AND SUBJECT to the Easement of a sanitary sewer line as shown on
the aforesaid plan.
TOGETHER with all and singular, the tenements, hereditaments and
appurtenances to the same, belonging or in any way appertaining, and the
reversion and reversions, remainder and remainders, rents, issues, and
profits thereof; And Also, all the estate, right, title, interest,
property, claim and demand whatsoever, both in law and equity, of the
said Parties of the First part, of, in, to or out of the said premises,
and every part and parcel thereof.
,,<
.1'.-
,--
, '
BEING the same premises which pin Hui Kuo and Kuei Ying Kuo (a/k/a Kuei
Hui Kuo) , his wife, by deed dated March 29, 1996 and recorded on April
1, 1996 in the Office of the Recorder of Deeds for Cumberland County in
Deed Book Volume 136, Page 965, granted and conveyed unto Kiran Kumar
Dandapat.
DBV
Page
Tax Parcel No.
By:
GlLiJ7J;i~'
Brian B. Dutton, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
136
965
09-17-1044-060
,
0-'
"""Ii
, -,~. ~ ,.,.
-, ,~
-.,-'
~\,
,.-, -~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
F/K/A PNC MORTGAGE CORP.
OF AMERICA,
CIVIL DIVISION
Plaintiff,
No.: 01-3821- Civil Term
ISSUE NUMBER:
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
TYPE OF PLEADING:
Pa. R.C.P. RULE 3129.2(c)
AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
CODE -
FILED ON BEHALF
OF PLAINTIFF: Washington
Mutual Home Loans, f/k/a
PNC Mortgage Corp. of America
COUNSEL OF RECORD
FOR THIS PARTY:
Kristine M. Faust, Esquire
Pa. I.D. # 77991
SHERIFF'S SALE DATE:
March 06, 2002
GRENEN & BIRSIC, P.C.
One Gateway Center
Nine West
Pittsburgh, PA 15222
(412) 281-7650
.
J~
"-,
"' ,'. L,.}
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
F/K/A PNC MORTGAGE CORP.
OF AMERICA,
CIVIL DIVISION
Plaintiff,
No.: 01-3821- Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
Kristine M. Faust, Attorney for Plaintiff, Washington Mutual Home
Loans, f/k/a PNC Mortgage Corp. of America, being duly sworn according
to law deposes and makes the following Affidavit regarding service of
Plaintiff's notice of the sale of real property in this matter on
February 6, 2002 as follows:
1. Kiran Kumar Dandapat is the owner of the real property and
has not entered an appearance of record.
2. On August 17, 2001, this court entered an order authorizing
Plaintiff to serve the Defendant by posting the property and by Certified
Mail, return receipt requested and First Class, U. S. Mail, postage
prepaid to the address set forth in the Order, with service to be valid
upon posting and mailing. A true and correct copy of the Order is marked
as Exhibit "A" attached hereto and made a part hereof.
~ " ,--' "" ",;.;">, - > '-- ~;""'-'-'''"'~~'''''t~
3. Pursuant to the Order and Pa R.C.P. 3129.2 tC) on December 13,
2001, the undersigned counsel served the Defendant with a true and
correct copy of Plaintiff 1 s notice of the sale of real property by
Certified mail, return receipt requested and First Class U. S. Mail,
postage prepaid, addressed to Kiran Kumar Dandapat at 852 Erford Road,
East pennsboro, PA 17011. True and correct copies of U.S. Service Postal
Forms 3800 and 3817, evidencing service by Certified mail, return receipt
requested and First Class u.s. Mail, postage prepaid, on the identified
Defendant, are marked Exhibit "B", attached hereto and made a part
hereof.
4. On or about December 26, 2001, the Sheriff of Cumberland
County posted the property located at 852 Erford Road, East Pennsboro,
PA 17011. A true and correct copy of the Affidavit of Posting from the
Sheriff of Cumberland County is marked Exhibit "C", attached hereto and
made a part hereof.
r verify that the facts contained in this Affidavit are true and
correct based upon my personal knowledge, information, and belief.
BY:
GRENEN & BIRSIC, P.C.
/ /~
(./': ~ {~
~e M. (Faus , Esquire
Attorneys for Plaintiff
Nine West, One Gateway Center
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS 7~AY OF.
Notary Public
Notarial Seal
Joanne M. Wehner, Notary Public
City of Pittsburgh, Allegheny County
My Commission Expires June 19, 200S
Member, Pennsylvania AsSOCiation of Notaries
EXHIBIT "A"
,
<t.
.,.,~I-'. -' ,
~';.!
-,.
-" ,- ",,~-- ?"'~f~.i --"-<~";'~-'-'_
,->-..." ';.-",---,.,'. -,'
,_' I
"""+:1i:H
.-"
AUG 1."~~
\ _ ~l \
K\' / \
( \ ,; ..
l_ jl
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
INc, f/k/a PNC MORTGAGE CORP. OF
AMERICA,
CIVIL DIVISION
No.: 01-3821 Civil Term
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
ORDER OF COURT
AND NOW, to wit, this /1 T!:
day of
{Lj"Ar
, 2001, upon
consideration of the within Motion for Service of the Complaint in Mortgage Foreclosure
Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that
the Sheriff of Cumberland County is hereby directed to serve Defendant, Kiran Kumar
Dandapat with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure by
posting the property at 852 Erford Road, East Pennsboro, PA 17011 and Plaintiff is permitted
to serve Defendant, Kiran Kumar Dandapat, by Certified Mail, return receipt requested and
First Class U.S. Mail, postage pre-paid at 852 Erford Road, East Pennsboro, PA 17011. Service
on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing
by the Plaintiff.
BY THE COURT:
TRUE COpy FROM RECORD
In Testimony whereof, I here unto set my hand
end the selll 01 said Court at Carlisle, Pa.
fhis /7()'-'i~~Y 2,Q~ J;;
I .
Protlmnotarf
/s/ [~~ 13, ~hy.
I.
.
, ~ .,; ..',---'-......__.0'"..
. ,
, ~-.--,..
EXHIBIT IIBII
~,
;" 'i.
,.;..,~
l!
, .'
<"'"'"--,,,,,,,.
o
GRENEN & SmSIC, P,C.
,.
pmSBURGfI. PA 15222
U,S, POSTA SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND lNTERNATlONAl MAll, DOES NOT
PROVIDE FOFlINSURANCE-POSTMASTER
Received From:
One piece of ordinary mail addressed to:
---.i,\ ~ ~IU\II/A ~~f\\>A-T
~ 8.~ .\<ofl&,
~t&-s.-l ~ \1c-z.o ~A- l'loLl
PS Form 3817, Mar. 1989
LI1
"'
LI1
o
ru
II'"
'"
C'-
Postage $
\.
Certified Fee
ru
o
o
o
Return Receipt Fee
(Endorsement Required)
Restricted DeliverY Fee
(Endorsement Required)
;,(\
Postmark
Here
o
ru
'"
o
Total Postage & Fees $
v'
r'l
t:l
t:l
C'-
I
-
'",-" '
EXHIBIT "e"
" ,,~. -,:.,,,,.... .~' k"i-
:J
,.
"'- .
,'. . ~ "
-, ,U;, ,-" 'L_",.~"
"~ "''''''',,-,,'''
Washington Mutual Home Loans,
Fik/a PNC Mortgage Corp. of
America
VS
Kiran Kumar Dandapat
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-3821 Civil Term
Douglas Donsen, Deputy Sheriff, who being duly sworn according to law, states
that on December 26, 2001 at 5:32 o'clock P.M., EST, he served the within Real Estate
Writ, Notice and Poster upon the within named defendant, to wit: Kiran Kumar
Dandapat, pursuant to a court order, by posting the premises located at 852 Erford Road,
Camp Hill, Cumberland County, Pennsylvania, according to law.
Gerald Worthington, Deputy Sheriff, who being duly sworn according to law,
states that on January 08, 2002 at 2:45 o'clock P.M., E.S.T., he posted a true copy of the
within Real Estate Writ, Notice, Poster and Description, in the above entitled action,
upon the property ofKiran Kumar Dandapat located at 852 Erford Road, Camp Hill,
Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one ofthe within named
defendants to wit: Kiran KumarDandapat, by regular mail to his last known address of
852 Erford Rd., Camp Hill, PA 17011. This letter was mailed under the date ofJanuary
23,2002 and never returned to the Sheriffs Office.
Sworn and subscribed to before me
This _ day of
So Ans~. .ss~: '
r~~~~
R. Thomas Kline, Sheriff
2002, A.D.
Prothonotary
BY ,--Io~ JnUf{,
Real Estate Deputy
'~~':""':";"~~'~HI~i;!~"'JlliJi>&1e.'''-'''':':'.i'_b%,,''l'''4i:_''''',-:'''''''';';,';,,_~'!'-';i>,.l_"
,,1.JUL.lI!lIDIIUIIULI.
- >.<'.""_ihi "-",,;_-'_ .""c,,,,,,*,jfi'i'~s.1~!llii~iIl!iii'~ "'r !~illM' rW!"";"~1aIRl ,,,"-, -~~~~_.
~u~.=_,-,,,=",,,_ ,~~",~ ~~.. ='~~'.""'"__~'_', ~",,'~''''_~', "'.~,_.,", "'~,o _, <,
. ~_ ~, _~ c .~<...
,
(")
f;
~~r\
!Qi::_.
r:.-:~ c>
"
~2
?~
-<
C)
''''
...,.,
r1
GJ
-
-.,\
...,...,
-:-)
;~~~~ ;:~~
;:-:;~~ [11
'::.::..
.~
"---0
=<
G.)
,"~
<=>
~
" -,~
.--".-
C" ,-,f'~_
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
F/K/A PNC MORTGAGE CORP.
OF AMERICA,
CIVIL DIVISION
Plaintiff,
No.: 01-3821-Civil Term
ISSUE NUMBER:
vs.
KIRAN KUMAR DANDAPAT,
TYPE OF PLEADING:
Defendant.
Pa. R.C.P. RULE 3129.2(c) (2)
LIENHOLDER AFFIDAVIT
OF SERVICE
CODE -
FILED ON BEHALF
OF PLAINTIFF: Washington
Mutual Home Loans, f/k/a
PNC Mortgage Corp. of America
COUNSEL OF RECORD
FOR THIS PARTY:
Kristine M. Faust, Esquire
Pa. I.D. # 77991
SHERIFF'S SALE DATE:
March 06, 2002
GRENEN & BIRSIC, P.C.
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
.,
,_ "-.,"",,- ^' .-, ~, 'i,- ,"'- ".ti0'i'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
F/K/A PNC MORTGAGE CORP.
OF AMERICA,
CIVIL DIVISION
Plaintiff,
No.: 01-3821-Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
Pa. R.C.P. RULE 3129.2(c) (2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Faust, Attorney for Plaintiff, Washington Mutual
Home Loans, f/k/a PNC Mortgage Corp. of America, being duly sworn
according to law, deposes and makes the following Affidavit regarding
service of the notice of the sale of real property on all persons named
in Paragraphs 3 through 7 of Plaintiff's Affidavit Pursuant to Rule
3129.1 as follows:
1. By letters dated December 13, 2001 and January 15, 2002,
undersigned counsel served all persons (other than the Plaintiff) named
in Paragraphs 3 through 7 of Plaintiff's Affidavit Pursuant to Rule
3129.1 and Supplemental Affidavit Pursuant to Rule 3129.1 with a notice
of the sale of real property by ordinary mail at the respective addresses
set forth in the Affidavit Pursuant to Rule 3129.1. True and correct
copies of said Affidavit Pursuant to Rule 3129.1, Supplemental Affidavit
Pursuant to Rule 3129.1, and Certificates of Mailing and any letters, if
returned as of this date, are marked Exhibit "A", attached hereto, and
made a part hereof.
Af
"
.r__
~ ,-"'
'.1:
I verify that the facts contained in this Affidavit are true and
correct based upon my personal knowledge, information and belief.
Qif!iJ.a/
BY:
Sworn to and subscribed before
g;;;;,y :;:
Notary Public
GRENEN & BIRSIC, P.C.
. .' fl
. /)/-" '///L"~'
'-/ ~ ,'~
Kristine M. st, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Notarial Seal
ct~~n~i~b Wehhner, Notary Public
C, ,u, Allegheny Coun
My ommlSSlon ~Pires June 19, 2Jbs
Member, Pennsy1\IanlaAssociationofNOlalies
-',---.
EXHIBIT IIAII
,,,.",-" .".--,..
--. ~";,;~y,:,j
,
',-d'" ,'-'. L'^v~ '. '.~;"'~- '~i1
.
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO.:01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
)
) ss:
)
COUNTY OF ALLEGHENY
Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of
America, Plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information
concerning the real property of Kiran Kumar Dandapat, located at 852
Erford Road, East Pennsboro, Pennsylvania 17011, and is more fully
described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
.
,,"';,C _'_Y__', ',"'
~'_d)
.
.
1. The name and address of the owner or reputed owner:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
2. The name and address of the defendant in the judgment:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
3. The name and last known address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Travelers Bank
11436 Cronhill Drive
Owings Mills, MD 21117-2285
PNC Mortgage Corp.
of America
539 South Fourth Street
Louisville, KY 40202-2531
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025-2796
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Dauphin Deposit Bank
and Trust Company
PO Box 4800
Harrisburg, PA 17111-0800
5. The name and address of every other person who has any record lien
on the property:
PA Dept. Of Revenue
Bureau of Individual
Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
Domestic Relations
Office
P. O. Box 320
Carlisle, PA 17013
Tax Assessment Office
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
. "
,_L
',. : .~- " ,,' ,,-'--
.-' >'- "",~~:,,j
.
.
6. The name and address
interest in the property
sale:
of every other person who has any record
and whose interest may be affected by the
None
7. The 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:
Tenant (s) or
Current Occupant (s)
852 Erford Road
East Pennsboro, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to
authorities.
Dated:
/t-7-v/
~b~6
BY:
Brian B. Dutton, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
~ chi. ;(/1 : day of ~.'/"
~?}u
/ ',~otary Public '
Notarial Seal
Joanne. M. Wehner, Notary Public
City of Pillsburgh, Allegheny County
My Commission Expires June 19, 2005
Member, PennsytvaniaAssociatlonotNolaries
.-, ",-
'"oj, :.,;',
~ ';~~'!
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
F/K/A PNC MORTGAGE CORP.
OF AMERICA,
CIVIL DIVISION
Plaintiff,
No.: 01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
)
) SS:
)
COUNTY OF ALLEGHENY
Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of America,
Plaintiff in the above-captioned action files the instant Supplemental
Affidavit Pursuant to Rule 3129.1. The information identified below is
in addition to the information previously identified in the Affidavit
Pursuant to Rule 3129.1.
As of the date that the Praecipe for Writ of Execution was filed, the
information set forth below was of record concerning the real property
of Kiran Kumar Dandapat, located at 852 Erford Road, East Pennsboro, PA
17011, and is more fully described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT, OF,
IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF
EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON
A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO, PENNSYLVANIA 17011.
DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER 09-17-1044-060.
1:
,
"-,,--,-,,-,'-.;,,,-,-,
,'" .'''''......1;
1. The name and last known address of every judgment
creditor whose judgment is a record lien on the property to be sold:
Reliance Finance Company
3810 Walnut Std.
Harrisburg, PA 17109-2532
Reliance Finance Company
800 South Cameron Street
Harrisburg, PA 17104
I verify that the statements made in the Supplemental Affidavit are
true and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification
to authorities.
0"( Ct' /d ~..
./~ LJ
l/ ,.C,X U~?L1c!-:-lia~
Kristine M. 'Faust~ Esquire
Attorneys for Plaintiff
SWORN TO and SUBSCRIBED BEFORE ME
'"~ 7~ OAY o~
~ .......~"..
ci~a~r~ilfs~:t:f)~sg~~~~ ~~~~~05J
My CommIssIon , p,ssOCIauonolNOlaTieS
~ --or pennsywa01a
Me\l~'
\
, ~""'"
.''''"'''
1"_ ,,,<
.~ -
""'""~'" -. 1llli!l!>Hj,)
u.s. POSTAL SERVICE
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
GRENEN & SIASle p,e.
ONE GAT[;W.ii, Y CENTER, NINE WESiT
pmSilURGN, PA 15222
2!J
-~,'
C',
PS Form 3817, Mar. 1989
:....
U,S, POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT
PROVIDE FOR INSURANCE POSTMASTER
AffiX fee )We)n St8l'f1PS
o meter PclS'~ ,nd
ost miJl,k, I rei of
stma&r force rr~nt
. ~ ",' i
o $;'
-H,~:Y
Received From:
. GRENEN & 8IRSle, P.C.
ON" GATEWAY CENTER NINE WE
pmSB '
One piece of ordinary mail addressed to:
94>1.+ ~ ("Vl1~ lI.1L~
C10 .sOl/d, ~t/hult"~
<[L ~o l /L ~.~ \ La:}.8 - c9- 7'1 C:.
( 1 ~
-."",..j
L;';
i, : ~
PS Form 3817, Mar. 1989
CERTIFICATE OF MAILING
u.s. POSTAL SERVICE C AND INTERNATIONAL MAil, DOES NOT
~:;V~~EUFS5~ ,~~~~f~\ST~OSTMASTER ~~
R".;YOd ,<om' GRENEN & BIRS~'~i~E ViES1f ~ \;J'0"u
ONE GATEW ~ Y CENTE , . q"
;'....3
O":;~f~':;~d1: t~^~ 'Bar-l(
~~-~ GlI~-\ (l~l\U\
~~n'6:.<{~oDA- \t,l\l-65CO".
PS Form 3817, Mar. 1989
,.,
--
l._:r:
"i:
'\
- -~
l'~~_""-"",.,,i
U,S, POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED fOR DOMESTIC AND INTERNATIONAL MAil DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER '
Received From:
GRENEN & 8IRSIC, P.C.
ON. GATEWAY CENTER, NINE WES1!
','I
.........)
"_
'"
PS Form 3817, Mar. 1989
U,S, POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil; DOES NOT
PROVIDE FOR INSURANCE POSTMASTER
Affix fee here in stamps
or meter :postage and
p f matk:/ )-o.qulre ,_ of
fi ostma*r tor..\urr+nt
m tJ'))'
r> ;
..,;:; CD i
@.'. C; y~"
-~\ ~~ ..:0'
, H~
&
"
"\
Received From:
GRENEN & 81RSIC, P.C.
ONE Gk Tt~"A Y CENTER, NINE WESif'
l..,"j
PS Form 3817, Mar. 1989
Received From:
US POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT
PROVIDE fOR INSURANCE POSTMASTER
GRENEIJ & BIRSIC, P,C.
,.
pmS8URGH, PA 15222
O~=h~'~ otbll :~~M3
<.pO B.~ :s.'c>
eN 0 llJa 'Pit- \'0 l3
III
........~ ,
L_;:'l
PS Form 3817, Mar. 1989
'\
-"-
~ ".
, J_
'~"_,i
Received From;
ONE GATEWAY CENrEA,'NINE WE$T
fmSBURGH. fA 15222
U,S, POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL DOES NOT
PROVIDE FOR INSURANCE POSTMASTER -'
,
I
j
'2:- (3- 0 \.
One piece of ordinary mail addressed to:
~~~:::
<:;-<:)
'_."l'
PS Form 3817. Mar. 1989
'\.
U,S, POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED fOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Reoalvad .F,om' Gremm & mrsir: P.C
~"\ ,--,......,-. ' ~ .
Fiti~t~i,~:: ~~~ 1~~2~
c:
-0 I
\-10,1
y~: 1
" \"\ ~ r0
:':,',j \~i
'>~, /-1
iFt- ""'--, 'I"
g#i'o':!;Ai~\"
, ;$ ~ ',\_~'J_
t 1 ( ! ~"'I'l
l. f~!
dltl'
If'l
"1'1
PI/II
It',l
j lL:
~
Lll
I"
>t.,c >I- >I- .. .. ,. ,. " ~ * ..
fS Form 3817, Mar, 1989
U.S, PO TAL SERVICE CERTIFI ATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT
PROVIDE FOR INSU NeE-POSTMASTER
rr~nt
!
Received From:
..3 ."'.".. I.
0-''\ r:~'~...~" Center. HI II'
~:'..;t"" ~~'~""f~<lI..' t ne tfliest
h..~hllrgJ, PA 15222
" ()CJ.s./~
~~ ()fT
Q!
I'll
"I
II (0'1
"*... ''\--.."'". '" .. >!-..,..
PS Form 3817, Mar. 1989
~~;~~i&:i,~.i;tjb!""-"i-';,,"'_)'\d,,'crl\la,",,~\,.~yt-~~.t_k.hM'-'l~,"'_,,~,-., . ",~,.,. - .~_;i"_'-"'''^'''''"'-'J!i~",,1M~~Jiili._li~i~>t~~~ti.
Irr.".J"..""I,.__
"d ~
_<,_,_-_,~^'~_~,<o
'" ._~ .
,
~""'-
0 c--.
c " '"
:~;p ~
-r, ," :Ti
ri::1 '--.J
:?; -,
"
U:
~ ~----:.l
~' i, "
7- C; - fTi
5> C.:: ";4;' ::.~I
:2, ....,,,"1 "1>
____I e...,,--.
,-< ~,
CO -<
t"";
~ ~ -,
" ". -;.>.,~"- ,
,-" ~';(,~h
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
F/K/A PNC MORTGAGE CORP.
OF AMERICA,
CIVIL DIVISION
Plaintiff,
No.: 01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
)
) SS:
)
COUNTY OF ALLEGHENY
Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of America,
Plaintiff in the above-captioned action files the instant Supplemental
Affidavit Pursuant to Rule 3129.1. The information identified below is
in addition to the information previously identified in the Affidavit
Pursuant to Rule 3129.1.
As of the date that the Praecipe for Writ of Execution was filed, the
information set forth below was of record concerning the real property
of Kiran Kumar Dandapat, located at 852 Erford Road, East Pennsboro, PA
17011, and is more fully described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT, OF,
IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF
EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON
A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO, PENNSYLVANIA 17011.
DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER 09-17-1044-060.
"
,,~, ~ "',
. ,- ,,.,,:
'-lJ,
'. ,~
.
1. The name and last known address of every judgment
creditor whose judgment is a record lien on the property to be sold:
Reliance Finance Company
3810 Walnut Std.
Harrisburg, PA 17109-2532
Reliance Finance Company
800 South Cameron Street
Harrisburg, PA 17104
I verify that the statements made in the Supplemental Affidavit are
true and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification
to authorities.
eft! {jJ jd 4.-/
,
J~.vcu~:fZ-~
Kristine M. ' Faust, Esquire
Attorneys for Plaintiff
SWORN TO and SUBSCRIBED BEFORE ME
Tm ~ DAYO~
~ ......'::\.,,""
Joanln~I~S~:;,e~\leghJUe~~ ?8U~W05
City 0 , . \ -explles '
My commiSSion, lafioootNolaries
Member, pennsyIVaOlaASSOC
~
; 'li~1iM,;"~<l,',~~J't'!;1'~#>l;;"""t,~~, ii,",)J''''''J€!O'1<-Il:{frh.d~~'''''Si",';Jj,,;.;: "W"'._,^,'~"
;,,-~',";
';""""c-"c.k-,"k;-"".,'t~i~*"~~ti~~.li!!miiOli~\$'~~'Bf~'
.
".
(") c:'} t-j
C r-..; --q
-~
~~ '"Tj
U CG r<1
rn cr co
Z
2: f:
UJ .::----
-~
r;: ," " .
'- -
;c.. ---0 -;
.,J.:'~ ". ,
Z '. "
r.~', ,
P' '"j u) ,---.,.\
,.::... i"..:l ~~;!
.:;J (~ :I)
-<
LU,!..",UIIBI" . ..."""""","'""..",,,,,.., ",b
-~.- ~ ~'^" -, ,,~" ~ ,~ ~,~."'
~ "-'" -- " -.,
:1
.,'''''......., ~,~ "~-- "
.-- .
. ~
--"
-
~~ '
Washington Mutual Home Loans, fi'kla
PNC Mortgage Corp. of America
VS
Kiran Kumar Dandapat
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-3821 Civil Term
l!lH;':.'~'
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Brian B. Dutton.
Sheriff s Costs:
Docketing
Surcharge
Posting Handbills
Law Library
Prothonotary
Share of Bills
Mileage
Levy
Advertising
Certified Mail
Poundage
Law Journal
Patriot News
Postpone Sale
30.00
20.00
15.00
.50
1.00
24.20
19.50
15.00
15.00
.82
16.45
381.65
279.90
20.00
$839.02 paid by attorney
5/30/02
Sworn and subscribed to before me So Answers:
This j)tf dayof ~, ~~ ~~ ~~
n ' R. Thomas Kline, Sh&iff
2002, A.D. ~,. () ~.~ ByJ~J~
Prothonotary Real E te Deputy
\.'~
Uz j L.~6:b
{.l.u. I;;'~ /1'1
.
,"
,_',L'
-'J
~ , rj~::d~
"'T~ '~-. ,
(
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO.:Ol-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT.
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COUNTY OF ALLEGHENY
)
) ss:
)
COMMONWEALTH OF PENNSYLVANIA
Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of
America, Plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information
concerning the real property of Kiran Kumar Dandapat. located at 852
Erford Road, East Pennsboro, Pennsylvania 17011, and is more fully
described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS ~52 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
',(0.-,
." '. , ,,-:j;, ., , " . ~
41
..~ ~ .
1. The name and address of the owner or reputed owner:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
2. The name and address of the defendant in the judgment:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
3. The name and last known address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Travelers Bank
11436 Cronhill Drive
Owings Mills, MD 21117-2285
PNC Mortgage Corp.
of America
539 South Fourth Street
Louisville, KY 40202-2531
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025-2796
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Dauphin Deposit Bank
and Trust Company
PO Box 4800
Harrisburg, PA 17111-0800
5. The name and address of every other person who has any record lien
on the property:
PA Dept. Of Revenue
Bureau of Individual
Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
Domestic Relations
Office
P. O. Box 320
Carlisle, PA 17013
Tax Assessment Office
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
,',
,
-, r "' ,'l.-'_~ ' ~
. '-':;lib
~ ". ,-...__. I
6. The name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
None
7. The name and address of every
knowledge who has any interest in
by the sale:
other person whom the plaintiff has
the property which may be affected
Tenant (s) or
Current Occupant (s)
852 Erford Road
East Pennsboro, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.B.A. ~4904 relating to unsworn falsification to
authorities.
Dated:
/t~7-0/
~b~~
BY:
Brian B. Dutton, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
, mo <hi. ;(./1 '~'Y Of~"'/'"
%Z<P'JP;U
/ "~otary Public
Notarial Seal
cJoanne. M. Wehner, Notary Public
,ty of Pittsburgh, Allegheny County
My Commission Expires June 19, 2005
Member, PennsylvaOlaAssociationOfNotaries
. ' I,,,,",,.,", ~;.._ . =,;.
{ ,-...;.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO.:01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: KIRAN KUMAR DANDAPAT
852 Erford Road
East Pennsboro, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out
of the Court of Common Pleas of Cumberland County, Pennsylvania, and to
the Sheriff of Cumberland County, directed, there will be exposed to
Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COMMISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17103
on March 06, 2002, at 10,00 A.M., the following described real estate,
of which Kiran Kumar Dandapat is the owner or reputed owner:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY,
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
"-,'
~d
J ~ -,
-,-"^
~--
.... ,cc_
~ ~:-'
-,
-
The said Writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
at Execution Number 01-3821 Civil Term in the amount of $76,287.78.
Claims against the property must be filed with the Sheriff before
the above sale date.
Claims to proceeds must be made with the Office of the Sheriff
before distribution.
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must
be filed with the Office of the Sheriff no later than ten (10) days from
the date when Schedule of Distribution is filed in the Office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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
ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717)249-3166
(800)990-9108
"
, ~
<~^" 'l!illicit
-.
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after service of the Complaint for Mortoaoe Foreclosure and Notice to
Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE
ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
GRENEN & BIRSIC, P.C.
$;d' ~.
By:
Brian B. Dutton, Esquire
Attorney for Plaintiff
.
L ~ ~,
"'
1---'-"j-
.
..
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO. :01-3821 Civil Term
vs.
KIRAN KOMAR DANDAPAT,
Defendant.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro,
Cumberland County, Pennsylvania, more particularly bounded and described
as follows, to wit:
BEGINNING at a point on Erford Road at the dividing line between Lots
Nos. 16 and 16(x) on the hereinafter mentioned Plan of Lots; thence along
said Erford Road South 89 degrees 50 minutes East 37.5 feet to a point
at the line dividing Lots Nos. 16(x) and 17; thence along said dividing
line South 0 degrees 10 minutes West 150 feet to a point; thence North
89 degrees 50 minutes West 37.5 feet to a point; thence North 89 degrees
50 minutes West 37.5 feet to the line dividing Lots Nos. 16(s) and 16;
thence along said dividing line North 0 degrees 10 minutes East 150 feet
to the point of BEGINNING.
BEING Lot No. 16(x) on Plan No. 19 of Ridley Park as recorded in the
Cumberland County Recorder's Office in Plan Book 22, Page 64.
HAVING thereon erected a dwelling house known and numbered as 852 Erford
Road.
UNDER AND SUBJECT to the Easement of a sanitary sewer line as shown on
the aforesaid plan.
TOGETHER with all and singular, the tenements, hereditaments and
appurtenances to the same, belonging or in any way appertaining, and the
reversion and reversions, remainder and remainders, rents, issues, and
profits thereof; And Also, all the estate, right, title, interest,
property, claim and demand whatsoever, both in law and equity, of the
said Parties of the First part, of, in, to or out of the said premises,
and every part and parcel thereof.
.",
l..
" ~ - "';1,
....
BEING the same premises which Pin Hui Kuo and Kuei Ying Kuo (a/k/a Kuei
Hui Kuo} , his wife, by deed dated March 29, 1996 and recorded on April
1, 1996 in the Office of the Recorder of Deeds for Cumberland County in
Deed Book Volume 136, Page 965, granted and conveyed unto Kiran Kumar
Dandapat.
By:
GR~~N &~IRSIC, P.C.
~f)~-
Brian B. Dutton, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
{412} 281-7650
DBV
Page
Tax Parcel No.
136
965
09-17-1044-060
~~ u'~m= ~ __" ~
"_h
~'"l~'
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA}
COUNTY OF CUMBERLAND}
NO,
01-3821 CIVIL 1~ TERM
CIVIL ACTION, LAW -
TO THE SHERIFF OF
()1f11hF!rlnnrl
COUNTY:
To satisfy the debt, interest and costs due Washington Mutual Hone Loans. f /k/a PNC Mortgage
Com. of America PLAINTIFF(S)
from Kiran Kumar Dandapat, 852 Erfoni Road, East pennsboro, PA 17011
DEFENDANT(S)
(1) You are directed to levy upon the properly of the defendant(s) and to sell S",,,, r""CY" flp"",riprion
(2) You are also directed to attach the property of the qefendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and,tommy the garnishee(s) that: (a) an attachment has been iss!led; (b) the garnishee(s) istare enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise dispOsing
thereof;
(3) If property of fhe defendant(s) not levied upon an subject to attachment is found inthe possession of anyonepther
than a named garnishee, you are directed to notify himlherthat he/sh~ has been added as a garnishee and is enjoined as libove
stated.
Atty's Comm
Ally Paid
Plaintiff Paid
%
LL
Due Prothy
Other Costs
$.50
$1.00
Interest
$73,592.67
$2,695.11
Amount Due
$158.50
Curtis R. Long
Prothonotary, Civil Division
Date:
December 11, 2001
bK ail/}'> P ,2 /If.l?~ ~
Deputy
REQUESTING PARTY:
Name Brian B. Dutton, Esq.
Address: One Gateway Center, Nine West
Pittsburqh, PA 15222
Attorney for Plaintiff
Telephone: 412-281-7650
Supreme CourllD No, 81QS3
'>'~'O,;,".," ,,1,-_;_,; ,-'-.!,u_
,_",_-,,,".k~;;;,,"",hj&i't1I&ThI~~li~~"i~"''''&'';Ji~}Jti!i,t~'Wi~~%m!!li>!iW."lli!:~
REAL ESTATE SALE No. 50
On December 12, 2001, the sherifflevied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA,
known and numbered as 852 Erford Road, Camp Hill
and more fully described on Exhibit "A" filed with
I
I:
this writ and by this reference incorporated herein.
I:
!
Date: December 12, 2001
By: gc4:t SrvU.::th
Real Estate Deputy
h.)
c:;:;;)
c;ru
c:::::::::;,
~1
\:'J-t~
~
\)"s~~jO
'V\~~!\;,\)Vi')
.:! \'.' ~
\\~ ~f. t \\ '.\~
\\\. ,.' ,.', , \\j'f\\\()
~~\\\I~~~ ~~~ 'j'o. 3~1~~O
j~\ >'"
","
--- ."
~, _,' _ = ~ ~ ^_ , _,e
,,1 -' ~~
~ '.... ~- ,
-11." ~j""""',~_"';_"_
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, appro:ved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor ofthe 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:
JANUARY 25, FEBRUARY 1,8,2002
Mfiant 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.
~
SWORN TO AND SUBSCRlBED before me this
8 day of FEBRUARY. 2002
NOTARIAL SEAL
LOIS E. SNYDER':: Public
ClllalBIlolo. CUm Coun\Y
My ComIlII8tIon EJcpir88 MaId'l5. 2005
---,
'Iii "'1,
fl ",' ~ ,',".
---".
1
.ll&lf..> ~,~"i i -F
i
i
\;'
I::
I'
I
I
I,
tl~ t(, t~:'Lt,;:~, r -'1'~ :1:(.IJ h:..,
REAL ESTA'l'E SALE NO. 60
Writ No. 2001-3821 Civil
Washington Mutual Home Loans.
fjkja PNC Mortgage Corp,
of America
vs,
!Gran Kumar Dandapat
Atty.: Brian B. Dutton
WNG FORM DESCRIPTION
ALL THAT CERTAIN tract of land
situate in the Township of East
Pennsboro. Cumberland County.
Pennsylvania. more particularly
bounded and described as follows.
to wii:
BEGINNING at a point on Erford
Road at the dividing line between
Lots Nos. 16 and 16(x} on the here-
inafter mentioned Plan of Lots;
thence along said Erford Road
South 89 degrees 50 minutes East
37.5 feet to a point at the line dMd-
ing Lots Nos. 161x) and 17: thence
along satd dividing line South 0 de-
grees 10 minutes West 150 feet to
a point; thence North 89 degrees
50 minutes West 37.5 feet to a
point; thence North 89 degrees 50
minutes West 37.5 feet to the line
dividing Lots Nos. 16(s) and 16:
thence along satd dividing line North
o degrees 10 minutes East 150 feet
to the point of BEG1NN1NG.
BEING Lot No. 16(x) on Plan No.
19 of Ridley Park as recorded in
the Cumberland County Recorder's
Office In Plan Book 22. Page 64.
HAVING thereon erected a dwell-
ing house known and numbered as
852 Erford Road,
UNDER AND SUBJECT to the
Easement of a sanitary sewer line
as shown on the aforesaid plan.
TOGETIfER with all and singu-
lar. the tenements. hereditaments
and appurtenances to the same.
belonging or in any way appertain..:
lng. and the reversion and rever-
sions. remainder and remainders.
rents. isSues. and profits - thereof;
And Also, all the estate. right. tltie.
interest. property. claim and de-
mand whatsoever. both in law and
equity. of the said Parties of the
First part. of. in. to or out of the
said premises. and every part and
parcel thereof.
BEING the same premises which
Pin Hui Kuo and Kuei Ying Kuo
(ajkja Kuel Hui Kuo), his wife, by
deed dated March 29. 1996 and re-
corded on April I. 1996 In the Of-
fice of the Recorder of Deeds for
Cumberland County in Deed Book
Volume 136. Page 965. granted and
conveyed unto Kiran Kumar
Dandapat.
DBV 136,
Page 965,
Tax Parcel No. 09-17-1044-060,
I
.....
,-
d
~j:
~
, '.
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
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Ass!. Controller of The Patriot News Co., a corporation organized and existing under the laws
of the Commonwealth 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 The Patriot-News and The
Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, In the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since:
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 29th day(s) of January and the 5th and
12th day(s) of February 2002. 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, afores1jid 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 Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
SALE#50
-Notarial Seal
Terry L, Ru"~", Notal}' Public
Herrisburg, Deuphin County
My commisSion Expires June i, 2002
Member, Pennsylvania AsSOCiation of NotarieMy 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
hereto on the above stated dates $
Probating same Notary Fee(s} $
Total $
278.40
1.50
279.90
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sundav 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"""",.,.....,.,.,.,.,.,.,.,.,.".",."""""".",.".,.,.,.,
R1i",('WtATESiitE Ho, '50'
Wrft No, 2(lQl-3821
Civil Term
WO$hlnglOnMulual
li"""'l.O<Inll,flkla
PN, C Mortgage Corp"
lI1 AmOrita '.
".
K~an KUI1I,!l' Dend.pat
Ally: Bo'(jne. OtJl\Cn
PESCIHrnON,,:
ALL THA:r {121ITAtN-- tract or land ~it!lat~ in
:the_lDWnShJ1i -oj" l!ait Penni'-txm:1. Cumberland
('.t.mnly, ai,_ Pen.n~ylvaJ1la, rr\()~ varti~larly N
bounded and dc:scribed ll,,-foUow,~, to_wit:
lIEGINNJ~::jlr rrpQiot.9t1 Emli'd Road at the
:dMding hue 1:icl\\1:CI.i lnt'; Nu.'\,J6 .aJld_16 (x)
on the: btte1na.ft'e'f .r):(e_I1I.1oIlCd Plan Ill' tots;
t!iem::tI _ f mo~- -~d_:_f.!;rtoj-(r:_:Road Sooth ~9
tlep::;'_ 50 mmUte~ l:~ _37 .:.~' feet IT! a lH;li[ii. at
the line_ r.:llvldilHr t.6ts.:_N.{)~_. 16_ (Xi and 17:
tiJeIK'{'-.njdng.-~~tt.r i$MdLnglirje)ouJh (J degt"..e,>
10 mlmJtes_VYcst _i50.1cef,\-o _Il jX)ll:lt: thence
_NOrth _89 q~~~:5IJ:l:li.ip'tifes_'Yrl~r37 J ie,e{ to a
1Kt.'nt:, tnenc'r :Ntifili .-g~ digxeeSc :5~ _Plinutes \\1:,<;1
.~l5 f~f-~ iile line di,;idin~ tots N'o~. ie';'!),
iliro l(];theiicc_all):, .-Mti(ldh7idin~lineN@li6
-~ m minUl~ ria~i 150 led t(t tlie pC/iut of
ll~:GINNtNlI ',. .,' "
MF.TNCrr..ofNo... Ib;:x_l Qn.P1M1_ NO',-l:9 -0:( Ridle~'
M _ al._ re...md.eJ ,iI! the Cumberland CQUl)\Y
.R'~~~i!\fcr's (lflice-Ji<prari_IJook_.z2;_~age M .
liA:VINrrth_cre()Q ~_a_dyjeUlng. hoJJ;se
linmNll and milt\~__a_s_ 352 _Erfotd Road.
U1i(1)ER AND S1L8JF.Cr-ri)_ rbe f:4-\'emcnt 0(' a
_~nilar~ _l!t'.V+'(~ line a; _;';.bowo on th~_ _M(ll'i~~id
pian.
}t)(iFJ'Hf;R'__:W~lC-ffll:_ iti:ii1_ ,~in:gu[iil_r, tiw.
ttn_l'11lCilf5, hctroilam.e-(l!.~ anO_appurteoan_cc.;o:. to
, thJ~ 'wmc._ rx:lunging of lIt 3~Y_ -~VllY_ _!!JJpcrul.llling,
ana ttir. J'c~'Ct!ikm II11d rel.mirms, renrdtrtder lllld
rCili<Uridetl!,'-:r~nts; ::i~:;_ue:':;_:al1_d -p_rortis tnetel)!:
~\rid also. all .the _ t'~lak._ rIght, _ ntfe., ll1tere'"'
~~~ dll(m:.itlld:<~m4mi wba:j.soe~~l'. bmh In
l&w" ;tl!d equity._ uf _lhe ~aiD_'partles__(1f ,!be r,~tn.t
JItIlt,' of, hr, 1:0 .>.!' ("It of t.he ~id preml;;e.~, and
I;!ve.,o.y -part and parcd_ thereof,
RHNCi tne-$<'Ime P1'~:l1ht's which PiJl Hili Kuo
aud Kuei Yitt.g Kllo.C'lI'k1a Kriei. HUt KtlO), his
Wlte. bv deed dated Marcb -'~9_. 1996 and
~,'Qt'dcd on April 1., 19%.illlhdll Office of fhe
Recorder (If l)e.cd~ I'or Ciimberlmtd County jn
DCCd Book in_ \1:1\.ume })(\" Pa,~ 96,5, s_nml.ed
iIl1d_i.n{,'OOV~'l'XJ JJ_1ItoKi_ca!l KurniuDa~pa1.
fJBV '_~ 136;,.Pilgc. ...,_%j_~TilX ft~t'cf.l_.No_.t19.1.1.
W44-OOO,
u "
- ~ ~
--j-;,-
, -, ~""'-"''-
~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Washington Mutual Home Loans, f/k/a
PNC MOrtgage Corp. of America
( Confessed Judgment
( Other
File No. 3 % :I- \ 0 J 200 \
vs.
Amount Due
Interest
Atty's Comm
Costs
73,592.67
7,737.63
Kiran Kumar Dandapat
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland
for debt, interest and costs, upon the following described property of the defendant(s)
See Attached.
County,
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date
/1/,x-6/tJr'"
Signature:
Print Name:
Address:
~WaLij08x.-
Kristine M. Anthou, Esq.
One Gateway Center, 9 West
Pittsburgh, PA 15222
Attorney for: Plaintiff
Telephone: 412-281-7650
Supreme Court ID No.: 77991
(over)
" ~.,,_,<_ ,'~",h-;'0H,!l~i!!IilllulillliliiiSli~IiIllil!i&o.\1\~,t;""1 ...;,,"...~oi~"""""~ '''''h'~lt!l:llil''''filli~l~l~~'
~~:JiMJlII~~Nia!l!JiiiI~~~hlid!:O:H~i0.Wi;!tIl~"~~""''-#'~'''~''~'"i- --""_';_,' ,
--=":0-
~ "
Notes: If real property, supply six copies of description including improvements and an original and copy of
affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list
To index writ, file separate praecipe with writ.
o
c
s:
"0(;)
mrT"'
z::c
Zt;,
~~Z-
GC}
~
:;in
=0
.vC
~~
",~"",l;_"tt~'f1I~'~ ~= ,_,,~ _""""'~""',,,,",,,, ._.'~"_.."~"^",",,,, ~_~_~~, ,__" ",,,e.".~ ,
o
!'-'
c:::>
j.....1
M
I
0'::
.._i
---
v
-~-'-
.'
>2l~;
.":~rn
, ,
-::-=1
~~
,~-
'-2
0;)
~%
..
.,,'
.'., ~ ,.." " . "
---r",
~
..
'"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
- --LGANS,flkl a--P-NC-MOR'rGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO. :01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro,
Cumberland County, Pennsylvania, more particularly bounded and described
as follows, to wit:
BEGINNING at a point on Erford Road at the dividing line between Lots
Nos. 16 and 16 (x) on the hereinafter menti'oned Plan of Lots; thence along
said Erford Road South 89 degrees 50 minutes East 37.5 feet to a point
at the line dividing Lots Nos. 16(x) and 17; thence along said dividing
line South 0 degrees 10 minutes West 150 feet to a point; thence North
89 degrees 50 minutes West 37.5 feet to a point; thence North 89 degrees
50 minutes West 37.-5 feet to the line dividing Lots Nos. 16 (s) and 16;
thence along said dividing line North 0 degrees 10 minutes East 150 feet
to the point of BEGINNING.
BEING Lot No. 16(x) on Plan No. 19 of Ridley Park as recorded in the
Cumberland County Recorder's Office in Plan Book 22, Page 64.
HAVING thereon erected a dwelling house known and numbered as 852 Erford
Road.
UNDER AND SUBJECT to the Easement of a sanitary sewer line as shown on
the aforesaid plan.
TOGETHER with all and singular, the tenements, hereditaments and
appurtenances to the same, belonging or in any way appertaining, and the
reversion and reversions, remainder and remainders, rents, issues, and
profits thereof; And Also, all the estate, right, title, interest,
property, claim and demand whatsoever, both in law and equity, of the
said Parties of the First part, of, in, to or out of the said premises,
and every part and parcel thereof.
'" .
,
" '
'l:~j
'~-~i ",._ - ~
BEING the same premises which pin Hui Kuo and Kuei Ying Kuo (a/k/a Kuei
Hui Kuo) , his wife, by deed dated March 29, 1996 and recorded on April
1, 1996 in the Office of the Recorder of Deeds for Cumberland County in
Deed Book Volume 136, Page 965, granted and conveyed unto Kiran Kumar
Dandapat.,~
DBV
,Page
Tax Parcel No.
GRENEN & BIRSIC, P.C.
By: ~~~
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
136
965
09-17-1044-060
." ~ lL
- ~ ;l!!;1i<~"","Ilr.<i"~';U'!-':-L-c.:,~
-l!~lli~"1i~1Il!li~iIlI!mj{j,W"ttil!<Bi;)J I\!I '"
\2~
---" ~
'-J-'
t-. .,...J'
.....J
-,
<:X:, e<::-
o -r---
."" ".h";~~)'''<'_i
'_;_J"~"""'.~",'hli:l'Icii~_~/,l~
(
~!
\
---
()
.......
\)
C>
)V
i0
J
-"- ~ -t:::- -.
J:;" tv ~ ~
, "0
~ \j
_-_,~r!~},- t _~~"::on";~~~)HJJ~!!lbf.l",,-_"~,~,,, "".' ",'-d>", - ,'", ,^~" '''",
},,)LJ:-~\~},_,l,L~I~.rlU J lLJ~IT,)UJ1!:~tlJ~"n:J!~,~" -t, ~ ,-"" <rt ,_~ _, _
ex;-,
........ l}.l-...
~ ~C!'\ ~
J:,
-J
~
-. . ~,~,
~jl"lI~
"'-""--1
__m_
..
((2)
(') c:, C)
c: f"',) T,
s;: C,
-00:0 '"'1
nip~' ,'")
z:i:;
ZC I ";{(7
~~2~ (.,) ~-~~j
!<G .,~ ~.,...,
~O .,
',,;C)
'-c ~) 25rn
Pc "'..,
Z :1>
=< :n
en -<
'"
~ ~
l.
-"'~',f
-....
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NOOl-3821 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS f/kla PNC
MORTGAGE CORP OF AMERICA Plaintiff (s)
From KlRAN KUMAR DANDAPAT 852 ERFORD ROAD, EAST PENNSBORO PA
(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
ofl
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued: (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated,
Amount Due $73,592.67
LL
Interest $7,737.63
Atty's Comm %
Atty Paid $1010.02
Plaintiffpaid
Date: DECEMBER 3, 2002
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
Prothonotary
By ,~"'~ 0./ {~'fnc.L~
I
Deputy
REQUESTING PARTY:
Name KRISTINE M ANTHOU ESQ
Address: ONE GA TEW A Y CENTER, 9 WEST, PITTSBURGH P A 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No, 77991
.'. '~..' -, k_ ,_ .'-.
"
- ~-i,:'i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO. :01-3821 civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT OF LAST KNOWN ADDRESS
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Before me, the undersigned authority, a Notary Public in and for the
said County and Commonwealth, personally appeared Kristine M. Anthou,
attorney for the Plaintiff, who being duly sworn according to law deposes
and says that the owner of the property located at 852 Erford Road, East
Pennsboro, Pennsylvania 17011 is Defendant, Kiran Kumar Dandapat, whose
last known address is 852 Erford Road, East pennsboro, Pennsylvania 17011
to the best of his information, knowledge and belief.
~LL;c('9YraL~
SWORN TO AND SUBSCRIBED BEFORE
r\0d\"
ME THIS MJ
DAY OF II.. 'P>\l 'PJ'('O..()'P",) ,2002.
~c::l)')'O("'''1~~ci)
Notary Public
Notarial Seal Public
" A 1bwnsend. Notary
Patne,. .' h A1\eghenyCounty
City of Pi!tshu:;Sispires June 2, 2003
My ComlOlsSlO, 'otNotartes
Memner, pennSyIVaOlaAsSOClahon
~~~l;-"~M;;JiM<iJ!i:il,;;;!i,?III",Mif!lliIll!T/"'!liiM!itiktWHt~;;.;u~l"_";;"l'~~"~"'" ,'''-L'''!;;''''':G'''_'''-'<,,"-j~B,~iitti:~~~~'-
.J>
~JfI[l ,r IT -(n~
'R _l!J_UtILJ _ ~~_~c" ~"~8_ ~O_'O,~_ ''''_~_ e ~~~., . .
__~~ C>'
!iLdf~MJI1'" ~'"
~.~= :lIl_1
"'M~I
0 0 0
c 1'0.:) -"
? Cl
-tTU; ", _;'2
fTtrri n -
2,:0
zr' I ,-,
cr-i:d?: L.) ~..->'
-<.~:;, '~~~~
\<'0 :s:~
);i-:(..--., g~
2'-
pO ~
c:
z ::t>
=< CO :D
-<
.
-,
,
-~-,
;-'-'" ~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO. :01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974, 41 P.S.101, ET. SEa.
AND ACT 91 OF 1983
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for the
said County and Commonwealth, personally appeared Kristine M. Anthou,
attorney for the Plaintiff, who being duly sworn according to law deposes
and says that onor about March 12, 2001, Defendant was mailed combined
Act 91 and Act 6 Notices, in compliance with the Homeowner's Emergency
Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. ~101,
et seq. by certified mail, return receipt requested and fist class, U.S.
mail.
~()ALMhc-
SWORN TO AND SUBSCRIBED BEFORE
ME THIS ~ DAY OF \\. ~ 'l?~<p^- ') ,2002.
~\l'o"i."",~ .~~
Notary Public
Notarial Seal Public
., A Townaend, NOlllry ~_.. ty
PattIe..: h Allegheny """n
City of Pitts\>Ur&E' 'rea 1.ne2, 2003
eommiSSlon Xpl
My , ASlillClatlono1NQ\anes
Mef!llJElf, PennsylVania
~~~
-
,
;-,
, ,
.#.,
",",
. , ,~, --., ~.,,~" ,,-
i-il i":"'::
I
,~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO. :01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
)
) SS:
)
COUNTY OF ALLEGHENY
Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of
America, Plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information
concerning the real property of Kiran Kumar Dandapat, located at 852
Erford Road, East Pennsboro, Pennsylvania 17011, and is more fully
described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
,u;,
"
.,. '-__. <. ~ i "
..
1, The name and address of the owner or reputed owner:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
2, The name and address of the defendant in the judgment:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
3, The name and last known address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Home
Loans I Inc., et al.
Plaintiff
Travelers Bank
11436 Cronhill Drive
Owings Mills, MD 21117-2285
PNC Mortgage Corp.
of America
539 South Fourth Street
Louisville, KY 40202-2531
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025-2796
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Dauphin Deposit Bank
and Trust Company
PO Box 4800
Harrisburg, PA 17111-0800
5. The name and address of every other person who has any record lien
on the property:
PA Dept. Of Revenue
Bureau of Individual
Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
Domestic Relations
Office
P. O. Box 320
Carlisle, PA 17013
Tax Assessment Office
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
Department of Welfare
Commonwealth of Pennsylvania
P.O. Box 2675
Harrisburg, PA 17105
lII' I
-
~, '" ,... ;.0,
,'C',.<j"
~,
u """I
I
I
.
6. The name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
None
7. The name and address of every
knowledge who has any interest in
by the sale:
other pers~ whom the plaintiff has
the property which may be affected
Tenant (s) or
Current Occupant (s)
852 Erford Road
East pennsboro, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. s4904 relating to unsworn falsification to
authorities.
Dated: /;j.2S/()~
,
BY:
t2"('LU~
M Anthou, Esquire
for Plaintiff
SWORN to and subscribed before
me this ~day of ./I.... 'A "f:>r<Y\.()"/2121,2002.
~~\\'1~oO)A~.~
Notary Public
Notarial :e~otary Public
Patricia A;. ~wn~enA.i\egheny Cou~3
City of P~ts. U'llexpires June 2, 2
My eomdUSSlOn . Notaries
~'lv.O\.AsSOC\.\ion01
Member, penn.,
~~-~.
J_> "
~.~'" . ,'" ,-j.
'. -1hlmf!
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO.:01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: KIRAN KUMAR DANDAPAT
852 Erford' Road
East Pennsboro, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out
of the Court of Common Pleas of Cumberland County, Pennsylvania, and to
the Sheriff of Cumberland County, directed, there will be exposed to
Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COMMISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA ,17103
on March 05, 2003, at 10:00 A.M., the following described real estate,
of which Kiran Kumar Dandapat is the owner or reputed owner:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
.
.
,
J~;;',~_",,' ,'-
, . '.'< "~I;
.
The said Writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
at Execution Number 01-3821 Civil Term in the amount of $81,330.30.
Claims against the property must be filed with the Sheriff before
the above sale date.
Claims to proceeds must be made with the Office of the Sheriff
before distribution.
Schedule of Distribution will be' filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must
be filed with the Office of the Sheriff no later than ten (10) days from
the date when Schedule of Distribution is filed in the Office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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
ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717)249-3166
(800)990-9108
"
i" ";,~ ). 'M
1 ~~ JL
,
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after service of the Complaint for Mortqaqe Foreclosure and Notice to
Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE
ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
GRENEN & BIRSIC, P.C.
By:
~alitL~
M.Anthou, Esquire
for Plaintiff
,,"
-<llt!;I;!;~WA~omll:~j;~~~I;iU;ji:IJl'lt"iliid"ElMlll-:!fIt~",.AH'_"C';;_I"",:C:~,D;._d.'_'C""-,,,.,t!L',;~[c_.,"","'"M4~ii;j'lIA;;:I~
.jb,"",mJI!ll!l!il"lIII1Jll.J.!IIJI1fJJI!,j!"m~!~UJ~", ",,,lb.,,.,..,,.,,,, A,"".''", . """. ..
,O~,'
r lL"~~
...
"=__o.~_
,. ~"'-' l.il'itl.ilM ' . ~ ~- "'"
-,-
t
(") 0 ()
C "" "n
:;:;:o~ c:J
.~ .,,,
-o~D P'1
mrr: " . ~:r]
Z:r
&5:~,: I . L',
"-, ;-10":::::1
-</ -', 1
[;2C -"0 ~--~~~
).':.'0- ,_, \,,2 ('-:::;:,
z<.
~() Cf? ~~~ ~j~
c
~~ -j>
ro ::0
O'-<
-
., ~~
^' '.
-"
~, '
.,,, ,,' .-, .-~-
"-!Ii
;
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, FIK/A PNC MORTGAGE
CORP, OF AMERICA,
CIVIL DIVISION
ISSUE NUMBER:
Plaintiff,
vs.
NO,: 01-3821
KIRAN KUMAR DANDAP AT
TYPE OF PLEADING:
Defendant
Pa. R.C.P. RULE 3129.2(c)
AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
CODE-
FILED ON BEHALF OF PLAINTIFF:
Washington Mutual Home Loans, f/k1a
PNC Mortgage Corp. of America
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M, Anthou, Esquire
Pa, I.D, #77991
GRENEN & BIRSIC, p,c.
One Gateway Center
9 West
Pittsburgh, PA 15222
(412) 281-7650
SALE DATE: March 5, 2003
."LLU.);."
. .
,""'~
;-, -.., ,-
-'''''fl]
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, F/K/A PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
NO.: 01-3821
Plaintiff,
vs.
KIRAN KUMAR DANDAP AT
Defendant.
Pa. Rc'P, RULE 3129.2(c) AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
Kristine M, Anthou, Esquire, Attorney for Plaintiff, Washington Mutual Home Loans,
flkla PNC Mortgage Corp. of America, being duly sworn according to law deposes and makes
the following Affidavit regarding service of Plaintiffs notice ofthe sale ofreal property in this
matter on March 5, 2003 as follows:
1, Kiran Kumar Dandapat is the owner of the real property and has not entered an
appearance of record.
2, On August 17, 2001 this Court entered an Order authorizing Plaintiff to serve
Defendants by posting the property and serving the Defendants by certified mail return receipt
requested and first class mail to addresses set forth in the Order, with service to be valid upon
posting and mailing, A true and correct copy of the Order is marked as Exhibit "A" attached
hereto and made a part hereof.
3, Pursuant to the Order and Pa R.C.P. 3129.2 (C) the undersigned counsel served
Defendant, ,with a true and correct copy of Plaintiffs notice of the sale of real property by
certified mail, return receipt requested on November 27,2002, and regular US, mail postage
L
~~.
, .
'4
."
._.b"
-i_L
prepaid on December 23,2002, addressed to 852 Erford Road, East Pennsboro, P A 17011. A
true and correct copy of the U.S. Postal Service form 3800, Article Numbers
70020510000257719327, and the Certificates of Mailing, evidencing service by certified mail
and first class mail on the identified Defendants, are marked Exhibit "B", attached hereto and
made a part hereof.
4. On December 12, 2002, Sheriffs Office of Cumberland County posted the
property located at 852 Erford Road, East Pennsboro, P A 17011,
I verify that the facts contained in this Affidavit are true and correct based upon my
personal knowledge, information, and belief.
GRENEN & BIRSIC, P.C.
BY:
~'~/lyJh(a/G<--~"{h1.../
Kristme M, Antliou, Esquire
Attorneys for Plaintiff
Nine West, One Gateway Center
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
TIllS n~AY OF~ :~~ 2(J()J
C?-.c:b ..~ .cr--:\ 0l
Notary Public
Notarial Seal .
" A Townsend Notary Public
Patncla . l' ., C
City of pittsburgh, ~llegheny 2 o~CZ3
My Commission ExpIres June, .
Member, Pennsylvania AssoclatlOnotNotanes
EXHIBIT A
. ,',.-
. --' ~
,. ";'" , ,,' _-J,"",-. - ''''+~i
.~ ;;-' .-~
.', " L' ""',. ~,
. "
AU(; 1 ,.,~,
1\\ tA
\1' "-
, \
\.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
INC, f/kJa PNC MORTGAGE CORP. OF
AMERICA,
CIVIL DIVISION
No.: 01-3821 Civil Term
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
ORDER OF COURT
AND NOW, to wit, this 11 'tE-
day of
()"r~j-
, 2001, upon
consideration of the within Motion for Service of the Complaint in Mortgage Foreclosure
Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that
the Sheriff of Cumberland County is hereby directed to serve Defendant, Kiran Kumar
Dandapat with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure by
posting the property at 852 Erford Road, East Pennsboro, PA 17011 and Plaintiff is permitted
to serve Defendant, Kiran Kumar Dandapat, by Certified Mail, return receipt requested and
First Class U.S. Mail, postage pre-paid at 852 Er(ord Road, East Pennsboro, PA 17011. Service
on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing
by the Plaintiff
BY THE COURT:
TRUE COpy FROM RECORD
In Testimony whereof. I here unto set my hand
and the s6Cl1 of said Court at Carlisle Pa.
This i1,t:t: day JJQ~ j;;
( k11/.<
I "
Protlroolltarf
/s/ [~13. ~.
I.
.
,..>i. ";'__...';'''':~;~~.~~j' ;
, ~ ~-,
, r 0' ",
<~
EXHIBIT B
, ,-- ". "~i;,
,"
I"-
ru
, rn
'II'"
'c'I
l'-
, l'-
:UJ
Postage $
\r ~/1L
Certified Fee
Iru
c:1
, c:1
, c:1
Retum Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
Postmark
Here
ru
c:1
c:1
l'-
c:1
M Total Postage & F~e5-
, U)
c:1
Grenen & Birsic
One Gateway Center Ni
Pittsburgh PA 15222
r' 7011
o
(f)
~
Cl
m
,
-.0
c::
!I,
U.S, POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAlL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
One piece of ordinary mall addressed to:
K (vtuJ
~3 J..
~t-
PS Form 3817, January 2,001 ,) ..lr,
-)11'31 PCVIv<^fI:4.,f-
:+.. ~ -'I "......". ...,
f'.JJ,>(}k,
'\
.J
'h!i~':'~~~"-!i~":'l1B!"*-""'*""';,.",";u';)"r'I~>i!i>'N,*~~~i'jl'll,!"J;-f)A -,- ,,;;'-, ,-,,:-,>,<,;',' -",.},'":':'-'';-''iJ1j,,:iJ~Hl!i'1!>:!!<fa'''.~I'''''''
P17 --I!Iili'.:"--;f,l~
L-J~.J~ ."Lj,~~;~"J,tlJ)I'\~lJt,_J)JtL*v~,)",~_~I~,>,,~_,;}.~~;t-0t-~},:,~"~~1:~IL1L,}KlWf[.",~t",, .;",.~,>"- <J,,;, "
<-.....I~
-~
,~,,___ ,.. '>CM'''' m"""",. _,,~"~_.~ ~,_~._
~:f(,
-:-~-'
~i
'."~
0'~~:'
FC
2~
:<
o
.
.0'
--.0.'-
o
C.)
C)
"r1
::--:!
i'<)
-::)
c-
::-.0
":':"'1
~,
~- .,
=<
'""
""",,,,"
il\J --"'''',.,-,;
INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Washington Mutual Home Loans,- f/k/a
PNC Mortgage Corp. of America
(
(
) Confessed Judgment
) Other
01-3821 Civil Term
File No.
vs.
Kiran Kumar Dandapat
Amount Due 73,592.67
Interest 12,225.92
Atty's Comm
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sherif! of Cumberland
for debt, interest and costs, UPCli'l th~ follpwingdes6(ibed propel1Y of the defendant(s)
852 Erford Road ,-
East Pennsboro, PA 17011
County,
PRAECIPE: FOR ATfACHMENT EXECUTION' ,
, ---lssue-writ-of-attaelmtentto-the~Sherif!-of : Gounty;-for debt,-interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the deSCription; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date
09/04/03
Signature:
Print Name:
Address:
~.xu---,4-taULb?-
Kristine M. Anthou
Attorney for:
Telephone:
Supreme Court 10 No.:
One Gateway Center, Nin", W",,,t
Pittsburgh, PA 15222
Plaintiff
(412) 281-7650
77991
(over)
.-d<<M~WM~l'Ill~ti(lru;l'll8il:tmi!iliJiliE-!li!i~I:i]~iiitili:~;~Oh!c,~,jdle:-"Y;',,~:,-~;~j",La:ti"","i~';&-~1!L'iJ_i.i6&.~~_~QiIl~lIIOiI'-'ltIlI~
~~,,- ~"-'lIiili - .-'
f
r- 1O(J .......
~ It.'i ofct ~ ,~ ~~~~ ~
~ !'l. 0;0!'t ~ r.v t ~
;.... . ogCl., "
~ ~~ 8 ..l:: D CC~2~~D
~
~ ~~ I I I I f I ()
f. ~ tr
tJ .. .. ,
, :: , - - .. -
, - ~ -
, , ~
- . .. . ..
:;... - . , -
.. ,
.. ..
&r
~
L;:,.LL."":11l~M~.u.rrJ_~;~.J-~A~_~~J~~f\4~:~-:,~c:_,'~~L~L'~;,L;;'~~i~:~!}};'~biW~it:<." ~",",*"' ..~,~, ,~^"",,fP"'-";.','''' '".,~'",
--
(')
c
:;;:;.
"DC)
tTlfT',
Z:JC
~~~
r::c
~(
.L.t-:-
>(",:'
2:
-;
-:..
-
1llJ!i.1&, ""~
c:.
C~-:.-
~:';
::'1)
r'l'l
''';J
u~;
~?,:
..."'"
~)
t::'
:'<::
-'."'
Ii""
,->.'.~
d
~O~;t"i
. I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO.:01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
)
) SS:
)
COUNTY OF ALLEGHENY
Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of
America, Plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information
concerning the real property of Kiran Kumar Dandapat, located at 852
Erford Road, East Pennsboro, Pennsylvania 17011, and is more fully
described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
r
.
---,
,
l."""-@",,.j
1. The name and address of the owner or reputed owner:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
2. The name and address of the defendant in the judgment:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
3. The name and last known address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Travelers Bank
11436 Cronhill Drive
Owings Mills, MD 21117-2285
PNC Mortgage Corp.
of America
539 South Fourth Street
Louisville, KY 40202-2531
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025-2796
Commonwealth of PA
Department of Welfare
P. O. Box 2675
Harrisburg, PA 17105
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Dauphin Deposit Bank
and Trust Company
PO Box 4800
Harrisburg, PA 17111-0800
5. The name and address of every other person who has any record lien
on the property:
PA Department of Revenue
Bureau of Individual Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
Domestic Relations
Office
P. O. Box 320
Carlisle, PA 17013
,~. "
~",,:
, '
Tax Assessment Office
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
6. The name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
None
7. The 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:
Tenant (s) or
Current Occupant (s)
852 Erford Road
East Pennsboro, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to
authorities.
Dated:
q/-I/cJY
BY:
~~a.LLL~
Kristine M. Anthou, Esquire
Attorney for Plaintiff
SWORN to ~$Cribed
me this ~day of
_ ~"_' ~~~~_,_".~~~._.r"
Notary
:: Not8.~{al Seal
, Joanne M, Wehner, Notary Public
City of Pittsburgh, Allegheny County
My CommissIon Expires June 19, 2005
Member, Pennsylvania Association of Notaries
~ ,
. ~~,~ .llll
<~"~
~~.4W,]~'fil.i'1''if:WB"""k~!J;:_0j''''':,",,,,,",, ,;'. !!-'i' ~-.,,,~;.,,.V ".'.-fA,;'!' J"-{,-,.,--,,-
"\.""~,,,,::,,r,;,,.W):;,:;)~SNf,,,(w'~~ii'l;lf,!jj~\!!IIilijm_Ui~:'.i&&_~""'~"'..... 0 '... ~ .--,'~~' 'iilMf"""'
I~",i'-I
~"
~'~
n ()
c::: -n
-:;0" c'>
--0 ij5 ;'-n
nl'iT "":J
z::-:-~; "
-I~r
"- -, \..0
(J) ~', ' ~
-< ,
r::Ci ~ -;",
",-, -T,'" r:::"
;.::;(~, --""" '"'
~:Ci " en
C:.~l '~-~
:>'"C ~
~ e:- j3
~ '-<
'..
r.)'"!''''~)''1>~..;$MW..t'l!~JJ;:'~J<~jlli",J~U",_,-J,;,4t~-L-IJ;~-.-,,>\,;fJ)-,~m,n'"~,s~,-,~,J~lt,::,,nL.c,; ,:'~,v",J!~ J..",t> ,,"1,'"~ "0 " ,^, ',," .' ""~' _ _", "" , ~^O<,' ,_..
~"
'7
-
~~
, ;
'r........"',_
..
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO.:01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO : KIRAN KUMAR DANDAPAT
852 Erford Road
East Pennsboro, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out
of the Court of Common Pleas of Cumberland County, Pennsylvania, and to
the Sheriff of Cumberland County, directed, there will be exposed to
Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COMMISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17103
on March 03, 2004, at 10:00 A.M., the following described real estate,
of which Kiran Kumar Dandapat is the owner or reputed owner:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
,H, ,..
->",
"'
-
, '
"
c'.
...~..",.,,,j
,
The said Writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
at Execution Number 01-3821 Civil Term in the amount of $85,818.59.
Claims against the property must be filed with the Sheriff before
the above sale date.
Claims to proceeds must be made with the Office of the Sheriff
before distribution.
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must
be filed with the Office of the Sheriff no later than ten (10) days from
the date when Schedule of Distribution is filed in the Office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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
ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717)249-3166
(800)990-9108
~M'~n
,
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after service of the Complaint for Mortqaqe Foreclosure and Notice to
Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE
ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
GRENEN & BIRSIC, P.C.
By:
~~(y()~a,LC-L t:J7-
Kristine M'. Anthou, Esquire
Attorney for Plaintiff
li!l'iitili1\~1~i!l.~~~!!:--,--"!w~~~li@\!;9>lH;;:'_""':r:-i",LM1.b1,U;Wv'~B,",:-;,"',h1;'j~, :':'i> -"i , ,,~,.;Jw,'> I'"";,.:, ",~'~L""i''''"~,,,L&.:,c,~,q;)1,,~,~o;'#...~~o:-iliIlIlti$l~~~ ~ H~J ~ ~~ .,,' Jj U
,.I lU IIIIIlUI!lU
,-
~,n","'c "',_~.' """,",,1_ ""'"'' ' ,~~,z~", ,~_ ,,, ~~__, ."... ,. ~~, - ,- ".,,, ,
,"',~< .," .~
,~ = ^ ,~
.Iilita
(')
C
"2'-
-oe[:
mrf
'~,~~
(f-~ ',",
C\'~-
7::z:-;:,(J
( -
S;~,
~
-z
r.0
:-i\
"0
I.D
~'::
-t,.
q:
Jljt!liM1
J
()
---n
?--
r,l(}_~
'-:'()
r-
.'~~~~
<,,_,-:/n
::::.~
~p-'
::0
'<
,~
~
'-1;
-
r
_.,_.,~~.
....
._,,;,
" .
,"
~-
,~
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO.:Ol-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro,
Cumberland County, Pennsylvania, more particularly bounded and described
as follows, to wit:
BEGINNING at a point on Erford Road at the dividing line between Lots
Nos. 16 and 16(x) on the hereinafter mentioned Plan of Lots; thence along
said Erford Road South 89 degrees 50 minutes East 37.5 feet to a point
at the line dividing Lots Nos. 16(x) and 17; thence along said dividing
line South 0 degrees 10 mlnutes West 150 feet to a point; thence North
89 degrees 50 minutes West 37.5 feet to a point; thence North 89 degrees
50 minutes West 37.5 feet to the line dividing Lots Nos" 16(s) and 16,
thence along said dividing line North 0 degrees 10 minutes East 150 feet
to the point of BEGINNING.
BEING Lot No. 16(x) on Plan No. 19 of Ridley Park as recorded in the
Cumberland County Recorder's Office in Plan Book 22, Page 64.
HAVING thereon erected a dwelling house kno~ and numbered as 852 Erford
Road.
UNDER AND SUBJECT to the Easement of a sanitary sewer line as shown on
the aforesaid plan.
TOGETHER with all and singular, the tenements, hereditaments and
appurtenances to the same, belonging or in any way appertaining, and the
reversion and reversions, remainder and remainders, rents, issues, and
profits thereof; And Also, all the estate, right, title, interest,
property, claim and demand whatsoever, both in law and equity, of the
said Parties of the First part, of, in, to or out of the said premises,
and every part and parcel thereof.
'>~'_';""i."",.- ,'~
.j.;~-,j
,
.;..
r
BEING the same premises which pin Hui Kuo and Kuei Ying Kuo (a/k/a Kuei
Hui Kuo) , his wife, by deed dated March 29, 1996 and recorded on April
1, 1996 in the Office of the Recorder of Deeds for Cumberland County in
Deed Book Volume 136, Page 965, granted and conveyed unto Kiran Kumar
Dandapat.
By:
GRENEN & BIRSIC, P.C.
G/L.;JL( /"C ({L.-L/ct>-
Kn. ;1ne M J Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
DBV
Page
Tax Parcel No.
136
965
09-17-1044-060
'-ili-'~~ ' ~ -~~,
""'"-I.
>. L
.~ ,
,
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 01-3821 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, ioterest and costs due W ASIDNGTON MUTUAL HOME LOANS, F/K/ A
PNC MORTGAGE CORP. OF AMERICA, Plaintiff (s)
From KIRANKUMARDANDAPAT
(I) 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 io the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) tbat: (a) an attachment bas been issued; (b) the garnishee(s) is enjoioed from
payiog any debt to or for the account of the defendant (s) and from deliveriog any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she bas been added as a
garnishee and is enjoioed as above stated.
Amount Due $73,592.67
Interest $12,225.92
Atty's Comm %
Ally Paid $1827.48
Plaiotiff Paid
Date: SEPTEMBER 9, 2003
L.L.
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
prothonz
By: 0-.. -[I 7f("1UJV'~
Deputy
REQUESTING PARTY:
Name KRISTINE M. ANTHOU, ESQUIRE
Address: ONE GATEWAY CENTER, NINE WEST
PITTS:QURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991
. '~ ,
, ", - ~":lQ'k
G"--'
,_.
-
-
,,< '~~'~J;
,
SHERIFF'S SALE DATE: MARCH 03, 2004
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
F/K/A PNC MORTGAGE CORP.
OF AMERICA,
CIVIL DIVISION
Plaintiff,
No.: 01-3821-Civil Term
ISSUE NUMBER:
vs.
KIRAN KUMAR DANDAPAT,
TYPE OF PLEADING:
Defendant.
Pa. R.C.P. RULE 3129.2(c) (2)
LIENHOLDER AFFIDAVIT
OF SERVICE
CODE -
FILED ON BEHALF
OF PLAINTIFF: Washington
Mutual Home Loans, f/k/a
PNC Mortgage Corp. of America
COUNSEL OF RECORD
FOR THIS PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. # 77991
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
.
,-,
.
-_~-i_
.-..'""-~'''!;,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
F/K/A PNC MORTGAGE CORP.
OF AMERICA,
CIVIL DIVISION
plaintiff,
No.: 01-3821-Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
Pa. R.C.P. RULE 3129.2 (c) (2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Anthou, Attorney for Plaintiff, Washington Mutual
Home Loans, f/k/a PNC Mortgage Corp. of America, being duly sworn
according to law, deposes and makes the following Affidavit regarding
service of the notice of the sale of real property on all persons named
in Paragraphs 3 through 7 of Plaintiff's Affidavit Pursuant to Rule
3129.1 as follows:
1. By letters dated September 15, 2003, undersigned counsel
served all persons (other than the Plaintiff) named in Paragraphs 3
through 7 of Plaintiff's Affidavit Pursuant to Rule 3129.1 with a notice
of the sale of real property by ordinary mail at the respective addresses
set forth in the Affidavit Pursuant to Rule 3129.1. True and correct
copies of said Affidavit Pursuant to Rule 3129.1, Certificates of
Mailing, ~nd any letters, if returned as of this date, are marked Exhibit
nAn, attached hereto, and made a part hereof.
-'. -
."'"" -~
" ,-,
I verify that the facts contained in this Affidavit are true and
correct based upon my personal knowledge, information and belief.
BY:
Sworn to and subscribed before
me this~day of
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Gerald L. Paller, Jr., Notaly Public
Qty Of Pittsburgh, Allegheny County
My Commission Expires Dec. 10, 2007
Member, Pennsylvania Association Of Notaries
GRENEN & BIRSIC, P.C.
L~LL~~L~
Kr~s ~ M. Anthou, Esqu~re
Attorneys for Plaintiff
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
, 2004.
'"'
~""~,. ~ "'i:
.
~'~;"w Lh~~:
EXHIBIT "A"
~ ;~~-i 1.-,.!lIlifill'iLl_-'k,",~;i:ith~~&"_"1ii
.
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA, '
CIVIL DIVISION
,Plaintiff,
NO.,:01-3821 Civil Term
, vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
}
) SS:
)
COUNTY OF ALLEGHENY
washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of
America, Plaintiff in the'above action, sets forth as of the date the
Praecipe for the Writ of 'Execution was filed the following inf~rrnatiGR
concerning the real property of Kiran Kumar Dandapat, located at 852
Erford Road, East Pennsboro, Pennsylvania 17011, and is more fully'
described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KlRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
""" - _~ ~, ~.I.. .......,~~_~~,~,~",~"""_""_;,;
.
~.
1. The name and address of the owner or reputed owner:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
2. The name and address of the defendant in the j~dgment:
kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
3. The name and last known address of every j'udgment creditor whose
judgment is a record lien on the real property to be sold:.
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Travelers Bank
11436 Cronhill Driv~
Owings Mills, MD 21117-2285
PNC Mortgage Corp.
of America
539 South Fourth Street
Louisville, KY 40202-2531
East pennsboro Township
98 South Enola Drive
Enola, PA 17025-2796
Commonwealth of PA
Department of Welfare
P. o. Box 2675
Harrisburg, PA 17105
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Dauphin Deposit Bank.
and Trust Company
PO Box 4800
Harrisburg, PA 17111-0800
5. The name and address of every other person who has any record lien
on the property:
PA Department of Revenue
Bureau of Individual Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
Domestic Relations
Office
P. o. Box 320
Carlisle, PA 17013
.__'_-c,,~.~_..-~'""~_J..'~-~"~
j ,
'-'"~~
-l;~~c__'" !i!:''Ill1i>''~~f~~A.
.
.
Tax Assessment Office
CumbeLland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
6. The name and address of every other person who has any record
interest in the property and whose interest may be affected by the
salE;!:
None
7. The name and address of every
knowledge who has any interest in
by the sale:
other person whom the plaintiff has
the property which may be affected .
Tenant (s) or
Current Occupant (s)
852 Erford Road
East Pennsboro, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to
authorities. '
Dated:
C;/-I/b.J
BY:
~aL~ t2-LC'(~
Kristine M. Anthou, Esquire
Attorney for Plaintiff
SWORN to ~~scribed
me this ~day 05;
. -- -~ -. -'-'~~-,--- .
Notary
Nots.r;a\ b-t";~~ I
. Joanne M. Wehner, Notary Public !
City of Pittsburgh, Allegheny County _I
My Commission Expires June 19, 200~
Member, pennsylvaniaAssociationotNotaries
-
G'RENEN ,,"- p'''::~r:'~ P.t;' ~:f
ONE GATE\\'.W C:' .1,I1INE WESlh..
A 15222"-. ,
'"
-'}'.
U.S. POSTAL SERVICE CERTIFICATE OF MAlUNG
MAY BE UseD FOR OOMEsne AND lNTERN~TIONAL MAlI.., DOE1- NOT "
PROVIDE FOR INSURANCE-POSTMASTER i - _.. ",
ReoeIved From:
~
.-
Lll
.
-.J::J
P
III
.. 01- ~ . " ,,-
.
.
U.S. POSTAL SERVICE
-11-131
One piece of ordinary mall addressed to:
Eos.\- ~t:Js\.~~LL\"1.. ~
~~u.:t1\ ~...,,",\Q_:btl~ ,
Stl -.!!l \q.. P-A- \'1odS - d-"""fU::,
H!~
C) i1W
III ~ tl P
...-J ~C
* >I- ,. .. .. '" .. .. ,. ~ .. ~ .'
PS Form 3817, January 2001
ReceiVed From:
GRENEll & BlRSle. p.c. SIf
EWAY CE!oITER, NINE WE
pm~B\!R()H, PA 15 lit
>I- .;,... '" ll-"" . '" ^ """
U.S. POSTAL SERVICE CERTIFICATE O.F MAILING
MAY BE USED fOR DOMESTIC AND IN'TERt-lATlONAl MAlL. Does 1II0T
PROVlOE FOR INSURANCE-POSTMASTER "
One piece of ordinary mail addressed to:
~~~
p.\-. \/'71 os..
c::s
.-
-~-
~
-
~ j
= ~. "=~,""'-KiI,I;,,"'k-,__j
__M..--'-'_
. U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY, BE USED FOR DOMESTIC
PROVIDE FOR INSURANCE-PO~l~~~NATIONAl MAll,.DOES NOT
ReceIved From:
GRENEN & BIRSIC, P.e..
~l (' ~ NINE WES1f
pmSBUiiGH, PA 15222
., /'-13 I
One piece of ordinary mall addressed to~
~-bL.~da:hm:s. ~
fO~3J.o
(\ {)..{ tL ~ tM- 1"10 13
C:.\.:~
:,:;1
[llll
>f-.. ".."".. ~ .
PS Form 3817, January 2001
.
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
.,. MAY BE USED FOR Q,OMESTlC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
, Racaived From:
GRENEN & B/RSIC, P.e.
, . ER, NINE WESIf
PirT' " ~
tHal
One piece of ordinary mall addressed to:
III
~
C.
III
PS Form 3817, January 2001
>1- ~ ". :>I- .. ~ ,;. <- -:- ~ .. " ,
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-PQSTMASTER
GRENEN & BIRSIC, P.e.
ONE GATEWAY CENTER, NINE WESIf
pmSaURGH PA 15222
".
Received From:
1H.s1
One piece of ordinary mall addressed to:
Bot-l..
~sr~1-1
-fOBoJC4 eoe
\t~ ~ Din-moo
PS Form 3817, January 2001 <3>
,:t'd
ll!
.
-..D
; ~f~i
'ili'
i i j ~
=
;iJi
~ 1 } .-1\F
* .. ", ,., '" " ,. ~ , ~ . . ,
~
~ ~
-=A"""",~,t'r
U.S. POSTAL SERVICE
MAY BE USED FOR CERTIFICATE OF MAILING
PROVIDE FOR IN$U~~rJ,%~~t~~NATlONAl MAil, DOes NO'T
Received Fro~:
instamp's
tar anc:(
postm'l!Ji. of I
~rforffi nl
. ~ OJ i
(:) C' !
-j) ,
i l-I~
GRENEN & BIRSIC, P.c.
:i ceNTER, I\I1IE WESll
PITTSBURGH, PA
o .
ne piece of ordinary maJJ addressed to:
\~ ~ ~ ..'
~~, \~ ~JlIn-21
PSForm3817 J ~LA ,ih,
, anuary 2001
':';(2
,;,,'"
.....0 :tt,ll
c: :!iil
Iii .'[lii
.. ~ ~~:-:-_J fU
.
.
GRENEN . BIRSIC, P .C.
- EWESll
PITTSBURGH, PA 15222
U.S~'POSTAL SERVICE CERTIFICATE OF MAILING
-; MAY BE USED FOR DOMEST
PROVIDE FOR INSURANCE)~~~~~NATlONAL MAI'L, DOES NOT
ReCeived From:
One piece of ordinary mail addressed to:
-rei :\-G.<1l
~ ~Aft,.J..'Rca!
"Cts,r ~...:.l:an() ~ nOli
c
1:1(
P$ Form 3817, January 2001
- ,,"'.... -!- ! ~
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNAilONAL MA.\l, DOES NOT
PROVIDE FOR, INSURANCE_POSTMASTER
Received F>Om' G!lENEN' BIRSIC, P.c.
ONE r,ATEV'AY CEMTER,I\I1IEWESll
-"
"H~I
Dna pIeCe Q{ o<<1iMrY mail addressed to:
* "- >!- ~ " ". ~ ?
il.!~I1iMi\\~~t:$,~~,.~j~"!,t;Ci;!rt" ",~-, "':_llil"'-'!b;.,,1!;'>",,~,;,-,<:, ;'>:c,"""
>>~\,,,,,,'j>#iiW""!OWiWI~$bao~~ll&o,~;Ml;A,Ii~~M4J,I,,,",*,_~~'~~
-A AL,~J;;~J,:r~~;.~J,';m)_,W~-;':;UL,.~')L,.4.'-.!fl~:--l!J:",,>,t-,,~;~,'R'~~"_<;_XN,'-, ,~, ,,",,-, __,",~, "~_ .'>~< - "-.~/-,
."'"
,..,
CO
:J2
...,
rr"'
OJ
,
U'
o
C'
-~
~-
...,.,1.....'
'~:~l:
C/)
19
J::'C:
~
JIlI!ll!;l,
o
...,
.....
"r::
fn~
::gi"'1~.
o
";i. ,
~'"n
~5
Om
000\
~
-0
:Jt
~
o
0'
"';
,.~ - ~~, "'...~-
.-
,~ J Ji
,'<
. ...i:Iii'-~ ^' ~~il::~~-
"-
.
,- -'"
SHERIFF'S SALE DATE: MARCH 03, 2004
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
F/K/A PNC MORTGAGE CORP.
OF AMERICA,
CIVIL DIVISION
Plaintiff,
No.: 01-3821- Civil Term
ISSUE NUMBER:
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
TYPE OF PLEADING:
Pa. R.C.P. RULE 3129.2(c)
AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
CODE -
FILED ON BEHALF
OF PLAINTIFF: Washington
Mutual Home Loans, f/k/a
PNC Mortgage Corp. of America
COUNSEL OF RECORD
FOR THIS PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. # 77991
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
.,
I <
oJ ,,,,-'Co,
, 'II Tnti'~)~'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
F/K/A PNC MORTGAGE CORP.
OF AMERICA,
CIVIL DIVISION
Plaintiff,
No.: 01-3821- Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
Kristine M. Anthou, Attorney for Plaintiff, Washington Mutual Home
Loans, f/k/a PNC Mortgage Corp. of America, being duly sworn according
to law deposes and makes the following Affidavit regarding service of
Plaintiff's notice of the sale of real property in this matter on
February 03, 2004 as follows:
1. Kiran Kumar Dandapat is the owner of the real property and
has not entered an appearance of record.
2. On August 17, 2001, this court entered an order authorizing
Plaintiff to serve the Defendant by posting the property and by Certified
Mail, return receipt requested and First Class, U. S. Mail, postage
prepaid to the address set forth in the Order, with service to be valid
upon posting and mailing. A true and correct copy of the Order is marked
as Exhibit "A" attached hereto and made a part hereof.
h
, "'~~~
,
~MIW&,j'_:
3. Pursuant to the Order and Pa R.C.P. 3129.2 (C) on September
15, 2003, the undersigned counsel served the Defendant with a true and
correct copy of Plaintiff's notice of the sale of real property by
Certified mail, return receipt requested and First Class U. S. Mail,
postage prepaid, addressed to Kiran Kumar Dandapat at 852 Erford Road,
East pennsboro, PA 17011. True and correct copies of U.S. Service Postal
Forms 3800 and 3817, evidencing service by Certified mail, return receipt
requested and First Class U.S. Mail, postage prepaid, on the identified
Defendant, are marked Exhibit nBn, attached hereto and made a part
hereof.
4. On or about November 18, 2003, the Sheriff of Cumberland
County posted the property located at 852 Erford Road, East Pennsboro,
PA 17011. A true and correct copy of the Affidavit of Posting from the
Sheriff of Cumberland County is marked Exhibit "C", attached hereto and
made a part hereof.
'lIi~fJh
I verify that the facts contained in this Affidavit are true and
correct based upon my personal knowledge, information, and belief.
BY:
SWORN TO AND SUBSCRIBED BEFORE ME
THIS ~. DAY OF r--tbwOJU..-..{
~ 01 vd ~olJv1. b- .
~' Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Gerald L. Potter, Jr., Notary Public
Oty Of Pittsburgh, Allegheny County
My Commission Expires Dec. 10,2007
Member, Pennsylvania Association Of Notaries
GREN~N & BIRSIC, P.C.
~uOff1w-ilh-
Kris 'n M. Anthou, Esquire
Attorneys for Plaintiff
Nine West, One Gateway Center
Pittsburgh, PA 15222
(412) 281-7650
, 2004.
~""'-'.~A:
EXHIBIT "A"
"-~
~,,'"
.-~".
AUG 1 ,-_
lvt\
\..
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME LOANS,
INC, f/k/a PNC MORTGAGE CORP. OF
AMERICA,
CIVIL DIVISION
No.: 01-3821 Civil Term
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
ORDER OF COURT
AND NOW, to wit, this /112f"
f}'<r.J-
.2001, upon
day of
consideration of the within Motion for 'Service of the Complaint in Mortgage Foreclosure
Pursuant to Special Order'of Court, it is hereby ORDERED, ADJUDGED and DECREED that
the Sheriff of Cumberland County is hereby directed to serve Defendant, Kiran Kumar
Dandapat with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure by
posting the property at 8S2 Erford Road, East Pennsboro, PA 17011 and Plaintiff is permitted
to serve Defendant, Kiran Kumar Dandapat, by Certified Mail, return receipt requested and
First Class U.S. Mail, postage pre-paid at 852 friord Road, East Pennsboro, PA 17011. Service
on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing
by the Plaintiff.
BY THE COURT:
TRUE COPY FROM RECORD
Testimony whereof, I here unto set my hand
Id the s~l(lf said Court at Carlisle. Pa.
liS 11, ~ day ?J.D~ ;;;;
C [;4.1: .
I '
ProthunCltarf
Is/ [ir 13. ~.
I.
.
'.: i- ,r. .~, ".~i.,,"l ",,'r.:-::'. :,- .- :,
. .~ ,.., ~, ;'.
. "l ;.<.
. -.- -....
.. ,: ..--::.'"
. . . ~_, ~ !{!'.t~~:,~~'-.'t'!: ':
j ~ '"
~
.
'J'---'<M';~'l'
EXHIBIT "B"
---
".
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
Received From:
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAll. DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
GR~NEN. BIRSIC, P.c.
~ i '. F. ...-,.~
pmSBURGH, PA 15222
One piece of ordinary mall addressed to:
,1-/3
_.Kl1U.-u 11~ ~MA-T
~s.~,&~ KO~
?eu:.:t- ~!.l::"lC::' 'PT\- noli
.
PS F2rm 3817, January 2001
I
,
,
'I
l..u
pr
'm
!<O
I
1m
IF'-
J<O
;<0
J.:r
10
ig
!~
/2
.F'-
I
~ ^ ,
_< I. " ,11 '",,-:",
~~
I '
I ,!
1 ~\
\ il
hi
111
------'
,.J:)
c::..
I"~
"
~ i,
;;- " ~ ~ ~" ,.
.
o F'F j CI Ii. l~"' .~"~"M'
Postage $ 9
. j
-..
1"""
.
Ben! · ~a.f\U
&;.;;(Apr19ii'-.--.......-........c..... 11-,
O1'POlJox'-' 0.,. \ ~e;-l'--...--......--........
''IU. D~J.- ___u_~___
citj.-;-siiJe;z;p;.4-._.---._--...~..~--""".._ ..._._..___
"<"-">T ~lJriO ifA"--i::;jSL'---".'"
Certffied Fee
A""'~Fee
(Endol'Slm18nt Required)
Restritted DeI!VeJy Fee
(~Aequlred)
TolaJ Postage & Fees $
~- " ,- ...:-
EXHIBIT "e"
~ ',j,
.............~,i1
,~
~-! ,', .~o$l~;,"!
.
.
Washington Mutual Home Loans
f/kIa PNC Mortgage Corp.. of America
VS
Kiran Kumar Dandapat
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-3821 Civil Term
Ronald Kerr, DeputySheriff, who being duly sworn according to law, states that
on November 18, 2003 at 5:11 o'clock PM, he served a true copy of the within Real
Estate Writ, Notice and Description, in the above entitled action, upon the within named
defendants, to wit: Kiran Kumar Dandapat, by posting the premises located at 852 Erford
Road, Camp Hill,P A pursuant to order of court, according to law.
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that
on January 12, 2004 at 2:42 o'clock P.M., he posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in.the above' entitled action, upon the property of
Kiran Kumar Dandapat located at 852 Erford Road,.Camp Hill, Pennsylvania, according
to law. "
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate'Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendant, to wit: Kiran Kumar Dandapat, by regular mail to his last known address of
852 Erford Road, Camp Hill, P A 17011. This letter was,mailed under the date of January
9,2004 and returned to the Sheriff's Office on January 20,2004 as unclaimed.
Sworn and subscribed to before me
This _ day of
~
R. Thomas Kline,d"
J'~
. w
BY . .
Real Estat eputy
2004, A.D.
Prothonotary
i,
I";. .,_J
:l1#"~""ma~)i~;;,tl)'l.J@ojl:h""J;,_."rt'\"",I~mi;I<<b;';-""''''''!t''~b',_&,;"",,'-_C"" c-.,'.'
.L-"O' _--'__';,!";''''';J""",~~~....!it~~~;~';;;,rn:W"#-,",,,-;@',;W,Ilj_~-tllill...iSli~i'-
;~ ,L-; _S-,)~~~\,lI~n~:..,~JJ;_l-1."i,)H,[~MJl,~~J"",,;C"'\~:U:~)J)"L",J,J~":;!.;~o':~<:"lQ ,JJ,..", ,:~I,JIIJJ~.~ "_"0"'" ~ ~.,^, ,_~,. C
"-",'-~-'
,,~*~ .
~~~~
()
c:
'g:
rf'~ ':~?,
~fl~::
-< ...
r'::Ci
~~~~
Z
~
.K>
=
=
...-
.."
J'T1
CO
I
(.J'\
"
3
r;-?
<:::)
0'
.....~'iibl!!li;il--~ .,
-'t
.
o
....,
'::r!
--:!l
rnr-
:B~
~<;:(.
O::rl
o
Zm
S
~
1M
~",'~' =~....., """""~~
i' ,.~
,.
......-"'k~"lIi,
,
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND } SS:
I, Robert P. Ziegler. Recorder of Deeds in and for said County and State do hereby certify that
the Sheriffs Deed in which Land Holding LLC is the grantee the same having been sold to said grantee
on the 3rd day of March A.D., 2004, under and by virtue of a writ Execution issued on the 9th day of
~,A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number
3821, at the suit of Washington Mutual HOmes Loans fka PNC Mtg Corp of America against Kiran
Kumar Dandapat is dilly recorded in Sheriffs Deed Book No. 262, Page 763.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this ;;3~
day of
, A.D2004
corder of Deeds
Cumberland CounIY, C8rI1sI8. PA
E>ipres the FirBt Monday of Jan. 2008
Jill,
,r'" ~ ~.~~~,
'-~,,"l'>,',i
"
Washington Mutual Home Loans
f/k/a PNC Mortgage Corp. of America
VS
Kiran Kumar Dandapat
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-3821 Civil Term
Ronald Kerr, Deputy Sheriff, who being duly sworn according to law, states that
on November 18,2003 at 5:11 o'clock PM, he served a true copy of the within Real
Estate Writ, Notice and Description, in the above entitled action, upon the within named
defendants, to wit: Kiran Kumar Dandapat, by posting the premises located at 852 Erford
Road, Camp Hill, P A pursuant to order of court, according to law.
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that
on January 12, 2004 at 2:42 o'clock P.M., he posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the abOve entitled action, upon the property of
Kiran Kumar Dandapat located at 852 Erford Road, Camp Hill, Pennsylvania, according
to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the al:)ove Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency ofthe action to the within named
defendant, to wit: Kiran Kumar Dandapat, by regular mail to his last known address of
852 Erford Road, Camp Hill, PA 17011. This letter was mailed under the date ofJanuary
9,2004 and returned to the Sheriff's Office on January 20,2004 as unclaimed.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on March 3, 2004 at 10:00 o'clock A.M. He sold the same for the
sum of$1.00 to Attorney Kristine Anthou for Land Holding, LLC. It being the highest
bid and best price received for the same, Land Holding, LLC of Two PNC Plaza, 19th
Floor, 620 Liberty Ave., Pittsburgh, PA 15222, being the buyers in this execution, paid to
SheriffR. Thomas Kline the sum of $948.22, it being costs.
Sheriff's Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Levy
Surcharge
$30.00
18.59
15.00
15.00
30.00
10.00
1.00
20.70
15.00
20.00
.-.
'~ ~11W'-'i1M!!&_:b"i'
Posting
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
6.00
344.45
328.66
29.32
25.00
39.50
948.22
$
Sworn and subscribed to before me
so~~
This~dayof~ r..J . ..::"'C~~
2004, A.D. q ", (J /Jtc.f;,., ~ Thomas Kline, Sheriff
rolhonotary , BY J{) ~ Srutl,
Real Estat Deputy
c.~
..]olJO
Iv" ./
. U>..../ 'f y:p ~
~ /'190'l3
J_, ,,^, "it"jlll~~",'.,i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaint.iff,
NO. :01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
)
) SS:
)
COUNTY OF ALLEGHENY
Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of
America, Plaintiff in the'above action, sets forth as of the date the
Praecipe for the writ of Execution was filed the following information
concerning the real property of Kiran Kumar Dandapat, located at 852
Erford Road, East Pennsboro, Pennsylvania 17011, and is more fully
described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
..
~lll;;j,
1. The name and address of the owner or reputed owner:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
2. The name and address of the defendant in the judgment:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
3. The name and last known address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Travelers Bank
11436 Cronhill Drive
Owings Mills, MD 21117-2285
PNC Mortgage Corp.
of Ameri,ca
539 South Fourth Street
Louisville, KY ,40202-2531
East pennsboro Township
98 South Enola Drive
Enola, PA 17025-2796
Commonwealth of PA
Department of Welfare
P. O. Box 2675
Harrisburg, PA 17105
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Dauphin Deposit Bank
and Trust Company
PO Box 4800
Harrisburg, PA 17111-0800
5. The name and address of every other person who has any record lien
on the property:
PA Department of Revenue
Bureau of Individual Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
Domestic Relations
Office
P. O. Box 320
Carlisle, PA 17013
~~-""""
, ~'
. ~
.,1. _
'"~t<,~
Tax Assessment Office
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
6. The name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
None
7. The 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:
Tenant (s) or
Current Occupant (s)
852 Erford Road
East Pennsboro, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to
authorities. '
Dated:
q/~C3
BY:
/~oaft.l1X a.,LL'(~
Kristine M. Anthou, Esquire
Attorney for Plaintiff
SWORN to ~.s bscribed ~e 4
me this day of/ /'
/,/' /
!Y
-Notary
h~ot9_;':a: 0U:;i!
Joanne M. Weh:1€r, No'lary Public
City 01 Pittsb",gh, Allegheny Coun:y _
My Commisslon Expires June 19, 200~
Me,nber, Pennsy\va.ni2~ Association ot Notaries
-
""~,
~~ ~.~
, ~,
~"tAA%~~
I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff ,
NO.:01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: KIRAN KUMAR DANDAPAT
852 Erford Road
East Pennsboro, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out
of the Court of Common Pleas of Cumberland, County, Pennsylvania, a~d to
the Sheriff of Cumberland County, directed, there will be exposed to
Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COMMISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COUR.THOUSE SQUARE
CARLISLE, PENNSYLVANIA 17103
on March 03, 2004, at 10:00 A.M., the following described real estate,
of which Kiran Kumar Dandapat is the owner or reputed owner:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
"~ " ~--'<' .
,
. .
The said Writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
at Execution Number 01-3821 Civil Term in the amount of $85,818.59.
Claims against the property must be filed with the Sheriff before
the above sale date.
Claims to proceeds must be made with the Office of the Sheriff
before distribution.
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must
be filed with the Office of the Sheri.ff no later than ten (10) days from
the date when Schedule of Distribution is filed in the Office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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
ADVICE.
Lawyer Referral Service .
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717)249-3166
(800)990-9108
~ "
~-:_'
'-~-
---,'--
" '.
-,~,~ "",~~
_~i#i'
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the executio~.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after service of the Complaint for Mortqaqe Foreclosure and Notice to'
Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid'
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was en~ered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may ~lsohave the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE
ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
GRENEN & BIRSIC, P.C.
By:
l~CJL (:'l/{NU ILex C7-
Kristine M. Anthou, Esquire
Attorney for Plaintiff
\. .
.
l_ ~,'"'"
-,-,-~j
~-...;,,- - "O""-~-'"r'''
~i_';
, .....,
"
'..,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL bIVISION
Plaintiff,
NO. :01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro,
Cumberland County, pennsylvania, more particularly bounded and described
as follows, to wit:
BEGINNING at a point on Erford Road at the dividing line between Lots
Nos. 16 and 16(x) on the hereinafter mentioned Plan of Lots; thence along
said Erford Road South 89 degrees 50 minutes East 37.5 feet to a point
at the line dividing Lots Nos. 16{x) and 17; thence along said dividing
line South 0 degrees 10 mlnutes West 150 feet to a point; thence North
89 degrees SO minutes West 37.5 feet to a point; thence North 89 degrees
50 minutes West 37.5 feet to the line Q~yjd~gLots Nos. 16{s) and 1&,
thence along said dividing line North 0 degrees'10 minutes East 150 feel:
to the point of BEGINNING.
BEING Lot No. 16(x) on Plan No. 19 of Ridley Park as recorded in the
Cumberland County Recorder's Office in Plan Book 22, Page 64.
HAVING thereon erected a dwelling house kno~ and numbered as 852 Erford
Road.
UNDER AND SUBJECT to the Easement of a sanitary sewer line as shown on
the aforesaid plan.
TOGETHER with all and singular, the tenements, hereditaments and
appurtenances to the same, belonging or in any way appertaining, and the
reversion and reversions, remainder and remainders, rents, issues, and
profits thereof; And Also, all the estate, right, title, interest,
property, claim and demand whatsoever, both in law and equity, of the
said Parties of the First part, of, in, to or out of the said premises,
and every part and parcel thereof.
~.~-
. .
-
~: "
_w _~,.
"'-"
'['~~
i..... f-
'.
BEING the same premises which Pin Hui Kuo and Kuei Ying Kuo (afkfa Kuei
Hui KuO) , his wife, by deed dated March 29, 1996 and recorded on April
1, 1996 in the Office of the Recorder of Deeds for Cumberland County.in
Deed Book Volume 136, Page 965, granted and conveyed unto Kiran Kumar
Dandapat.
By:
GRENEN & BIRSIC, P.C.
'~/-L..2 [, I~L1' {lLCIf. 6',-
K .~ne M./Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine,West
Pittsburgh, PA 15222
(412) 281-7650
DBV
Page
Tax Parcel No.
136
965
09-17-1044-060
----_7
-'\
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-3821 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS, F/K/A
PNC MORTGAGE CORP. OF AMERICA, Plaintiff (s)
From KIRAN KUMAR DANDAPAT
(I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoioed from
payiog any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposiogthereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoioed as above stated.
Amount Due $73,592.67
Interest $12,225.92
Ally's Comm %
Ally Paid $1827.48
PlaiotiffPaid
Date: SEPTEMBER 9, 2003
L.L.
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
prothon~ 8 ~
-...BY: "__I _. i7.JLJ
Deputy
REQUESTING PARTY:
Name KRISTINE M. ANTHOU, ESQUIRE
Address: ONE GATEWAY CENTER, NINE WEST
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991
!L~",~.,I"'M'U~~'''~,\:";i"""''''''''''f"'''''''",~"",,,,,,,,,,,,,~"-~~,,,,-,-, ,. "
"'-'""o;,__.,",.,~",~"""__,,,,"""~r.,,,,,,,..,,,,_,",,,,,,,,,,,,,~,,_,~,_~~~_'--~,,----------------~
Real Estate Sale # 07
On November 03,2003 the sherifflevied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, P A
Known and numbered as 852 Erford Road,
Camp Hill, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: November 03, 2003
By: Jbd.u,SnU.t:h
Real E;tale Deputy
(jil.. .....
~.
c::::3
@
~
'''I',lb''l "'''''3d
'f jP; 'f f\ l,;:)!"I rl
~ .". --, '
'\"),':'"
EO. Hd 61 8 II d3S
A1Hnt~~', >~;~.; id.JIJWnO
lIl111HHS 3h, .:10 3:/1.:1"0
;_".J"~,;.J9;ll.~\J.i~".J!(\t)I'if)JJ. ,L~Tl~).;J)l.J.~-"J .rm:-),lUJIlJOL Jl ,'!h "~~" .>,,-r"_,-,~,. ,,,. ~f, ',- ~,
'" ,~, '''^''''_'."_"' '.""" __, __<C_'._.. , _~". 0 .~,'
.J.~'~j"':~I!'i'~' ~ ,
1~'
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
,-,
~-"',- "~'~":"I
Proof of Publication
UnderAct No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Michael Morrow, being duly sworn according to law, deposes and says:
That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth 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 The Patriot-News and~
Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, In the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
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 20th and 27th day(s) of January and the
3rd day(s) of February 2004. That neither he nor said Company is Interested in the subject matter of said printed
nolice or adverlising, and that all of the allegations of lhis slalement 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 duiy recorded In
the office for the Recording of Deeds in and for said County of Dauph' In Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
S ALE #7
Sworn to and subscribed befor
Notarial Seal
Teny L. Russell, Notary Public
OtyOfHanisburg,DauphinCounly NO 7I.RY PUBLIC
My Commission Expires June 6, 2006 M .. . J 6 2006
. ., Of Notaries Y commission expires une ,
Member. Pennsyl'lanla_
CUMBERlAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
t'
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates
Total
$
328.66
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sundav 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....................................................................
R\;JO,l.\;l>i'AU1.S!<tJ;:Na. t
Wrll No.2001-3lJ21
CMITe.m
Wuhlngton Mutual
Hortle, Loans.
tMe Pl'IC ,",al'lgelle Corp.
of'Amerlca
Ve
:19..an Kumar Dandapal
AI:ljc Kristine Al)lhQu
Ue:,CRIPTlON
M..l11iAT t:.~Bj{rAt~::tt'1i~h;r1.and.s.illilIte, in
~"t~''I~~lI\p cl', .fi~tI>\ ,-fr~\l!l\.b<J!1J" {)nnhe.(lattrl
{';:Il!l!IY. Peill1~yJ\r;mtl, IJli:'~~ p;1rticularl,y, ixJ~Itl.de.rl
Il:!:!ii dC.<;o.~.l1~d a~ t()ll(l\l,~i~ Ii,) w,:d:,
... RJ2'(.\\NN1NG: al,<\~fur{jlt~.t9,(1:/ .R0l~1 ~l, lrw
:,::iijq~ugJllj.e,J)(hWccll.t.p,ts"N[I~ :l,O,aild .16 (:-'} on
. Il'i'.11r'reWi:ft~r..rlJe11l1(,meiI Plan (11 Lots: fliel)A~~
,alOO~,_,\l;\.\l;t 'E-riOfd,RlJad Sfiutli _&9, de,~,~ ~J
.l't\iflUlS;';'O,f&.~,~1:-}?~~,fret.,1D i1,f,KlJvl ,l!t Jhr. I'inr
dlVidhlg 1.{lts).j~0l',J6J(I,,:r04, 11~Awnt-": ?JOtiE
;,", ~~__jjh,.rding. Ime SOlltn,'_ :{j~' l.d Ilucmlk~
::'wr~~t,J,5!): tee! lill1 PO[n\~ thence: NQl1b iN dept'~~~
.' :~~Wminutes V,'rn :n..; t~{to;ll,.,int,tb,eun NoM
::::,:,:~:',d,ei!.r~~.~ ::il, rrUtf1Jte\ Wt:M J7.,5 !l:lil. jq a jX\ltlt~
,:-:-::',t.ijWti ,Nhrth '89),eetti:~,:;ifr mi~'Llti;,~,~~~$f' '!//:}!-
: :'~'lQ,~e llrie d!\'l.l~.ng).,()1,:> ,N()!,,:,l~,hi ~l.1d"l!3;
'>:Jlj:~?lf,mg,,~~i:I.,(l\\:idjJ)g)inr.,N,Orlh(J1legr(~~!; 10
. 'jitUitii6-":}1iBt,:::'S'l::}f.f,-J; }Q, -:~'" t:~( ,'yr
>mrot\ltN1NG".- ,~"",:,:., '':'''''>::~
: :lif.1Nr; ,1.,QX"No: 16J:x},rm f'fau"NiJ:)9: QJ:'
"::~le-v:J';iJl:At: ,~lJ'd:ed ,in, Am:, '{.'1,Jlt)):\t'.rlitJJd
r::: . ~,:&\J"-,,11 :R~:,:jj\l_~,t'!;.Q~lce::1n-,l?lan :Boo,k 1.,~~ Ji'.Jt;l;"
li[
.:,..-,,:,:,:,:1tA\:'I.~q-ltJi::#.it~,r.~::i(:dW(11j~ i1f,ll,l~'
:-- :,A<it1QW((.at)l.l-,IJ.ltti;lbe~,i ~f~Jl:32'&:Ihi:d, ,RQad,
."..-__.-:,:.-"lJ~pr:R.i~~n. SDj3JE(1)o lhe E;l~~tDf
:':',:'rr'~1t1jt;lt>",~iit,tlne':?~: ~l~ll,r"fll,lb,e :,W\1i~.~\tt
:",:,,'ui:ltrt,,:_ ",.,-,,':' ":' .- ',:'-:,:,' :'",':
',.-:,,: ',::,::: :,,_.-,rpG1ITITh:lt :)~il'tw], a!1(sitigi~aj; ':the,
':":'.,:I~c,ti.t~'-,Jf(~re,djramL~,~"I\!ld,,apvtniejla.uC'~' to
":~, W!,~~":IlerQnglIlt,(if"m,JUtY,,w:::i:t:j!j,'!.~'l1ahllng,
",~tfi~41P~:
i::':":,':~.i!i,:'~~:'<Je~,::~~~~f;'::,~:::Jif:l~W':,::,~i!r':'
<:,:,~~.{jf~--ll&kl,:Pamf:~,,{ifi'i~ Ht>;l pJ,rt~.M,:,J~\
!,:..:::tir~.:rJUr (d,lhl!"sal{1,tm',mJst:~. ana eveq.-;liitt:iriit
:~,thereof. ,",' ," ,:~':,':,:,,:,:
.....,,:--:,ltHNO the.:i-alre .(l1'em15e~ 'k'bicU Pi,"- Hm Knu .
~i1d Km::iYi.CiM" KI.l(l. fa,lkia K!l!~f Hui KlltiL hi's
.'iilfe, bJd!:t:oi dated Yard 29,. t Y% Ilnd I'e.cGrded
,)JlApril L .l99t.,irllb.~,iJl\l'e,.:,.-\\hd\\:o.:\)Trlel'cf
peed", tm CtlmberlalJ.u ,Co~mty _ in, fJee4 Book
~lll~~, J1~" ~k~ ,.i}6$. ,~lteJ:I "na, ~1tlw"~d
':I:ltl.ti.ltit.m,:Klli:l'lar \11nii~,., ::, :::' ' ~:
iJJ,lV: ,1.11\ fk..er %.k"'F,\X J"ARCEL NO.; ,00-
J7.IU44CiW. .
------' ,- - -"-
,
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. 1.1784
STATEOFPENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Jouma1, of the County and
State aforesai,o, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the officia11egal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues ofthe said Cumberland Law
Journal on the following dates,
VlZ:
JA~PJRY 16,23,30,2004
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Joumal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
SWORN TO AND SUBSCRIBED before me this
30 day of JANUPJRY 2004
NorAR L SEAL .
LOIS E. SNYDER, Notary PubliC
Carlisle BOlO, cumberland County
My Commis$ion Expires March 5. 2005
1J
,',
".'<c","",'
. .
--~
, --" ~~~
REAL ESTATE SALE NO.7
Writ No. 2001-3821 Civil
Washington Mutual Home Loans,
f/k/a PNC Mortgage Corp.
of Ameri'ca
VS.
Kiran Kumar Dandapat
Atty.: Kristine Anthou
LONG FORM DESCRIPTION
ALL TIlAT CERTAIN tract of land
situate in the Township of East
Pennsboro, Cumberland County,
Pennsylvania, more particularly
bounded and described as follows,
to wit:
BEGINNING at a point on Erford
Road at the dividing line between
Lots Nos. 16 and 16(x) on the here-
inafter mentioned Plan ',of Lots;
thence along said Erford Road
South 89 degrees 50 minutes East
37.5 feet to a point at the line divid-
ing Lots Nos. 16(x) and 17; thence
along said dividing line South 0 de-
grees 10 minutes West 150 feet to
a point; thence North 89 degrees
50 minutes West 37.5 feet to a
point; thence North 89 degrees 50
minutes West 37.5 feet to the line
dividing Lots Nos. l6(s) and 16:
thence along said dividing line North
o degrees 10 minutes East 150 feet
to the point of BEGINNING.
BEING Lot No. 16(x) on Plan No.
19 of Ridley Park as recorded in
the Cumberland Cormty Recorder's
Office in Plan Book 22. Page 64.
HAVING thereon erected a dwell-
ing house known and numbered as
852 Erford Road.
UNDER AND SUBJECT to the
Easement of a sanitary sewer line
as shown on the aforesaid plan.
TOGETHER with all and sIngu-
lar, the tenements, hereditaments
and appurtenances to -Lhe same,
belonging or in any way appertain~
ing, and the reversion and rever-
sions, remainder and remainders,
rents, issues, and profits thereof;
And Also. all the estate, tight, title,
interest, property, claim and de-
mand whatsoever, both in law and
equity, of the said Parties of the
First part, of, in, to or out of the
said premises, and every part and
parcel thereof.
BEING the same premises which
Pin Hui Kuo and Kuei Ying Kuo
(a/k/a Kuei Hui Kuo), his wIfe, by
deed dated March 29, 1996 and re-
corded on April 1. 1996 in the Office
of the Recorder of Deeds for Cum-
berland County in Deed Book Vol-
ume 136, Page 965, granted and con-
veyed unto Kiran Kumar Dancfapat.
DBV 136. Page 965. Tax Parcel
No. 09-17-1044-060.
,,~
-, , ~,l "',
-' ~
L
._' ~~~-
, ,
'c.
.,_'J ",.
L.;~~."
Washington Mutual Home Loans, f/k/a
PNC Mortgage Corp of Anierica
VS
Kiran Kumar Dandapat
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 200l-3821Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Kristine Anthou.
Sheriffs Costs:
Docketing
Poundage
Surcharge
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Posting Handbills
Advertising
Postpone Sale
Posting
Law Journal
Patriot News
Share of Bills
30.00
15.62
20.00
1.00
20.70
1.95
15.00
15.00
15.00
20.00
6.00
344.45
272.53
25.21
$ 802.46 paid by attorney
6/11/03
Sworn and subscribed to before me So Answers:
.., ~ r~r.-t:#~
This ~ day of ,
n' R. Thomas Kline, Sheriff
2003, A.D. ~.l_(2 ~').~, By~J~~
Prothonotary Real Est Deputy
\,~ ~ 4111't
~ 1~110~
~~...'
~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
bOANS; f/k!-aPNf:-MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO. :01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
)
) SS:
)
COUNTY OF ALLEGHENY
Washington Mutual Home Loans, f/k/a PNC Mortgage Corp. of
America, Plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information
concerning the real property of Kiran Kumar Dandapat, located at 852
Erford Road, East Pennsboro, Pennsylvania 17011, and is more fully
described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
-"',
"
, '
"",--=',"",,i
1. The name and address of the owner or reputed owner:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
2. The name and address of the defendant in the judgment:
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
3. The name and last known address of every jUdgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Travelers Bank
11436 Cronhill Drive
Owings Mills, MD 21117-2285
PNC Mortgage Corp.
of America
539 South Fourth Street
Louisville, KY 40202-2531
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025-2796
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Home
Loans, Inc., et al.
Plaintiff
Dauphin Deposit Bank
and Trust Company
PO Box 4800
Harrisburg, PA 17111-0800
5. The name and address of every other person who has any record lien
on the property:
PA Dept. Of Revenue
Bureau of Individual
Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
Domestic Relations
Office
P. O. Box 320
Carlisle, PA 17013
Tax Assessment Office
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
Department of Welfare
Commonwealth of Pennsylvania
P.O. Box 2675
Harrisburg, PA 17105
~"~"wl
6. The name and address of every other person who has any record
interest in the property and whose interest may be affected by the
s-a-le :
None
7. The 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:
Tenant (13) or
Current Occupant (s)
852 Erford Road
East pennsboro, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to
authorities.
Dated:
Jlj..u>/o/
,
BY:
t2"LLt6.-~
M Anthou, Esquire
for Plaintiff
SWORN to and subscribed before
me this ~day of Ale! "P""^()"el~,2002.
G~)\'i ~o 1"":':\ f\~ ,"'-.CaRS)
Notary Public
Notarial se~o\lIry Public
.' A Townsend. Cou~
PatnCla ~. b Allegheny
City of J'j!ts\>UrgE' 'res June 2. 2 3
My eoroouss,on .pl NOUlrlSS
~nsy"'aniaA5soc\alion01
Membllr,r~'
,
..1 '..H
~~ ~iIlJ,;_,,",,'
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO. :01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: KIRAN KUMAR DANDAPAT
852 Erford Road
East pennsboro, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out
of the Court of Common Pleas of Cumberland County, Pennsylvania, and to
the Sheriff of Cumberland County, directed, there will be exposed to
Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COMMISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17103
on March 05, 2003, at 10:00 A.M., the following described real estate,
of which Kiran Kumar Dandapat is the owner or reputed owner:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF KIRAN KUMAR DANDAPAT,
OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING KNOWN AS 852 ERFORD ROAD, EAST PENNSBORO,
PENNSYLVANIA 17011. DEED BOOK VOLUME 136, PAGE 965. TAX PARCEL NUMBER
09-17-1044-060.
. ,
~l
"'>''''''''''''''~''"
The said Writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL HOME
LOANS, f/k/a PNC MORTGAGE
CORP. OF AMERICA,
Plaintiff,
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
at Execution Number 01-3821 Civil Term in the amount of $81,330.30.
Claims against the property must be filed with the Sheriff before
the qbove sale date.
Claims to proceeds must be made with the Office of the Sheriff
before distribution.
Schedule of Distribution will be- filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must
be filed with the Office of the Sheriff no later than ten (10) days from
the date when Schedule of Distribution is filed in the Office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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
ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717)249-3166
(800)990-9108
.1.-0'.
"~ ~ ., .
&~ -,.......""",,-.
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after service of the Complaint for Mortqaqe Foreclosure and Notice to
Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of serVice of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE
ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
GRENEN & BIRSIC, P.C.
By:
M. Anthou, Esquire
for Plaintiff
. "
-
j, ; '~
-"~,', "'>lIII....,i\sJli.,.,,"';:
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL HOME
-:bGANSimf-/-k-l-aJ?NC-MORTGAGE
CORP. OF AMERICA,
CIVIL DIVISION
Plaintiff,
NO. :01-3821 Civil Term
vs.
KIRAN KUMAR DANDAPAT,
Defendant.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro,
Cumberland County, Pennsylvania, more particularly bounded and described
as follows, to wit:
BEGINNING at a point on Erford Road at the dividing line between Lots
Nos. 16 and 16(x) on the hereinafter mentioned Plan of Lots; thence along
said Erford Road South 89 degrees 50 minutes East 37.5 feet to a point
at the line dividing Lots Nos. 16(x) and 17; thence along said dividing
line South 0 degrees 10 minutes West 150 feet to a point; thence North
89 degrees 50 minutes West 37.5 feet to a point; thence North 89 degrees
50 minutes West 37.5 feet to the line dividing Lots Nos. 16(s) and 16;
thence along said dividing line North 0 degrees 10 minutes East 150 feet
to the point of BEGINNING.
BEING Lot No. 16(x) on Plan No. 19 of Ridley Park as recorded in the
Cumberland County Recorder's Office in Plan Book 22, Page 64.
HAVING thereon erected a dwelling house known and numbered as 852 Erford
Road.
UNDER AND SUBJECT to the Easement of a sanitary sewer line as shown on
the aforesaid plan.
TOGETHER with all and singular, the tenements, hereditaments and
appurtenances to the same, belonging or in any way appertaining, and the
reversion and reversions, remainder and remainders, rents, issues, and
profits thereof; And Also, all the estate, right, title, interest,
property, claim and demand whatsoever, both in law and equity, of the
said Parties of the First part, of, in, to or out of the said premises,
and every part and parcel thereof.
.',",
'.'~\'>'~;"''''',"'.I
BEING the same premises which Pin Hui Kuo and Kuei Ying Kuo (a/k/a Kuei
Hui Kuo) , his wife, by deed dated March 29, 1996 and recorded on April
1, 1996 in the Office of the Recorder of Deeds for Cumberland County in
Deed Book Volume 136, Page 965, granted and conveyed unto Kiran Kumar
Dandapa-t.
DBV
Page
'Tax Parcel No.
136
965
09-17-1044-060
By:
GRENEN & BIRSIC, P.C.
CLuL~
K 's 'ne M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
_-'"~,"""_'~. ,. ~__ ._ ~4
~~'~Iil
"~~'i~=';""',~-'--"',;.i~_~
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NOOI-3821 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, ioterest and costs due W ASIDNGTON MUTUAL HOME LOANS f/k/a PNC
MORTGAGE CORP OF AMERICA Plaintiff (s)
From KIRAN KUMAR DANDAPAT 852 ERFORD ROAD, EAST PENNSBORO PA
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of!
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoioed from
paying any debt to or for the account ofthe defendant (s) and from deliveriog any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is fOUlld in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she bas been added as a
garnishee and is enjoioed as above stated.
Amount Due $73,592.67
L.L.
Interest $7,737.63
Ally's Comm %
Ally Paid $1010.02
PlaiotiffPaid
Date: DECEMBER 3, 2002
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
Prothonotary
By: ~a~
Deputy
REQUESTING PARTY:
Name KRISTINE M ANTHOU ESQ
Address: ONE GATEWAY CENTER, 9 WEST, PITTSBURGH PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991
~~_~!lli""t"'1.<'liJ'h'.""c'f _, ;'~""':')',1,",-c~'"~:'c'>!--._',-",,-<,,
_""_"""'.d~""",,,,,.u,,,..!,,,,,'I1;J,irHo;,,ib!~,,,-.j';dJcitJ)I,,,"..M"~''''~",,,,,>?,,w,,-iMlli'.-Si"'"'~'!+:'I-.,,&i.j.r":/1!!\;(~,;\Jii1tijlili$'~~'" "''''''j['~I."''~'''~"
Real Estate Sale # 30
On December 5,2002 the sherifflevied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, P A
known and numbered as 852 Erford Road, Camp Hill,
more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: December 5,2002
By:-J6 olLl ,j}vll~h
Real Estate Deputy
,~ ~,
"< L",._.III!!lIJ
,~.",~--""-)--,,"',~"~,,,~"'~',.,=~---,=~ '~,'" ~,- ~ ~.~,-",'~,",~,~,~
"-"^,, -)
~-
~
~
~
~:
~'ifa"- ~~.~~~~
~~l
~",~I
J$""",~"'f-<>,,,.j
, I
~
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he Is the Ass!.
Controller of The Patriot News Co., a corporation organized and existing under lhe laws of the Commonwealth of
Pennsylvania, wilh 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 The 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 28th day(s) of January and the 4th and
11th day(s) of February 2003. That neither he nor said Company Is Interested In the subject matter of said printed
notice or advertising, and lhat 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
statemenl on behalf of The Patriol-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 subsequenlly duly recorded in
the office for the Recording of Deeds In and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
SALE #30
Sworn to and subsc e
Notarial Seal
Teny L. Russell, Notary Public
City Of Harrisburg, Dauphin County
My commiSSion Expires June 6, 2006
Memller. Pennsylvania AssocIation Of Notaries
My commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
I
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 $
270.78
1.75
272.53
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sundav 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....................................................................
.,j
~R"EALESTATI!~No.:!O --
Writ. No.2I>>1-3l!21
CMIT.""
....',.......-.................... 1)..!l!Q...........in.......'..U... _......,.............H....."""'................
tb8l111,MiI8:PNC MOrtgtiile:
'Cilrp...,Alti!!l'le.o.,...
.'... ,.,'....'..'..,..'.'.,.,."VS,.',.,......,......,.,..'.,.,..,.,.',.
...Kli.hKum.roandilpat
AIfy:Krlslln.Anlhou,
OESCRlPTION .....
. ;\1:1 THAT W.1'AIN tract.JJf1ai1d S.itlU1le' ili'the
TowIljilJlP:' -of Ew PcrJ!!dlill"iI" '('':orit'herland
CoJil'l.ty, 'Penn~-ylwillja~' more '~itiCtilarlr bouoded
,ltJiddes...-riijeq.a.J.)no~.rowit
,BEG~'"'NfNG ili a pdtit OJ[ J..:rt'Ord Ro.1d ,at ,lhe
dfvidingJtne between Lol,\No~, 16 and 16(1) ot!
the bci'eloafrer mentioned Plan.of ,[.~is; lb.ent:-e
'af~nt. '~id E'rlbJ:d',Roiuf Soml 8'J di:gree~ ~i.1
mtritJte.~':F...as.t .37.'$ feel l') a p.lint at L1ll.' line-
:-,f!~idi'ng I.ots, N()oj',16,(x}and 11: th~lice ,liiQng,
';,\,3id dividing fine Sm:!lli D deg,:rces 10 .minute~
\\~$ 150 .feet to a pOint; theoce N(lrth IN d~~
3U,1U1rnllxS 'M;i,{- :n.~. f~ ID, a ,point;, thence
Nllrib &9: de,gms 50 ml,nutes, Wf:,~f 31,,5 [ttt in
IP..eline ,([ivjdihgl.cil~'NQ~ j,{i(~:1 and 16-:, thr.nr..e
'~ong, Mid r.tlviding Une Noith, 0 de.grt'~,~ .! I)
:!!!ilillles: ,East ,H)(j, feel to tlle pnim v,f
:BfJ.JLNNTNG. .
g~lNG l:{)!, t-ia:"f6{x) on Phm,No ,J,9 of Ridley
p-.,irl a~, reroriicil in l1te Cumberland COllJlry
~.ccitdet\ Office in Pl..m.aook 22, p.-~ 64
HAVING, !.hereon e.reclf,d <<, dwcJ11t1g bnuse
,knnwn,llnd' numbered Il6 852 Erfl'td R!Xl{l.
UNPER A.ND SUBJECT 10 the" Ea~efiicnt of a
~Jl;m :,l'Vi'J::, )joe. 1I~ ~hQ1>,'1L on tbe a:forf.~iil'
plan. .
ltXif,1lJER: wiih lll1 iIJld !,..jn~ll!at, Ihe len~ments,
limdlfarnt'nts" ll,nd, 1l1>p1rt,el1~nw.. bJ the, same.
beIDnging Ol' in ari)' I'(d:y' appertain"ll'l8", :;tld 1M
re'Yt"l.1-'ion ,~l!d n....,fisirUl!\.", remainder, ,~IHj
Te<<lillndm. renl'i, i.s!iues;:(ltld ptl)!lrslhereot: Arid
Also"all the e.i-f.are.tightIWe, lntell',st, propcrt)',
claim and demand v;-li:.t!~ver, both in I~\\o and
f.:quiry: blthe' ~iiiI.P-aitie~',l'ijj{f1ri,1 PMl; of, in"
1n',~t' out 01' I.nc s.'ittu pteqtise~, :Jt1d e~--ery Van and
jJllocelfnt'rem
llElNG ,the ,saUlt premi~ which Pin Hoi KilO
mid Kuei \"ins;. ~llO (aIkIa K.uer HUl R'J,v.t), hl~
wit€:, b, dr:el1 d:ated Matt:h,29i 19q{"<l.l'ld Tt~
:tlh AJ;rtl,l" 19% ,i.1t t.lie, Oftj'ce of the RecDrder of
Deed~ fur Cumberland COlUltV }11 Deed 8001:.-
,"'villi.rine, C\6, P~e ~~, granteq and r.1)nvey~
:,tI~!o,KtranKlllI1a+.D;uliiapJ1i,
fi8v; 06 Pll.)le: %5
,;<lm'~G!!:1.N(),ll'l-n.IIJ44_.
-- ,- _" - ',,_0-<__'_ ______.
~ '"
i., (
'~
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 :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Joumal, 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:
JANUARY 31, FEBRUARY 7,14, 2003e
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 ofthe aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
ORN TO AND SUBSCRIBED before me this
14 day of FEBRUARY. 2003
~~
N
LOIS E. SNYDER. Notary PublIc
Carilsle Bcro, Cumberland County
My Comi'ni&sion Ellpires MareIl5. 2005
~~
.~ ,
" ~ ~i..L:~""";
.'-
-
Rl!l& ES'l'A:rE _ NO. 30
Writ No. 2001-3821 Civil
Washington Mutual Home Loans,
f/k/a PNC Mortgage Corp.
of America
vs.
Kiran Kumar Dandapat
AtIy.: Kristine Anthou
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land
sitUate in the Township of East
Pennsboro. Cumberland County,
Pennsylvania. more particularly
bounded and described as follows
to vvit: .
BEGINNING at a point on Erford
Road at the dividing line between
Lots Nos. 16 and 16(K) on the here-
inafter mentioned Plan of Lots:
thence along said Erford Road
South 89 degrees 50 minutes East
37.5 feet to a point at the line divid-
ing Lots Nos~ 16(K) and 17: thence
along said dividing line South 0 de-
grees 10 minutes West 150 feet to
a point; thence North 89 degrees
50 minutes West 37<5 feet to a point;
thence North 89 degrees 50 min-
utes West 37.5 feet to the line divid-
ing Lots Nos. 16[s) and 16: thence
along said dividing line North 0 de~
grees 10 minutes East 150 feet to
the point of BEGiNNING.
BEING Lot No. l6[x) on Plan No.
19 of Ridley Park as recorded in the
Cumberland County Recorder's Of-
fice in Plan Book 22, Page 64.
HAVING thereon erected a dwell-
ing house known and numbered as
852 Erford Road.
UNDER AND SUBJECT to the
Easement of a sanitary sewer line
as shown on the aforesaid plan.
TOGETHER with all and singu-
lar, the tenements. hereditaments
and appurtenances to the same.
belonging or in any way appertain-
ing, and the reversion and rever-
sions, remainder and remainders,
rents, issues. and profits thereof:
And Also. all the estate. right, title,
interest, property, claim and de-
mand whatsoever. both in law and
equity, of the said Parties of the Frrst
part, of. in, to or out of the said prem-
ises. and every part and parcel there-
of.
BEING the same premises which
Pin Hui Kuo and Kuei Ying Kuo
(a/k/ a Kuei Hui Kuo). his wife, by
deed dated March 29, 1996 and re-
corded on April 1, 199B in the Of-
fice of the Recorder of Deeds for
Cumberland County in Deed Book
Volume 136. Page 965, granted and
conveyed unto Kiran Kumar Dan-
dapat.
DBV 136, Page 965.
Tax Parcel No. 09-17-1044-060.
",,-