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HomeMy WebLinkAbout99-01914 1. Plaintitt i. BANK UNITED 3200 SOUTHWEST FREEWAY MAIL DROP 1422 HOUSTON, TX 77027 2. The name(s) and last known addressees) of the Defendant(s) are JENNIFER L. MOHN ANDREW M. COVER 226 NORTH 36TH STREET CAMPHILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 11/30/92 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FLEET REAL ESTATE FUNDING CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1106, Page 204. By Assignment of Mortgage recorded 10/5/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 590, Page 776. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/1/98 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The fOllowing amounts are due on the mortgage: Principal Balance Interest 10/1/98 through 3/1/99 (Per Diem $15.22) Attorney's Fees Cumulative Late Charges 11/30/92 to 3/1/99 Cost of Suit and Title Search $74,280.81 2,328.66 3,714. 00 140.55 Subtotal 550.00 Escrow Credit Detici t 81,014.02 Subtotal 0.00 43.66 43.66 TOTAL $81,057.68 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. S 1692 et seg. (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. WHEREFORE, PLAINTIFF demands an in rem JUdgment against the Defendant(s) in the sum of $81,057.68, together with interest from 3/1/99 at the rate of $15.22 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. /s/:(tirf~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff f l~kR 2 g \qg9 \ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-01914 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK UNITED VS, MOHN JENNIFER L ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: COVER ANDREW M but was unable to locate Him in his bailiwick, deputized the sheriff of PERRY County, to serve the within COMPLAINT - MORT FORE He therefore Pennsylvania, On April 20th, 1999 the attached return from Defendant Left no Forwarding Sheriff's Costs: Docketing Out of County Surcharge Dep. pen;y Co. Not Found Return , this office was in receipt of PERRY County, Pennsylvania. Address with Cumberland Co. or SO~~~~~~S70. po~st ~f# r-<'7',~./ ~ K. . omas 1.ne,. erl 6,00 9,00 8,00 25,00 5,00 $5:FUU 04/20/1999 Sworn and subscribed to before me this 02vi!:; day of rr':c 19 9<7 A,D. ~ ,(,l<,il{~}{~Hac~~ In The Court of Common Pleas of Cumberland County, Pennsylvania Bank United VS, Jennifer L. Mohn, et. al. Serve, Andrew M. Cover No, 99-1914 Civil 19_ N 4115/99 ow, Perry 19_.1 SHERIFF OF CUMBERLAND COUNTY, PA do bereby depullze the SherllToC COUDty 10 execute this Wrlt,lbls depul'llon being Illude utthe reque.t.nd risk oflhe PI.IDliff. ~~~ ~erlrroccumberl.nd County, P.. Affidavit of Service Now, wllbin UpOD al by bandiDg 10 altesled copy oC tbe origin.l the contents thereof. 19 o'clock ,.1 M, served the i I L I a true and and m.de known to So answers, Sheriff oC County, Pa. COSTS SworD and subscribed before me Ihis d.yof 19_ SERVICE MILEAGE AFFIDA VIT s s ~ FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 C2151 563-7000 BANK UNITED 3200 SOUTHWEST FREEWAY MAIL DROP 1422 HOUSTON, TX 77027 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. qq- \91Y- L~u:...Q\erM v. CUMBERLAND COUNTY JENNIFER L. MOHN ANDREW M. COVER 226 NORTH 36TH STREET CAMPHILL, PA 17011 Defendant(s) CIVIL ACTION - LAW MORTGAGE PORECLOSURE NOTICE THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. We hQ(OOy ~!tlO wtthin to be a true Iind correct copy of Ihe ortginal filed of record FEDERMAN AND PHELAN CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 TRUE COpy FROM RECORD 10 T ostimony wherooi, I hefa unto Sit my hand and the seal of said Court at Carlisle, Pa, This 1>4- day ~' 19n~:G-tt \ ,^rl.. "Cr0N1:- . . Prothonotary -.... - -.. . .. 6. The following amounts are due on the mortgage: principal Balance Interest 10/1/98 through 3/1/99 (Per Diem $15.22) Attorney's Fees Cumulative Late Charges 11/30/92 to 3/1/99 Cost of Suit and Title Search Subtotal $74,280.81 2,328.66 3 ,714.00 140.55 550.00 81,014.02 Escrow Credit Deficit 0.00 43.66 Subtotal TOTAL 43.66 $81,057.68 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. S 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. WHEREFORE, PLAINTIFF demands an in ~ Judgment against the Defendant(s) in the sum of $81,057.68, together with interest from 3/1/99 at the rate of $15.22 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. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff , VERIFICATION FRANK FEDERMAN, ESQUIRE, hereby states that he is Attorney for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C, S. Sec, 4904 relating to unsworn falsification to authorities. ~~ FRANK FEDERMAN DATE: FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty, I,D. n78020 Ste, 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 BANK UNITED ATTORNEY FOR PLAINTIFF vs. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County No, 99-1914-CIVIL JENNIFER L. MOHN ANDREW M, COVER CERTIFICATION I, LISA D. BLANKENBURG, ESQUIRE, hereby certify that a copy of the Motion for Alternate Service has been sent to the individual(sl as indicated below by first class mail, postage prepaid, on the date listed below. ANDREW M. COVER 226 NORTH 36TH STREET CAMPHILL, PA 17011 JENNIFER L, MOHN 226 NORTH 36TH STREET CAMPHILL, PA 17011 The undersigned understands that this statement is made subject to the penalties of 18 PA C.S, 4904 relating to unsworn falsification to authorities. ~nkenbUrg, Federman and Phelan Esquire Date: Mav 14, 1999 I - '-:",-",:" . '\1AY' 2~' /99& ,A-' BY: Lisa D, Blankenburg, Esq, Atty. I,D, #78020 Ste, 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 BANK UNITED COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No, 99-1914-CIVIL VO, JENNIFER L, MOHN ANDREW M, COVER ORDER AND NOW, this ~'7 Ir~a- day of , 1999, 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 Complaint on the above captioned Defendant(s), ANDREW M. COVER, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address at 226 NORTH 36TH STREET, CAMPHILL, PA 17011. '"\ , S~rvice ,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 as to the mailing, BY THE COURT: /.5( &iF 8, ~J J, (Rule of Civil Procedure No, 236 _ Revised) Bank United : Cumberland COUNTY Plalnt/ff : Courl of Common Pleas vs. Jennifer L. Mohn Andrew M. Cover : CIVIL DIVISION : NO. 99-1914 Civil Term Defendant(s) : Notice is given thai a Judgment in the above captioned matter has been entered against you on Januarv .2000, By DEPUTY If you have any questions concerning this matter. please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (2151563-7000 "THIS FIRM IS A DEBT COLLECTOR A '/TEMPTING 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 REAFFlRMED. THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A '/TEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. " f'EDERMAN AND Plif:LMl BY: f'RANK f'EDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 BANK UNITED Attorney for Plaintiff COURT Of' COMMON PLEAS Plaint if f CIVIL DIVISION vs, CUMB~RLAND COUNTY JENNHER L. MOliN ANDREW M. COVER NO. 99-1914-CIVIL TERM Defendant(s) VERIFICATION I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage f'oreclosure in the above captioned matter was sent by regular and certified mail, return rece~pt requested, to the following persons, to ANDREW M, COVER at 226 NORTH 36TH STREET, CAMPHILL, PA 17011 , on DECEMBER 1. 1999, in accordance with the Order of Court dated MAY 27, 1999, The undersigned understands that this statement is made subject to the penalties of 18 Pa, C. S. Sec, 4904 relating to unsworn falsification to authorities. -~~~ FRANK FEDERMAN,ESQUIRE DATE: December 1, 1999 , , . FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq, Atty. I,D. #70020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 BANK UNITED ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-1914-CIVIL vs, JENNIFER L, MOHN ANDREW M. COVER ORDER AND NOW, this ~'-~ J, ^ AlA.. ".. . , 1999, upon day of 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 Complaint on the above captioned Defendant(s), ANDREW M, COVER, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address at 226 NORTH 36TH STREET, CAMPHILL, PA 17011. 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 > j . FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty, I.D, #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 ' (215) 563-7000 BANK UNITED ATTORNEY FOR PLAINTIFF vs, COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-1914-CIVIL JENNIFER L, MOHN ANDREW M. COVER 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 (s) and the reasons why service cannot be made. Note: A Sheriff's 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, I, , ! As indicated by the attached Sheriff's Return of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Complaint. A good Faith effort to discover the whereabouts of the Defendant (s) has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit "B", WHEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and regular mail to the defendant's last known address. Respectfully submitted: ';/J) Lisa D~nkenbUrg, Esquire Attorney for Plaintiff V. VI. AFFIDA VIT OF GOOD FAITH INVESTIGATION - II, Inquiry of Telephone Company A. Directory Assistance Search: The Telephone Company has no IIsllng for Andrew M. Cover wllh an address of226 North 361h Slreet, CamphUJ, PA 17011.2605. III, Inquiry of Neighbors Could not locale any neighbors to verify Ihal Andrew M, Cover does Indeed reside al 226 North 361h Slreel, IV. 12XIi18/r 8 Inquiry of Post Office A. National Address Update: As of May 6, 1999 the Nallonal Change of Address has Andrew M, Cover listed at 226 North 361h Street, CamphllJ, PA 17011-260S. Inquiry of DMV The Pennsylvania Departmenl of Motor Vehldes has Andrew M. Cover IIsled at 226 North 36th Street, CamphUJ, PA 17011-260S, Other Inquiries A, Death Records: As of May 6, 1999 the Social Security Death Index has no death record on file for Andrew M. Cover under his social security number, B, Public Lieenses None Found C, County Voter Registration: The county does not have Andrew M. Cover listed as a registered voter with an address of226 North 36th Street, Camphill, PA 17011-260S, D, A.K.A,: Andrew 1'01, Cover, Andrew Cover, Andy M. Cover E, D,O,B.: Andrew M, Cover: 1971 <::::-- a ~ .. ] a ;) --:I ~ - ::I .. =,8 ..-I' ..en... o-S< ~ U"'ll... . M-roC ~.a::~ ",:$ ~1::=_ I:: 0 c. a 2: .. 02: 2: ..,,,,aE ~~ a... .. 0 <...Ull. - \ol...l I- ...l> ;) ll.'" U 2:2: ~~ "E 02: I:: - ci ~~ a .. \ol ::I Ol- e .a .. 1::- -< o ;. '" ~ '" .., =....~ '" ~ . ~e or:; ~ a- 0> .. .a"'- - I- I:: a- U~ 'Cj .J~ O.CI< ~ a- ;) .; Q!~ ~.:Qll. "';) ;. .. ,'" . e ~ 00 .:.: ~ ~ ~ ~ ..J..c= c .- ~ 1:: ,- ~ ~ I-U .. c.., Cl: .. ~c= g. Cl:Q Q:l c c o~ .- 2: c. g~ ~o( '" 0 ~ '" a c. \ol6 ..... .. l:! UQj ......U '" ll. .c - ~ \ol\ol U '" =Q:l \ol '" I-~ ~ oi:J l:! 2 "0 2:;) "0 -U ll. t.i: 0( , DESCRIPTION I ALL THAT CERTAIN lot of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: / BEGINNING at a point on the Soulhweslern legal right-of-way line of Wood Street at the Southeastern corner of lands now or formerly of Albert and Elizabeth Schaffhauser; thence along the legal right-of-way line of Wood Street by a curve to the left having a radius of 58 feet, an arc distance of 60,72 feet to an "x" in lhe concrete at the intersection of the southern legal right-of-way line of Wood Street with the western legal right-of-way line of North 36th Slreet: thence through Lot No, 16l of which this was formerly a pan, the following three courses and distances: (1) South 46 degrees 17 minutes 23 seconds West, a distance of 75,87 feet: (2) through [he pany wall separating the house known as 226 Wood Slreet, hereon erected, ami house known as 2:!~ Wood Street, South 5~ degrees ~2 minutes 40 seconds West, a distance of 30,077 feet: (3) South 72 degrees 18 minutes 58 seconds West, a distance of 167,29 feet [0 a p,k, nail in tree: thence North 19 degrees 2~ minutes 30 seconds West. a distance of ~5 feet to a lree at the Southwestern corner of lanus now or formerly of Albert and Elizabeth Schaflnauser: thence along lands now or formerly of Schaflnauser, North 63 degrees 07 minutes 0 seconds East. 225.1~ feet [0 a point, the place of beginning, BEING [he ;.Iorthern portion of Lot No, 162 as shown on Plan of Hollywood Development. as recorded in Plan Book 9, page 17, Cumberland County Records, and funher being LOt No, 162-B, Preliminary-Final Subdivision of Lot No. 16l Hollywood Development, dated January 22, 1981 recordeu in Plan Book , page HAVING thereon erected a semi-detached dwelling known as 2~6 North 36th ~treet, Camp Hill, Pennsylvania, Also being known as 226 Wood Street. Camp HIll, Pennsylvama, Tax Parcel # 10-20-1850-0400 TITLE TO SAID PREMISES IS VESTED IN Jermifer Lynn Mohn, single and Andrew M, Cover, J '01 . Joint Tenants with the Right of Survivorship by Deed from Thomas M, Markley and r" Sln= e as -, d d 11/'0/9" ded Dinah Scabo-Markley, his wife and Doris j, Mowery, Single person ate J -, recor 12/4/91, in Deed Book A-36, Page 448, - ; ~) r~~ --th' e .. -' ... .... , . . - 'h. q~. ~ " ... ' - , , " , i..J -- .. ~ J ~ - :, .. ,'" 'U) - - - , 0., !.--: " , .... , ~ (Jo.... r~: . ':"1] (3-1 \) t..:_' ._'e:.. ~ ....9 -, ::,'j J -.(' C'.l U I \ -J ....... I 0- "() 0 \) 0 v () 0 Q ~ 0 0 /"'Y) 0 ~ 0 In "'l t t? l.,; 1:1 ~ 0-:. c) () ~~ ~ ~ I'Y) ~ ~ ...... \:J ; Dank United 1'lalnUrr, CUMIIERLAND COUNTY COURT OF COMMON "I.EAS v, CIVil. IlIVISION Jennifer L, Mohn Andrew M, Cover NO, 99.1914 Civil Term Ddend.nl(I), AFFIDA VIT PURSUANT TO RULE 3129 (Affidavit No,l) Bank United, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praeeipe for the Writ of Execution was filed the following infonnation concerning the real property located at 226 North 36th Street, Camp Hill. P A 17011. 1. Nwne and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) Jennifer L. Mohn 226 North 36th Street Camp HiII, PA 17011 Andrew M, Cover 226 North 36th Street Camp Hill, PA 17011 Present Whereabouts Unknown 2, Nwne and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address eannot be reasonably ascertained, please so indicate,) Same as above 3, Nwne and address of every judgment creditor whose judgment is a reeord lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably aseertained, please so indicate,) None :'J >- v: '-; , ,~ ) - " - ~~:j 'I 'fl (,-, I~; _c , '!U 4.:. ,'-, , '-."::) .' C:J 0 t v I t ':~ ) .' ,,"; I.;. " " -~ J ..I f. e,,-' , " :;.: ~.C ~- ::5 ___I '..J Oink UnUed CUMOERLAND COUNTY PlllnUrr, v, No, 99.1914 Civil Term Jennlrer L. Mohn Andrew M, Cov.r D.rendant(.), February 16.2000 TO: Jennifer L. Mohn Andrew M, Cover 226 North 36th Street Camp Hill. PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATfEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TflA 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 ATfEMPTTOCOLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY,.. Your house (real estate) at 226 North 36th Street. Camp Hill. PA 17011, is seheduled to be sold at the Sheriffs Sale on June 7. 2000 at 10:00 a,m, in the Cumberland County Courhtouse. South Hanover Street. Carlisle, PA 17013, to enforce the court judgment obtained by Bank United (the mortgagee) against you, If the Sheriffs sale is postponed, the property will be relisted for the Sheriff's Sale, NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be eancelled 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 eall: (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 eause, 3, You may also be able to stop the sale through other legal proeeedings, .... .... You may need an allomey 10 assen your rillhts, Thc sooner you conlact one, the Illore chance you will have of stopping the salc, (Scc nolicc on pallC two on how 10 obtain an allomey,) YOU MAY STILI. liE AIILE TO SA VE YOlllt l'IWI'EltTY ANI) YOII IIA VE OT/n:R IUGHTS EVEN IF TilE SIIEIUFF'S SALE I)OES TAKE I'LACE. I, If the Shcriffs Sale is not stoppcd, your propcn)' will be sold to the hillhcst bidder, You may find out the price bid by ealling (215) 563.7000, 2, You may be able to petition the Coun to set aside the sale if the bid price was grossly inadequate compared to the value of your propcny, 3, The sale will go through only if the buyer pays the Sheriff the full amount due in Ihe sale, To find out if this has happened, you may call (717) 240-6390, 4, [fthe amount due from the Buyer is not paid to the Sheriff. you will remain the owner of the property as if the sale never happened, 5, You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proeeedings to cviet 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 sehedule will state who will be receiving that money. The money will be paid out in accordance with this sehedule 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 gelling your home back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (SOO) 990-9108 DESCRIPTION / ALL THAT CERTAIN lot of land silUate in the Township of Hampden. County of Cumberland and Slate of Pennsylvania, more particularly bounded and described as follows: I BEGINNI:-IG al a point on [he Southwestern legal right-of-way line of Wood Street at [he Southeastern corner of lands now or formerly of Albert and Elizabeth Schaffhauser: thence along the le2al ri2ht-of-wal' line of Wood Slreet bv a curve to the left havin2 a radius of 58 feet, an arc di;tanc~ of 60,72 feet to an "x" in the concrete at the intersection ~f the southern legal right-of-way line of Wood Street with the western legal right-of-way line of North 36th Street; thence through Lot :-10, 162 of which lhis was fonnerly a part, the following three courses and distances: (I) South 46 degrees 17 minutes 23 seconds West, a distance of 75.87 feet; (2) through the party wall separating the house known as 216 Wood Streer. hereon erected, and house known as 224 Wood Street, South 54 degrees 42 minutes 40 seconds West, a distance of 30,077 feet: (3) South 72 degrees 18 minutes 58 seconds West, a distance of 167,29 feet to a p,k, nail in tree: thence North 19 de2rees 24 minutes 30 seconds West, a distance of 45 feet to a tree at the Southwestern corner of lands ~ow or formerly of Albert and Elizabeth Schaffhauser: thence along lands now or formerly of Schaftl1auser, North 63 degrees 07 minutes 0 seconds East, 225,14 feet to a point, the place of beginning, BEING the Northern portion of Lot No, 162 as shown on Plan of Hollywood Development, as recorded in Plan Book 9, page 17, Cumberland COUnty Records, and further being Lot No, 162-B, Preliminary-Final Subdivision of Lot No, 162 Hollywood Development, dated January 22, 1981 recorded in Plan Book , page HAVING thereon erected a semi-detached dwelling known as 2~6 North 36th ~treet, Camp Hill, Pennsylvania, Also being known as 226 Wood Slreet, Camp HIll. Pennsylvama, Tax Parcel # 10-20-1850-0400 TITLE TO SAID PREMISES IS VESTED IN Jennifer Lynn Mohn, single and Andrew M, Cover, Jr" single as Joint Tenants with the Right of Survivorsh!p by Deed from Tho~as ~1. Markley and Dinah Scabo-Markley, his wife and Doris J, Mowery, smgle person dated 1l/JO/9_, recorded 12/4/92, in Deed Book .'\-36, Page 448. Bank United Plaintiff, Cumberland COUNTY COURT OF COMMON PLEAS v, Jennifer L. Mohn Andrew M, Cover 226 North 36th Street Camp Hill, Pa 17011 CIVIL DIVISION NO, 99-1914 Defendanl(s), AND NOW, this ORDER .:;,\1- day of ~ , 2000, after consideration of Plaintiffs Motion for Special Service, it is hereby: ORDERED that no further advertising or additional notice to lienholder or Defendant(s) is required; and, ORDERED that pursuant to Pa. R,C,P, 430(a), service of the Notice of Sale is permitted on Defendant(s) Jennifer L, Mohn . / -:;7 REGULAR MAIL AT JENNIFER L, MOHN'S LAST KNOWN ADDRESS CERTIFIED MAIL AT JENNIFER L, MOHN'S LAST KNOWN ADDRESS 3., Plaintiff attempted to serve the Defendant(s) via certified mail at226 North 36'" Street Camp Hill, Pa 1701l,Mail was not returned by the V,S, POSl Office and is attached hereto as Exhibit" A", 4. Pursuant to Pa.R.C,P, 430, Plaintiff has made a good faith effort to locate the Defendant(s), An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "D", WHEREFORE, Plaintiff respectfully requests the allowance of service of the Notice of Sale in accordance with Pa.R,C.P. 430 by certified and regular mail to Jennifer L, Mohn's last known address, EKL DATA, INC. AFFII>A VIT OF GOOD FAITH INVESTIGATION VI. Other Inquiries A. Pc,lIh l{cl:ords: 1\' ur ~JlIr('h 8, 2000 the Sud.. Srcur'h' Ih-llth Indu bl. DO dtltb rtcord on nle ror J~'III1Ift..'r t. .\'u'an under IIt'r lodalsrcurity number. 0. l'uhlJl.: liccl1~cs NUllt'ruund C. ('ollm)' VOler RL'gislrlUiun: , The "ullnh' dill'S 110' h:n-c Jcnnlrrr L. ,'111110 listed ... ~red voter wltb an Iddren or llr. No;th 36th SIre.., Camp 1111I,1''\ 17011-2605, ..."",.,(,,, 'V(jl'_ 0, A,K,A,: ;Ie '-, J.'uulror ,\Iohn ...... Q'J ~/ E, DO.fl: .h'lJlllh.'r I.. ~Iuhn: 11J7U F. ~ri~l:cll;1l1cuus Infonnation NUllc ,_i_.. I~;.-t 'I~I) ."VLittyi~..... , "c'{&;;,.." u '," . .......09 V / fl~ i'tJ<. -- --.. ~ " r::'r...,.V . .,n.:a e-. ""'''"'''' ..!",..... .1. .J) ~J ^oll)n." .. . '. .:' . "," ! '~.. -- "-'- EKI. DATA, INC, 01423 SUFFOLK LANE 0 WYNNEWOOD, PA 19096 Tel,: 1-888-829-5768 El Fax: (, I 10-649.2637 0 emall: ekJ-data@hom.,com " FEDERMAN AND PHELAN By: Fraok Federman, Esquire Attorney I.D. No.: 12248 Two Penn Center Plaza, Suite 900 Phlladelpbla, PA 19102 (215) 563-7000 Attorney Cor PlalntUT Bank United v, Plaintiff, Cumberland COUNTY COURT OF COMMON PLEAS Jennifer L, Mohn Andrew M, Cover 226 North 36th Street Camp Hill, Pa 17011 CIVIL DIVISION NO, 99-1914 Defendant(s), PLAINTIFF'S MEMORANDUM OF LA W Pursuant to Pennsylvania Rule of Civil Procedure 3129, it is now necessary in a foreclosure action for the Sheriff to serve upon the Defendant(s) Notice of the Sale of the mortgaged premises. Pa.R.C.P. 3129(b)(2) provides in part: (2) The written notice prepared by the Plaintiff shall contain the same information as the handbills or may consist of the handbill and shall be served by the Sheriff at least thirty (30) days before the Sale on all persons whose names and addressed are set forth in the affidavit required by subdivision (a), The Plaintiff shall direct the Sheriff to make service either: (i) in the manner prescribed by Rule 402 for the service of original process upon a Defendant. (ii) or by mailing a copy.., Because the Defendant(s)' whereabouts are unknown, a reasonable investigation of the whereabouts was made in accordance with Pa,R,C,P, 430(a), .. , ",'. ,..I' \: '. " ..~..:Al':;"'~~"I"'-' '. , , .; .., ,"I.. '" ,. '. lt~~~ . ""A'~~.....;I", ...l,'a.'-....,...,~ ". :" ".!J( ''',,;''41j';- e ">ON,. ~::t h ~! "'~ Ri g~ I '00 ---.- , I RETlJRN RECEIPT SERVICE .---- f'- ru .... '0, .... 0'" :r f'- 0'" Q. JENNIPER L. ~~HN ':':26 :-IOR...H 36TH STRJ::I::T C~~P HILL, PA 17011 + " .,.;:~. PS FORM 3800 US Postal Service Receipt for Certified Mail ',,1. MSB . '~.' , ..:-..- ". .... . ...,'.. , -, . .-" .'1 :J-; f..- l_~. 'J ,~..; " , ~.. roo ,'-:.J 1':;.1 ~ .~- " U ". FEDBRMAN AND PHELAN by. Lisa D. Blankenburg, Bsquire Atty. I.D. No. 78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (21~) ~~1-7Qaa ATTORNEY FOR PLAINTIFF BANI!: ONITBD CllIIIIBRLAND COUNTY COtl'llT OF COMMON PLBAS VB, JlIIlNIFBR L. MOlIN ANDREW M. COVER CIVIL DIVISION NO, 99-1914 CIVIL TBRM ORDBR AND NOW, this day of , the Prothonotary is ORDERED to reassess the damages in this case as follows: Principal Balance Interest Amount 10/1/98 through 6/7/00 Late Charges Legal fees Cost of Suit and Title Sheriff's Sale Costs Inspections/Other Appraisal Fees Escrow Credit Deficit $74,280,81 9,324.62 522,93 3,714,00 1,437.00 0,00 301. 75 0,00 0,00 2,160,49 TOTAL $91,741.60 Plus interest per diem from 6/7/00 through Date of Sale at six (6%) percent, NOTE: THE ABOVE FIGURE IS NOT A PAY OFF - SHERIFF'S SALE COSTS AND COMMISSION ARE NOT INCLUDED IN THE ABOVE FIGURES, BY THE COURT: J, PEDERMAN AND PHELAN by. Lisa D. Blankenburg. Esquire Atty. 1.0. No. 78020 Two Penn Center Plaza, Suite 900 Philadelphia. PA 19102-1799 (2'~) ~~~-7nllO ATTORNEY POR PLAINTIFF BANIC UNITED CUMBERLAND COUNTY COURT OJ' COMMON PLIAS VI. JBNNIJ'IIR L. MOIIII ANDRIlW M. COVllR CIVIL DIVISION NO. 99-1914 CIVIL TERM BRIIIF 01" LAW IN SUPPORT OF PLAINTIFF'S MOTION TO RIlASSBSS DAMAGES I. BACKGROUND OF CASE Plaintiff and Defendant (8) entered into a Promissory Note and Mortgage Agreement, wherein Defendant (8) agreed to pay Plaintiff principal, interest, late charges, real estate taxes, hazard insurance premiums and mortgage insurance premiums as said monies became due. In turn. Plaintiff I s Note was secured by a mortgage on the subject premises. The Mortgage Agreement indicates that in the event Defendant (8) defaults, Plaintiff may pay any necessary obligations in order to protect its collateral, the subject premises. In the case sub ;udicia, Defendant (s) failed to abide by the Mortgage Agreement by failing to tender numerous, promised monthly mortgage payments. Accordingly, after Plaintiff determined that Defendant(s) were not going to cure the default and bring the loan current, Plaintiff commenced a Mortgage Foreclosure Action. Judgment was subsequently entered by the Court, and the subject property is scheduled for Sheriff's Sale. Because of the excessive period of time between the initiation of the Mortgage Foreclosure Action, the entry of Judgment and the Sher.iff's Sale date, damages as previously assessed by the Court are outdated and must be increased to include current interest, real estate taxes, insurance premiums, and other expenses which Plaintiff has been obligated to pay under the Mortgage Agreement in order to protect its interest. II. ARGtlMENT FOR REASSBSSMENT OF DAMAGES The Pennsylvania Rules of civil Procedure are silent with respect to the issue of Reassessment of Damages; however, Rule 1037 provides, lithe Prothonotary shall assess damages for the amount which Plaintiff is entitled if it is a Dum certain or which can be mclde certdu1 by computllt ion..." In the instant caDe, the amount to which Plaintiff io entitled iD readily calculated by review of the Mortgage A.greement, which in of record, together with the Complaint which Dpecitically lists the itemD cll<lrq""blc. Clearly, if Ruie 1037 gives the Prothonotary the right to aDDeBD damages for the amount to which Plaintiff is entitled aB Det forth in the Complaint, the Court has similar power to reassess damages at a later date. In addition, Rule 1037 (a) provides that the Court, on motion of a party, may enter an appropriate judgment against a party upon default or admission. If the Court has the power to enter judgment, it certainly has the power to do a lesser act, to wit, reassess damages. It is settled law in Pennsylvania that the Court may exercise its equitable powers to control the enforcement of a judgment and to grant any relief until that judgment is satisfied. 20 P.L.E., Judgments Sec. 191. See also, Stephenson v. Butts, 187 Pa.Super 55, 59, 142 A.2d 319, 321 (1958); Chase Home Mortqaqe Corporation of the Southwest v. Good, 537 A.2d 22, 24 (Pa.Super 1988) . In Chase Home Mortqaqe, the Court stated that where a judgment has been assessed following defendant I s failure to file a responsive pleading in a mortgage foreclosure action, a mortgagee "... could properly move the court to amend the judgment to add additional sums due by virtue if the mortgage's failure to comply with the terms of the mortgage agreement...1I Id. at 24. Because a judgment in mortgage foreclosure is strictly in rem, it is critical that the judgment reflect those amounts expended by the Plaintiff in protecting the property. See Meco Reality Company v. Burns, 414 Pa. 495, 200 A.2d 335 (1971) . Plaintiff submits that if Plaintiff went to sale without reassessing damages, and if there was competitive bidding for the subject premises, Plaintiff would suffer irreparable harm in that it would not be able to recoup monies it paid to protect its interest. Conversely, a reassessment of damages will not be detrimental whatsoever to Defendant (s) a~ it imputes no personal liabili ty. The Supreme Court of Pennsylvania found in the Landau v. Western Pa. Nat. Bank case that the debt owed on a mortgage changes and can be "xpectf'd to ctMneJc from d.1Y to day, becAuse Western Pennoylvania muot p.1Y ~xpen(lco tor the property in order to protect its collateral. 445 Pa. II? 282 A.2d )]5 (1971). Bec3une a mortgage lien In not extlngulohed until tho debt 10 p.id, PI.lntiff muot protect ito coll.teral up until the date of Dale. ::cc Ucckl1}cln V.A)_~_~l.l~.~Tr;a_~~, 332 Pa. 545, 2 A.2d 826 (1939). Therefore, Plaintiff r"opectfuJ Iy submits that if the enforcement of its rights are delayed by legal proceedings and enforcement of its judgment, and such delays require the mortgagee to expend additional sums pursuant to the Mortgage, then said expenseD become part of the mortgagee1s lien and should be included in said judgment. As the Court indicated in FNMA v. Jefferson, an unreported case a copy of which is attached hereto, since the charges enumerated in Plaintiff's Motion for Reassessment of Damages were incurred pursuant to the Mortgage Agreement, and the mortgage had not yet been paid, said charges should be included in Plaintiff's judgment amount. May Term, 1986, No. 2359 (CCP PHlLA. 19861. III. CONCLUSION Plaintiff respectfully requests this Honorable Court grant its Petition to Reassess Damages. Plaintiff respectfully submits that it has acted in good faith in maintaining the property in accordance with the Mortgage, and in reliance on said instrument with the understanding that it would recover the monies it expended to protect its collateral. WHEREPORE, Plaintiff respectfully requests this Honorable Court to reassess the damages as set forth in the Petition to Reassess Damages. ~m LISA D. BLANKllNBURG, ESQUIRE . c:-.:--. ....1.. ..-. :.".".. ~..,. : VII. I . . JOSEn Jr;rn;UOti ~:::i ~OS:E JI7r~S:lN. ~~A ~~!. I I . . t1.\~ 'ttll.."I. '19&2: ';t.' ,.,C. 2~59 . ,~: .: .- O~:~ ~~: OP:~:C~ ~A:r!, 3. A,."I:) NOW. ~~~s '. r' ~Il~ c! f~tJ I 1;;;:1... . . - "~Cl'\ ccns'~lI.a..~" c. ~t.'__C.. re~A:a' .... ._ .. __..... .. #i___..__~_, _...... . . ..,.. . NI~!.cn~~ ti::-:;a-;= I I , I I I i I I I , I I I I I I i ! . AA.oc1&~an'. ~.~1:~c~ t:= ^e:=~.i~e=&:!cr. ~:.:~: P:: ~.:~= c! t::~1 C:u:,-:'. O::~e= c! :fc"".=,=~= 7, LSSS a::! ~:~C >.::s~.:' :.hh:.1':: . C. II · .... ..M .c.....-\o -":'...e..-- ...... -..-'" .. e_Oi1~&I._ t...J ...:-.. -..-- .._u. ...1__ I\~.._- :e!~~:s=:: , i: !.JIr h .. Cft"'~"'" c! C----- .., I ' e'=cy' i'..,.......... c.:: .:.-"\~- e.,s .0. .c-.."S: I ,..l I .' 1.\ ..'~ ~._~4~_ 4. ~,,~-~~. ..--- O"r-...--....... -~ "'I....".., ..;-~. ~~~ ro. I' ~~s' J~--.s O.A.- c~ '.'cv._,_"~-. · '0'. I- . ~.._ i'~"---, .--- -. - .. -, .~..- .-' ~'c:-(::-., . ~~,:'~ . RZ'n..~S:;!) a~c! 'i1.&!.~:!.~!t'~ MC:!Q~.~c: :;eaS"sess::e::~""'o~ c~~;=s ," ('... .. ...~"t~"" ~ ..,. _, 1.~.."I- -, '," , ......., (3.;\.~':'!:O : ,~ .. . I'"".J- ~t,~ J) 3~~~n; is ~~=Q~; ir.=:Qa~~: ~~ $;,l~r.?t. ..- 5e=~~3~ :l~~~:~:: W~3 r;..-:.'.f .....: ~: -::::e_.-; c~':=~~; -~----- - ... ==::asc pz:!=e:tt,s 1.:.:;:0:\ t..':':! !J.li:':~ . c~ t)e~=~e~~ ~~. ~,:,~k:~;r;::~o . . ' pe':L:!.c:n a:lC 1:'\ ~~::: ci~ sc I 1: i!li nC!ccs:;;=::o ~c =~~!iS:lS~ p".._ ,__.._. c. ..1.._"'-;'\1.- .:"'~- ....1.:..1 to. '.~-e .s'c."S''''' :,"::Q~ _.... ....._..._ - ...........7....=- ....-- _'o_"_"..~ ...... ... -- . , " j..c,c:-..... '-v ..2;",.:'a."!- ".as C!~:..::c= "_':0: ~:~!.s a:::!.c:':.. . =::.'':S~ - ~.._..- '". ~I,;;- _._ ::c~e~.:~::~s :.a'..e ::e-: .-- ....,,- ------- ~:-.e ._~~.~.~ ~~-_~~~s c!~~~c: ~:-c,;_____ - " : , , i! ", i' 'I I, i . !f.'~ =-,': . ".),.~ ~. t':- ~ (s."'" .f t; "'- .... .~~ '-~ .-.r"' .' I . I'.' .' E.... . 'I.'B.... E.... C' OP' .... .'. .. . I . .. . . . . ..' .' .,1 . I" '. If,... II: '.' . I', . . I" ..' ". .: .. . .' " . . . .'. '. . . . 'f,.. '. . . ' .10. ' '.. . '. ...... II . . " . " ....'. ..:ll:.:..".:..L~.::... .:'.: V ILLEGIBLE COpy ILLEGIBLE COpy ILLEGIBLE COpy '.' . E'" . I'B"'" E'" C' O' P" "'1" IL' L" : " ..; "L: . ..... '. I,' .. ~'.:::: ':>:.:."":~~:,:':,:.: .::.: ...........::..:........... f . " . .. . . ,0 . . .' .. .'. . . '.. I.. . . . . . '0 . . . .: I , .... .'. . I".. . .' . . .' , ., . ......' . .... . . VIlRIPICATION Lisa D. Blankenburg, Esquire, hereby states th~'1t she is the attorney for Plaintiff in this action, that ahe ia authorized to take this affidavit, and that the statements made in the foregoing Petition for Reassessment of Damages are true and correct to the beat of her knowledge. information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. DATE: May 26, 2000 ~~~~ Lisa D. Blankenburg, Esquire Attorney for Plaintiff >- 1.0 ~ 0-; '. '" '.-" 0=: ;5~ , l~, ". .~ ..... '-)~ ~. ~ - .", :c t...J::l.: ., n.. l.'.- ,:.~ ., } % (" :, 0 .S~ 11.1, M . ;\.2 I... ~t:' >- w~ Ujff! ,.. ,- - .~ ~~ <:> ::.J 0 U . " \ . MAY _~ 1 20'WJ - .- c> iT ," j".: ("':. ': -- , , . ~.j ~r: , ; .' .!.. , '. (;..~ -- ',~l -. ,- C::) , " I , ;".: ; u , ,,- . - 'C> j l..J U " . -SENDER: . o.c.a bQa '" ngN II ~ r<<JJW. FW,tu.Jlfd ~1 .Pt'nII.,o." _ .m~...onl""f"""Holl"'t ~"m"II""I". (......."..tt...tM'1 10101 . . _"n.c:.tl tno'i ",."PI ""l_ Ifontd lhlt~~. Of onltwt;acto, 'tp<<. 'tr..1 '.}l~""l . The Rft.r", ,,'~...,. st'OW 10 wI'Iom lhe .,110;" WD l~..-.d IN "....--.d 3. At1~ M:l~Pd 10" I also With 10 f1tC81YO tho lollowing nrvlCel (lot an exu. '''I' 'ill Realneled Delowry ~It postmaster for fee. 4<1. Article Number , ., P 973 7311 bll7 JUl/lUDl" J.. .JiIlIDI 2~'6 ~'36'Il1 STIlEn' r~;l' IH1.t.: l'A 17011 OWi K 4b. Service Type !. Received By. (Print Name) fv1 nnniV ~ <JA<f\ e, Signalure~" or A9""'j;.' x 'A:; '/f~~/' - PS OR 3811, December 1994 Vh6@ )( CERTIFIED 17. Da~~~rUV 8 Addressee's Address Domestic Return Receipt . -' . .~- SENDER: . ChKk boa al rJotll if you reqJire Restricted DelNery _Print yo.:t'n&meand address onlne nt'o'l!fWoI thi:lllotrnsotl1at..... canretumtholcard 10"", . Attach tI"'" form to the front 01 the mailpiece. or on 1M bado: if space does I'(lt pemIll . The Return Ree('ipl will 3how to whom the artiCle was de/ivefed and the date deIMlred. 3. Article Ad<ire~sed 10: J~!I:J~FEr( .... :.'IOllH .; ::6 ?~or.':il 36TH :J'.:'}=EI..:.r CA:1I' Ii:;':',., Pi\ 17011 -..",.....(...! t'1O~......'-~~. oosoll postmaster for fee. 4a. Article Number P 974 910 127 4b. Service Type e,Addre Domestic Return Receipt , .. r- I\J .... III 11.~~'1 11('.14" '.11'..1([ '.r"If{~'q . lit" ""'''I'ro'' g ~ ~ .. l!l ~ ~ .. g ~ l[ i i -- _"_._ _ h_ . ._., ..__.__ +_.._ h,__ ____...._ .._ ,_ _ ___ '=-=:-~~-:'--=-=-~~-=---:""--'::'-"- - - - - - - - - - - - - -- " '" ..!l '" m r- m r- 0"" a. .., "TTlw,'(:,) Cfl """'1'0 c .... 0"" ~.:Y" ~".....r .'.,)<(1 'i g w c. g ~ z w u. o c. g ~ a: w '" u r: '" w U .. ~ c. ~ /! a: o c. ;!! ------- - - - ----- - -----..- ---- :; NT 10 frtO"OIIIfr1l...... M4Il. " r- IT" a. , " '" . \." ~ PS FORM 3800 US Postal Service Receipt for Certified Mail IT" '" .II '" III r- m r- 0"" a. R(rumr ..E-~~'Pl ':lONer I'" I.J A,. V 0'01 NCTFQRINt[R,."'nO,....LMAlL , ' , r-s...."',{ POSTMARK OR DATE 1l[<;lt"CT~::: ~(~;~'f.'~ .:r'HI,t=-'" . "f","',IlCfPf '0'-'<. ~'J;r':";E .....G 'EE., SENT TO: ..\':tH~L:. '-t.. l;eVJ:~ -'- _r~ 'j . ":"'- /" <.' . ,..- \ t',:.' -.' . ~-.~ ";:.!6 ~';(<11'l! "!C :~-: Si!1 ::."%;,' eJ....':? .t~~...... ::"..t ~ ::01 ~ DVV\K PS FORM 3800 US Postal Service Receipt for Certified Mail RETUAN RECEIPT SERVICE TOTAlP'JSTA,.EAACFEES N IN U AN V ROVIO_ Nor FOR INTERNAnONAL MAIL ! OfN ~ llOf f'08T.i....E IlEsrRICTEor;EU'IE;:;y POSTMARK OR DATE GERTIF'EOfEE-IlE.URNREGEIPT SENT TO: .:!~~,~;?F'!:~ 7. :.t;::o,' ,::~'2 J.,~::lo';'~.~ :it~T~' .~T::L~ET c?-\.' J/ f';; ----'. ' 5: "'0 \ \ ~'t::'~"'i~J \-' ~;;:/' .'.....,\ '~/.~ '."~ ./ ',' 1,;-:"--., ,,/ ,. '/'j."I '" .........:...- - ~ Li.'i1l !iL..L, P.' . ":'."., . , ...lL OWl K PS FORM 3800 US Postal Service Receipt for Certified Mail ti; C") '- C": f.- ;<5 -/ lJ.I8 A ~~.1 ;;: (J- fj:c :c; ~i-!' CL, <.~ (. c> --';!;~ (; Ujl.". .--I;~ ctLt. -.--" >- . n(Ci " ..._( F' ~.'~ 0._ .. :..:: 1.!~ c:> :.3 0 c.., C;J . '-' STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55, I, - nun____ _n _[l9_i!.~r L?'_~j_e.g!!!J'_n_n n_ __nhUUn _n_ __n__ n__ ____ _ n__ Reeo.der 01 Deed. in and lor said Count)' and Slale do hereb)' eertil)' that the Sheriff'. Deed in whieh h__n______u__ Bank United . --------------------------- ---------------.----- ---.---- ----------------- ----_______ 15 the grantee , 7th the same having been sold to said granlee on the ---------------h-__________________________u_ day of nh______~~~~_n___n____n___n____n_ A. D., 9n__~!l_~?under and by virtue ola writ______________ n___~~~_'":.~~~.?_~_h_______n__n_ _____ ___n_n__ i..ued on the _____ _n__~~!:~_n____ ____n____n___ February ~ 00 day or nh___nnn_____________ A. D., I"n____' oul or the Court or Cornman PIe.. or !laid County as 01 civil 99 n_____________n___ n_nh n _.. __ u_ - - - __ _ _ n _ __ __ __n__ _ _ __ _n_n __ __ n_ _ __ _ _ _ _ _ Tenn, 19_ __ ____ 1914 Bank United Number ______________, at the suit or ______________________________________________________________. ----------- ------------ ------ -. - - - - againsL__:~~~_~: ~.:__~ _~~_~~_~__~~~:_~~_ ~_ _~ ~~~_~___ __ _____ it dul)' recorded in Sherirr. Deed Book No. _ _: ~~ _ _ _ ___ _, Page n ~~_~___ _n' IN TESTIMONY WHEREOF, I have hereunto .et m)' hand and .eal ol.aid office Ihis ___:Z~____ day 01 ____~_~/}.__s.n_____n___n____ A, D,. t9"_c9-~ ~~~~.;;:~in;.d.. llecerdef" Deeds, OImlledond Coulllr, CIrtisle, M IIJOIl"" , .1,Elpiwaa,rilllllllllll.......... Bank United In the Court of Common Pleas of -vs- Cumberland County,Pennsylvania Jennifer L.Mohn and Andrew M. Coover No. 99-1914 Civil lIarold J. Weary, Deputy SheriITwho being duly sworn according to law. says on March 29. 2000 at 4: 13 o'clock P.M. EST, he posted a copy o!' Rcal Estate Writ Notice Poster and Description, in the above entitled action upon the property of Jennifer Mohn and Andrew Coover located at 226 North 36th Street. Camp Hill. Cumberland County. Pennsylvania according to law, Richard E. Smith Deputy SheriITwho being duly sworn according to law. says on April 6, 2000 at 10:27 o'clock A.M. EDST. he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Jennifer Mohn by making known unto Martin ManaH, husband at 226 North 36th Street. Camp Hill, Cumberland County. Pennsylvania. its contents and at the same time handing to him personally the said true and attested copies of the same. 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: Jennifer Mohn by first class mail to 226 North 36th Street, Camp Hill, Pennsylvania. This letter was mailed under the date of April 7,2000 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff who 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 out cry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 7, 2000 at 10:00 o'clock A.M. EDST and sold the same for the sum 01'$ 1.00 to Dale Shughart JR. for Bank United. It being the highest bid and best price quoted for the same Bank United of 3200 Southwest Freeway, Mail Drop 1422, Houston Texas paid to Sheriff R. Thomas Kline the sum of $ 1.0 I 1.04 it being costs. Sheriffs Costs Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds 30.00 19.82 15.00 15.00 30.00 10.00 .50 1.00 18.60 1.17 15.00 30.00 423.50 324.15 24.80 25.00 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Und!rAct No. 587. AoomuM Mau 16.1929 Commonwealth 01 Pennsylvania, County 01 Dauphin} S8 Michael Morrow being duly sworn according to low, deposes and says: Thai he is tho Asslslanl Controllor 01 THE PATRIOT.NEWS CO.. a corporallon organized and existing under Ihe laws 01 Iho Commonwoalth 01 Ponnsylvanla, with its principal office and place of business al B12 10 BIB Markel Slreet, In Ihe City 01 Harrisburg, Counly 01 Dauphin, Slate of Pennsylvania, owner and publisher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS nowspapers of general circulation, prlnled and published 01 B12 10 B18 Market Slreel, In Iho Cily, Counly and Slale aforesaid; Ihat THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS were eslabllshed March 4th, 1854, and September lBlh, 1949, respectively, end all have been continuously published aver since; Thai Ihe printed notlco or publication which Is securely altached hereto Is exaclly as prlnlad and published In Ihelr rogular dally and/or Sunday and Metro edltlonsllssuos which appeared on the 2nd, 91h end 16th day(s) of May 2000. That neither he nor said Company Is In Ie res led In the subject molter of said printed notice or advertising, and Ihal all of Ihe allegations of Ihls statement as to the time, place and character of pubtication are true; and That he has personal knowledgo of the facts aforesaid and Is duly authorized and empowered to verify this slatemenl on behalf of The Patrlot.News Co. aforesaid by virtue and pursuant to a resolullon unanimously passed and adopted severally by the stockholders and board of dlrecto s of the said Company and subsequently duly recorded In the office for the Recording 01 Deods In and for said Count of auphl'1ln Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy s ALE #16 n to and subscribed be re Nolanal Seal 7 h Terry ,L. Russell. Notary Public P/ I ~ HarriSburg, Daupl1ln County My Commission Ell'Pites June 6. 2002 N ARV PUBLIC Member, Pennsylvania ASSOCiatiOn Of NOI I commission expires June 6, 2002 ~ 1;,1>\"'" -A ";:'; -.. ,c- ;;.,,~~~t'f}r EA1;E8TATE . " . -!(!(;'\;'.ci" ,WrltNo.,!A1EHo.18 . ~.~ \"""J1:f~,~ i CMlr;;:.~~4 , 'Jq3~',,,,\,c .~.,~,,;:. . I "jilt J;"!\':'). -"~.1tV ' . <.:f" ,f:"",, \ "' l VI'1 t ~~;it~~'t:1:tLlIof\,;ind "',,' , .;.t,'~:l~p &:'. . , . u -'.' , ; ~rflnk ~;,:;;" c'~ c ~aescA ON ~ctRJ: JototlWslhLi In t. "',.~1~~:Iv~:tc(, , bOiilidiir:ll1id" deiiiiiiil'~ ; ,e,~:::.wr,,"':"":'-~~",':'~ :1/ir~:-s.'J~::(~i~:~;;v~ . _lIrr.;;'h,~...-f'r:Jl.!l~'~(!~~ltnowor' CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURlHOUSE CARLISLE, PA. 17013 Statement of Advertisina Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication allached hereto on the above stated dates $ Probating same Notar/ Fee(s) $ Total $ 322.65 1.50 324,15 Publisher's Receipt for Advertising Cost THE PATRIOT-NEWS CO., pUblisher ofTHE PATRIOT-NEWS and THE SUNDAY PATRIOT.NEWS, newspapers of general circulation. hereby acknowledge recoipt of the aforesaid notice and publication costs and certifies that the seme have been duly paid. THE PATRIOT-NEWS CO. By.............................................................."'... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approvcd May 16, 1929), p, L.1784 STATE OF PENNSYLVANIA : 55, COUNTY OF CUMBERLAND : Roger M, Morgentbal, 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 28. MAY 5. 12, 2000 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. REAL ESTATE SALE NO. 16 Wrtt No. 99.1914 CIvil Bank United VS, JennIfer L. Moho and Andrew M. Cover Atty.: Frank Federman DE:SCRlPTION ALL THAT CE:RTAlN lot or land situate In the Township of Hampden. County of Cumberland and State of Pennsylvania. more particularly bounded and descrtbed as follows: BE:GINNING at a point on the Southwestern legal right-oC-way line , of Wood Street at the Southeastern comer of lands now or formerly of Albert and Ellzabeth Schaflhauser: thence along the legal right-oC.way line of Wood Street by a curve to the left having a radius of 58 feel. nn arc \ distance of 60.72 feet to an "x" In the " concrete at the Intersectlon of the i"/~ Rogett'M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 12 day of MAY. 2000 NOTAR1^t seAL tDlG E. SNYOER, ,"""')' Publk Car1id. 150'0, Cumb.rlond County, PA My Commillion Expir.. March .5, 200 1 ~ . . You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MA Y STILL BE ABLE TO SA VE YOUR PROPERTY AND YOU If A VE OTHER RIGIfTS EVEN IF THE SHERIFF'S SALE nOES TAKE PLACE, I. If the SherifCs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution 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 LA WYER 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 A VENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 II , r "" . DESCRIPTIO:>; I ALL TH.-\T CERTAIN lot or land situate in the Township or Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: I BEGINNI:-;G at a point on the Southwestern legal right,of-way line of Wood Street at the Southe:lstern corner or l:lnds now or formerly or Albert and Elizabeth Schafthauser: thence along the leg:ll right-or'-w:lY line or Wood Street by a curve to the left having J radius of 58 reet, an :lCC distance or 60. i2 reet to an "x" in the concrete at the intersection of the southern legal right-of-way line or Wood Street with the western leg:ll right-or-way line or North 36th Street: thence through Lot :-10. 162 or' which this was rormerly a part, the following three courses and distances: (1) South 46 degrees 17 minutes 23 seconds West. a distance or 75.87 feet; (:!) through the party wall sep:lrating the house known as 226 Wood Street. hereon erected. :lnd house known as 22~ Wood Street, South 54 degrees ~2 minutes ~O seconds West. a distance of 30.077 feet: (3) South 72 degrees 18 minutes 58 seconds West, a distance of 167.29 feet to a p.k. nail in tree; thence North 19 degrees 2~ minutes 30 seconds West, :l distance of ~5 feet to a tree at the Southwestern corner or' lands now or formerly of .-\Ibert and Eliz:lbeth S.:h:lffhauser: thence :llong lands now or formerly or Sch:lftl1auser. North 63 degrees 07 minutes 0 seconds East. 225.1~ feet to a point. the place of beginning. BEI:-iG the :-iorthern portion of Lot :-io. 162 as shown on Plan of Hollywood Development. as recorded in Plan Book 9. page 17, Cumberland County Records. and further being Lot :-io. 162-B, Preliminary-Final Subdivision of Lot No 162 Hollywood Development. dated January 22. 1981 recordeu in Plan Book . page HAVING thereon erected a semi-detached dwelling known as 226 North 36th ~treet, Camp Hill, Pennsylvania. Also being known as 226 Wood Street. Camp HIli, Pennsylvania. Tax Parcel /I 10-20-1850-040D TITLE TO S.-\ID PREMISES IS VESTED IN Jennifer Lynn Mohn: single and Andrew ~~. Cover, Jr.. single as Joint Tenants with the Right of Survivorsh~p by Deed tram Tho~~as ~l. ~~arl..ley and Dinah S'::lbo-Markley. his wife and Doris J. Mowery, single person dated II'JO/9_. re.orded 12/4/92, in Deed Book A-36, Page ~48. . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANtA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF _Cumberl1!Dd COUNTY: To satls'y the debt, Inleres. end COSls due _!lank United NO. 99-1914 CIVIL tGC-.:Ji'rm CIVIL ACTION. LAW PLAINTlFF(S) 'rom Jennifer L, /obhn llnd Andrew M, Cover, 226 North 36th Street, CIlJTp HIll, PA 17011 DEFENDANT(S) (1) You are directed to levy upon the property 01 Ihe delendanl(s) and 10 sell See Legal Description I (2) You are also directed 10 allach Ihe property of the defendant(s) not levied upon in Ihe possession 01 _ GARNISHEE(S) as lOllows: I and 10 nolffy Ihe garnishee(s) that: (a) an allachment has been issued; (b) Ihe garnishee(s) Is/are enjoined from paying any debIto or for the accounl 01 the defendant(s) and from delivering any property 01 Ihe defendant(s) or otherwise disposing thereof; (3) If property 01 the defendant(s) nol levied upon an Subject 10 allachment is lound in the possessionol anyoneolher than a named garnishee. you are direcledlo notify hiOVherlhat he/she has been added as a garnishee and Is enjoined as above slaled. $85,775,88 from 1/4/00 - 6/7/00 ~2,le5 50 aRG CGsts Amounl Due Inleresl Ally's Comm Ally Paid Plainlilf Paid % L.L. Due Prolhy Other Cosls $,50 n.OO S160 lO Dale: F"'brua~ 22. 2000 Cllrt-i.c:: R _ T I1ng Prothonotary, Civil Division ~ .an.,,-,. p ~~-Ir-- ~ Deputy REQUESTING PARTY: Name Frank Fedenran, Esq, Address: '!Wo Penn Center Plaza Suite 900 Philadelphia, PA 19102 Altorney tor: Plaintiff Telephone: 215-563-7000 Supreme Court fD No. 12248 .- ff' " }"":: : f',....;_. ,-- ~-. , ....- . --- ~.\ 1 0,>) '.; ./ ~ -- -' - -. - -' ~- ~J!S~' '-. -....----. " , f h Prothonotary ,,_ Office 0 t e C IrthouSlr,;:' ,c'_'"1 b I nd County Ol " "".,,, Cum er a _ _\-, ',"" 1 Courthouse Squareo:. , " , I 1; 17013 ,., or. , Carlisle, PA _ (,' :,.. !] ..: ,.. '_ ." '( C' T:,.::: .~.. '_. ,_' .:>",. ...,. . -\'~ '.~ IL /. ., ,,", i~'t11"'" ~~. ~RA8(f ...... .... A, DDf/ESSro FOf/WAf/O/Jli ORDIH I;';?/Hr;, .. Andrew M. co~ver 226 North 36th SIr Camphill, PA I (Q~ ~~D~ .. .... .' .j .....,.., . E'EDERr-'.AN JU1D P~:::"l\~: Fran;'; Federman, Esqu: r') Identification r-;o, 122~3 Two Penn Center Pla:a Sui te 900 Philadelphia, PA 19102-1799 (215) 563-7000 BANK UNITED A7,OPNE'( fOR PLAW,I" COURT Of COMMON PLEAS vs, CIVIL DIVISION CUMBERLAND COUNTY NO, 99-1914-CIVIL TERM Plaintiff JENNIFER L. MOHN ANDREW M, COVER Defendant(s) TO: JENNIFER L, MOHN 226 NORTH 36TH STREET CAMPHILL, PA 17011 DATE OF NOTICE: DECEMBER 22, 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, ANY INfORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY, 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 Frank Federman, Esquire Attorney for Plaintiff . - . . ~ %lAY' 2 fj' /,qSS ,t~ BY: Lisa D. Blankenburg, Esq, ACCy, I.D. #78020 SCe. 900/Two Penn CenCer Plaza Philadelphia, PA 19102 (215) 563-7000 BANK UNITED COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No, 99-1914-CIVIL vs. JENNIFER L, MOHN ANDREW M, COVER ORDER AND NOW, chis ~ 7 'n 1l1il , 1999, upon day of consideracion of Plainciff' s Mocion and the Affidavic of Good Faich Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of che Complaint on the above captioned Defendant(s), ANDREW M. COVER, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address at 226 NORTH 36TH STREET, CAMPHILL, PA 17011, i"\ , S~tVice .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 as to the mailing. BY THE COURT: l.s/ i:irr<-- 8, a3a-.~'J J. CORRECTION Previous Image Refilmed to Correct Possible Error 1 , - BY: Llsa 0, Blankenburg. Esq. A~~y, I,D. "'8020 S~e. 900/Two Penn Cen~er Plaza Philadelphia, PA 19102 (215) 563 -7000 BANK UNITED ~:... oWA ~ 2.'i l.q9~, l ~ COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No, 99-1914-CIVIL vs. JENNIFER L, MORN ANDREW M, COVER ORDER AND NOW, ~his ,.;[7 day of 'n:j./1(l , 1999, upon considera~ion of Plain~iff's Mo~ion and ~he Affidavi~ of Good Faith InveS~iga~ion attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), ANDREW M. COVER, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address at 226 NORTH 36TH STREET, CAMPHILL, PA 17011. '\ , Se,t'irice ,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 as to the mailing. BY THE COURT: I~/ Cdr<- 8. ~d J.