HomeMy WebLinkAbout01-06553
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FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQUIRE
IDENTtFICATIONNO, 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F, KENNEDY BOULEVARD
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTWF
COURT OF COMMON PLEAS
CIVIL DIVISION
MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE
7105 CORPORATE DRIVE
PLANO, TX 75024
Plaintiff
TERM
NO, 01- l.,sS3 C:,~\I
v,
CUMBERLAND COUNTY
CAROL J, WElNELL
CAROL E, WElNELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
Defendant(s)
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
IN FORMA TlON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
You have been sued in Court, If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attomey 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 TIllS PAPER TO YOUR LAWYER AT ONCE, W YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Loan #; 9802115
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IF TillS IS THE FIRST NOTICE THAT YOU HAVE
RECEIVED IFROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT, 15 U.S.c. ~ 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. IF
DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO
BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
SEND DEFENDANT(S) THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT
FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT
UNTIL THE END OF THE THIRTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH
YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES
THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY
(20) DAYS, YOU MAY OBTAIN AN EXTENSION OF
THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY
(30) DAYS AFTER YOU HAVE RECEIVED THIS
COMPLAINT. HOWEVER, IF YOU REQUEST
PROOF OF THE DEBT OR THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS
UPON YOUR RECEIPT OF THIS COMPLAINT,
THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR
OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY
FOR ADVJ[CE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
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1. Plaintiff is
MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE
7105 CORPORATE DRNE
PLANO, TX 75024
2, The name(s) and last known addressees) of the Defendant(s) are:
CAROL J, WEINELL
CAROL E. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
who is/ate the mortgagor(s) and real owner(s) of the property hereinafter described,
3, On 4/26/99 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to CONTIMORTGAGE CORPORATION which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No, 1539, Page 803, PLAINTIFF is now the legal owner of the mortgage and is in the
process of formalizing an assignment of same,
4, The premises subject to said mortgage is described as attached,
5, The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 10/30/00 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith,
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6, The following amounts are due on the mortgage:
Principal Balance
Interest
9/30/01 through 1011/01
(per Diem $24.41)
Attorney' s Fees
Cumulative Late Charges
4/26/99 to 10/1101
Cost of Suit and Title Search
Subtotal
$94,990.26
8,958.47
4,000,00
491.59
550,00
$108,990,32
Escrow
Credit
Deficit
Subtotal
0,00
173,72
$ 173,72
TOTAL
$109,164,04
7, The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriffs Sale, If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged,
8, This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000,00,
9, The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P,S, ~1680.403c,
10, The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i,) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiff's written Notice to Defendants;
or
(ii,) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency,
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$109,164,04, together with interest from 10/1101 at the rate of $24.41 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property,
~2~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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ALL that cer~ain piece or parcel D~ land with the ~mprovemer.ts
the::'eon ere-ctecJ. situate in the Boroug:' of' :~ew Cumberland ~ county of
Cumberland and State o~ ?ennsy~vania, more pa~ticularly bour.d~d
and'oescribed as rollows, to wit:
HEGI}JNI::--:G at a po~n'e on the northern line of' Ninth Street.
said po~nt being referenced eastwardly>> a distance of 100 feet from
the northeastern ~i.ne or Ninth Street 'and 9ra~dt Avenue; thence along
the eU$tern 1ine o~ land noW or late OL Kern. ~or~h 30 degrees 15
minutes West, a distarlce or 57.57 reet to a point; thence North 65
degreeo 0 m~nutes West. a distance or 57.58 feet to a point; thence
North 59 degree~ 50 minutes Ease, a distance or 113.31 reet to a
poInt on the western line of a 10 roo~ alley; thence along the same,
South 30 degrees ~O m1~utes East~ a dista~ce or l05 ~ee~ to a po~n~
on the norehe~n l.1ne or ,IJinth St=-eet; t~i.ence along the sa.me.. 30uth
59 degrees 50 m~nutes West, a distance of 80.30 reet to a po!n0, the
Place or BEGINNING.
PREMISES ON: 419 NINTH STREET
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VERIFICATION
BRANDON SCIUMBATO hereby states that he is VICE PRESIDENT of
COUNTRYWIDE HOME LOANS, INe. mortgage servicing agent for Plaintiff in this matter. that he
is authorized to take this Verification, and that the statements made in the foregoing Civil Action in
Mortgage Foreclosure are tnie and correct to the best of his knowledge, information and belief, The
undersigned understands that this statement is made subject to tlie penalties of 18 Pa, C,S,
relating to unsworn falsification to authorities,
DATE:.-lJ -I S- -01
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-06553 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUS
VB
WEINELL CAROL J ET AL
JASON VIORAL
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
WEINELL CAROL J
the
DEFENDANT
at 1903:00 HOURS, on the 26th day of November, 2001
at 419 NINTH STREET
NEW CUMBERLAND, PA 17070
by handing to
CAROL E WEINELL, DAUGHTER
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
11.05
.00
10.00
.00
39,05
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R. Thomas Kline
11/28/2001
FEDERMAN & PHELAN
Sworn and Subsc~ibed to before
me this 304 day of
By:
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De ty Sheriff
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-06553 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUS
VS
WEINELL CAROL J ET AL
JASON VIORAL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
WEINELL CAROL E
the
DEFENDANT
, at 1903:00 HOURS, on the 26th day of November, 2001
at 419 NINTH STREET
NEW CUMBERLAND, PA 17070
by handing to
CAROL E WEINELL
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof,
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
So Answers:
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R. Thomas Kline
11/28/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before
By:
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me this 3o-U,
day of
A.D.
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FEDERMAN AND PHELAN
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, By: FRANK FEDERMAN
Identification No. 12248
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
fHILADELPmA, PA 19103-1814
(215) 563-7000
MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE
7105 CORPORATE DRIVE
fLANO, TX 75024
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DMSION
Plaintiff,
v.
NO. 01-6553
CAROL J. WElNELL
CAROL E. WEINELL
Defendant(s).
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor ofthe Plaintiff and against CAROL J. WEINELL and CAROL
E. WEINELL, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from
service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages
as follows:
As set forth in Complaint
Interest from 10/1/01 to 1/14/02
TOTAL
$109,164.04
$2,563.05
$111,727.09
I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and
(2) that notice has been given in accordance with Rule 237.1, copy attached.
F.Al ~ERMAN~UffiB
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED, ~
DATE: ~ );z. ). f7 ~DO^,--- (] (AL ) e
I PRO PROTHY
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(Rule of Civil Procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE
7105 CORPORATE DRIVE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff,
v.
NO. 01-6553
CAROL J. WEINELL
CAROL E. WEINELL
Defendant(s).
Notice is given that a Judgment in the above-captioned matter has been entered against you on
Jd<) '7 20OJ...
By~
/A04J P
DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESOUIRE
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F, KENNEDY BLVD" SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HA VB PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A
LIEN AGAINST PROPERTY. **
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FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563 -7000
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
MANUFACTURERS AND TRADERS
TRUST COMPANY AS INDENTURE
TRUSTEE
Plaintiff
CIVIL DIVISION
CUMBERLAND COUNTY
vs.
NO.01-6553
CAROL J, WEINELL
CAROL E. WErNELL
Defendant
TO: CAROL E. WEINELL
419 NINTH STREET
NEW CUMBERLAND ,PA 17070
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DATE OF NOTICE: DECEMBER 18. 2001
THIS FIRM IS A DEBT COLLECTOR ATTEMPTrNG TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN
AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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Frank Federman,Esquire
Attorney for Plaintiff
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FEDERMAN AND PHELAN, L.L.P.
~ Frank Federman, Esquire
Identification No. 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
MANUFACTURERS AND TRADERS
TRUST COMPANY AS INDENTURE
TRUSTEE
Plaintiff
crVIL DIVISION
CUMBERLAND COUNTY
vs.
NO. 01-6553
CAROL J. WEINELL
CAROL E. WEINELL
Defendant(s)
fILE CuPY
TO: CAROL J. WEINELL
419 NINTH STREET
NEW CUMBERLAND ,PA 17070
DATE OF NOTICE: DECEMBER 18. 2001
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT,
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE
PREVIOUSLY RECErVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE rs NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN
AGArNST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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Frank Federman, Esqulre
Attorney for Plaintiff
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~ FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPIDA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE
7105 CORPORATE DRIVE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff,
v.
NO. 01-6553
CAROL J. WEINELL
CAROL E. WEINELL
Defendant(s).
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that on information and belief, he has knowledge ofthe following facts,
to wit;
(a) that the defendant(s) is/are not in the Military or Naval Service of the United States
or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress
of 1940, as amended.
(b) that defendant CAROL J. WElNELL is over 18 years of age and resides at, 419
NINTH STREET, NEW CUMBERLAND, P A 17070 .
(c) that defendant CAROL E. WEINELL is over 18 years of age, and resides at, 419
NINTH STREET, NEW CUMBERLAND, P A 17070.
This statement is made subject to the penalties of 18 Pa, C,S. Section 4904 relating to
unsworn falsification to authorities,
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FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE
Plaintiff,
v.
No. 01-6553
CAROL J. WEINELL
CAROL E. WEINELL
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$111,727.09
Interest from 1/14/02 to 6/5/02
(per diem -18.37)
$2,607,99 and Costs
TOTAL
$114,335,07
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FRANK FEDERMAN, ESQUIRE
One Penn Center at Suburban Station
1617 John F, Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property,No.
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MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE
CUMBERLAND COUNTY
Plaintiff,
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
CAROL J. WEINELL
CAROL E. WElNELL
NO. 01-6553
Defendant(s).
AFFIDA VlT PURSUANT TO RULE 3129
(Affidavit No, I)
MANUFACTURERS AND TRADERS TRUST COMPANY AS INDENTURE TRUSTEE,
Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following information concerning the real property
located at .419 NINTH STREET. NEW CUMBERLAND. PA 17070.
1. Name and address ofOwner(s) orreputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
CAROL J. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
CAROL E, WEINELL
419 NINTH STREET
NEW CUMBERLAND, PA 17070
2, Name and address ofDefendant(s) in the judgment:
CAROL J. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
CAROL E. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
3, Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
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4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
CITI FINANCIAL, INC.
3401 HARTZDALE DRNE SUITE 126
CAMP HILL, PA 17011
5, Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None,
6, Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
419 NINTH STREET
NEW CUMBERLAND, P A 17070
Domestic Relations of Cumberland County
13 North Hanover Street
Carlisle, PA 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, P A 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties ofl8 Pa, C,S, Sec. 4904 relating to unsworn falsification to authorities,
January 14. 2002
DATE
4~~!
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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By: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BL YD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
v.
CML DIVISION
CAROL J. WEINELL
CAROL E. WEINELL
NO. 01-6553
Defendant(s).
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
o an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn
falsification to authorities,
4--J; tl--
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE
Plaintiff,
CUMBERLAND COUNTY
No. 01-6553
v.
CAROL J. WEINELL
CAROL E. WEINELL
Defendant(s).
January 14, 2002
TO: CAROL J. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
CAROL E. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
Your house (real estate) at. 419 NINTH STREET. NEW CUMBERLAND. PA 17070. is
scheduled to be sold at the Sheriffs Sale on JUNE 5. 2002 at 10:00 a.m, in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 111.727.09
obtained by MANUFACTURERS AND TRADERS TRUST COMPANY AS INDENTURE
TRUSTEE (the mortgagee) against you. In the event the sale is continued, an announcement will bc
made at said sale in compliance with Pa.R.C,P" Rule 3129.3,
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due, To find out how much you must pay, you may
call: (215) 563-7000.
2, You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered, You may also ask the Court to
postpone the sale for good cause,
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale, (See notice on page two on how to obtain an attorney,)
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YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000,
2, You may be able to petition the Court to set aside the sale ifthe bid price was grossly
inadequate compared to the value of your property,
3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To
find out if this has happened, you may call (717) 240-6390,
4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as ifthe sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you,
6, You may be entitled to a share of the money which was paid for your house, A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale, This
schedule will state who will be receiving that money, The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed,
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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FEDERMAN AND PHELAN
BY: FRANKFEDERMAN
IDENTIFICATION NO, 12248
SUITE 1400 - ONE PENN CENTER
PHILADELPHIA, PA 19103
215) 563-7000
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE
vs,
COURT OF COMMON PLEAS
CNIL DIVISION
CAROL J. WEINELL
CAROL E, WEINELL
NO, 01-6553
VFR TFTC: A nON
I hereby certify that a true and correct copy of the Notice of Sheriffs Sale in the above captioned
matter was sent by regular mail and certified mail, return receipt requested, to the following
personCs) CAROL J, AND CAROL E, WEINELL on 4/2/02 at 419 NINTH STREET, NEW
CUMBERLAND, P A 17070 in accordance with the Order of Court dated, 3/22/02,
The undersigned understands that this statement is made subject to the penalties of 18 P A. C.S,
s4904 relating to unsworn falsificaton to authorities,
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FRANK FEDERMAN, ESQUIRE
ATTORNEY FOR PLAINTIFF
DATE: April 8, 2002
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
,
PENNSYLVANIA
RE: MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE )
)
CIVIL ACTION
vs,
CAROL J, WEINELL
CAROL E. WEINELL
)
)
CIVIL DIVISION
NO, 01-65f3
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
)
)
SS:
I, FRANK FEDERMAN, ESQUIRE attorney for MANUFACTURERS AND
TRADERS TRUST COMPANY AS INDENTURE TRUSTEE hereby verify that on
1/16/02 true and correct copies of the Notice of Sheriff's sale were served by
certificate of mailing to the recorded lienholders, and any known interested party
see Exhibit "A" attached hereto, Notice of Sale was sent to the Defendant(s) on
1/16/02 by certified mail return receipt requested see Exhibit "B" attached
hereto,
DATE: April 16. 2002
~AAJLJL~j~
FRA K FEDERMAN, ESQUIRE
Attorney for Plaintiff
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, TO: CAROLJ,WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
SENDER:
TEAM 5
REFERENCE: WElNELL
PS Form 3800 June 2000
.1 RETURN Postage
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REFERENCE: WEINELL
PS FeRn 3800 June 2000
RETURN Postage
RECEIPT '
SERVICE Certlfred Fee
Retum Receipt Fee
Restricted Delivery
Total Postage & Fees
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQtmRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUIrE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
g(; 2002
COURT OF COMMON PLEAS
CIVIL DIVISION
MANUFACTURERS AND TRADERS
TRUST COMPANY AS INDENTURE
TRUSTEE
CUMBERLAND COUNTY
No,: 01-6553
vs,
CAROL J, WEINELL
CAROL E, WEINELL
ORDER
~
AND NOW, thijhay ofM, 2002, upon consideration of Plaintiff's
Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED
that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant( s),
CAROL J. WEINELL and CAROL E, WEINELL, by mailing a true and correct copy of the
Notice of Sale by certified mail and regular mail to Defendant's last known address and the
mortgaged premises,
Service of the aforementioned mailings is effective upon the date of mailing and is to be
done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit of service,
BY THE COURT:
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO, 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
COURT OF COMMON PLEAS
CIVIL DIVISION
MANUFACTURERS AND TRADERS
TRUST COMPANY AS INDENTURE
TRUSTEE
CUMBERLAND COUNTY
No,: 01-6553
vs,
CAROLJ, WElNELL
CAROL E, WElNELL
MOTION FOR SERVICE PURSUANT TO
SPECIAL ORDER OF COURT
Plaintiff, by its counsel, Frank Federman, Esquire, moves this Honorable Court for an
Order directing service ofthe Notice of Sale upon the above captioned Defendant(s) by certified
mail and regular mail to Defendant's last known address,
1, Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated
by the Affidavit of Service attached hereto as Exhibit "A,"
2, Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith
effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific
inquiries made and the results therefrom is attached hereto as Exhibit nB. n
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order
pursuant to Pennsylvania Rule of Civil Procedure 430 directing service ofthe Notice of Sale by
certified mail and regular mail to Defendant's last known address,
-;;----1 ~L
FRANK FEDERMAN, ESQUIRE
ATTORNEY FOR PLAINTIFF
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. FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO, 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
MANUFACTURERS AND TRADERS
TRUST COMPANY AS INDENTURE
TRUSTEE
No,: 01-6553
vs.
CAROL J, WEINELL
CAROL E, WEINELL
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430( a) specifically provides:
(a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a
special order directing the method of service, The Motion shall be accompanied by an Affidavit stating
the nature and extent of the investigation which has been made to determine the whereabouts of the
Defendant and the reasons why service cannot be made,
Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a
new forwarding address is insufficient evidence of concealment. Gonzales vs, Polis, 238 Pa, Super, 362,
357 A,2d 580 (1976), "Notice of intended adoption mailed to last known address requires a good faith
effort to discover the correct address," Adoption of Walker, 468 Pa, 165,360 A.2d 603 (1976),
An illustration of good faith effort to locate the defendant includes (1) inquires of postal
authorities including inquiries pursuant to the Freedom of Information Act, 39 C,F,R. Part 265,
(2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations
of local telephone directories, voter registration records, local tax records, and motor vehicle
records.
As indicated by the attached Affidavit of Service, marked hereto as Exhibit "A", the
Sheriff has been unable to serve the Notice of Sale, A good faith effort to discover the
whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good
Faith Investigation, marked Exhibit "B,"
WHEREFORE, Plaintiff respectfully requests service of the Notice of Sale by certified
mail and regular mail to Defendant's last known address,
Respectfully submitted:
~ 1.. -;hd~~
RANK FEDERMAN, ESQUIRE
ATTORNEY FORPLAINTWF
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VERIFICATION
FRANK FEDERMAN, ESQUIRE, hereby states that he is the Attorney for the Plaintiff
in this action, that he is authorized to take this Affidavit, and that the statements made in the
foregoing MOTION FOR SERVICE OF THE NOTICE OF SALE PURSUANT TO
SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information
and belief.
The undersigned understands that this statement herein is made subj ect to the penalties of
18 Pa, C,S, Sec, 4904 relating to unsworn falsification to authorities,
"?-~ '1-uL..
FRANK FEDERMAN, ESQUIRE
ATTORNEY FORPLAINTWF
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FEDERMAN AND PHELAN
By: FRANK. FEDERMAN, ESQUIRE
IDENTIFICATION NO, 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814 COURT OF COMMON PLEAS
(215) 563-7000 CIVIL DIVISION
MANUFACTURERS AND TRADERS
TRUST COMPANY AS INDENTURE
TRUSTEE
CUMBERLAND COUNTY
No,: 01-6553
vs,
CAROL J. WEINELL
CAROL E. WEINELL
CERTIFICATION OF SERVICE
I, FRANK. FEDERMAN, ESQUIRE, hereby certify that a copy of the Motion for Service
Pursuant to Special Order of Court has been sent to the individuals indicated below on
March 12,2002,
CAROL 1. WEINELL
CAROL E. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
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FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
Date: March 12,2002
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AHIVAVlT OF SERVKE
PLAINTIFF
MANUFACTURERS AND TRADERS
TRUST COMPANY AS INDENTURE
TRUSTEE
CUMBERLAND COUNTY.
:rptr
No. 01-6553
DEFENDANT(S)
CAROL J. WEINELL
CAROL E. WEINELL
ACCT. #9802115
SERVE CAROL E. WEINELL AT
419 NINTH STREET
NEW CUMBERLAND, P A 17070
Type of Action
- Notice of Sheriff's Sale
Sale Date: JUNE 5, 2002
SERVED
Served and made known to
, Defendant, on the
day of
,200~
1 o'clock_.m., at
, Commonwealth
at
of Pennsylvania, in the manner described below:
Defendant personally served,
Adult family member with whom Defendant(s) residers), Relationship is
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship,
Manager/Clerk of place oflodging in which Defendant(s) residers),
Agent or person in charge of Defendant(s)'s office or usual place of business,
an officer of said Defendant(s)'s company,
Other:
Description:
Age_
Height_ Weight_ Race
Sex
Other
I, , a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated above,
Sworn to and subscribed
before me this _ day
of , 200_,
Notary:
By:
PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED.
NOT SERVED
On the ,;leA day of -:ra ",,,,, {I,( ,200 2, at / ['(o o'clock~,m., Defendant NOT FOUND because:
~ Moved Unknown No Answer Vacant
Other: A ~c.o ~ J", 'N ") 40 IV t; ') \" b (') ) w ""'j.) ~ e \ \ 5 {.UO\le. 6 .h F(fj<,:' J.... r 1M.. "d':'l a .
Sworn to and subscribed
before me this~day ~ -j ~
of ~",,,-, , 200 ~ (]
Notary: Et...;,cJ.u,l.h. -rn~ By: U
Attornev rQ Plaintiff
Frank Federman, Esqnire - I.D. No. 12248
One Penn Center at Suburban Station
1617 John F. Kenuedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
EXHIBIT UAII
~ -..-..' <
"",,,~,J' NOTARlALSEAL
C1171BETH M. JOHANSSON, NoIaIy PubIc
Gr8eI\81Wp., Franklin County
My Can\mi88illn &pir8I Dee. 19, 2005
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PLAINTIFF
AFFIDAVIT OF SERVICE
MANUFACTURERS M'lD TRADERS"
TRUST COMPANY AS INDENTURE
TRUSTEE
CUJvffiERLAND COUNTY
No. 01-6553
ACCT. #9802115
DEFENDANT(S)
CAROL J. WEINELL
CAROL E. WEINELL
Type of Action
- Notice of Sherifrs Sale
SERVE CAROL J. WEINELL AT
419 NINTH STREET
NEW CUMBERLAND, P A 17070
Sale Date: JUNE 5, 2002
SERVED
Served and made known to
, Defendant, on the
day of
,200~
,o'clock _,m., at
. Commonwealth
at
of Pennsylvania, in the manner descnbed below:
Defendant personally served,
Adult family member with whom Defendant(s) reside(s), Relationship i.
Adult in charge of Defendant(s)'s residence who refused to give name or relationship,
Manager/Clerk of place oflodging in which Defendant(s) reside(s),
Agent or person in charge of Defendant(s)'s office or usual place of business,
an officer of said Defendant( s)'s company,
Other:
Description:
Age_
Height_ Weight _ Race
Sex
Other
I, , a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned caSe on the date and at
the address indicated above,
~ ,.;!c':"1 ~o ;:;;:d 3ubscribed
before me thiS _ day
of ,200_,
Notary:
By:
PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED.
NOT SERVED
On the ;1 c {i. day of --J;". Q ~ rti , 200~ at (I.'lfo o'clockE.,m, Defendant NOT FOUND because:
-L Moved Unknown No Answer Vacant
Other: ACt.t\~;N., ~<l tv....i~\,,\,.r<.S I \;V~..""~"\\5 lA.AOV~~ e\a P.ot<:;j~ I W'o,
'850.
Sworn to and subscribed
before me this ...2.2!day
of $....".,,'1 ' 200 2-
Notary:~ -rY\, ~BY:
Attornev M Plaintiff
Frank Federman, Esquire - I.D. No. 12248
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814 '
(215) 563-7000
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EXHIBIT UAg
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NOTARIAlSfAL. PubIc
8.1ZABETH M. JQHANSSOtoI, NQ1aIy
Gl8en8lWp., FranIlUIiCaUl:!lY.2OlI5
My Cla,.lII",m ElqiIIII)Ic. 19.
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EKLDATA,INC.
AFFIDAVIT OF GOOD FAITH INVESTIGATION
Loan Number:
File Number:
Attorney Firm:
Federman & Phelan
Subject:
Carol J, Weinell
Property Address:
419 9th Street
New Cumberland, P A 17070
Last Known Address:
419 9th Street
New Cumberland, PA 17070-1513
Current Address:
419 9th Street
New Cumberland, PA 17070-1513
EXHIBIT "B"
Last Known Number:
717-774-4552
George H, Lewis, lll, being duly sworn according to law, deposes and says:
1. I am employed in the capacity ofpresident ofEKL DATA, INC,
2, On March 1, 2001, I conducted an investigation into the whereabouts of the above named
defendant(s), The results of my investigation are as follows:
Credit Information.
A. Social Securi ty Number
Carol J. Weinell: 265-48-7911
B. Employment Search:
Could not locate any employment information for the above named subject at this time.
C. Inquiry of Creditors:
The creditors indicated that Carol J. Weinell resides at 419 9th Street, New Cumberland,
PA 17070-1513,
II. Inquiry of Telephone eompany
A. Directory Assistance Search:
The Telephone Company has C. J. Weinelllisted with an address of 419 9th Street, New
Cumberland, PA 17070-1513, The phone number is 717-774-4552.
III, Inquiry of Neighbors
Contacted Mr. Woodruff of 417 9th Street, New Cumberland, PA 17070-1513 and verified
that Carol J. Weinell does indeed reside at 419 9th Street,
IV, Inquiry of Post Office
A, National Address Update:
As of March 1, 2001 the National Change of Address has no forwarding ret:ord for Carol
J. Weinelllisted at419 9th Street, New Cumberland, PA 17070.1513.
V, Inquiry ofDMV
The Pehnsylvania Department of Motor Vehicles has Carol J. Weinelllisted at 419 9th Street,
New Cumberland, PA 17070-1513,
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EKL DATA, INC.
AFFIDAVIT OF GOOD FAITH INVESTIGATION
VI. Other Inquiries
A. Death Records:
As of March 1, 2001 the Social Security Death ludex has no death record on file for
Carol J. Weinell under her socialsecurity number.
B. Public Licenses
None found
C. County Voter Registration:
The county does have Carpi J. Weinelllisted as a registered voter with an address of 419
9th Street, New Cumberland, PA 17070-1513.
D. A.K.A.:
Carol E. Weinell
E. D.O.B.:
Carol J. Weinell: 04-21-36
F. Miscellaneous Infonnation
None
EXH1SIT_"B"
/--------;
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Affiant George H Lewis III
~Cribed and sworn before me March 1,2001.
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EKL DATA, INC. 01423 SUFFOLK LANE 0 WYNNEWOOD, PA 19096
Tel.: 1-888-829-57680 Fax: 610-649-26370 email: ekl-data@home.com
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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55.
Robert P Ziegler
I, ______________________________________________________________________________Ilecorderof
Deeds in and for said County and State do 'herdly certify that the Sheriff's Deed in which ________________
MAnufactures and Traders Trust Co Tr .
___________________________.________________________________________________________ ~thegrantee
the same having been sold to said grantee on the ____.?_t..J:_______________________________________ day of
June 2002
________________________________________ A. D., ; _____, under and by virtue 01 a wriL_____________
Execut ion . 17th
_________________________________ _____ ___ _ ______ ISSued on the ________ __On ___ ____ ____ ________ _ _ ___
January
day of __________________________ A. D.,
2002 ..
_____, out of the Court of Cornman Pleas of said County as of
2001
Civil
______________________________... _________ ________ _________ _____________ ____ ____ ___ Term, :
. 6553 Manufactures & Traders Trust Co Tr
Number ______________, at the suit of _______________________________________u______________________
Carol J Weinell & Carol E Weinell
____________________________w______against__________________________________.____________.____ m
252 1572
duly recorded in Sherifr. Deed Book No. ____________, Page ____________.
IN TESTIMONY WHEIlEOF, I have hereunto
d and seal of said office this d..'i_t!:__ day
01 Deeds
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Manufacturers and Traders Trust Company
As Indenture Trustee
VS
Carol E. Weinell and Carol 1. Weinell
In The Court of Common Pleas of
CwnberIand County, Pennsylvania
Writ No. 2001-6553 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
served the within Real Estate Writ, Notice and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action by Certified Mail, Return Receipt
Requested, Restricted Delivery, Deliver to Addressee Only to one of the within named
defendants, to wit, Carol 1. Weinell, to her last known address of6168 Old Hickory
Road, Crestview, FL 32539-7211. This letter was mailed under the date of March 13,
2002. Carol J. Weinell received the Iytter on March 18,2002. Return receipt card was
returned to the Cwnberland County Sheriffs Office on March 21,2002 signed by Carol
J. Weinel1.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
served the within Real Estate Writ, Notice and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action by Certified Mail, Return Receipt
Requested, Restricted Delivery, Deliver to Addressee Only to one of the within named
defendants, to wit, Carol E. Weinell, to her last known address of6168 Old Hickory
Road, Crestview, FL 32539-7211. This letter was mailed under the date of March 21,
2002. Carol E. Weinell received the letter on March 25, 2002. Return receipt card was
returned to the CwnberIand County Sheriffs Office on April 1,2002 signed by Carol E.
Weinel1.
Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states
that on April 4, 2002 at 2:25 o'clock P.M., E.S.T., she posted a true copy of the within
Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Carol J. Weinell and Carol E. Weinell located at 419 Ninth Street, New
CwnberIand, 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 of the within named
defendants to wit: Carol J. Weinell, by regular mail to her last known address of6168
Old Hickory Road, Crestview, FL 32539-7211. This letter was mailed under the date of
April 04, 2002 and never returned to the Sheriff s Office.
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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 of the within named
defendants to wit: Carol E. Weinell, by regular mail to her last known address of 6168
Old Hickory Road, Crestview, FL 32539-7211. This letter was mailed under the date of
April 04, 2002 and never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, whp being duly sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on June 5, 2002 at 10:00 0' clock A.M., EST. He sold the same for the sum
of$1.00 to Attorney Frank Federman for Manufactures and Traders Trust Company as
Indenture Trustee. It being the highest bid and best price received for the same,
Manufactures and Traders Trust Company as Indenture Trustee of 7105 Corporate Drive,
PIano, TX 75024, being the buyer in this execution, paid SheriffR. Thomas Kline the
sum of$698.18, it being costs.
Sworn and subscribed to before me
This ,)6 'E. day o~
2002, A.D. g~,-,-, D. ~, ~
ro onotary
Sheriff s Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of
Proceeds
Sheriffs Deed
$30.00
13.69
15.00
15.00
30.00
10.00
.50
1.00
23.46
16.53
15.00
30.00
223.55
193.75
24.20
25.00
30.50
$698.18 paid by attorney
06/19/02
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R. Thomas Kline, Sheriff
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MANUFACTVRERS ANDTRAIDERS TRUST
COMPANY AS INDENTURE TRUSTEE
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CUMBERLAND COUNTY
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Plaintiff,
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
CAROL J. WEINELL
CAROL E. WEINELL
NO. 01-6553
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No.1)
MANUFACTURERS AND TRADERS TRUST COMPANY AS INDENTURE TRUSTEE,
Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following information concerning the real property
located at .419 NINTH STREET. NEW CUMBERLAND. PA 17070.
1. Name and address ofOwner(s) orreputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
CAROLJ. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
CAROL E. WEINELL
419 NINTH STREET
NEW CUMBERLAND, PA 17070
2. Name and address of Defendant( s) in the judgment:
CAROL J. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
CAROL E. WEINELL
419 NINTH STREET
NEW CUMBERLAND, PA 17070
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address~annot be
reasonably ascertained, please indicate)
None.
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. 4. Name and address of last recorded holder-6f every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
cm FINANCIAL, INC.
. 3401 HARTZDALE DRIVE SUITE 126
CAMP HILL, PA 17011
5. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
Last Known Address (if addreso cannot be
reasonably ascertained, please indicate)
None.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
419 NINTH STREET
NEW CUMBERLAND, P A 17070
Domestic Relations of Cumberland County
13 North Hanover Street
Carlisle, P A 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, P A 171 05
1 verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
January 14. 2002
DATE
-4 --Y ~J,
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE r
Plaintiff,
CUMBERLAND COUNTY
No. 01-6553
v.
CAROL J. WEINELL
CAROL E. WEINELL
Defendant(s).
January 14, 2002
TO: CAROL J. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
CAROL E. WEINELL
419 NINTH STREET
NEW CUMBERLAND, P A 17070
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THA T PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at. 419 NINTH STREET. NEW CUMBERLAND, PA 17070, is
scheduled to be sold at the Sheriff's Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of111,727.09
obtained by MANUFACTURERS AND TRADERS TRUST COMPANY AS INDENTURE
TRUSTEE (the mortgagee) against you. In the event the sale is continued, an announcement will be
made at said sale in compliance with Pa.R.C.P., Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
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YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
s. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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PREMISES ON: 419 NINTH STREET
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) ".
COUNTY OF CUMBERLAND)
NO 01-6553 Civil
CML ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due MANUFACTURERS AND TRADERS TRUST
COMPANY AS INDENTURE TRUSTEE PLANTIFF(S)
From CAROL J. WEINELL, CAROL E. WEINELL, 419 NINTH STREET, NEW CUMBERLAND, PA
17070
(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 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.
AmountDue $111,727.09 L.L. $.50
Interest FROM 1/14/02 TO 6/5/02 (pER DIEM - 18.37) $2,607.99 AND COSTS
Atty's Corom % Due Prothy $1.00
Arty Paid $127.05 Other Costs
Plaintiff Paid
Dffie: JANUARY 17,2002
CURTIS R. LONG
Prothonotary, Civil Division
....By:
40/>0" - P. 7f/l/u)tJ;~
REQUESTING PARTY:
Name FRANK FEDERMAN, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHNF. KENNEDY BOULEVARD, SUITE 1400
PIDLADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ill No. 12248
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,R~~L ESTATE SALE No. -;
On February 6, 2002, the sherifflevied upon the
defendant's interest in the real property situated in
Borough of New Cumberland, Cumberland County, P A,
known and numbered as 419 Ninth Street, New Cumberland,
and more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: February 6, 2002
By: Jo~ S~
Real Estate Deputy
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATEOFPENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
VIZ:
APRIL 26, MAY 3,10,2002
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 SUBSCRIBED before me this
10 day of MAY, 2002
NO
LOIS E. SNYDER. Nobly PublIc
, Carlisle Boro, Cumbertand CounlY
.. '!rf Commis8ion Expims Man:h 5. 2005
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REAL ESTATE SALE NO.7
WrIt No. 2001-6553 Civil
Manufacturers and Traders Trust
Company as Indenture Trustee
vs.
Carol J. Weinell and
Carol E, Weinell
Atty.: Frank Federman
ALL that certain piece or parcel
of land with the improvements
thereon erected situate in the Bor-
ough of New Cumberland, County
oLCwnberland and State of Penn-
sylvania, more particularly bounded
and described as follows, to wit:
BEGINNING at a point on the
northern line of Ninth Street, said
point being referenced eastwardly,
a distance of 100 feet from the nort..~-
eastern line of Ninth Street and
, Brandt Avenue: thence along the
eastern line- of land now or late of
Kern. North 30 degrees 15 minutes
West. a distance of 57.57 feet to a
point; thence North 65 degrees 0
minutes West. a distance of 57.58
feet to a point; thence North 59 de-
grees 50 minutes East, a distance
of 113.31 feet to a point on the west-
em line of ala foot alley; thence
along the same, South 30 degrees
10 minutes Eas.t, a distance of 105
feet to a point on the northern line
of Ninth Street; thence along the
same, South 59 degrees 50 minutes
West, a distance of 80.30 feet to a
point. the Place of BEGINNING.
PREMISES ON: 419 NINTH
STREET.
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Frank J. Epler 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 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
tMir regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the
7th day(s) of May 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. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded In
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COpy
S ALE #7
~~.......................................................
Swor. . efore me t' 17th day of M 200 A.D.
Notarial S.al
Tony l. R\lSll~, Nota'Y Pub
Harrisburg, Dauphin Cou
My Commission ExpifesJune 6, 2002 0 ARY PUBLIC
Member, PennsylVania AssO€iation 01 /1lA1lIlitInmission expires June 6, 2002
CUMBERlAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTl-lOUSE
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 $
192.00
1.75
193.75
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..............................................,.....................
. HEAl ESTAre SALE N~.7
~ . . Wril No. 2001-6553
E'~-'~ c~ci';ffterm -
~.' - ---~ Uanufacturem and
~ -""l'racl$)J.'(rtisfCo..'
=- __ a,sli1denture Trustee
=-..: ;:;=- _. --'\is
ji:t-~~ Carol J.Wi'inellantl
: - :=-. ,carol E. Welnoll
~~: Frank Fe<lerman
_DES 0/>1-
~-tlilitcertampieceorparcel ofland with the
~1Jijpibvements thereon ermed. situate in the
IB)Jr~'-ug!l.:. of New Cumberland, County of
m-mhedand and "State of Penn~ylvania. more
~i:ularlY boUnded and, deScnOed as follows, to -
~JOJNNiNd at ~ pOint on the northern fine of
~_~iiif1j Street, said point being referenced
~r:ii!dlY, a distance of 100 feet from the
_ 0 -ea-s'tem line of Ninth Street and Brandt
~.:ye:n~'1l1enceaJODg!be eastern litle__oflandnow
~ late of Kern, North 30 degrees 15 minutes
ges-ca,distance of 57.57 feet to a point; thence
':'lforth -65 degrees 0 minutes Wes~ a distance of
~7 S8 feet to a point; thence North 59 degrees SO
~l!1~s Eas&-\l- distance of 113.31 feet to a point
~ori:'ilie we~eorj'me Qia 10 'flJ9f all~;_ ilience~along~-ilie same., -South 3C degrees 10 minutes
~-.-1_a distance of 105 feet to a point on the
~ noriliern line of N'mth Street; tbence along the
~~_soutb 59 qegrees 50 minutes West, a
~ ilistaiic!; Qf 8030 fe;et to a point; the place of
, BEGINNING. .
~ES_ON:4191,mthS_