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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION
1100 CORPORATE CENTER DRIVE
RALEIGH, NC 27607-5066
Vs.
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
. CIVIL DIVISION
. NO. 99-3995 CIVIL
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
G FRANKLIN EICHELBERGER A/K/A GUY FRANKLIN EICHELBERGER, A/K/A
GUY EICHELBERGER AND LINDA MARIE EICHELBERGER A/K/A LINDA M.
EICHELBERGER, 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 $66,036.74
Interest - 6/1/99 TO 9/7/99 $ 1,564.20
TOTAL $67,600.94
I hereby certify that (1) 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.
DAMAGES ARE HEREBY ASSESSED AS INDI
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DATE:
FRANK FEDERMAN, ESQUIRE
Attorney for laintiff
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FEDERMAN AND PHELAN
Frank Federman, Esquire
} Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
FIRST UNION MORTGAGE
CORPORATION, S/B/M TO SIGNET
MORTGAGE CORPORATION
Plaintiff
Vs.
G. FRANKLIN EICHELBERGER, A/K/A
GUY FRANKLIN EICHELBERGR, A/K/A
GUY EICHELBERGER
LINDA MARIE EICHELBERGER, A/K/A
LINDA M. EICHELBERGER
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-3995 CIVIL
TO: LINDA MARIE EICHELBERGER, A/K/A
LINDA M. EICHELBERGER
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
DATE OF NOTICE: AUGUST 10, 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 to enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (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
FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
FIRST UNION MORTGAGE
CORPORATION, S/B/M TO SIGNET
MORTGAGE CORPORATION
Plaintiff
VS.
G. FRANKLIN EICHELBERGER, A/K/A
GUY FRANKLIN EICHELBERGR, A/K/A
GUY EICHELBERGER
LINDA MARIE EICHELBERGER, A/K/A
LINDA M. EICHELBERGER
Defendant(s)
ATTORNEY FOR PLAINTIFF
. COURT OF COMMON PLEAS
. CIVIL DIVISION
. CUMBERLAND COUNTY
NO. 99-3995 CIVIL
TO: G. FRANKLIN EICHELBERGER, A/K/A
GUY FRANKLIN EICHELBERGER, A/K/A
GUY EICHELBERGER
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
DATE OF NOTICE: AUGUST 10, 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 to enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (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
FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
ATTORNEY FOR PLAINTIFF
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION
. CUMBERLAND COUNTY
. COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
. NO. 99-3995 CIVIL
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is
attorney for the Plaintiff in the above-captioned matter, and that
on information and belief, he has knowledge of the following facts,
to wit:
(a) that the defendant(s) 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 G. FRANKLIN EICHELBERGER, A/K/A GUY
FRANKLIN EICHELBERGER, A/K/A GUY EICHELBERGER is over 18 years of
age and resides at 924 ALEXANDER SPRING ROAD, CARLISLE, PA 17013.
(c) that defendant LINDA MARIE EICHELBERGER, A/K/A LINDA
M. EICHELBERGER is over 18 years of age, and resides at 924
ALEXANDER SPRING ROAD, CARLISLE, PA 17013.
This statement is made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities.
F K FEVER ESQUIRE
Attorney for Plaintiff
(Rule of Civil Procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION )
) NO. 99-3995 CIVIL
Plaintiff
VS.
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER )
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER )
Defendants
Notice is given that a Judgment in the above-captioned
matter has been entered against you on SEPTEMBER 1999.
By: Y
,
If you have any questions concerning this matter, please
contact:
FE ER ESOUiRF
Att rney for Party Filing
Two Penn Center Plaza, Suite 900
Philadelphia, PA 19102
(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 HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
FIRST UNION MORTGAGE
CORPORATION, S/B/M TO SIGNET
MORTGAGE CORPORATION
Plaintiff
Va.
G. FRANKLIN EICHELBERGER, A/K/A
GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER, A/K/A
LINDA M. EICHELBERGER
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 99-3995 CIVIL
PRAECIPE FOR WRff OF EXFkVnON
(MORTGAGE FORECLOSURE)
Defendant(s)
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due $67.600.94 V/
Interest from 9/7/99 TO $ 1,033.23 and Costs
12/8/99
(PER DIEM - $11.11)
$68,634.17 Total
FRANI FEDERMAN ESQUIRE
TWO PENN CENTS PLAZA
SUIT 900
PHILADELPHIA, PA 19102
Attorney for Plaintiff
Note: Please attach description of property.
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DESCRIPTION
ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County,
Pennsylvania more particularly bounded and described in accordance with a Survey by Stephen G.
Fisher, R.S. dated November 4, 1976 (revised) as follows:
BEGINNING at an iron pin on the Northern dedicated right-of-way line of the Alexander Spring
Road (T-467) a 33 foot right-of-way said iron pin being also at the Southeast comer of Lot No. 6 of
the hereinafter mentioned Plan of Lots; thence along the dividing line of Lots No. 5 and 6 North 36
degrees, 56 minutes, 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of
Lot No. 6 North 31 degrees, 21 minutes, 40 seconds East 96.63 feet to an iron pin at the corner of
Lots Nos. 6 and 7; thence along the dividing line of Lots Nos. 6 and 7 South 58 degrees, 38
minutes, 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of
Alexander Spring Road (T-467); thence along said right-of-way line South 31 degrees, 21 minutes,
40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way
line in an arc with a radius of 290.0 feet a distance of 89.18 feet (erroneously described as 82.35
feet in prior Deed) to an iron pin, the point and place of beginning.
BEING Lot No. 6 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County
Recorder of Deeds Office in Plan Book 29 page 41.
TITLE TO SAID PREMISES IS VESTED IN G. Franklin Eichelberger and Linda Marie
Eichelberger, his wife by Deed from John M. Shearer and Rebecca S. Shearer, his wife and Jay A.
Galloway and Patricia D. Galloway, his wife dated 1/28/83 recorded 2/1/83 in Deed Book B-30
page 3.
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FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION
VS.
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-3995 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
FIRST UNION MORTGAGE CORPORATION, S/B/M TO SIGNET MORTGAGE
CORPORATION , Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ
of Execution was filed the following information concerning the
real property located at 924 ALEXANDER SPRING ROAD, CARLISLE, PA
17013.
1. Name and address of owner(s) or reputed Owner(s):
NAME
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN
EICHELBERGER,
A/K/A GUY EICHELBERGER
924 ALEXANDER SPRING ROAD
CARLISLE. PA 17013
LINDA MARIE EICHELBERGER, 924 ALEXANDER SPRING ROAD
A/K/A LINDA M. EICHELBERGER CARLISLE, PA 17013
CARLISLE. PA 17013
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
4. Name and address of the last recorded holder of every mortgage
of record:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
PENNSYLVANIA HOUSING 2101 NORTH FRONT STREET
FINANCE AGENCY HARRISBURG, PA
5. Name and address of every other person who has any record lien
on the property:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
7. Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
NAME
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
TENANT/OCCUPANT
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
13 NORTH HANOVER STREET
CARLISLE, PA 17013
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 of 18 Pa. C.S. Sec. 4904 relating
to unsworn falsification to authorities.
September 4, 1999
DATE F. K FEDER , ESQUIRE
At rney for Plaintiff
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION
Va.
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
ATTORNEY FOR PLAINTIFF
. CUMBERLAND COUNTY
. COURT OF COMMON PLEAS
. CIVIL DIVISION
. NO. 99-3995 CIVIL
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:
( ) an FHA mortgage
( ) non-owner occupied
( ) vacant
(XX) 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.
F K FEDERMAI, ESQUIRE
Attorney for Plaintiff
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FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE
CORPORATION CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Va.
CIVIL DIVISION
G. FRANKLIN EICHELBERGER, A/K/A
GUY FRANKLIN EICHELBERGER, A/K/A
GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER NO. 99-3995 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
September 4, 1999
TO: G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
**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, 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 924 ALEXANDER SPRING ROAD.
CARLISLE. PA 17013, is scheduled to be sold at the Sheriff's Sale
on DECEMBER 8, 1999 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce
the court judgment of $67,600.94 obtained by FIRST UNION MORTGAGE
CORPORATION, S/B/M TO SIGNET MORTGAGE CORPORATION (the mortgagee)
against you. If the sale is postponed, the property will be
relisted for the MARCH 1, 2000 Sheriff's Sale.
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.
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.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will
be sold to the highest bidder. You may find out the price bid by
calling (215) 563-7000.
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate 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 proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff not later than
thirty (30) days after the sale. The schedule shall be kept on
file with the SHeriff and will be made available for inspection in
his office. The 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 filing of
the proposed schedule.
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 ATORNEY REFERRAL
CUMBERLAND COUNTY BAR ASOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
DESCRIPTION
ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County,
Pennsylvania more particularly bounded and described in accordance with a Survey by Stephen G.
Fisher, R.S. dated November 4, 1976 (revised) as follows:
BEGINNING at an iron pin on the Northern dedicated right-of-way line of the Alexander Spring
Road (T-467) a 33 foot right-of-way said iron pin being also at the Southeast comer of Lot No. 6 of
the hereinafter mentioned Plan of Lots; thence along the dividing line of Lots No. 5 and 6 North 36
degrees, 56 minutes, 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of
Lot No. 6 North 31 degrees, 21 minutes, 40 seconds East 96.63 feet to an iron pin at the comer of
Lots Nos. 6 and 7; thence along the dividing line of Lots Nos. 6 and 7 South 58 degrees, 38
minutes, 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of
Alexander Spring Road (T-467); thence along said right-of-way line South 31 degrees, 21 minutes,
40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way
line in an arc with a radius of 290.0 feet a distance of 89.18 feet (erroneously described as 82.35
feet in prior Deed) to an iron pin, the point and place of beginning.
BEING Lot No. 6 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County
Recorder of Deeds Office in Plan Book 29 page 41.
TITLE TO SAID PREMISES IS VESTED IN G. Franklin Eichelberger and Linda Marie
Eichelberger, his wife by Deed from John M. Shearer and Rebecca S. Shearer, his wife and Jay A.
Galloway and Patricia D. Galloway, his wife dated 1/28/83 recorded 2/1/83 in Deed Book B-30
page 3.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION
Plaintiff
Vs.
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
Defendants
CIVIL DIVISION
No. 99-3995 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS:
I, FRANK FEDERMAN, ESQ., attorney for FIRST UNION
MORTGAGE CORPORATION S/B/M TO SIGNET MORTGAGE CORPORATION,
hereby verify that on SEPTEMBER 21. 1999, true and correct copies
of the Notice of Sheriff's Sale were served by certificate of
mailing to the recorded lienholder(s), and any known interested
party, see Exhibit "A" attached hereto, and the Notice of Sale
was sent to defendant(s) on SEPTEMBER 15. 1999 by first class
mail and certified mail return receipt requested, see Exhibit nB"
attached hereto.
RANK FED MAN, ESQUIRE
Attorney or Plaintiff
Date: November 8. 1999
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION
Plaintiff CIVIL DIVISION
VS.
No. 99-3995 CIVIL
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
Defendants
AMENDED
AFFIDAVIT OF SERVICE PURSUANT TO RULE. 3129
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS:
I, FRANK FEDERMAN, ESQ., attorney for FIRST UNION
MORTGAGE CORPORATION, S/B/M_ TO SIGNET MORTGAGE CORPORATION ,
hereby verify that on SEPTEMBER 21, 1999 AND NOVEMBER 29, 1999,
true and correct copies of the Notice of Sheriff's Sale were
served by certificate of mailing to the recorded lienholder(s),
and any known interested party, see Exhibit "A" attached hereto,
and the Notice of Sale was sent to defendant(s) on SEPTEMBER 15,
1999 by first class mail and certified mail return receipt
requested, see Exhibit "B" attached hereto.
FRANK FED4RMAN, ESQUIRY4
Attorney for -
Plaintiff
Date: December 1, 1999
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION
VS.
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-3995 CIVIL
AMENDED
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
FIRST UNION MORTGAGE CORPORATION, S/B/M TO SIGNET MORTGAGE
CORPORATION , Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ
of Execution was filed the following information concerning the
real property located at 924 ALEXANDER SPRING ROAD. CARLISLE PA
17013.
1. Name and address of Owner (s) or reputed Owner(s):
NAME
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN
EICHELBERGER,
A/K/A GUY EICHELBERGER
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
LINDA MARIE EICHELBERGER, 924 ALEXANDER SPRING ROAD
A/K/A LINDA M. EICHELBERGER CARLISLE, PA 17013
CARLISLE, PA 17013
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
4. Name and address of the last recorded holder of every mortgage
of record:
NAME
PENNSYLVANIA HOUSING
FINANCE AGENCY
UNITAS BANK
C/O DONALD KORNFIELD
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
2101 NORTH FRONT STREET
HARRISBURG, PA
17 NORTH CHURCH STREET
WAYNESBORO, PA 17268
5. Name and address of every other person who has any record lien
on the property:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
7. Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
NAME
TENANT/OCCUPANT
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
13 NORTH HANOVER STREET
CARLISLE, PA 17013
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 of 18 Pa. C.S. Sec. 4904 relating
to unsworn falsification to authorities.
December 1, 1999
DATE F YANK FEDE , ESQUIRE
Attorney for Plaintiff
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION
Vs.
Attorney for Plaintiff
COURT OF COMMON PLEAS
COUNTY
CIVIL DIVISION
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER NO. 99-3995 CIVIL
WAIVER OF THIRTY-DAY NOTICE
OF SHERIFF'S SALE
Unitas National Bank hereby acknowledges receipt of the Notice
of Sale with respect to the instant matter and waives the thirty-
day notice required to be given under Rule 3129 of the Pa. Rules of
Civil Procedure in connection with the Sheriff's Sale scheduled for
the above-captioned matter on Wednesday, December 8, 1999.
UNITAS NATIONAL BANK 0
C/0'DONALD ORNF n
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IN SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03995 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST UNION MORTGAGE CORP
VS.
EICHELBERGER G FRANKLIN ET AL
J. MIKE ICKES Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE AND COMPLAINT IN was served
upon _EICHELBERGER LINDA MARIE A/K/A EICHELBERGER LINDA M the
defendant, at 20:35 HOURS, on the 19th day of July
1999 at 924 ALEXNADER SPRING ROAD
CARLISLE, PA 01013 CUMBERLAND
County, Pennsylvania, by handing to LINDA MARIE EICHELBERGER
a true and attested copy of the NOTICE AND COMPLAINT IN
together with MORTGAGE FORECLOSURE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 6.00
Service .00 irC
Affidavit .00
Surcharge 8.00 omas in 5 ei
$14 FEDERMAN & PHELAN
07/20/1999 by ?i-
?UPULY
e i
Sworn and subscribed to before me
this la = day of
19 9LI A.D.
rocnonota
ti
CASE NO: 1999-03995 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST UNION MORTGAGE CORP
VS.
EICHELBERGER G FRANKLIN ET AL
J. MIKE ICKES , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE AND COMPLAINT was served
upon FRANKLIN G EICHELBERGER A/K/A EICHELBERGER GUY FRANKLIN the
defendant, at 20:35 HOURS, on the 19th day of July
1999 at 924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to LINDA MARIE EICHELBERGER
a true and attested copy of the NOTICE AND COMPLAINT
together with IN MORTGAGE FORECLOSURE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:_
Docketing 18.00
Service 3.10 Affidavit 100
Surcharge 8.00 R. I mas i FED07/E0/ 1999 P/HELAN
by ? e ?
Pu 999Y eritr
Sworn and subscribed to before me
this d - T__ day of
19 A. D.
I' wTL Fr?f no ?y'?
FEDERMAN AND PHELAN
BY: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
FIRST UNION MORTGAGE CORPORATION COURT OF COMMON PLEAS
PLAINTIFF
VS. CUMBERLAND COUNTY
No. 99-3995-CIVIL
G. FRANKLIN EICHELBERGER
LINDA MARIE EICHELBERGER
DEFENDANT
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification with
respect to the Complaint filed in the instant matter.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
Date: August 30. 1999
A
VERIFICATION
KEVIN COLGAN hcreb.N states that hu is ASSISTANT SECRETARY of FIRST UNION
MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter. that he is
authorized to take this Verification. and that the statements made in the foregoing Civil Action in
Mortgage Foreclosure are true and correct to the best of Iris kno%%lodge. information and belief.
The undersigned understands that this statement is made subjcet to the penultics of I g Pa. C.S.
Sec. 4904 relating to unsworn talsification to authorities.
DATE:
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION
1100 CORPORATE CENTER DRIVE
RALEIGH, NC 27607-5066
V.
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. W• 3W
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
Defendant(s)
CUMBERLAND COUNTY
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
4?1
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.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Plaintiff is
FIRST UNION MORTGAGE CORPORATION,
SB/M TO SIGNET MORTGAGE CORPORATION
1100 CORPORATE CENTER DRIVE
RALEIGH, NC 27607-5066
2. The name(s) and last known address(es) of the Defendant(s) are:
G. FRANKLIN FRANKLIN,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described
3. On 4/8/87 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to MEREDITH MORTGAGE CORPORATION which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 859, Page 607. By Assignment of Mortgage dated 6/3/87 the mortgage was assigned
to CITIZENS SAVINGS BANK, FSB which Assignment is recorded in Assignment of
Mortgage Book No. 398, Page 820. By Assignment of Mortgage dated 10/30/95 the
mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of
Mortgage Book No. 511, Page 992.
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 3/1/99 and each month thereafter are due and unpaid, and by the terns of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith. A copy of such notice is attached as Exhibit "A."
6. The following amounts are due on the mortgage:
Principal Balance $60,687.17
Interest 1,927.60
2/1/99 through 6/1199
(Per Diem $15.80)
Attomey's Fees 3,034.00
Cumulative Late Charges 87.52
4/8/87 to 6/1/99
Cost of Suit and Title Search 550.00
Subtotal 66,286.29
Escrow
Credit 249.55
Deficit 0.00
Subtotal 24( 9.55)
TOTAL $66,036.74
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 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 Plaintiffs written Notice to Defendants,
a true and correct copy of which is attached hereto as Exhibit `B'; or
(ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
t•
10. 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.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$66,036.74, together with interest from 6/1/99 at the rate of $15.80 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
First Union Mortgage Corpora
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GUY EICHELBERGER
924 ALEXANDER SPRING RD
CARLISLE, PA 17013
April 30, 1999
RE: FUMC Loan Number 0009599662
NOTICE OF INTENTION TO FORECLOSE
First Union Mortgage Corporation is the holder of the mortgage on your property located at 924
ALEXANDER SPRIN, which mortgage is in SERIOUS DEFAULT because you have not made the
current monthly payment of 744.74 for 03/01/1999 through 04/01/1999. Late charges (and other charges)
have also occurred in the amount of 58.26. The total amount now required to cure this default, or in other
words, get caught up in your payments, as of the date of this letter is 1610.00.
You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30)
days of receipt of this letter, we will obtain and provide you with written verification thereof, otherwise,
the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter,
we will send you the name and address of the original creditor if different from above.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above
amount of 1610.00, plus any additional monthly payments and late charges which may fall due during this
period. Such payment must be made in the form of certified check, cashier's check or money order, and
made at First Union Mortgage Corporation, ATTN: Cash Processing, P.O. Box 900001, Raleigh, NC
27675-9000.
If you do not cure this default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the
mortgage payments. This means whatever is owing on the original amount borrowed will be considered
due immediately and you may lose the chance to pay off the original mortgage in monthly payments. If
the full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a
lawsuit to foreclose on your mortgaged property.
If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage
debt. If you cure the default before we begin legal proceedings against you, you will still have to pay the
reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against
you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees
will be added to whatever you owe us, which may also include our reasonable costs. If you cure this
default within the THIRTY (30) DAY period, you will not be required to pay the attorney's fees. YOU
HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN
EXHIBIT A
• ????? Raleigh First Union Mortgage Corporadon
Post Oce Box North Ceroona 276754MI
UN N 1100 Corporate Center Drive
l1v Raleigh, North Carolina 276075066
LINDA EICHELBERGER
924 ALEXANDER SPRING RD
CARLISLE, PA 17013
April 30,1999
RE: FUMC Loan Number 0009599662
NOTICE OF INTENTION TO FORECLOSE
First Union Mortgage Corporation is the holder of the mortgage on your property located at 924
ALEXANDER SPRIN, which mortgage is in SERIOUS DEFAULT because you have not made the
current monthly payment of 744.74 for 03/01/1999 through 04/01/1999. Late charges (and other charges)
have also occurred in the amount of 58.26. The total amount now required to cure this default, or in other
words, get caught up in your payments, as of the date of this letter is 1610.00.
You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30)
days of receipt of this letter, we will obtain and provide you with written verification thereof, otherwise,
the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter,
we will send you the name and address of the original creditor if different from above.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above
amount of 1610.00, plus any additional monthly payments and late charges which may fall due during this
period. Such payment must be made in the form of certified check, cashier's check or money order, and
made at First Union Mortgage Corporation, ATTN: Cash Processing, P.O. Box 900001, Raleigh, NC
27675-9000.
If you do not cure this default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the
mortgage payments. This means whatever is owing on the original amount borrowed will be considered
due immediately and you may lose the chance to pay off the original mortgage in monthly payments. If
the full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a
lawsuit to foreclose on your mortgaged property.
If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage
debt. If you cure the default before we begin legal proceedings against you, you will still have to pay the
reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against
you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees
will be added to whatever you owe us, which may also include our reasonable costs. If you cure this
default within the THIRTY (30) DAY period, you will not be required to pay the attomey's fees. YOU
HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN
EXHIBIT A
THE FORECLOSURE PROCEEDINGS THE NON-EXISTANCE OF A DEFAULT OR ANY OTHER
DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE.
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage. If you have not cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, you still have the right to cure the default and prevent sale at any time up to one
hour before the Sheriffs foreclosure sale. You may do so by paying the total due, as well as the reasonable
attorney's fees and cost incurred in connection with the foreclosure sale (and perform any other
requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs Sale could be
held would be approximately six months from the date of this letter. A notice of the date of the Sheriffs
Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the
longer you wait. You may find out any time exactly what the required payment will be by calling us at the
following number: 1.800.654-1350. This payment must be in the form of certified check, cashier's check
or money order and made payable to us at the address stated above.
You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right
to remain in it. If you continue to live in the property after the Sheriffs Sale, a lawsuit could be started to
evict you.
You have additional rights to help protect your interests in the property. YOU HAVE THE RIGHT TO
SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT (YOU
MAY HAVE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO
A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT
ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE
PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE
MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCE
THIS MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD
PARTY ACTING ON YOUR BEHALF.
If you cure this default, the mortgage will be restored to the same position as if no default has occurred.
However, you are not entitled to this right to cure your default more than three (3) times in any calendar
year.
Sincerely,
Z)4" ( ,Sony
David Smith
Delinquency Control
Mortgage Loan Servicing Group
BLPA01
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GUY EICHELBERGER
924 ALEXANDER SPRING RD
CARLISLE, PA 17013
April30, 1999
RE: FUMC Loan Number 0009599662
Property Address 924 ALEXANDER SPRIN
CARLISLE, PA 17013
From: First Union Mortgage Corporation, owner and holder or agent for owner and holder for the
referenced Mortgagor (s).
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be
able to help you. Read the following notice to find out how the program works.
If you need more information call the Pennsylvania Housing Finance Agency at 1-800-3422-397.
La notification en adjunto es de suma inportancia, pues afecta so derecho a continuar viviendo en su casa.
Si no comprende el contenido esta notification obtenga una traduccion immediatamente Ilamanda esta
agencia (Pennsylvania Housing Finance Agency) sin cargos al numem meniconado arriba. Puedes ser
elegible pars un prestamo por el programa Ilamado "Homeowner's Emergency Mortgage Assistance
Program" el cual puede salvar su casa de la perdida del derecho a redimir so hipoteca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
You may be eligible for financial assistance that will prevent foreclosure on your mortgage if
EXHIBIT B
First Union Mortgage Corporation
Post
p
ION R
aleigh, North Ca
rolna2 6764MI
1100 Corporate Center Drive
UN Raleigh, North Carolina 276076066
LINDA EICHELBERGER
924 ALEXANDER SPRING RD
CARLISLE, PA 17013
April 30, 1999
RE: FUMC Loan Number 0009599662
Property Address 924 ALEXANDER SPRIN
CARLISLE, PA 17013
From: First Union Mortgage Corporation, owner and holder or agent for owner and holder for the
referenced Mortgagor (s).
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be
able to help you. Read the following notice to find out how the program works.
If you need more information call the Pennsylvania Housing Finance Agency at 1-800-3422-397.
La notification en adjunto es de sums inportancia, pues afecta su derecho a continuar viviendo en su casa.
Si no comprende el contenido esta notification obtenga una traduccion immediatamente llamanda esta
agencia (Pennsylvania Housing Finance Agency) sin cargos al numero meniconado arriba. Puedes set
elegible para un prestamo por el programa Ilamado "Homeowner's Emergency Mortgage Assistance
Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
You may be eligible for financial assistance that will prevent foreclosure on your mortgage if
EXHIBIT B
you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of
1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has
been caused by circumstances beyond you control, you have a reasonable prospect of resuming
you mortgage payments, and if you meet other eligibility requirements established by the
Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an
explanation of you rights.
Under the Act, you are entitled to a temporary stay of foreclosure of your mortgage for thirty (30) days
from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with
a representative of the lender, or with a designated consumer credit counseling agency. The purpose of
this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This
meeting must occur in the next thirty (30) days.
If you attend a face to face meeting with this lender, or with a consumer credit counseling agency identified
in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the
date of this meeting. Your mortgage holder is First Union Mortgage Corporation, 1100 Corporate Center
Drive, Raleigh, NC 27607, telephone number 1-800-654-1350.
The names and addresses of designated consumer credit counseling agencies are shown on the attached
sheet. It is only necessary to schedule one face-to face meeting. You should advise your lender
immediately of your intentions.
Your mortgage is in default because you failed to pay promptly installments of principal and interest, as
required, for a period of at least sixty (60) days. The total amount of the delinquency is 1610.00.
That sum includes the following:
Total of 2 monthly payment(s) from
03/01/1999 to 04/01/1999
Late Charges
1489.48
58.26
Property inspections and NSF check charges, if any 0.00
Other charges accrued, if any
62.26
LESS: Suspense (unapplied funds): -0.00
TOTAL AMOUNT OF DELINQUENCY: 1610.00
Your mortgage is also in default for the following reasons: N/A
If you have tried and are unable to resolve this problem at or after your face to face meeting, you have the
right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In
order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance
Application with one of the designated consumer credit counseling agencies listed on the attachment. An
application for assistance may only be obtained from a consumer credit counseling agency. The consumer
credit counseling agency will assist you in filling out your application and will submit your completed
application to the Pennsylvania Housing Finance Agency. Your applications must be filed or post marked,
within thirty (30) days of your face-to face meeting.
It is ertremely important that yon frle your application promptly. lfyou do not do .so, or iif vmu do not
follow the other times periods se! forth in this loner, foreclosure may proceed against your home
EXHIBIT B
immediately
It is extremely important that your application is accurate and complete in every respect. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During
that additional time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by that Agency of its decision of your
application.
The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029,
Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1-800-342-2397 (toll free number).
Persons with impaired hearing can call 1-800-342-2397.
In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called
"Notice of Intention to Foreclose". You must read both notices, since they both explain your rights that
you now have under Pennsylvania law. However, if you choose to exercise your rights described in this
notice, you cannot be foreclosed upon while you are receiving that assistance.
Sent by Regular Mail, Certificate of Mailing (PS Form 3877)
Sincerely,
Vauad .50f a
David Smith
Delinquency Control
Mortgage Loan Servicing Group
BLPA02
MAHIBIT B
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
A c o r a H o u s i n g
Corporation
846 North Broad Street
Philadelphia, PA 19130
(215) 765-1221
(215) 765-1427 (tax)
Sucks, Chester,
Delaware, Montgomery,
Philadelphia
Action Housing, Inc.
Number Two Gateway
Center
9th Floor
Pittsburgh, PA 15222
(412) 391.1956
(412) 391-4512 (fax)
Allegheny, Beaver,
Butler, Fayette, Greene,
Washington, Westmoreland
AM Credit Counseling
Institute
175 Strafford Avenue,
Suite 1
Wayne. PA 19087
(610) 911-2210
(6101 687.7860 (fax)
Bucks, Chester,
Delaware, Montgomery,
Philadelphia
American Red Cross-
Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
(717) 637.3769
(717) 637-3294 (fax)
Adams, York, Franklin
Bedford-FUltcu Housing
Services
R.D. #1, Box 384
Everett, PA 15537
(814) 623-9129
(814) 623.7187 (fax)
Bedford, Blair, Cambria,
Fulton, Huntingdon,
Somerset
Blair County aeon
opportunity council
:100 6th Avenue
Altoona, PA. 16602
(814) 946.3651
(814) 946.5451 (fax)
Adams
Booker T. Washington
Center
,20 Holland Street
Erie. PA 16503
(814) 453-5744
(814) 453.5749 (fax)
Crawford, Erie, Warren
Bucks County Housing
Group, Inc.
140 E. Richardson Avenue
Langhorne, PA 19047
(215) 750-4310
(215) 750-4319 (fax)
Bucks
Budget Counseling Center
247 Ncrth Fifth Street
Reading, PA 19601
(610) 375-7866
(610) 376.6575 (fax)
e er ka, C h a star,
Montgomery, Schuylkill
CCCS of Western
Pennsylvania, Inc.
312 Chestnut Street
Suite 227
Meadville, PA 16335
(814) 333-8570
Lawrence
CCCS of Western
Pennsylvania, Inc.
Senior activity center
550 Main Street
Johnstown, PA 15901
(814) 539-6335
Cambria. Somerset
CCCS of Northeastern
Pemsylvaaia
185 Elmira Street
P.O. Box 218
Troy, PA 16947
(717) 297-2101
(717) 297-2799 (fax)
Bradford, Sullivan,
Susquehanna, Tioga,
Wayne, Wyoming
CCCS of Northeastern
Pennsylvaaia
Human Services Building
541 Wyoming Avenue,
Box 168
Scranton, PA 18501
(717) 342-1072 or
800.922-9537
(717)342-8040 (fax)
Bradford, Carbon,
Columbia, Lackawanna,
Luzerne, Lycoming,
Monroe, Montour,
Northumberland, Pike,
Sullivan, Susquehanna,
Tioga, Wayne, Wyoming
CCCS of western
Pennsylvania, Inc.
1 North Gate Square
#2 Garden Center Drive
Greensburg, PA 15601
(412) 838-1290
Payette, Greene, Indiana,
Somerset, Washington,
Westmoreland
CCCS of Delaware valley
1515 Market Street
Suite 1325
Philadelphia, PA 19107
(215) 563-5665
(215) 864-2666 (fax)
Sucks, Chester, Delaware,
Mcntgo, Philadelphia
CCCS of western
Pennsylvania, Inc.
309 Smithfield St.
Pittsburgh. PA 15222
(4'2) 471-7584
Allegheny
CCCS of Northeasters
Pennsylvania
17 Crafton Street
Wellsborc, PA 16901
(717) 724.5252
(717) 724-5793 (fax)
Bradford, Sullivan,
Susquehanna, Tioga,
Wayne, Wyoming
CCCS of Western
Pennsylvania, Inc.
500-02 3rd Avenue
P. O. Box 278
Duncansvilla, PA 16635
(814) 696.3546
Armstrong, Bedford,
Blair, Cambria, Cameron,
Contra, Clearfield,
Huntingdon, Juniata,
Mifflin, Onion
CCCS of Northeastern
Pemsylvasia
31 W. Market Street
Wilkes-Barre, PA 18702
(717) 821-0837 or
800-922-9537
(717) 821.1785 (fax)
Bradford, Carbon,
Columbia, Lackawanna,
Luzerne, Lycoming,
Monroe, Montour,
Northumberland, Pike,
Sullivan, Susquehanna,
T109a, Wayne, Wyoming
CCCS of Northeastern
Pennsylvania
9 South 7th Street
Stroudsburg, PA 18360
800-922.9537
(717) 420-8981 (fax)
Bradford, Carbon,Mouroe,
Pike, Wayne
CCCS of Western
Pennsylvania, Inc.
675 Chertytree Lane
Uniontown, PA 15401
(412) 439-8939
Westmoreland
CCCS of Western
Pennsylvania, Inc.
Sa E. Cherry Avenue
Washington, Pa 15301
(412) 222-8292
Washington
CCCS of Northeastern
Pennsylvania
German Street
P.O. Box 389
Dushcre, PA 18614
(717) 928.9668
(717) 928-8144 (fax)
Bradford, Sullivan,
Susquehanna, Tioga,
Wayne, Wyoming
CCCS of Western
Pennsylvania, Inc.
YMCA 3u4ldin9
339 N. Washington Street
Butler, PA 16001
(412) 282-7812
Butler, Clarion,
Jefferson, Mercer,
Venango
CCCS of Lahigh Valley
3671 Crescent Court East
Whitehall, PA 18052
(610) 821-4011 or
800.220-2733
(717) or (814) only
(610) 821.0137 (fax)
(610) 821-4010 (fax)
Barks, Bucks, Carbon,
Lancaster, Lehigh,
Northampton, Schuylkill
Rev 1/97
CCC9 of Western
Pennsylvania, Inn.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
(717) 731.9589 (fax)
Adams, Cumberland,
Dauphin, Franklin, Perry,
Snyder, York
CCCS of Western
Peansylvaaia, Inc.
971 Third Street
Beaver, PA 15009
14121 774-0798
Beaver
CCCS of Northeaster
Pennsylvania
103 Warren Street
P.O. Sax 709
Punkha=cck, PA 18657
(717) 836-Sa40
17171 936-5332
Bradford, Sullivan,
Susquehanna, TSOga,
Wayne, Wyoming
CCCS of Northeastern
Pennsylvania
931 Main Street
Hcnesdale, PA 18431
(717) 253-4981
(717) 253-4a17 (fax)
Bradford, Sullivan,
Susquehanna, Tioga,
Wayne, Wyoming
CCCS of Western
Pennsylvania, Inc.
912 South George Street
York. PA 17403
(717) 845.4176
Fulton, Lancaster, York
Franklin
CCCS of Western
PennaYlvaaia, Inc.
let Federal Plaza
Suite 406
North Mill Street
New Castle. PA 16101
(412) 652-8074
Lawrence
Commission an Economics
Cpportunity of Luzerua
County
163 Arher Lane
Wilkes-3arre, PA 1a702
(777) 826-05.9 or
800-322-0359
(717) 329 1665 Call
before fazing
(717! 455-4994 (Hare'-ton,
1?17;455 5631 (fax) Ca_
before faxing
( 7 1 7) 8 3 6. 4 0 9 3
(^,rkhar_ ock)
Carbon, Columbia.
Luzerne, Monroe,
Schuylkill, Wyoming
Community Action
Commission of the
Capital Region
1514 Derr( Street
Harrisburg, PA 17104
(717) 232-9757
(717) 234-2227 (fax)
Cumberland, Dauphin,
Pranklia. Perry, Snyder
Community Action
Development Comm
701 Dekalb Street
Norristown, PA 19401
(610) 277-6363
(610) 277-2123 (fax)
Montgomery
Community Development
Corp. of Frankfosd
Group Ministry
4620 Griscom Street
Philadelphia, PA 19124
(215) 744.2990
(215) 744.2012 (fax)
Bucks, Chester, Delaware
Philadelphia
Community Action
Southwest
22 West High Street
Waynesburg, PA 15370
(412) 852-2891
Allegheny, Fayette,
Greene, Washington,
Westmoreland
Community Housing
Counselor, Inc.
P.O. Box 244
Kennett Square, PA 19348
(610) 444.3682
(610) 444.3178 (fax)
Barks, Chester,
Delaware, Lancaster,
Montgomery
Economic Opportunity
Cabinet of Schuylkill
County
225 N. Centre Street
Pottsville, PA 17901
(717) 622-1995
(717) 622.0429 (fax)
Barks, Carbon, Lebanon,
Lehigh, Luzern,
Northumberland,
Schuylkill
Fayette Cc Community
Action Agency, Inc.
137 North Beeson Avenue
Uniontown, PA 15401
(412) 437.6050 or
800-427-INFO
(412) 437-4418
Payette
Financial Counseling
Services of Franklin
31 West 3rd street
Waynesboro, PA 17268
(717) 762-3285
Adams, Cumberland,
Fulton, Perry
Financial Services
Unlimited
31 West 3rd Street
Waynesboro. PA 17268
(717) 762-3285
Franklin
Greater Brie community
Action Committee
18 West 9th Street
Erie, PA 16501
(814) 459-4581
(614) 456.0161 (fax)
Crawford, Erie, Vena.ego,
Warren
Hispanic Assoc, of
Contractors/Enterprisea
2921-27 North 5th Street
Philadelphia, PA 19133
(215) 744-2990
(215) 744.2012 (fax)
sucks, Chester, Delaware
Philadelphic
Housing Opportunities of
Beaver County, Inc.
1501 3rd Street
Beaver, PA 15009
(412) 728-7511
(412) 664-1590
(412) 728-7202 (fax)
(412) 664.0873 (fax)
Beaver, Butler, Lawrence
Housing Opportunities,
Inc.
133 Seventh Street
P.O. Box 9
McKeesport, PA 15132
(412) 664-1590
(412) 664.0873 (fax)
Allegheny, Beaver,
Butler, Washington,
Westmoreland
Housing Council of York
116 North George Street
York, PA 17401
(717) 854-1541
(717) 845.7934 (fax)
York
Housing Association of
Delaware Valley
1500 walnut street
suite 601
Philadelphia, PA 19102
(215) 545.6010
(215) 790-9132 (fax)
Philadelphia
Indiana County Community
Action Program
827 Water Street, Box 187
Indiana, PA 15701
(412) 465-2657
(412) 465-5118 (fax)
Armstrong, Cambria,
Clearfield, Indiana,
Jefferson, Westmoreland
John P. Kennedy Center,
Inc.
2021 East 20th Street
Erie, PA 16510
(814) 898-0400
(814) 898-1243 (fax)
Crawford, Elk, Brie,
Jefferson, Mcksan,
Venango
Keystone Economic
Development Corp.
1954 Mary Grace Lane
JChnatOwn, PA 15901
(8'4) 535-6556
(814) 539-1688 (fax)
Bedford, Blair, Cambria,
Clearfield, Indiana,
Somerset, Westmoreland
Lycoming-Clinton Counties
Commission for Community
Action (STEP)
2138 Lincoln Street
P.O. Box 1328
Williamsport, PA 17703
(7171 326-0587
(7.7) 3:2-2'37 (fax)
Centre, Clinton,
Lycoming, Union
Media Pellowship House
302 S. Jackson Street
Media, PA 19063
(610) 565-0846
Chester, Delaware,
Montgomery, Philadelphia
Media Fellowship House
658 North Watts Street
Philadelphia, PA 19123
(215) 978.0224
(215) 765-7614 (fax)
Philadelphia
Non-Valley Unemployed
Committee
120 E. 9th Avenue
Homestead, PA 15120
(412) 462-9962
(412) 462-9964 (fax)
Allegheny, Beaver,
Butler, Payette, Greene,
Washington, Westmoreland
Northern Tier Community
Action Corp.
P.O. Box 389
135 West 4th street
Emporium, PA 15834
(814) 486-1161
(814) 486.0825 (fax)
Cameron, Elk, McKean,
Potter
Philadelphia Council for
Community Advancement
100 North 17th Street
Suit 600
Philadelphia, PA 19103
(215) 567-7803
(215) 961-9941 (fax)
Chester, Delaware,
Montgomery, Philadelphia
Shenango valley Orb=
League, Inc.
601 Indiana Avenue
Farrell, PA 16121
(412) 981.5310
Crawford, Lawrence,
Mercer
Tableland Services, Inc.
131 North Center Avenue
Scmerset, PA 15501
(814) 445-9628
(814) 443-3690 (fax)
Bedford, Cambria,
Fayette, Somerset,
Westmoreland
Tabor Community Services,
Inc.
439 E. King Street
Lancaster, PA 17602
(717) 397-5182 or
800-788-5062 (H.O. only)
(717) 399-4.27 (fax)
Chester, Lancaster,
Labanca
The Trehab Center of
Northeastern PA
7 Lake Avenue. Box 339
Montrose, PA 18801
(717) 278.3338 or
800-982-4045
(717) 278-1389 (fax)
Bradford, Sullivan,
Susquehanna, Tinge,
Wayne, Wyoming
Urban League of
Pittsburgh, Inc.
Building For Equal
Opportunity
One Smithfield Street
Pittsburgh, PA 15222-2222
(412) 221.4802
(412) 261.5207 (fax)
Allegheny
Urban League of
MatroPolltam Harrisburg
25 N. Front Street
Harrisburg, PA 17101
(717) 234.5925
(717) 234.9459 (fax)
Perry
Urban League of
2Marropolitan Harrisburg
2107 N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
(717) 234-9459
Cumberland, Dauphin.
Franklin, Snyder
Warren-Forrest Counties
Economic Opportunity
Council
204 Liberty Street
P.O. BOX 547
Warren, PA 16365
(814) 726-2400
(814) 723.0510 (fax)
Forest, Warram
Weatheriration office
917 Mifflin Street
Huntingdon, PA 16652
(814) 643-2343
Bedford, Blair, Fulton,
Huntingdon, Juniata,
Mifflin, Perry
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243.3818
(717) 731-9589 (fax)
Cumberland, Franklin,
Perry
Rev 1/97
EXHI
ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County,
Pennsylvania more particularly bounded and described in accordance with a Survey by Stephen G.
Fisher, R.S. dated November 4, 1976 (revised) as follows:
BEGINNING at an iron pin on the Northern dedicated right-of-way line of the Alexander Spring
Road (T-467) a 33 foot right-of-way said iron pin being also at the Southeast corner of Lot No. 6 of
the hereinafter mentioned Plan of Lots; thence along the dividing line of Lots No. 5 and 6 North 36
degrees, 56 minutes, 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of
Lot No. 6 North 31 degrees, 21 minutes, 40 seconds East 96.63 feet to an iron pin at the corner of
Lots Nos. 6 and 7; thence along the dividing line of Lots Nos. 6 and 7 South 58 degrees, 38
minutes, 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of
Alexander Spring Road (T-467); thence along said right-of-way line South 31 degrees, 21 minutes,
40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way
line in an arc with a radius of 290.0 feet a distance of 89.18 feet (erroneously described as 82.35
feet in prior Deed) to an iron pin, the point and place of beginning.
BEING Lot No. 6 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County
Recorder of Deeds Office in Plan Book 29 page 41.
PREMISES:
924 ALEXANDER SPRING ROAD
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 IS Pa. C. S. Sec. 4904 relating to unsworn
falsification to authorities.
DATE: (?/Ltz
000L•E99 (9IZ)
ZOt6l Md'e144!ePe1!4d
eze!d 18100 uuad Oml
006 epS
mHdawwwimu
s
00&29,"00 TUE 18:83 FAX 21S8231034
FEDERMAN AND PHELAN
By: Frank Federman, Esquire
Atty. I. D. No. 12248
Suite 900/Two Penn Center Plaza
Philadelphia, PA 19102-1*799
(215) 563.7000
CST, INC.
First Union Mortgage Corporation,
s/b/m to Signet Mortgage Corporation
vs.
MAR o 1 200y,
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CUMBERLAND COUNTY
No. 99-3995 CIVIL
G. Franklin Eichelberger,
a/k/a Guy Franklin Eichelberger,
a/k/a Guy Eichelberger and
Linda Marie Eichelberger,
a/k/a Linda M. Elchelberger
ORDER
AND NOW, this t%l - day of A&Aee?. , 2000, after
consideration of Plaintiffs Motion to Postpone Sheriffs Sale of the mortgaged property,
it is hereby
ORDERED that the said sale is extended 3 month(s) to the regularly
scheduled CUMBERLAND COUNTY Sheriffs Sale dated JUNE 72000.
No further advertising or additional notice to lienholder or defendant(s) is
required.
BY THE Cgtl
J.
FEB-29-2000 17:46 2159231034
P.02
R1002
00 MaR -1 A;1 n, 98
CU;,trti;d•:.i ;.;vUf::N
PEidt??51'Ll!?'v?l!A
pc,,4,,
02/29/00 TUE 18:34 FAY 2159231034
FEDERMAN AND PHELAN
By: Frank Federman, Esquire
Atty. I.D. No. 12248
Suite 900/Two Penn Center Plaza
Philadelphia, PA 19102-1799
(215) 563-7000
First Union Mortgage Corporation,
s/b/m to Signet Mortgage Corporation
vs.
G. Franklin Eichelberger,
a/k/a Guy Franklin Eichelberger,
a/k/a Guy Eichelberger and
Linda Marie Eichelberger,
a/k/a Linda M. Elchelberger
MOTION FOR POSTPONEMENT OF SHERIFF'S SALE
0 003
Griot"7ai.Q
n o n
Z
7 rn
j r
C
N
C M
Plaintiff, by its counsel, Federman and Phelan, petitions this Honorable Court for
a 3 month postponement of its Sheriffs Sale scheduled in the above captioned
matter and in support thereof avers the following:
1. A Sheriffs Sale of the mortgaged property involved herein has been
scheduled for MARCH 1. 2000.
2. Plaintiff has agreed to possibly modify the mortgage, which would allow
the Defendant(s) to cure the mortgage default.
3. A 3 month postponement of the Sheriffs Sale will enable Plaintiff
ample time to complete negotiations.
WHEREFORE, Plaintiff respectfully requests that the Sheriffs Sale of the
mortgaged premises be continued to JUNE 7. 2000.
Federman and Phelan
Attorn y
FEB-29-2000 17:46 2159231034 7111
CST. INC.
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CUMBERLAND COUNTY
No. 99-3995 CIVIL.
??? 4.03
02129/00 TUE 18:34 FAX 2159231034 CST. INC.
0004
.r
FEDERMAN AND PHELAN
By: Frank Federman, Esquire
Atty. I.D. No. 12248
Suite 9001Two Penn Center Plaza
Philadelphia, PA 19102-1799
(215) 563-7000
First Union Mortgage Corporation,
s/b/m to Signet Mortgage Corporation
vs.
Court of Common Pleas
Civil Division
CUMBERLAND COUNTY
No. 99-3995 CIVIL
G. Franklin Eichelberger,
a/k/a Guy Franklin Eichelberger,
a/k/a Guy Eichelberger and
Linda Marie Eichelberger,
a/k/a Linda M. Elchelberger
PLAINTIFF'S MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 3129.3 provides for the postponement of a
Sheriffs Sale of real property by special order of Court.
In the case sub judicia, a Sheriffs Sale of the mortgaged premises has been
scheduled for MARCH 1. 2000. However, a 3 month postponement is requested to
allow Plaintiff and Defendant time to complete negotiations. Inasmuch as the
postponement will inure to the benefit of the Defendant(s), Defendant(s) will not be
injured by the granting of the relief requested.
Accordingly. Plaintiff respectfully requests a _3^ month continuance of the
Sheriffs Sale of the mortgaged premises to the JUNE 7, 2000 Sheriffs Sale.
Respectfully submitted:
FEB-29-2000 17:47
Federman and Phelan
ATTORNEY FOR PLAINTIFF
for-Pllaipfiff
,( I?? P.04
02/29/00 TUE 18:34 FAX 2159231034 CST. INC.
ra
VERIFICATION
Frank Federman, Esquire, hereby states that he is the attorney for the plaintiff
in this action, that he is authorized to take this verification, and that the statements
made in the foregoing Motion for Postponement of Sheriffs Sale are true and correct
to the best of his knowledge, information and belief.
The undersigned also understands that this statement herein is made subject to
the penalties of 18 Pa. Sec. 4904 relating to unsworn falsification to authorities.
Date:
zoos
FEB-29-2000 17 47 2159231034 P.05
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First Union Mortgage Corporation SB/M In the Court of Common Pleas of
To Signet Mortgage Corporation Cumberland County, Pennsylvania
-vs- No. 99-3995 Civil
G. Franklin Eichelberger, A/K/A Guy
Franklin Eichelberger Linda Marie Eichelberger
A/K/A Linda M. Eichelberger
R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ
is returned STAYED.
Sheriff's Costs:
Docketing 30.00
Poundage 18.05
Posting Bills 15.00
Advertising 15.00
Law Library .50
County 1.00
Mileage 3.10
Certified Mail 1.60
Levy 15.00
Postpone Sale 40.00
Surcharge 24.00
Law Journal 278,75
Patriot News 455.06
Share of Bills 23.63
$ 920.69 Pd By Atty
04/04/00
So answers:
Sworn and subscribed to before me
R. Thomas Kline, Sheriff
This / 7 '-day of 4
2000, A.D.?,? t? BY
Prothonotary Real Estate Deputy
P11., gy4LC
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE
CORPORATION CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Vs. CIVIL DIVISION
G. FRANKLIN EICHELHERGER, A/K/A
GUY FRANKLIN EICHELBERGER, A/K/A
GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER NO. 99-3995 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
G. FRANKLIN EICHELHERGER, September 4, 1999
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
**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, 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 924 ALEXANDER SPRING ROAD,
CARLISLE, PA 17013, is scheduled to be sold at the Sheriff's Sale
on DECEMBER 8. 1999 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce
the court judgment of $67,600.94 obtained by FIRST UNION MORTGAGE
CORPORATION, S/B/M TO SIGNET MORTGAGE CORPORATION (the mortgagee)
against you. If the sale is postponed, the property will be
relisted for the MARCH 1. 2000 Sheriff's Sale.
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.
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 t'.e sale for good cause.
f
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.)
1. If the Sheriff's Sale is not stopped, your property will
be sold to the highest bidder. You may find out the price bid by
calling (215) 563-7000.
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate 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 proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff not later than
thirty (30) days after the sale. The schedule shall be kept on
file with the Sheriff and will be made available for inspection in
his office. The 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 filing of
the proposed schedule.
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 ATORNEY REFERRAL
CUMBERLAND COUNTY BAR ASOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
DESCRIPTION
ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County,
Pennsylvania more particularly bounded and described in accordance with a Survey by Stephen G.
Fisher, R.S. dated November 4, 1976 (revised) as follows:
BEGINNING at an iron pin on the Northern dedicated right-of-way line of the Alexander Spring
Road (T-467) a 33 foot right-of-way said iron pin being also at the Southeast comer of Lot No. 6 of
the hereinafter mentioned Plan of Lots; thence along the dividing line of Lots No. 5 and 6 North 36
degrees, 56 minutes, 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of
Lot No. 6 North 31 degrees, 21 minutes, 40 seconds East 96.63 feet to an iron pin at the comer of
Lots Nos. 6 and 7; thence along the dividing line of Lots Nos. 6 and 7 South 58 degrees, 38
minutes, 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of
Alexander Spring Road (T-467); thence along said right-of-way line South 31 degrees, 21 minutes,
40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way
line in an arc with a radius of 290.0 feet a distance of 89.18 feet (erroneously described as 82.35
feet in prior Deed) to an iron pin, the point and place of beginning.
BEING Lot No. 6 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County
Recorder of Deeds Office in Plan Book 29 page 41.
TITLE TO SAID PREMISES IS VESTED IN G. Franklin Eichelberger and Linda Marie
Eichelberger, his wife by Deed from John M. Shearer and Rebecca S. Shearer, his wife and Jay A.
Galloway and Patricia D. Galloway, his wife dated 1/28/83 recorded 2/1/83 in Deed Book B-30
page 3.
rr v
FIRST UNION MORTGAGE CORPORATION,
S/B/M TO SIGNET MORTGAGE CORPORATION
VS.
G. FRANKLIN EICHELBERGER,
A/K/A GUY FRANKLIN EICHELBERGER,
A/K/A GUY EICHELBERGER
LINDA MARIE EICHELBERGER,
A/K/A LINDA M. EICHELBERGER
CUMBERLAND COUNTY
. COURT OF COMMON PLEAS
. CIVIL DIVISION
NO. 99-3995 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No 1)
CORPORATION , Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ
of Execution was filed the following information concerning the
real property located at 924 ALEXANDER SPRING ROAD CARLISLE PA
17013.
1. Name and address of Owner (s) or reputed Owner(s):
NAME
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
G. FRANKLIN EICHELBERGER
A/K/A GUY FRANKLIN
EICHELBERGER,
A/K/A GUY EICHELBERGER
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
LINDA MARIE EICHELBERGER. 924 ALEXANDER SPRING ROAD
A/K/A LINDA M. EICHELBERGER CARLISLE. PA 17013
CARLISLE, PA 17013
2. Name and address of Defendant (s) in the judgment:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
hr ..
4. Name and address of the last recorded holder of every mortgage
of record:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
PENNSYLVANIA HOUSING 2101 NORTH FRONT STREET
FINANCE AGENCY HARRISBURG, PA
5. Name and address of every other person who has any record lien
on the property:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
j * i?
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 so indicate)
NONE
7. Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
NAME
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
TENANT/OCCUPANT
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
924 ALEXANDER SPRING ROAD
CARLISLE, PA 17013
13 NORTH HANOVER STREET
CARLISLE, PA 17013
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 of 18 Pa. C.S. Sec. 4904 relating
to unsworn falsification to authorities.
September 4, 1999
DATE F K FEDERh , ESQUIRE
At rney for .Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-3995 CIVIL 19 _
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due First Union Mortgage Corporation, S/B/M To
Signet Mortgage Corporation PLAINTIFF(S)
from G. Franklin Eichelberger, A/K/A Guy Franklin Eichelberger, A/K/A Guy Eichelberger
Linda Marie Eichelberger, A/K/A Linda M. Eichelberger
(1) You are directed to levy upon the property of the defendant(s) and to
(2) You are also directed to attach the property of the detendant(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/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property 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 h1m/her that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due // $67,600.94
////
Interest f(Per9biem9-t0$11211)99 $1,033.23
Arty's Comm
Atty Paid
$115.10
Plaintiff F
Date: September 8, 1999
L.L. $.50
DueFrothy _ $1.00
Other Costs
Curtis R.
Prothonotary, Civil Division
REOUESTING PARTY:
Name Frank Federman, Esq.
Address: Two Penn Center Plaza Suite 900
Philadelphia, PA 19102
Attorney for: Plaintiff
by:
Deputy
Telephone: (215) 563-7000
Supreme Court ID No. 12248
REA"', L??iATL LL 1W.
Un 9 99Q the shrriif i6! i^;;
interast in the real property
situated inB1L J
''
Cumberland County, Pa., kno•ryn and nu,n?ered as: f g ?
42,a?-- and more full; descrWed on Exhibit "A" filed +ith
this writ and by this reference incorporated herein.
Date:C?GG?s? g??t ?y?d?c?e.?
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000 ATTORNEY FOR PLAINTIFF
First Union Mortgage Corporation,
SB/M To Signet Mortgage Corporation
Plaintiff
VS.
G. Franklin Eichelberger,
A/K/A Guy Franklin Eischelberger,
A/K/A Guy Eichelberger
Linda Marie Eichelberger
A/K/A Linda M. Eichelberger
Cumberland County
Court of Common Pleas
CIVIL DIVISION
NO. 99-3995 Civil
Defendant(s)
ORDER TO SATISFY JUDGMENT
AND NOW, this day of OAAO , 1999, after
consideration of Plaintiff s Motion to Satisfy Judgment, it is hereby
ORDERED AND DECREED that the judgment entered on G. Franklin
SATISFY without prejudice.
in the amount of $67.60 0 4 is
BY TPE COURT:
J. . r
Jr. J 'O O
9 KS
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215)563-7000 ATTORNEY FOR PLAINTIFF
First Union Mortgage Corporation, : Cumberland County
SB/M To Signet Mortgage Corporation
Plaintiff : Court of Common Pleas
VS.
CIVIL DIVISION
G. Franklin Eichelberger,
A/K/A Guy Franklin Eischelberger, : NO. 99-3995 Civil
A/K/A Guy Eichelberger
Linda Marie Eichelberger
Defendant(s)
MOTION TO SATISFY JUDGMENT
Plaintiff, by its counsel, Federman and Phelan, petitions this Honorable
Court for an Order to vacate judgment in the above captioned matter and in support
thereof avers the following:
1. Judgment was entered in favor of Plaintiff in this mortgage foreclosure on
G. Franklin Eichelberger, A/K/A Guy Franklin Eischelberger, A/K/A Guy Eichelberger
and Linda Marie Eichelberger A/K/A Linda M. Eichelberger in the amount of
$67,600.94.
2. Plaintiff desires to Satisfy the judgment entered due to Defendant(s)'
account being paid off.
3. Plaintiff petitions the Court to satisfy the judgment described above
without prejudice.
WHEREFORE, Plaintiff respectfully requests that thejudgment be
vacated without prejudice.
FEDERMAN AND PHELAN
By:
ank Feder an, Esq.
Attorney for Plaintiff
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA. SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000 ATTORNEY FOR PLAINTIFF
First Union Mortgage Corporation, : Cumberland County
S/B/M To Signet Mortgage Corporation
Plaintiff : Court of Common Pleas
VS.
CIVIL DIVISION
G. Franklin Eichelberger,
A/K/A Guy Franklin Eischelberger, : NO. 99-3995 Civil
A/K/A Guy Eichelberger
Linda Marie Eichelberger
A/K/A Linda M. Eichelberger
Defendant(s)
PLAINTIFF'S MEMORANDUM OF LAW
Plaintiff petitions this Honorable Court for an order to satisfy judgment entered on
G. Franklin Eichelberger, A/K/A Guy Franklin Eischelberger, A/K/A Guy Eiellelberger
and Linda Marie Eichelberger, A/K/A Linda M. Eichelberger.
I'laintiff desires to satisfy the judgment entered due to Defendant(s)'
account being paid off.
The instant request for relief is, therefore, brought before thejudge of
motion court for disposition.
Accordingly, Plaintiff respectfully requests an Order Satisfying judgment
without prejudice.
Respectfully submitted,
FEDERMAN AND P 'LAN
ra k Fedenn , Esq.
Attorney for Plaintiff'
VERIFICATION
Frank Federman, Esquire, hereby states that he is the attorney for Plaintiff
in the instant action, that he is authorized to make this verification, and that the
statements made in the foregoing Motion to Satisfy Judgment are true and correct to the
best of his knowledge, information and belief.
The undersigned also understands that his statement herein is made subject
to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities.
Date:
Frank ederman, Esq.
Attorney for Plaintiff
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000 ATTORNEY FOR PLAINTIFF
First Union Mortgage Corporation,
S/B/M To Signet Mortgage Corporation
Plaintiff
VS.
G. Franklin Eichelberger,
A/K/A Guy Franklin Eischelberger,
A/K/A Guy Eichelberger
Linda Marie Eichelberger
A/K/A Linda M. Eichelberger
Defendant(s)
Cumberland County
: Court of Common Pleas
: CIVIL DIVISION
: NO. 99-3995 Civil
CERTIFICATION OF SERVICE
Frank Federman, Esquire, hereby states that he is the attorney for Plaintiff
in this action and that a true and correct copy of the within pleading was sent to the
following interested parties on the date indicated below by first class mail, postage
prepaid:
G. Franklin Eichelberger, A/K/A Guy Franklin Eischelberger, A/K/A Guy Eichelberger
and Linda Marie Eichelberger, A/K/A Linda M. Eichelberger
Date: 5 /
qx.4W Frank ederman, Esq.
Attorney for Plaintiff
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