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HomeMy WebLinkAbout99-05429 Qr ? ':?; H a ? j' N ? ? ?. ? o ?, FEDERMAN AND PHELAN Fy: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION RESOURCE BANCSHARES MORTGAGE GROUP, INC. 7909 PARKLANE ROAD COLUMBIA, SC 29223 V. Plaintiff TERM MICHAEL J. MANNAI LINDA H. MANNAI 333 ALLEN STREET CARLISLE, PA 17013 Defendant(s) NO. q -SSQ / CUMBERLAND COUNTY CIVIL ACTION - LAW MO GAGE FORECLOSURE 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249.3166 I. Plaintiff is RESOURCE BANCSHARES MORTGAGE GROUP, INC. 7909 PARKLANE ROAD COLUMBIA, SC 29223 The name(s) and last known address(es) of the Defendant(s) are: MICHAEL I. MANNAI LINDA H. MANNAI 333 ALLEN STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described 3. On 6/28/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE INVESTORS CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1392, Page 522. By Assignment of Mortgage dated recorded 9/13/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 554, Page 586. 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 12/1/98 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such a notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $91,888.17 Interest 5,263.50 II/1/98 through 8/1/99 (Per Diem $19.14) Attorney's Fees 4,594.00 Cumulative Late Charges 267.84 6/28/97 to 8/1/99 Cost of Suit and Title Search 750 00 Subtotal 102,763.51 Escrow Credit 0.00 Deficit 0.00 Subtotal 0.00 TOTAL $102,763.51 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. 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 "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 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 $102,763.51, together with interest from 8/1/99 at the rate of $19.14 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/ FFec4ANAESQU'IM- k 4--1 FRANK FED, for Plaintiff Attorney U1 RESOURCE BANCS MORTGAG F, February 10, 1999 GROUP, INC. Michael J Mannai Linda H Mannai 333 Allen Street Carlisle, PA 17013 RE: RBMG Loan Number 463659 NOTICE OF INTENTION TO FORECLOSE Dear Mortgagor(s): The mortgage held by RBMG (herein we, us or our) on your property located at: 333 Allen Street, Carlisle PA 17013 is in SERIOUS DEFAULT because you have not made the monthly payments of $ 837.02 for 12/01/99 through 02/01/99. Late charges (and other charges) have also accrued in the amount of $ 66.96. The total amount now required to cure this default, or, in other words, to get caught up in your payments, as of the date of this letter is $ 2578.02. You may cure this default withing THIRTY (30) DAYS of the date of this letter by paying to us the above amount of $ 2578.02, 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, cashiers check or money order, and made at 7909 Parklane Road, Columbia, South Carolina. 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 installments. If 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 paroceedings 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 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 THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACELERATION AND FORECLOSURE. EXHISITq 7909 Parklane Road (21p 29223) Post OMce Box 7126 Columbia, South Carolina 29202.7126 803741.3530 ,oosa J RESOURCE BANCSHARES MORTGAGE GROUP, INC. 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 day period, and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale of your home at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total due, as well as the reasonable attorney's fees and costs 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 Sheriff f-a sale could be held would be approximately six (6) months from the date of this letter. A notice of the date of the Sheriff's 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 at any time exactly what the required payment will be by calling us at the following number: 1-800-933-2652. This payment must be in the form of cashier's check, certified check or money order, and made payable to us at the address stated above. You should realize that a Sheriff's 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 Sheriff's sale, a law suit could be started to evict you. You have additional rights to help protect your interest 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 THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO ANOTHER BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDING 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.) CALL US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF. If you cure this default, the mortgage will be restored to the same position as if no default had occurred; however, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, DONALD SHEALY Default Specialist C1099 L?XH131TR 7909 Parklane Road (Zip 29223) Post Office Box 7126 Columbia, South Carolina 292027126 8037413530 weto INC. February lo, 1999 Michael J Mannai Linda H Mannai 333 Allen Street Carlisle, PA 17013 RE: RBMG Loan Number 463659 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Dear Mortgagor(s) : 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 this program works. If you need more information, call the Pennsylvania Housing Finance Agency at 1-800-342-2397. La notificacion en adjunto es de sums importancia pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificacion obennga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible Para un prestamo por el programs llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecino 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. EXHIBIT B 7909 Parklane Road (Zip 29223) Post Office Box 7126 Columbia, South Carolina 29202.7126 803.741.3530 1a10 February 10, 1999 Michael J Mannai Linda H Mannai 333 Allen Street Carlisle, PA 17013 RE: RBMG Loan Number 463659 IMPORTANT NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM. PLEASE READ THIS NOTICE. Dear Mortgagor(s) : You may be eligible for financial assistance that will prevent foreclosure on your mortgage if 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 your control, you have a reasonable prospect of resuming your 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 your rights. Under the Act, you are entitled to a temporary stay of foreclosure on 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 this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, cr 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 agenncy identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is necessary to schedule one face- to-face meeting. You should advise this lender immediately of your intentions. ORBITS V 7909 Parklane Road (ZIP 29223) Post Office Box 7126 Columbia, South Carolina 29202.7126 803.741.3530 1010 I I J RESOURCE BANCSHARES MORTGAGE GROUP, INC. Your mortgage is in default because you have 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 $ 2578.02. That sum includes principal, interest, and any accrued late charges or other related fees. 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 application must be filed or postmarded within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and 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 the Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone number (717) 780-3800, or 1-800-342-2397 (toll free). 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 a "Notice of intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Sincerely, DONALD SHEALY LJ 1 B 7909 Parklane Road (Zip 29223) Post Office Box 7126 Columbia, South Carolina 292027126 803.741.3530 n„a PENNSYLVANIA HOUSING PINANCS AGSNCY HOMEOAINER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSVPUIR CREDIT COUNSELING AGENCIES Acorn Houaiag Corporation 846 North Sroad Street Philadelphia, PA 19130 (215) 765-1221 (215) 765.1427 (fax) Bucks, Chester, Delaware, Montgomery, Philadelphia Action Housing, Tue. 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) 971-2210 (610) 687-7860 (fax) Bucks, Chester, Delaware, Montgomery, Philadelphia American Red Cross- Ranover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 (717) 637-3294 (fax) Adams, York, Franklin Bedford-Fulton Housing Services R.D. W1, Box 384 Everett, PA 15537 (814) 623-9129 (814) 623-7187 (fax) Bedford, Blair, Cambria, Fulton, Huntingdon, Somerset Blair County 3Com opportunity Council 2100 6th Avenue Altoona, PA. 16602 (814) 946-3651 (814) 946-5451 (fax) Adams Backer T. Washington Center 1720 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) 750-4318 (fax) Bucks 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, Son rest CCCS of Northeastern Pennsylvania 105 Elmira Street P.O. Box 218 Troy, PA 16947 (717) 297-2101 (717) 297-2799 (tax) Brad ford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming CCCS of Northeastern Pennsylvania 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, Tinge, Wayne, Wyoming CCCS of Western Pennsylvania, Inc. 1 North Gate Square W2 Garden Center Drive Greensburg, PA 15601 (412) 838-1290 Fayette, Greene, Indiana, Somerset, Washington, Westmoreland CCCS of Delaware valley 1515 Market Street Suite 1325 Philadelphia, PA 19107 (215) 563-5665 (215) 864-2666 (fax) Bucks, Chester, Delaware, Nootgo, Philadelphia CCCS of Western Pennsylvania, Inc. 309 Smithfield St. Pittsburgh, PA 15222 (412) 471-7584 Allegheny CCCS of Northeastern Pennsylvania 17 Crofton Street Wellsboro, PA 16901 (717) 724-5252 (717) 724-5783 (fax) Bradford, Sullivan, Susquehanna, Tinge, Wayne, Wyoming CCCS of Western Pennsylvania, Ina. 500-02 3rd Avenue P. 0. Box 278 Duncansville, PA 16635 (814) 696-3546 Armstrong, Bedford, Blair, Cambria, Cameron, Centre, Clearfield, Huntingdon, Juniata, Mifflin, Onion CCCS of Northeastern Pennsylvania 31 W. Market Street Wilkes-Barre, PA 18702 (717) 821.0837 or 800-922.9537 (717) 831.1785 (fax) Bradford, Carbon, Columbia, Lackawanna, Luzerne, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tinge, Wayne, Wyoming CCCS of Northeastern Pennsylvania 9 South 7th Street Stroudsburg, PA 18360 800-922-9537 (717) 420.8981 (fax) Bradford, Carbon,Monroe, Pike, Mayne CCCS of Western Pennsylvania, Inc. 675 Cherrytree Lane Uniontown, PA 15401 (412) 439-8939 Westmoreland CCCS of Western Pennsylvania, Inc. 58 E. Cherry Avenue Washington. Pa 15301 (412) 222.8292 Washington CCCS of Northeastern Pennsylvania German Street P.O. Box 389 Duehore, PA 18614 (717) 928.9668 (717) 928-8144 (fax) Bradford, Sullivan, Susquehanna, Tinge, Wayne, Wyoming CCCS of Western Pennsylvania, Inc. YMCA Building 339 N. Washington Street Butler, PA 16001 (412) 282.7612 Butler, Clarion, Jefferson, Mercer, venango 1" 1/9' CCCS of Waster: Pennsylvania, Yet. 2000 Linglestown Road Harrisburg, PA 17102 (717) S41-1757 (717) 731.9589 (fax) Adams, Cumberland Dauphin, Franklin, Perry Snyder, York CCCS of Neater: Pennsylvania, Inc. 971 Third Street Beaver, PA 15009 (412) 774-0798 Beaver CCCS of Northeaster: Pennsylvania 103 Warren Street P.O. Box 709 Tunkhannock, PA 18657 (717) 836.6840 (717) 836-6332 Bradford, Sullivan Susquehanna, Tinge Wayne, Wyoming CCCS of Northeaster Pennsylvania 931 Main Street Honesdale, PA 18431 (7171 253-4981 (717) 253-4817 (fax) Bradford, Sullivan Susquehanna, Tioga Wayne, Wyoming CCCS of Nester Pennsylvania, Inc. 912 South George Street York, PA 17403 (717) 546-4176 Fulton, Lancaster, York Franklin CCCS of Natter Pennsylvania, Inc. 1st Federal Plaza Suite 406 North Mill Street New Castle, PA 16101 (412) 652-8074 Lawrence Budget Counseling Center 147 North Fifth Street Reading. PA 19601 (610) 375-7866 (610) 376-6575 (fax) Barks, Chester, Montgomery, Schuylkill EXHIBIT B CCCS of Lehigh 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 Commission on Economic Opportunity of Luzerr County 163 Amber Lane Wilkes-Barre, PA 18702 (717) 826-0510 or 800.822.0359 (717) 829 1665 ca., before faxing (717) 455-4994 (Hazeltor (717)455 5631 (fax) ca2 before faxing ( 7 1 7) 8 3 6- 4 0 9 (Tunkhanncek) Carbon, Columbia Luzerne, Monroe Schuylkill, Wyoming Community Actic Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 (717) 234-2227 (fax) Cumberland, Dauphin Franklin, Perry, Snyder Community Action Development Comm 701 Dekalb Street Norristown, PA 19401 (610) 277-6363 (610) 277-2123 (fax) Montgomery Community Development Corp. or Frankford Croup ministry 4620 Oriscom Street Philadelphia, PA 19124 (215) 744-2990 (21S) 744-2012 (tax) 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 Bennett Square, PA 19348 (610) 444-3682 (610) 444-3178 (tax) Berke, Ch a star, 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, Luzerns, Northumberland, Schuylkill Fayette Co Community Action Agemey, Inc. 137 North Beeson Avenue Uniontown, PA 15401 (412) 437-6050 or 800-427-INFO (412) 437-4418 Fayette 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 aria Community Action Ccomaittes 18 West 9th Street Erie, PA 16501 (814) 459-4581 (814) 456-0161 (tax) Crawford, Erie, Venango, Warren Hispanic Assoc. of Contractors/Emt eryriess 2921-27 North 5th Street Philadelphia, PA 19133 (215) 744.2990 (215) 744-2012 (fax) Bucks, Chester, Delaware Philadelphia 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 (tax) Philadelphia Indiana County Community Action Program 827 Water Street, Box 187 Indiana, PA 15701 (412) 465-2657 (412) 465-5118 (tax) Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 (814) 898-1243 (tax) Crawford, Elk, Erie, Jefferson, Xckean, Veaaago Keystone Economic Development Corp. 1954 Mary Grace Lane Johnstown, PA 15901 (814) 535-6556 (914) 539-1688 (fax) Bedford, Blair, Cambria, Clearfield, Indiana, Somerset, Westmoreland Lycoming-Clintoncoustie¦ Commission for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williamsport, PA 17703 (717) 326.0587 (717) 322-2197 (fax) Centre, Clinton, Lycoming, Union Media Fellowship Nouse 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 Moa-Valley Unemployed Committee 120 E. 9th Avenue Homestead, PA 15120 (412) 462-9962 (412) 462.9964 (tax) Allegheny, Beaver, Butler, Fayette, 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) 963-9941 (fax) Chester, Delaware, Montgomery, Philadelphia Shenaago Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 Crawford, Lawrence, Mercer Tableland Services, Inc. 131 North Center Avenue Somerset, 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) (117) 399-4127 (fax) Cheater, Lancaster, Lebanon The Trehab Center of Northeastern PA 7 Lake Avenue, Box 339 Montrose, PA 18801 (7171 278-3338 or 800-982-4045 (717) 278-1889 (fax) Bradford, Sullivan, Susquehanna, TLoga, Wayne, Wyoming M-I MI E - la,s' Urban League of Pittsburgh, Inc. Building For Equal Opportunity One Smithfield Street Pittsburgh, PA 15222.2222 (412) 227-4802 (412) 261-5207 (tax) Allegheny . Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, PA 17101 (717) 234-5925 (717) 234-9459 (fax) Perry Urban League of Xetropolitan 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 (tax) Forest, Warren Weatherization 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 1/9" ALL that certain tract or parcel of land and premises, situ lying and being in the Township of South Middleton, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as followas BEGINNING at an iron pipe on the northern line of Allen Stree (50 feet wide) which point is located 469.80 feet measured westwardly from the western line of Valley Street is shown on the Plan of Carlisle Manor Extension recorded in Plan Book 3, Page 99; thence from said beginning point by lands now or formerly of L. Don Patterson, North 12 degrees 45 minutes Eas a distance of 150 feet to an iron pipe; thence by land now or formerly of John R. Mellinger and lands now or formerly of Jo: W. Heikes, South 77 degrees 15 minutes East, a distance of 75 feet to a point] thence through the center of Lot No. 34, Sou 12 degrees 45 minutes West a distance of 150 feet to a point the northern line of Allen Street; thence North 77 degrees 15 minutes West, a distance of 75 feet to an iron pipe, the Plac of BEGINNING. CONTAINING 75 feet in front along the northern line of 50 fee wide Allen Street extending northwardly therefrom at an even width, a distance of 150 feet and being all of Lot No. 35 andi the western 1/2 of Lot No. 34 of Block "D" of Carlisle Manor Extension as recorded in the hereinafter mentioned Reeorder'sl office in Plan Book 3, Page 99, on which there is erected a brick and aluminum siding covered 1 story range type dwelling house with attached garage numbered 333 Allen Street, Carlisl4 1. D. 940-22-0489-015 'i'Deed Source: Book 123, page 363" PREMISES: 333 ALLEN STREET IT:7ERMAY & MICHAEL J. MANNAI 1463659 VERIFICATION hereby states that he/she is Kenneth D. Cavins Mortgage Officer of Resource Bancshares Mortgage Group, Inc. mortgage servicing agent for Plaintiff in this matter, that he/she 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/her 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. Kenneth D. Cavins - Mortgage Officer Q 008 DATE: --=?-Z'i"'`- 1 ?1 ! ? N ti 1 n> Cy ?, r`-) 01- v Cy: ..? ? z Z a C=t ? F.. 1 • iwnut:aa rrr Y a?sorrr mx r •• wl Tiu In Nlul +lYi 4 IU ?Ouni() V is LLa ?MJ I l llvlt ns SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-05429 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RESOURCE BANCSHARES MORTGAGE vs. MANNAI MICHAEL J 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: MANNAI LINDA H but was unable to locate Her _ in his bailiwick. He therefore returns the COMPLAINT - Mnnm annn NOT FOUND , as to the within named defendant MANNAI LINDA H DEFT. NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FWDG. WITH P.O., RETURN NOT FOUND AS PER ATTY. Sheriff's Costs: So answe s: Docketing 6.00 Not Found Return 5.00 Affidavit 00 / Surcharge 8.00 omas ine, eri? $TT.-UU FEDERMAN & PHELAN Sworn and subscribed o before me this )V br- day of 19-9?q A.D. i rro on a SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-05429 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RESOURCE 13ANCSHARES MORTGAGE vs. MANNAI MICHAEL J 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: MANNAI MICHAEL J but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE XMMTl v NOT FOUND , as to the within named defendant MANNAI MICHAEL J DEFT. NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FWDG WITH P.O., RETURN NOT FOUND AS PER ATTY. Sheriff's Costs: So answers: Docketing 18.00 Service 3.10 Not Found Return 5.00 Surcharge 8.00 omas ine, 5 eri $3-4. FEDER & PHELAN 09/24 1999 Sworn and subscribed to before me this d y ? day of 19 I A.D. 1 c vJ SEP 3 4i l?f'S? u04?•?r,, t9?G1 Ll1lGl t`d':-?y il'cDa??ld rV.W 131U?? lIU3G F'? ?? a X33 ? ti 413V48 aaxouexm m ?a?oozuwe corm 'Inp)13m6-nv FEDERMAN AND PHELAN By: FRANK FEDERMAN. ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 463-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION RESOURCE BANCSHARES MORTGAGE GROUP, INC. 7909 PARKLANE ROAD COLUMBIA, SC 29223 V. Plaintiff TERM MICHAEL J. MANNAI LINDA H. MANNAI 333 ALLEN STREET CARLISLE, PA 17013 Defendant(s) NO.q,q - .?zg) ? 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. 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 TRUE COPY FROM RE0019D CARLISLE, PA 17013 la TAAww u y whereof, I here unto aet my hW (717) 249-3166 We hereby certify the and thlk seal of d l lsb, Pa. Wfthin to be a true acid T, i?umt 1 correct copy otthe oNinal hied o?p pd Pnlfla? FEDERMAN 'f .4 C v? f A Plaintiff is RESOURCE BANCSHARES MORTGAGE GROUP, INC. 7909 PARKLANE ROAD COLUMBIA, SC 29223 2. The name(s) and last known address(es) of the Defendant(s) are: MICHAEL J. MANNAI LINDA H. MANNAI 333 ALLEN STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 6/28/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE INVESTORS CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1392, Page 522. By Assignment of Mortgage dated recorded 9/13/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 554, Page 586. 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 12/1/98 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such a notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance Interest -$91,888.17 I l/l/98 through 8/I/99 5,263.50 (Per Diem S 19.14) Attorney's Fees Cumulative Late Charges 4,594.00 6/28/97 to 8/1/99 267.84 Cost of Suit and Title Search Subtotal 750.00 102,763.51 Escrow Credit Deficit 0.00 Subtotal 0.00 0.00 TOTAL $102.763.51 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 attomey'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 Stav as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: G-) 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 "A"; or (ii-) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 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 $102,763.51, together with interest from 8/1/99 at the rate of $19.14 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 February lo, 1999 Michael J Mannai Linda H Mannai 333 Allen Street Carlisle, PA 17013 RE: REMG Loan Number 463659 NOTICE OF INTENTION TO FORECLOSE Dear Mortgagor(s): The mortgage held by RRMG (herein we, us or our) on your property located at: 333 Allen Street, Carlisle PA 17013 is in SERIOUS DEFAULT because you have not made the monthly payments of $ 837.02 for 12/01/99 through 02/01/99. Late charges (and other charges) have also accrued in the amount of $ 66.96. The total amount now required to cure this default, or, in other words, to get caught up in your payments, as of the date of this letter is $ 2578.02. You may cure this default withing THIRTY (30) DAYS of the date of this letter by paying to us the above amount of $ 2578.02, 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, cashiers check or money order, and made at 7909 Parklane Road, Columbia, South Carolina. 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 installments. If 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 paroceedings 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 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 THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACELERATION AND FORECLOSURE. EXHIS17-A 7w ruuanc Kozo tblp ZyZZ3) Post Office Box 7126 C01umbi2, South Carolina 292027126 803.741.3530 iaa RBMG RESOURCE BANCSHARES MORTGAGE GROUP, INC. 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 day period, and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale of your home at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total due, as well as the reasonable attorney's fees and costs 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 Sheriff's sale could be held would be approximately six (6) months from the date of this letter. A notice of the date of the Sheriff's 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 at any time exactly what the required payment will be by calling us at the following number: 1-800-933-2652. This payment must be in the form of cashier's check, certified check or money order, and made payable to us at the address stated above. You should realize that a Sheriff's 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 Sheriff's sale, a law suit could be started to evict you. You have additional rights to help protect your interest 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 THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO ANOTHER BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDING 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.) CALL US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF. If you cure this default, the mortgage will be restored to the same position as if no default had occurred; however, you are not entitled to this right to cure your default more than three (3) times in any calendar year. sincerely, DONALD SHEALY Default Specialist 01099 L'xHIBITA 7909 Parklane Road (Zip 29223) Post Office Box 7126 Columbia, South Carolina 29202.7126 803-741.3530 1010 February lo, 1999 Michael J Mannai Linda H Mannai 333 Allen Street Carlisle, PA 17013 RE: RBMG Loan Number 463659 ACT 91 NOTICE TRICE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Dear Mortgagor(s): 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 this program works. If you need more information, call the Pennsylvania Housing Finance Agency at 1-800-342-2397. La notificacion en adjunto es de sums. importancia pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de seta notificacion obennga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible Para un prestamo par el programs llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecino 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. EXHIBIT B 7909 Parklane Road (Zip 29223) Post Office Box 7126 Columbia, South Carolina 29202.7116 803•741.3530 ioa,o February 10, 1999 Michael J Mannai Linda H Mannai 333 Allen Street Carlisle, PA 17013 RE: RBMG Loan Number 463659 IMPORTANT NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM. PLEASE READ THIS NOTICE. Dear Mortgagor(s) : You may be eligible for financial assistance that will prevent foreclosure on your mortgage if 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 your control, you have a reasonable prospect of resuming your 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 your rights. Under the Act, you are entitled to a temporary stay of foreclosure on 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 this 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 agenncy identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is necessary to schedule one face- to-face meeting. You should advise this lender immediately of your intentions. 9XHisir e 7909 Parklane Road (Zip 29223) Post Office Box 7126 Columbia, South Carolloa 29202.7126 803.741.3530 1u18 RBMG RESOURCE BANCSHARES MORTGAGE G_ROUP. INC. Your mortgage is in default because you have 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 $ 2578.02. That sum includes principal, interest, and any accrued late charges or other related fees. 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 i consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarded within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and 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 the Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone j number (717) 780-3800, or 1-800-342-2397 (toll free). 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 a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Sincerely, DONALD SHEALY EXHIGI1 B 7909 Parltlane Road (Zip 29223) Post Office Box 7126 Columbia, South Carolina 292027126 803.741.3530 iaw PENNSYLVANIA HOUSING FINANCE AGE33Cy HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES A C a r a R a u a i a g Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 (215) 765.1427 (fax) Bucks, 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, Payette, Greens, Nasbington, Westmoreland AM Credit Counseling Institute 175 Strafford Avenue, Suite 1 Wayne, PA 19087 (610) 971-2210 (610) 687-7860 (fax) Bucks, Chester, Delaware, Montgomery, Philadelphia American Red Cross- Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 (717) 637-3294 (fax) Adams, York, Franklin Bedford-Fulton 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 Econ opportunity council 2100 6th Avenue Altoona, PA. 16602 (614) 946-3651 (814) 946-5451 (tax) Adams Booker T. Washington Center 1720 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) 750-4318 (fax) Bucks 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 Pennsylvania 189 Elmira Street P.O. Box 218 Troy, PA 16947 (717) 297-2101 (717) 297.2799 (fax) Bradford,9ullivan, Susquehanna, Tiaga, Wayne, Wyoming CCCS of Northeastern Pennsylvania 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, Tiaga, Wayne, Wyoming CCCS of western Pennsylvania, Inc. 1 North Gate Square F2 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) Bucks, Chester, Delaware, Montgo, Philadelphia CCCS of Western Pennsylvania, Inc. 309 Smithfield St. Pittsburgh, PA 15222 (412) 471.7584 Allegheny CCCS of Northeastern Pennsylvania 17 Crafton Street Wellsboro, PA 16901 (717) 724.5252 (717) 724.5783 (tax) Bradford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming CCCS of western Pennsylvania, Inc. S00.02 3rd Avenue_ P. 0. BOX 278 Dnncansville, PA 16635 (814) 696.3546 Armstrong, Bedford, Blair, Cambria, Cameron, Centre, Clearfield, Huntingdon, Juniata, Mifflin, Onion CCCS of Northeastern Pennsylvania 31 W. Market Street Wilkes-Barre, PA 18702 (717) 821-0837 or 800-922-9537 (717) 821.1785 (fax) Bradford, Carbon, Columbia, Lackawanna, Luzern*, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tinge, Wayne, Wyoming CCCS of Northeastern Pennsylvania 9 South 7th Street Stroudsburg, PA 18360 800.922-9537 (717) 420.5981 (fax) Bradford, Carbcn,Monroe, Pike, Wayne CCCS at Western Pennsylvania, Inc. 675 Cherrytree Lane Uniontown, PA 15401 (412) 439-8939 Westmoreland COOS of Western Pennsylvania, Inc. 58 E. Cherry Avenue Washington, Pa 15301 (412) 222-8292 Washington CCCS of Northeastern Pennsylvania German Street P.O. Box 389 Dushore, PA 18614 (717) 928.9668 (717) 928-8144 (fax) Bradford, Sullivan, Susquehanna, TSoga, Wayne, Wyoming CCCS of western Pennsylvania, Inc. YMCA Building 339 N. Washington Street Butler, PA 16001 (412) 282.7812 Butler, Clarion, Jeffersoa, Mercer, vanango Rev 1/9 CCCS of Nester Pennsylvania, Inc, 2000 Linglestovc Road Harrisburg, PA 17102 (717) 541-1757 (717) 731.9589 (fax) Adams, Cumberland DauPbia, Franklin, Perry Snyder, York COOS of Neater nc. P971 Thi7&lTKlVrd Stania,reeit Beaver, PA 15009 (412) 774-0798 Beaver CCCS of Northeaster Pennsylvania 103 Warren Street P.O. Box 709 Tunkhannock, PA 18657 (717) 836-6840 (717) 836-6332 Bradford, Sullivan. Susquehanna, Tiaga Wayne, Wyoming CCCS of Northeaster Pennsylvania 931 Main Street Honesdale, PA 18431 (717) 253-4981 (717) 253-4817 (tax) Bradford, Sullivan. Susquehanna, Tiaga Wayne, Wyoming CCCS of Nester Pennsylvania, Inc. 912 South George Street York, PA 17403 (717) 846-4176 Fulton, Lancaster, York Franklin CCCS of Neater Pennsylvania, Inc. 1st Federal Plaza Suite 406 North Mill Street New Castle, PA 16101 (412) 652-8074 Lawrence Commission on Economic Opportunity of Luzer. County 163 Amber Lane Wilkes-Barre, PA 18702 (717) 826-0510 or 800-822-0359 (717) 829 1665 ca: before faxing (717) 455.4994 (Hareltc: (717) 455 5631 (fax) ca. before taxing ( 7 1 7) 8 3 6. 4 0 9 (TUnkhannOCk) Carbon, Columbia Luzerna, Monroe Schuylkill, Wyoming Budget Counseling Center 247 North Fifth Street Reading, PA 19601 (610) 375-7866 (610) 376-6575 (fax) Barks, Chester, Montgomery, Schuylkill EXHIBIT B CCCS of Lehigh 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) Barka, Bucks, Carbon, Lancaster, Lehigh, Northampton, Schuylkill Community Actio Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 (717) 234-2227 (fax) Cumberland, Dauphir Franklin, Perry, Snyder Connumlty Action Dewlopmaat coma 701 oek31b Street Norristown, PA 19401 (610) 277-6363 1610) 277.2123 (fax) Montgomery Community Development Corp, of Framkford Group Ministry 4620 Griscom Street Philadelphia, PA 19124 (215) 744-2990 (21S) 744-2012 (fax) Bucks, Cheater, Delaware Philadelphia Community Action southwest 22 West High Street Waynesburg, PA 15370 (412) 952-2891 Allegheny, Fayette, Greene, Washington, Westmoreland Community Housing Counselor, Inc. P.O. Sex 244 Kellett Square, PA 19348 (610) 444.3682 (610) 444.3178 (fax! Barka, Chester, Delaware, Lancaster, Montgomery Economic opportunity Cabinet of Schuylkill County 225 N. Centre Street Pottsville, PA 17901 (717) 622-1995 (717) 622-0429 (fax) Darks, Carbon, Lebanon, Lehigh, Lucerne, Northumberland, Schuylkill Fayette Co Community Action Agency, Inc. 137 North Beeson Avenue UnionCOWD, PA 15401 (412) 437-6050 or 800-427-INFO (412) 437-4418 Fayette 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 Hrie Community Action Committee 18 West 9th Street Brie, PA 16501 (814) 459-4581 (814) 456.0161 (fax) Crawford, Hrie, Veusmgo, Warren Hispanic AASOC. of Contractors/EOterprises 2921-27 North SCh Streat Philadelphia, PA 19133 (215) 744-2990 (215) 744-2012 (fax) Bucks, Chester, Delaware Philadelphia Housing Opportunities of Beaver County, Ise. 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 Houaing Council of Tork 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 Cmnmunity Action Program 827 Water Street, Box 187 Indiana, PA 15701 (412) 465-2657 (412) 465-5118 (fax) Armstrong, Cambria, Clearfield, Indiana, Jefferson, Weetmoroland John F. Kecnedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 (814) 898-1243 (fax) Crawford, Elk, Erie, Jefferson, Nckean, Venango Keystone Economic Development Corp, 1954 Mary Grace Lane JohnsCOWn, PA 15901 (814) 535-6556 (814) 539-1688 (fax) Bedford, Blair, Cambria, Clearfield, Indiana, Somerset, Westmoreland Lycoming-ClintonCOuotles Commission for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williamsport, PA 17703 (717) 326-0587 (717) 322-2197 (fax) Centre, Clinton, Lycoming, Union Media Fellowship House 302 S. Jackson Street Media, PA 19063 (610) S65-0846 Chester, Delaware, Montgomery, Philadelphia Media Fellowship House 658 North Watt, Street Philadelphia, PA 19123 (215) 978-0224 (215) 765.7614 (fax) Philadelphia Man-Valley VaemPlayed Committee 120 E. 9th Avenue Homestead, PA 15120 (412) 462-9962 (412) 462.9964 (fax) Allegheny. Beaver, Butler, Fayette, Greene, Washington, Westmoreland Northern Tier Community Action Corp. P.O. Box 389 135 West 4th Street Emporium, PA 15834 (914) 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) 963-9941 (fax) Chester, Delaware, Montgomery, Philadelphia Shaaaago Valley Urban League, Inc. 601 Indiana Ave... Farrell, PA 16121 (412) 981-5310 Crawford, Lawrence, Mercer Tableland Services, Inc. 131 North Center Avenue Somerset, PA 15501 (814) 445-9628 (814) 443-3690 (fax) Bedford, Cambria, Payette, Somerset, Westmoreland Tabor Canonicity Services, Inc. 439 E. King Street Lancaster, PA 17602 (717) 397-5182 or 800-788-5062 (H.O. only) (717) 399-4127 (fax) Chester, Lancaster, Lebanon The Trehab Center of Northeastern PA 7 Lake Avenue, Box 339 Montrose, PA 18801 (717) 278-3338 0, 800-982-4045 (717) 278-1889 (fax) Bradford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming VEMH IBIT B Urban League of Pittsburgh, Inc, Building For Equal Opportunity one Smi"field Street Pittsburgh, PA 15222-2222 (412) 227.4802 (412) 261-5207 (fax) Allegheny . Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, PA 17101 (717) 234.5925 (717) 234.9459 (fax) Perry Urban League of Netropolitan Harrisburg 2107 N. 6th Street Harrisburg, PA 17101 (717) 234.5925 (717) 234-9459 Cumberland, Dauphin, Franklin, Snyder Warren-Porrest Couatios economic Opportunit, Council 204 Liberty Street P.O. BOX 547 Warren, PA 16365 (814) 726.2400 (814) 723.0510 (fax) Forest, Warren Weetherixation Office 917 Mifflin Street Huntingdon, PA 16652 (914) 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 ALL that certain tract or parcel of land and premises, situatQ, lying and being in the Township of South Middleton, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pipe on the northern line of Allen Stree (50 feet wide) which point is located 469.80 feet measured westwardly from the western line of valley Street is shown on the Plan of Carlisle Manor Extension recorded in Plan Book 3, Page 997 thence from said beginning point by lands now or formerly of L. Don Patterson, North 12 degrees 45 minutes Eas a distance of 150 feet to an iron pipe; thence by land now or formerly of John R. Mellinger and lands now or formerly of Jol W. Heikes, South 77 degrees 15 minutes East, a distance of 75 fact to a point; thence through the center of Lot No. 34, Sou; 12 degrees 45 minutes West a distance of 150 feet to a point the northern line of Allen Street; thence North 77 degrees 151 minutes West, a distance of 75 feet to an iron pipe, the Placj of BEGINNING. CONTAINING 75 feet in front along the northern line of 50 fee wide Allen Street extending northwardly therefrom at an even width, a distance of 150 feet and being all of Lot No. 35 and the western 1/2 of Lot No. 34 of Block "D" of Carlisle Manor !Extension as recorded in the hereinafter mentioned Recorder's Office in Plan Book 3, Page 99, on which there is erected a brick and aluminum siding covered 1 story range type dwelling house with attached garage numbered 333 Allen Street, Carlisl I- D. 040-22-0489-015 "Deed Source: Book 123, page 363" PREMISES: 333 ALLEN STREET rEDERNAN & PRUTAN MICHAEL J. MANNAI #463659 Kenneth D. Cavins hereby states that he/she is Mortgage Officer Of Resource Bancshares Mortgage Group, lnc. mortgage servicing agent for plaintiff in this matter, that he/she 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/her 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. Kenneth D. Cavins - Mortgage Officer (41108 Z DATE: --442 OFF SEP I 3 41 [ _V CCWLLL6[6 M ur 01lvg ]ul ?ggllNl[Ni alllSpV to vorwQy CGILO 1tl931 ]ltll5'1lV • Ao FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION RESOURCE BANCSHARES MORTGAGE GROUP , INC. 7909 PARKLANE ROAD COLUMBIA, SC 29223 TERM Plaintiff V. NO. C? CUMBERLAND COUNTY MICHAEL J. MANNAI LINDA H. MANNAI 333 ALLEN STREET CARLISLE, PA 17013 Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE; NOTICE THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TIIATPURPOSE:, e'tetLL You have been sued in Court. If you wish to defend against the claims set turih in the following pages, you must take action within twenty (20) days after this Complaint and Notice rare 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 ajudgment 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 TELEPI IONS THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GETLEGAL HELP CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIA'HON 2 LIBERTY AVENUE TRUE DOPY FROM CARLISLE, PA 17013 RECORD (717) 249.3166 In TWNnony WlerW I here Ufa so my MW eaaf of caM,? ` That We hereby certify the within to be a true and correct copy of the original filed of record \ FEDERMAN AND PHELAIV Plaintiff is RESOURCE BANCSHARES MORTGAGE GROUP, INC. 7909 PARKLANE ROAD COLUMBIA, SC 29223 2. The name(s) and last known address(es) of the Defendant(s) are: MICHAEL J. MANNAI LINDA H. MANNAI 333 ALLEN STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/28/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE INVESTORS CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1392, Page 522. By Assignment of Mortgage dated recorded 9/13/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 554, Page 586. 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 12/1/98 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such a notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance '$91.888.17 Interest 5,263.50 11/1198 through 8/1/99 (Per Diem $19. 14) Attorney's Fees 4,594.00 Cumulative Late Charges 267.84 6/28/97 to 8/1/99 Cost of Suit and Title Search 750.00 Subtotal 102,763.51 Escrow Credit 0.00 Deficit 0.00 Subtotal 0.00 TOTAL $102,763.51 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 "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 10, Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 ct 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 $102,763.51, together with interest from 8/1/99 at the rate of $19.14 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 1 , J February 10, 1999 Michael J Mannai Linda H Mannai 333 Allen Street Carlisle, PA 17013 RESOURCE BANCSHARES MORTGAGE GROUP, INC. RE: REMG Loan Number 463659 NOTICE OF INTENTION TO FORECLOSE Dear Mortgagor(s): The mortgage held by RBMG (herein we, us or our) on your property located at: 333 Allen Street, Carlisle PA 17013 is in SERIOUS DEFAULT because you have not made the monthly payments of $ 837.02 for 12/01/99 through 02/01/99. Late charges (and other charges) have also accrued in the amount of $ 66.96. The total amount now required to cure this default, or, in other words, to get caught up in your payments, as of the date of this letter is $ 2578.02. You may cure this default withing THIRTY (30) DAYS of the date of this letter by paying to us the above amount of $ 2578.02, 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, cashiers check or money order, and made at 7909 Parklane Road, Columbia, South Carolina. 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 installments. If 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 paroceedings 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 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 THE FORECLOSURE PROCEEDING THE NON-EXISTENCE. OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACELERATION AND FORECLOSURE. EXH1B1TA 7909 Parklane Road (Zip 29223) Post Office Box 7126 Columbia, South Carolina 29202.7126 803.7413530 iaw 0MG RESOURCE adwCSHAREs MORTGAGE ` GROUP, INC. 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 day period, and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale of your home at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total due, as well as the reasonable attorney's fees and costs 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 Sheriff's sale could be held would be approximately six (6) months from the date of this letter. A notice of the date of the Sheriff's 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 at any time exactly what the required payment will be by calling us at the following number: 1-800-933-2652. This payment must be in the form of cashier's check, certified check or money order, and made payable to us at the address stated above. You should realize that a Sheriff's 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 Sheriff's sale, a law suit could be started to evict you. You have additional rights to help protect your interest 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 RAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO ANOTHER BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDING 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.) CALL US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF. If you cure this default, the mortgage will be restored to the same position as if no default had occurred; however, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, DONALD SHEALY Default Specialist 01099 9XHIBITA "7 raraune noas (Zip 29223) Post Me Box 7126 Columbla, South Carolina 29202-7126 803.7413530 16614 February 10, 1999 Michael J Mannai Linda H Mannai 333 Allen Street Carlisle, PA 17013 RE: RHMG Loan Number 463659 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Dear Mortgagor(s): 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 this program works. If you need more information, call the Pennsylvania Housing Finance Agency at 1-800-342-2397. La notificacion en adjunto es de sums importancia pues afecta su derecho a continuar viviendo en su Casa. Si no comprende el contenido de esta notificacion obennga Una traduccion immediatamente llamanca esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible Para un prestamo por el programs llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salver su case de la perdida del derecino 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. EXHIBIT B iyuy rarxtane Road (zip 29223) Post Office Box 7126 Columbia, South Carolina 29202.7126 803-741.3530 1"10 INC. February 10, 1999 Michael J Mannai Linda H Mannai 333 Allen Street Carlisle, PA 17013 RE: RBMG Loan Number 463659 IMPORTANT NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM. PLEASE READ THIS NOTICE. Dear Mortgagor(s) You may be eligible for financial assistance that will prevent foreclosure on your mortgage if 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 your control, you have a reasonable prospect of resuming your 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 your rights. Under the Act, you are entitled to a temporary stay of foreclosure on 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 this 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 agenncy identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is necessary to schedule one face- to-face meeting. You should advise this lender immediately of your intentions. 9)(HISIT S 7909 Parklane Road (Zip 29223) Post Office Box 7126 Columbia, South Carolina 29202.7126 8037413530 Ime RBMG RESO- BANCSHARES MORTGAGE GROUP, INC. Your mortgage is in default because you have 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 $ 2578.02. That sum includes principal, interest, and any accrued late charges or other related fees. 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 application must be filed or postmarded within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and 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 the Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone number (717) 780-3800, or 1-800-342-2397 (toll free). 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 a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Sincerely, DONALD SHEALY CVL.1 IT 7909 Parklane Road (Zip 29223) Post Office Box 7126 Columbia, South Carolina 29202.7126 803.741.3530 We PENNSYLVANIA HOUSING FINANCE AGM= HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES Acorn 8ouaiag Corporation 046 North Broad Street Philadelphia, PA 19130 (215) 765.1221 (215) 765.1427 (fax) Sucks, Chester, Delaware, Montgomery, Philadelphia Action Housing, Inc. Number Two Gateway Cancer 9th Floor Pittsburgh, PA 15222 (412) 391-19SC (412) 391.4512 (fax) Allegheny, Beaver, Butler, Payat o. Greece, Washington, Westmoreland AN Credit Counseling Institute 175 Strafford Avenue, Suite 1 Wayne, PA 19087 (610) 971-2210 (610) 687-7860 (fax) Bucks, Chester, Delaware, Montgomery, Philadelphia American Red Crass. Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 (717) 637-3294 (fax) Adams, York, Franklin Bedford-Pulton Housing Services R.D. P1, Box 384 Everett, PA ISS37 (814) 623-9129 (814) 623-1187 (fax) Bedford, Blair, Cambria, Fulton, Huntingdon, Somerset Blair County soon opportunity Council 2100 6th Avenue Altoona, PA. 16602 (814) 946-3651 (814) 946-5451 (fax) Adams Booker T. Washington Center 1720 Holland Street Erie, PA 16-003 (814) 453-5744 (814) 451.5749 (fax) Crawford, Brie, Warren Sucks County Housing Group, Inc. 140 E. Richardson Avenue Langhorne, PA 19047 (215) 750-4310 (215) 750.4318 (fax) Bucks CCCS of Western Pennsylvania, Inc. 312 Chestnut Street suits 227 Meadville, PA 16335 (814) 333-8$70 Lawrence CCCS of western Pennsylvania, Inc. Senior Activity Center 550 Main street Johnstown, PA 15901 (814) 539-6335 Cambria, Somerset CCCS of Northeastern Pennsylvania 185 Elmira Street P.0. Box 210 Troy, PA 16947 (717) 297.2101 (717) 297-2799 (fax) Bradford,9u111van, Susquehanna, Tioga, Wayne, Wyoming CCCS of Northeastern Pennsylvania 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 02 Garden Center Drive Greensburg, PA 15601 (412) 838-1290 Fayette, Greene, Indiana, Somerset, Washington, Westmoreland CCCS of Delaware valley 1515 Market Street Suite 1325 Philadelphia, PA 19107 (215) 563-5665 (215) 864-2666 (fax) Bucks, Cheater, Delaware, Montgo, Philadelphia CCCS of Western penaaylvarda, Inc. 309 Smithfield St. Pittsburgh, PA 15222 (412) 471-7504 Allegheny CCCS of Northeastern Pennsylvania 17 Crafton street Wellsboro, PA 16901 (717) 724-5252 (717) 724-5783 (fax) Bradford, Sullivan, Susquehanna, Tinge, Wayne, Wyoming CCCS of western Pennsylvania, Int. 500-02 3rd Aveouq P. 0. Box 278 Ountansville, PA 16635 (814) 696.3546 Armstrong, Bedford, Blair, Cambria, Cameron, Centre, Clearfield, Huntingdon, Juniata, Mifflin, Onion CCCS of Northeastern Penaaylvania 31 W. Market Street Wilkes-Barre, PA 18702 (717) 821.0837 or 800-922-9537 (717) 821-1785 (fax) Bradford, Carbon, Columbia, Lackawanna, Luzerne, Lyccming, Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tinge, Wayne, Wyoming CCCS of Northeastern Pennsylvania 9 South 7th Street Stroudsburg, PA 18360 800-922.9537 (717) 420.8981 (fax) Bradford, Carban,MOarae, Pike, Wayne CCCS of Western Pennsylvania, Inc. 675 Cherrytree Lane Uniontown, PA 15401 (412) 439.8939 Westmoreland CCCS of Western Pennsylvania, Inc. 58 E. Cherry Avenue Washington, Pa 15301 (412) 222-8292 Washington CCCS of Northeastern Pennsylvania German Street P.O. Box 389 Dushore, PA 18614 (717) 928.9668 (717) 928.8144 (fax) Bradford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming CCCS of Western Pennsylvania, Inc. YMCA Building 339 N. Washington Street Butler, PA 16001 (412) 282-7812 Butler, Clarion, Jefferson, Mercer, Venango Rw 1/9 CCC3 of eaC Pennsylvania, Inc. er 2000 LinglOSCOVn Road Harrisburg, PA 17102 (717) 541-1757 (717) 731-9$89 (fax) Adams, Cumberland Dauphin, Franklin, Perry Snyder, York CCC9 of waster Penaaylvania, Inc. 971 Third Street Beaver, PA 15009 (412) 774-0798 Beaver CCCS of Northeaster Pennsylvania 103 Warren Street P.O. Box 709 Tunkhannock, PA 18657 (717) 836-6840 (717) 836-6332 Bradford, Sullivan. Susquehanna, Tioga Wayne, Wyoming CCCS of Northeaste: Pennsylvania 931 Main Street Honesdale, PA 18431 (7171 253.498: (717) 253-4817 (fax) Bradford, Sullivan. Susquehanna, Tioga Wayne, Wyoming CCCS of wester Pennsylvania, Inc. 912 South George Street York, PA 17403 (717) 846.4176 Fulton, Lancaster, York Franklin CCCS of Waster Pennsylvania, Inc. let Federal Plaza Suite 406 North Mill Street New Castle, PA 16101 (412) 652-8074 Lawrence Budget Counseling Center 247 North Fifth Street Reading, PA 19601 (610) 375.7866 (610) 376-6575 (fax) B er ka, Cheater, Montgomery, Schuylkill EXHIBIT B CCCS of Lehigh 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 Commission on Economic Opportunity of Luzern County 163 Amber Lane Wilkes-Barre, PA 18702 (717) 826.0510 or 800-822-0359 (717) 829 1665 ca' before faxing (717) 455-4994 (Hazeltc: (717)455 5631 (fax) ca. before faxing ( 7 1 7) 8 1 6- 4 0 5 (TUnkhannock) Carbon, Columbia Luzerne, Monroe Schuylkill, Wyoming Community Acioc Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 (717) 234-2227 (fax) Cumberland, Dauphir Franklin, Perry, Sayde: Community Action Development Costs 701 Dekalb Street Norristown, PA 19401 (110) 277-6363 (610) 277-2123 (fax] Montgomery Community Development Corp. of Frankford Group Ministry 4620 Griscom Street Philadelphia, PA 19124 (2131 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 Opportuaity 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, Zoe. 137 North Beeson Avenue Uniontown, PA 15401 (412) 437-6050 or 800-427-INFO (412) 437-4418 Fayette Financial Counseling Services of Franklin 31 Nest 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 (814) 456.0161 (fax) Crawford, trio, Venango, Warren Stimpaalc Amoco. of Contractors/Enterprises 2921-27 North 5th Street Philadelphia, PA 19133 (215) 744.2990 (215) 144.2012 (fax) Bucks, Chester, Delaware Philadelphia Mousing 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 Mousing 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 627 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, Erie, Jefferson, Mcksan, van=go Keystone Economic Development Corp. 1954 Mary Grace Lane JOhnstOVn, PA 15901 (814) 535-6556 (814) 539.1688 (fax) Bedford, Blair, Cambria, Clearfield, Indiana, Somerset, Mestmorelaad Lycoming-C3lntoncounties C-48slon for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williamsport, PA 17703 (717) 326-0587 (717) 322.2197 (fax) Centre, Clinton, Lyeoming, Union Media Fellowship House 302 S. Jackson Street Media, PA 19063 _ (610) 565-0846 Chester, Delaware, Mont9o24rY, Philadelphia Media Fellowship Mouse 658 North watts Street Philadelphia, PA 19123 (215) 978-0224 (215) 765.7614 (fax) Philadelphia Mon-Valley Unemployed Committee 120 E. 9th Avenue Homestead, PA 15120 (412) 462-9962 (412) 462-9964 (Lax) Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Northern Tier Community Action Corp. P.0. Box 389 135 Nest 4th Street Emporium, PA 15834 (814) 486.1161 (814) 486-0825 (fax) Cameron, Rik, Mclteaa, Potter Philadelphia Council for Community Advancement 100 North 17th Street suit 600 Philadelphia, PA 19103 (215) 567-7803 (215) 963-9941 (fax) Chester, Delaware, Mcntgomery, Philadelphia Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 Crawford, Lawrence, Mercer Tableland Services, Inc. 131 North Center Avenue Somerset, 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) (117) 399-4127 (fax) Chester, Lancaster, Lebanon The Trehab Center of Northeastern PA 7 Lake Avenue, Box 339 Montrose, PA 18801 (717) 278-3338 or 800.982-4045 (717) 278-1889 (fax) Bradford, Sullivan, Susquehanna, Tinge, Wayne, Wyoming EXHJBFT B Urban League of Pittsburgh, Zen. Building for Squat opportunity One Smithfield Street Pittsburgh, PA 15222.222: (412) 227-4802 (412) 261-5207 (fax) Allegheny . Urban League of Metropolitan tarrtaburg 25 N. Front Street Harrisburg, PA 17101 (717) 234-5925 (717) 234-9459 (fax) Perry Urban League of Metropolitan Harrisburg 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 (717) 234-9459 Cumberland, Dauphin. Franklin, Snyder Warren-Forrest Counties Hcoaomic opportunit% Council 204 Liberty Street P.O. Box 547 Warren, PA 16365 (814) 726-2400 (814) 723-OSLO (fax) Forest, Marren Weatherisatica office 917 Mifflin Street Huntingdon, PA 16652 (814) 643-2343 Bedford, Blair, Fulton, Huntiagdon, Juniata, Mifflin, Perry YWCA of Carlisle 301 o Street Carlisle, PA 17013 (717) 243.3816 (717) 731-9589 (fax) Cumberland, Franklin, Perry Rev 1/9" ALL that certain tract or parcel of land and premises, situatq, lying and being in the Township of South Middlaton, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows, BEGINNING at an iron pipe on the northern line of Allen Strew (50 feet wide) which point is located 469.80 feet measured westwardly from the western line of Valley Street is shown on the Plan of Carlisle Manor Extension recorded in Plan Book 3, Page 99; thence from said beginning point by lands now or formerly of L. Don Patterson, North 12 degrees 45 minutes Ear a distance of 150 feet to an iron pipe; thence by land now or formerly of John A. Mellinger and lands now or formerly of Jot W. Heikes, South 77 degrees 15 minutes East, a distance of 75 feet to a point] thence through the center of Lot No. 34, Sou 12 degrees 45 minutes West a distance of 150 feet to a point i the northern line of Allen Street; thence North 77 degrees 15 minutes West, a distance of 75 feet to an iron pipe, the Plaa of BEGINNING. CONTAINING 75 feet in front along the northern line of 5o fee wide Allen Street extending northwardly therefrom at an even width, a distance of 150 feet and being all of Lot No. 35 and; the western 1/2 of Lot No. 34 of Block ^D" of Carlisle Manor Extension as recorded in the hereinaf ter mentioned Recorder' a Office in Plan Book 3, Page 99, on which there is erected a brick and aluminum siding covered 1 story range type dwalling house with attached garage numbered 333 Allen Street, Carlisl?. 1. D. #40-22-0489-015 "Deed Source: Book 173, page 363^ PREMISES: 333 ALLEN STREET FEDERMAN 6 P11E..\N MICHAEL J. MANNAI ,0467659 vvR1FI9ATION hereby states that he/she is Kenneth D. Cavins Mortgage Officer of Resource Bancshares Mortgage Group, lnc. mortgage servicing agent for plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civi I l Action in Mortgage ? Foreclosure are true and correct to the best of his/her 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. Kenneth D. Cavins - Mortgage Officer Qona DATE: 4Z .1 --- FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215)563-7000 Attorney for Plaintiff RESOURCE BANCSHARES MORTGAGE GROUP, INC. Plaintiff vs. MICHAEL J. MANNAI LINDA H. MANNAI Defendants COURT OF COMMON PLEAS CIVIL DIVISION . Cumberland County No. 99-5429-CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: November 11. 1999 ,-- c ? _ cr, c: _- i ' . u ; '- ... : ' .r ? C) !_.! " 1 ' _ . , . __J_. i 1 . _. (. ?- 1 u: 5 LI. 1 " l (I[Ip Zll. "I w OISOttLCgl wl ........ aw...:, p 9.110 Wool ilv6 llv NOV 2 2? FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 RESOURCE BANCSHARES MORTGAGE GROUP, VS. MICHAEL J. MANNAI LINDA H. MANNAI ORDER ATTORNEY FOR PLAINTIFF INC. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-5429-CIVIL AND NOW, this Z:? r?i 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), MICHAEL J. MANNAI, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address, 7514 A MILL RUN ROAD, FORT WAYNE, IN 46819, and to thelI (mortgaged premises at /3?33I AILLEIN// STREET, CARILISLE, PA 17013 yld b1 Ip?L(LCt? QgCCVi CGtcI??I?e?1?C? v?°`U0?I 24 C &)7 LLl`i a 17C`ySP; U 6 ox).4( GI«U?2lleA 1? LoO C--J? =J Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's office an Affidavit as to the mailing. J "a • ? r w (J K BY THE COURT: a C7 v FEDERMAN AND PHELAN ATTORNEY FOR PLAINTIFF BY: Lisa D. Blankenburg, Esq. Atty. I.D. 478020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 1215) 563-7000 RESOURCE BANCSHARES MORTGAGE GROUP, INC. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY VS. No. 99-5429-CIVIL MICHAEL J. MANNAI LINDA H. MANNAI MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Lisa D. Blankenburg, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by Certified mail and regular mail to the defendant's last known address, 7514 A MILL RUN ROAD, FORT WAYNE, IN 46819, and to the mortgaged premises,333 ALLEN STREET, CARLISLE, PA 17013 and in support thereof avers the following: 1. Attempts to serve Defendant (a) with Complaint have been unsuccessful, as indicated by the Sheriff's Return of Service by the Sheriff's Office attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as exhibit "B". WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail. Ic h Lisa D. lan burg, Esquire ATTORNEY FOR PLAINTIFF FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 RESOURCE BANCSHARES MORTGAGE GROUP, VS. MICHAEL J. MANNAI LINDA H. MANNAI ATTORNEY FOR PLAINTIFF INC. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-5429-CIVIL 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. 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. Ie ul L ly submitted: Lisa D Bla kenburg, Esquire Attorney for Plaintiff CASE NO: 1999-05429 P SHERIFF'S RETURN - NOT FOUND COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RESOURCE BANCSHARES MORTGAGE vs. ^\ MANNAI MICHAEL J ET AL aHIBl7A 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: MANNAI MICHAEL J but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named defendant MANNAI MICHAEL J DEFT. NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FWDG WITH P.O., RETURN NOT FOUND AS PER ATTY. Sheriff's Costs: Serviceng 18.00 3.10 So answers: Not Found Return 5.00 Surcharge 8.00 o mas ine, eri $34:1 FEDERMAN & PHELAN 09/24/1999 Sworn and subscribed to before me this day of 19 A.D. ro ono dry AFFIDAVIT OF SERVICE PLAINTIFF ILESOURCt ANCSHARES MORTGAGE GROUP IN COUNTY CUMREAL.&" DEFENDANT hg COURT N0.99.5g29 Ajmqpfidwddil? FILED: 09103(py PROPERTY ADDRESS: MALLpNSTgE TYPE OF ACTION GA_QT ISL. PA 17013 JLX Mortsw Formlaaure SERVEAT: zu AMR>a.1, sla Alm Eviction FORT WAYM IN J?1g Civil Action CPL OIL Promissory Note SERVE Served and made known to t??{tF4.l_ 1 Yl WA Defendant on the day of lgq_ at o'clock at 75l4 City of F'i , tT? Commonwealth of { nl I?, Nts N in the manner described below: _ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defeadant's residence who refused to give name/reladonship. Manager/Cktk of place of lodging in which Defendant(s) reside(s? V Agent or person in charge of Defendant's office or usual place of business. E1H1811 A v an office of said defendant company. ?1 Other. E AWZ?gl -i 1AZA A410 /1)/C/-/4C-4 01t;We-EO L I Y 1t a competent adult, being duly sworn according to law, depose and state that I personally hand a true and correct copy of the NMt1NS t Cn rtso?r hand to in the pptioned case on Ne date and the address indicated above. Sworn to and Before me lh subS b dey ptllL?tiL? SOp of N tN14 of 799qq AR`(PUB r)5 1,o3Nj .l_2LtLm ?i • ...LNt7t ?1M MA / J1 NOlary: M?.C . M BY=- ? ' 111 i of rved fvliETON lr2 y On the day of 199, at o'clock `.M., Defeadan} RIOT FOUND bcceusc: Moved -Unknown No Answer vacant Sworn to and subscribed Before me this _ day of _ 199__ Notary: By: ATTORNEY FOR P1 AINTIFF ?° FRANK FEDERMAN, SQUIRE- I.D. k 12245 Ar MtA1=0 AnDa 5oNLye TWO PENN CENTER PLA7A-SU M900 PHMADEUR A, PA 19102 (215) 563-7000 ' 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 546- PHONE: : ( 12115) 51 S46J400 Philadr... la j FAX: 215-985-0169 I'nAseminrio of drssional aervlcee for ProteuloaW Inc. Pnaess Srnrr. AFFIDAVIT OF SERVICE PLAINTIFF(S) 7- Michael J. Mannai Court of Common Pleas I of Cumberland Count NEAT Type of Service 1475 Mill Run Rd, #A I Civil Action Mortgage Foreclosure Fort Wayne IN 46804 SERVE BY: November 3, 1999 Accepted By: )Servedend made known tp Michael J. Mannai i ion the day of '19 _ , at o'clock, M,r let Commonwealth of Pennsylvania, in the manner described below: ? Defendant(s) personally served. ? Adult family member with whom said Defendant(s) reside(s). Relationship is i ?I Adult in charge of Defendant's residence who refused to give name or relationship. EXHISITA El Manager/Clerk of placing of lodging in which Defendant(s) resides). D ? Agent or person in charge of Defendant's office or usual place of business. ? Posted Other ---ESCRIPTION AGE---------HEIGHT--- WEIGHT RACE SEX Defendant ? day of fQ?DlfiyL 1990, at 101-5- o'clock, M., Dendant not found: -Moved -Unknown _No Ans -Vacant Other '971L Llve3 AT rv&etzsdler- IiKomE tn/ 61heLlse / . _L S S S = DEPUTIZED SERVICE Now, this day of 19-, I do hereby deputize the Sheriff of County to serve this Summons -Complaint _Other and make return therof and according to Law. By (Competent Adult) County Sheriff's Check $ x=========s===x====s__-_x___=_-__sSLSL==Sa *** Special Instructions *x ---- RUSH!!! 1 of 3 NAME OF SERVER Process 914-rO/ Sworn to & subscribe before me Server being duly sworn. ccording t law, day of 19 deposes and says that he/she is process server herein names; and PHILLIP D ROUDEBUSH t that the facts herein set forth above are true and correct to the best of NOTARY PUBLIC STATE OF INDIANA /l. // ii, their knowledge, information and belief, THIT-,v Sheriff MY COM?•' CO)UNTY l a5n, ?.e C1I' MnY;,Z(V Process Server/ Competent Adult Law Firm ' ---' -- `°" Attorney's Na -T?7?PST11-C8T7 el'--P1?Z--' 'Address ?Telephonep :+oryvvv ------ __ Identification I0 1990 Phdiid i,rhie Assoc. of Proleseionel Prncese server, aev I ATTEST . .„ PRO PROTHY December 3, 1999 DATE 235 SOUTH 13TH STREET PHILADELPHIA, 191074 PHONE: 12151 546-7400 [IL FAX: 215-985.0169 for ProleeelonW foe. AFFIDAVIT OF SERVICE e Phil6kiphla A.wci,nian a( Pndiviunnl Pncea &rvrn Re;:ource Ean•_t? I,,are_ Mr_,rr - "`??•"' 7a4r. croup <+?-54?-' Goober lA, 1999 DEFENDANT(S) our t of lbmmOll P1 I eas Michael Mannai :.` C;umn; ei lam:' COUnty SERVE AT T:pe. It 7 Ice ,cti<.n Mcrt.ua;? Fcoreclosure Fort Wavnr IN at,804 1 4 °•ERVE 8Y: Novemher 3, 1999 the CG:.24'-(90.A and made known to Ml•. ndel J. Man•',ai day of 19_, at o'clock, Commonwealth of Pennsylvania, in the manner described below: ? Defendant(s) personally served. ? Adult family member with whom said Defendant(s) reside(s). Relationship is ? Adult in charge of Defendant's residence who refused to give.name or relationship. ? Manager/Clerk of placing of lodging in which Defendant(s) reside(s). BXHIBITA p ? Agent or person in charge of Defendant's office or usual place of business. Posted pp??h1t r 9S&IPTION AGE HEIGHT 1•1F"iI-. DACE 5EY Defendant not frjurn?': r•IO,;.U -,w-, ___Plo An. _.a_8n JthteI- 5/LL Zi Vr5 47 z)/1f e4 ? i:5 61rlel/SC£ DEF'L!TI-EG `•RVICE NOW. t.hi!s _ Jar _ - tl - -_ ----- 1'' cl iff of )unLY [ and make return th-ref -- D'r (Competent ,vd,.l l t ' -----------?--?------?-"-- - .•?I rl! . - , .. : `' _ _ hec: k 9• xff Special Inssr v ri,> RUSH!!: I t s rv e Ur btnvtft , YOC Sworn tq & subscribe belora me this E-_S c .Brvti 7 ?i-rllN 'a-fC?/ `lt p being duly sworn according t law. day of 19 r ideposes and says that he/she is process server herein names: and that the facts herein set forth above are true and correct to the best of ?J )their knowledge, information and belief. 00000 Process Server/ /???- •? >i !Sheriff Competent Adult Firm 's Name. For -x'13-1= cc fF '' i # Identification lohle Assoc. of Profasslanel Promu Servers Ray 1 Z, ,:: oc t _.,) ATTEST PRO FROTHY :999 DATE PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 99.6429-CIVIL Attorney Firm: TRACK STARS Case Number: Subject: MICHAEL J & LINDA H MANNAI A.K.A.: LINDA MARTIN Property Address: 333 ALLEN STREET CARLISLE, PA 17013 Last Known Address: 7514 MILL ROAD A FORT WAYNE, IN 46819 ?`t1?? Last Known Number: ( ) - `?IH?e1r? Michael K Gross, being duly sworn according to law, deposes and says: 1. 1 am employed in the capacity of President for Players National Locator. 2. On 10/07/1999, 1 conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER: 028.54-8258 006-58-1341 B. EMPLOYMENT SEARCH: Contacted Linda at work, 219436-2679, Copy Solutions, 5928 W Jefferson Blvd., Fort Wayne, IN. 46804. She stated she is working at this address. She also stated she and Michael are both living at 1475 Mill Run Road #A, Fort Wayne, IN. 46819. C. INQUIRY OF CREDITORS: The creditors indicated that Michael and Linda are both living at 1475 Mill Run Road #A, Fort Wayne, IN. 46819 with no valid home phone number. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: The directory assistance has no listing for Michael and Linda Mannai. INQUIRY OF NEIGHBORS - N/A INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of October 5, 1999 the National Change of Address (NCOA) has no change for Michael and Linda from 1475 Mill Run Road #A, Fort Wayne, IN. 46819. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE 8 DMV OFFICE: The Indiana Department of Drivers Licensing has Michael and Linda listed at 1475 Mill Run Road #A, Fort Wayne, IN. 46819. OTHER INQUIRIES - A. DEATH RECORDS: As of October 5, 1999 the Social Security Administration has no death records on file for Michael B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC. " None Found C. COUNTY VOTER REGISTRATION: N/A ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: Michael 05160 Linda 12/58 AFFIANT Michael K Gross "NOTARY SEAL" 999 Kristine M. Scott, Notary- Public St. Louis County, State of Missouri My Commission Expires 91212002 Players National Locator 16201 Westwoods Business Park Drive St. Louis, MO 63021 Phone: (314) 230-9922 Fax: (314) 230-0558 LwAn , rB V E R I F I C A T I O N Lisa D. Blankenburg, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE COMPLAINT PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. October 28, 1999 Lisa D. Blan enburg, Esquire Attorney for Plaintiff 'FEDEI2MAN AIJD PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 56.3-7000 RESOURCE SANCSHARES MORTGAGE GROUP, INC. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County vs. No. 99-5429-CIVIL MICHAEL J. MANNAI LINDA H. MANNAI AN ANDPHEWtV CERTIFICATION F A RNY pj Y KENBURG, ESQUIRE, hereby certify that a copy ion for Alternate Service has been sent to the i iv "ual(s) as indicated below by Ea,. yet class mail, postage prepaid, on the date listed below. F'AgA MICHAEL J. MANNAI LINDA H.'` r? N??PW?Cq? 333 ALLEN STREET 333 ALLENr //IIppCAo? I CARLISLE, PA 17013 CARLISLE, PA 1 Y3Y 7514 A MILL RUN ROAD 7514 A MILL RUN ROAD FORT WAYNE, IN 46819 FORT WAYNE, IN 46819 The undersigned understands subject to the penalties of 18 PA falsification to authorities. that this statement is made C.S. 4904 relating to unsworn Lisa D. Blank burg, Esquire Federman and Phelan Date: October 28. 1999 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 RESOURCE BANCSHARES MORTGAGE GROUP, VS. MICHAEL J. MANNAI LINDA H. MANNAI INC. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County No. 99-5429-CIVIL CERTIFICATION I, LISA D. BLANKENBURG, ESQUIRE, hereby certify that a copy of the Motion for Alternate Service has been sent to the individual(s) as indicated below by first class mail, postage prepaid, on the date listed below. MICHAEL J. MANNAI 333 ALLEN STREET CARLISLE, PA 17013 7514 A MILL RUN ROAD FORT WAYNE, IN 46819 LINDA H. MANNAI 333 ALLEN STREET CARLISLE, PA 17013 7514 A MILL RUN ROAD FORT WAYNE, IN 46819 The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. Lisa D. Blankenburg, Esquire Federman and Phelan Date: October 28. 1999 a ?:_ W L_ C\ j X ?rZ c.n v rmx:iw rH.aisoueom wi }.,o-?rvwwi a w v COCO 1"31 3W 1aIS 15 l iv FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215)563-7000 RESOURCE BANCSHARES MORTGAGE GROUP, INC. Plaintiff vs. MICHAEL J. MAN NAI LINDA H. MANNAI Defendants TO THE PROTHONOTARY: Attorney for Plaintiff . COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County No. 99-5429-CIVIL Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. Date: January 10, 2000 c T FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff C i ? GAL. - , rpI? ILL) CL ? o U FEDERMAN AND PHEI.AN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 . iV Ponn CF'Ilt .? !'i'l.:a Philadelphia, PA 19102 1215) 563-7000 RESOURCE BANCSHARES MORTGAGE GROUP, INC. Plaintiff. VS. MICHAEL _T, ^1.nNNhi LINDA H. MANNAI Defendant(s) Attorney for Plaintiff COURT OF COMMON PLEAS ('TVTI., DIVISION CUMBERLAND COUNTY NO. 99-5429-CIVIL VERIFICATION I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to MICHAEL J. MANNAI at 333 ALLEN STREET, CARLS ILE, PA 17013 and 7514 A MILL RUN ROAD, FORT WAYNE, IN 46819 on January 28. 2000, in accordance with the Order of Court dated November 23, 1999. The undersigned understands .., ,t this statement is made subject to the per;alties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: January 28. 2000 FRANK FEDERMR Attorney for Plaintiff f-- c - ie "_' r. 'Lru 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 PHONE: 12151 546.7400 FAX: 215-985.0169 Bervicee Ior Prot'e?dorsW Inc. AFFIDAVIT OF SERVICE I'hdudelPhia V,4 ... ?iun u( Prufi.•wn:J I'ner.. tivrven I "^"? ""• Uq 1 t HtCEIVED Resource Bancshares Mortgage Group 99-5429 October 15, 1999 nece sin n wrrm. Manna i 1475 Mill Run RD, #A Fort Wayne IN 46804 of Cumberland County Civil Action Mortgage Foreclosure SERVE BY: November 3, 1999 CS1 rved and made known to Linda H . Ma n nna?.i c? A the ,.2 4 day of Ajw E fe- , 19 Q ?/ , at if 5l o'clock, th 9-514 Mu L Rlw QTR#a c-,- r , i A t i A ic, -,-.? 41 o :ommtIo,,nwealth of Pennsylvania, in the manner described below: pp I Iv Defendant(s) personally served. ? Adult family member with whom said Defendant(s) reside(s). Relationship is ? Adult in charge of Defendant's residence who refused to give name or relationship, ? Manager/Clerk of placing of lodging in which Defendant(s) reside(s). ? Agent or person in charge of Defendant's office or usual place of business. ? Posted n N ` 9NIPTION AGE y? HEIGHT Syy WEIGHT 13s RACE WI'K(TF-ZEX FEM&4--e. =a--?=cxxxxxxxxxcx=-xxxvxx=xxxxx:xxxxcxxxxcxx=xxcxxx=xxxxxx=xx;=x=xx=cacao=xxxaxxxx: On the day of 19_, at o'clock, _M., Defendant not found: -Moved -Unknown _No Ans Vacant Other ------ ------ ----- DEPUTIZED SERVICE Now, this day of 19_, I do hereby deputize the Sheriff of County to serve this -Summons -Complaint -Other and make return therof and according to Law. By (Competent Adult) County Sheriff's Check $ axxxxxxx=xxx=xx==xxxxxxxv=xx=xx=cxxvx=c=xa=xxaxxxa; *** Special Instructions *** RUSH!!! 2 of 2 OF SERVER //f /L Ocess Server being duly sworn according to law, case and says that he/she is process server herein names: and the facts herein set forth above are true and correct to the best of knowledge, information and belief. i Rx"AwteAm vOrY G PHI: La' I • ri,,,nc. NOTARY PUBLIC STATE OF INDIANA MY CC TII'TON COUNTY / Xi1MI5SI - ON EXP .1 MAY5,20(q Firm ' - 1110.. a ruoaan / mey's Nary rank i-e(Te an-?squire Fef_ aIntl ess wo enn enter Plaza e p la elephoneIf --- "'__ Identification 1990 Philadelphia Assoc. of Professional Process Sarver, Rev 1 Sworn to & subscribed before me this ,24 _day of?19? n?r CJ ^ ATTEST f roL.nonotary PRO PROTHY December 3, 199 DATE -- ;., -- , :_; ->; - ': ;;-; _ , !L ?? -_l - 1 ?? ?? Bror Pro[eulonW Inc. I ncshar AFFIDAVIT OF SERVICE Gr Philn.lelphia It \NK r.I I ITT .1( Pndc..i?mal I'n Kee, ticreen Ivcrnvurav,tal Court of Common Pleas Linda H. Mannai of Cumberland Count SERVE AT Type of Service i Copy Solutions Civil Action 5928 W. Jefferson Blvd Fort Wayne IN 46804 SERVE BY: November 3, 1999 12 mad and made known to Linda the y ?J` Y' 1 day of _ mmonwealth of Pennsylvania, in the manner described below: / © Defendantls) personally served. ? Adult family member with whom said Defendant(s) reside(s). Relationship is ? Adult in charge of Defendant's residence who refused to give name or relationship. ? Manager/Clerk of placing of lodging in which Defendant(s) reside(s). ? Agent or person in charge of Defendant's office or usual place of business. ? Posted By: VESCRIPTION AGE ?V HEIGHT WEIGHT ?3S RACEwy//?? SEX ?=vacvvcc==vac=cxxx==cccxcvvcxxvccc==cc xvvccaxxvccvcxxxa==cccxxxvvcccavvccxxavcc== On the day of 19_, at o'clock, _M., Defendant not found: -Moved -Unknown _No Ans -Vacant -Other --------------- ---------- --------- --------------- - ----- DEPUTIZED SERVICE Now, this day of 19_, I do hereby deputize the Sheriff of County to serve this -Summons -Complaint -Other and make return therof and according to Law. By (Competent Adult) County Sheriff's Check ---------- -------- *** Special Instructions ** RUSH!!! Attempt at this address if unsuccessful at home address. ocess?Server 072-74/ :deposes and says that he/she is process server herein names; and that the facts herein set forth above are true and correct to the best of their knowledge, information and belief. Sheriff Process Server/ Competent Adul ROLIDEBUSH NOTARYYgP BL D STATE OF INDIANA TIPTON COUNTY MYCOMMISSIONEXP MAYS2000 Firm , quire Frank nay's Nar-b i'CB-goo . W Penn CenFf reT-P'1_aZa- ess Philadeiphia PA j9,04 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 PHONE: (215) 546-7400 FAX: 215-965-0169 Sworn to & subsc U ? day of me 19 ATTEST . " . , PRO FROTHY December 3, 1999 Identification!! - - DATE ..???•L ? ? a ?..r "YF4' ?) ,'-? " ? J _, CJ FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE Attorney I.D. No. 12248 Suite 900 - Two Perm Center Plaza Philadelphia, PA 19102 (215) 563-7000 RESOURCE BANCSHARES MORTGAGE GROUP, INC. VS. MICHAEL J. MANNAI LINDA H. MANNAI Attorney for Plaintiff . COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-5429-CIVIL AFFIDAVIT OF SERVICE BY PUBLICATION IN ACCORDANCE WITH COURT ORDER I hereby certify that service of the Civil Action Complaint in Mortgage Foreclosure was made in accordance with the attached Court Order dated NOVEMBER 23. 1999 as indicated below: By publication as provided by Pa. R.C.P. Rule 430(b) in THE SENTINEL on January 21. 2000 and in the CUMBERLAND COUNTY LAW JOURNAL on JANUARY 28. 2000 Proofs of said publication is attached hereto. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK. FEDERMAN, ESQUIRE DATE: February 15, 2000 ... .,: , q9, s`Ya9 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Sherry Clifford, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued In said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published In the regular editions and issues of THE SENTINEL on the following dates, viz January 21, 2000 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Jan ry 26, 2000 Sworn to and subscribed before me this 26th day of January 2000 Notary Public My commission expires: NOTARIAL SEAL EHIRLE 0. DURNIN, Notary Pubfc Boro., Cumberland Cour,,y ission Ex Tres Au . 9, 2003 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, JANUARY 28, 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 of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are 2)/h Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 28 day of JANUARY. 2000 NOTARIAL 5c Al LCAS F.. SwoER, Notary Public Cadive Solo, Cumbodand County, PA My Cx miww Ecpuw Morch S, 2001 APL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Liw No. 09-5429-Civil RESOURCE BANCSHARES MORTGAGE GROUP. INC.. PLAINTIFF MICHAEL J. MANNAI and LINDA H. MANNA]. DEFENDANTS TO: MICHAEL J. MANNAI: You are hereby notified that on Sep- tember3. 1999, Plaintiff. RESOURCE BANCSHARES MORTGAGE GROUP. INC.. Ned a Mortgage Foreclosure Com- plaint endorsed with a Notice to De- fend, against you in the Court of Common Pleas of CUMBERLAND County, Pennsylvania, docketed to No. 99-5429-CML, wherein Plaintiff seeks to foreclose its mortgage se- cured on your property located. 333 ALLEN STREET, CARLISLE, PA 17013 whereupon your property would be sold by the Sheriff of CUMBERLAND County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of (his publication or a Judgment will be entered against you. NOTICE You have been sued In Court. If you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses or objections in writing with the court. You are warned that if you fail to do so, [tic case may proceed without you and J udgmcnt may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. You should take this notice 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 FRANK FEDERMAN FEDERMAN AND PHELAN Attorneys for Plaintiff 900 Two Penn Center Plaza Philadelphia. PA 19102 (215) 563-7000 Jan. 28 Cumberland Notices T 'r W. - FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Resource Bancshares Mortgage Group, Inc. 7909 Parklane Road Columbia, SC 29223 Plaintiff Attorney for Plaintiff : Cumberland COUNTY :COURT OF COMMON PLEAS : CIVIL DIVISION VS. NO. 99-5429 Civil Michael J. Mannai Linda H. Mannai 7514 Mill Road Run, #A Ft. Wayne, IN 46819 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enterjudgment in favor of the Plaintiff and against Michael J. Mannai and Linda H. Mannai, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $102,763.51 Interest 8/1/99 to 311100 4,095.96 TOTAL $106,859.47 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237. 1, copy attached. P NRp AN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 1 '! n a 1 0,00 C? PRO PROT "THIS FIRM IS A DEm' COLLEC 1"OR ATI'F.MPTING TO COLLF.CI',t IIF:B"r AND,%NI' INFOR,%Lt7'ION OBTAINED WILL RE USED FOR THAT PURPOSE. IF YOU I6WE PRF.VIOUSIA' RECEIVEII A DISCHARGE IN BANRRurrCY AND Tms DEBT WAS NO'r REAFFIRMED, TI IIS CWItRF.SI'ONDENC'E IS NO'F AND 51101111) NO I- BE CONS '1'RUF.D TO BEAN AT'r&NIPT TO COLLECT A DEBT, BUTONLV F.NFORC'F.MENT OFA LIEN AGAIN51' PROPEWIA'. •• FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 RESOURCE BANCSHARES MORTGAGE GROUP, INC. Plaintiff V5. MICHAEL J. MANNAI LINDA H. MANNAI Defendant(s) TO: MICHAEL J. MANNAI 7514 A MILL RUN ROAD FORT WAYNE, IN 46819 DATE OF NOTICE: FEBRUARY 18. 2000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 99-5429-CIVIL 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 r? 1 7-EUERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza .1V 4V - ATTORNEY FOR PLAINTIFF Suite 900 Philadelphia, PA 19102-:799 (215) 563-7000 I RESOURCE BANCSHARES hIORTGAGE COURT OF COMMON PLEAS GROUP, INC. Plaintiff CIVIL DIVISION CUMBERLAND COUNTY VS. MICHAEL J. MANNAI NO. 99-5429-CIVIL LINDA H. MANNAI Defendant (s) TO: MICHAEL J. MANNAI 333 ALLEN STREET CARLSILE, PA 17013 DATE OF NOTICE: FEBRUARY 19, 2000 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 FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 RESOURCE BANCSHARES MORTGAGE GROUP, INC. Plaintiff Vs. MICHAEL J. MANNAI LINDA H. MANNAI Defendant TO: LINDA H. MANNAI 7514 A MILL RUN ROAD CARLSILF,, PA 17013 DATE OF NOTICE: FEBRUARY 18. 2000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 99-5429-CIVIL THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROEPRTY. 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 FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Resource Bancshares Mortgage Group, Inc. Plaintiff VS. Michael J. Mannai Linda H. Mannai Defendant(s) Attorney for Plaintiff Cumberland COUNTY : Court of Common Pleas : CIVIL DIVISION : NO. 99-5429 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 Michael J. Mannai is over 18 years of age and resides at Present Whereabouts Unknown. (c) that defendant Linda H. Mannai is over 18 years of age, and resides at 7514 Mill Road Run, #A, Ft. Wayne, IN 46819. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. F "K FEDERMAIU Attomey for Plaintiff (Rule of Civil Procedure No. 236 - Revised) Resource Bancshares Mortgage Group, Inc. Plaintiff VS. Michael J. Mannai Linda H. Mannai Cumberland COUNTY Court of Common Pleas CIVIL DIVISION NO. 99-5429 Civil Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on March 2000. By DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN ESQUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA 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 AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. -- i 1 ( L ? ? W ? ?1. [ [ l. (x? gyp{ U O v U N PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 Resource Bancshares Mortgage Group, Inc. Cumberland County Plaintiff, V. No. 99-5429 Civil Michael J. Manual Linda H. Mannai Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 3/1/00 - 9/6/00 (per diem - $17.57) $106,859.47 $3,338.3 0 and Costs $110.197.77 TOTAL IF?K' FEDN, ESQUIRE NN CE ER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property.No. dA- t A Q a H w;? ?z o .. ar _ 4 z i zz w OF ? Uz co F U ? C: Q y Oz m U ? F ? o z? C R ? C W O ?x c W a o 2.4 0 F a WU w W O F a w w w w o. d 0 h O w° e x u. a °c •W =aZ W l C4 cc Q3 e 93 ON W 00 Cae,? o y Cl W D W ? L >. ?d3 a -V t a N a Q /' DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of South Middleton, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pipe on the Northern line of Allen Street, (50 feet wide) which point is located 469.80 feet measured Westwardly from the Western line of Valley Street is shown on the Plan of Carlisle Manor Extension recorded in Plan Book 3, Page 09; thence from said beginning point by lands now or formerly of L. Don Patterson, North 12 degrees 45 minutes East, a distance of 150 feet to an iron pipe; thence by land now or formerly of John R. Mellinger and lands now or formerly of John W. Heikes, South 77 degrees 15 minutes East, a distance of 75 feet to a point; thence through the center of Lot No. 34, South 12 degrees 45 minutes West, a distance of 150 feet to a point on the Northern line of Allen Street; thence North 77 degrees 15 minutes West, a distance of 75 feet to an iron pipe, the Place of the BEGINNING. CONTAINING 75 feet in front along the Northern line of 50 feet wide Allen Street extending Northwardly therefrom at att. even width, a distance of 150 feet and being all of Lot No. 35 and the Western 1/2 of Lot No. 34 of Block "D" of Carlisle Manor Extension as recorded in the hereinafter mentioned Recorder's Office in Plan Book 3, Page 99, on which there is erected a brick and aluminum siding covered 1 story ranch type dwelling house with attached garage numbered 333 Allen Street, Carlisle. TITLE TO SAID PREMISES IS VESTED IN Michael J. Mannai and Linda H. Mannai, His Wife by Deed from Michael J. Mannai, dared 06/02/95, recorded 06109195 in Deed Book 123, Page 363 1 c fz; `.- ?\ _ _Q? I I i I v `1 ag°L7 q a OL .. Resource Bancshares Mortgage Group, Inc CUMBERLAND COUNTY Plaintiff, V. COURT OF COMMON PLEAS Michael J. Manual CIVIL DIVISION Linda H. Manual NO. 99-5429 Civil Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Resource Bancshares Mortgage Groun Inc., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 333 Allen Street. Carlisle, PA 17013 Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Michael J. Manual 7514 A Mill Run Road Fort Wayne, IN 46819 Present Whereabouts Unknown Linda H. Mannai 7514 A Mill Run Road Fort Wayne, IN 46819 2. 3. 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 Name and address of everyjudgment 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.) PA Housing Finance 2101 North Front Street Agency Harrisburg, PA Household Realty 25 Gateway Drive, Suite 107 Corporation Mechanicsburg, PA 17055 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 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 333 Allen Street Carlisle, PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County 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 unswom falsification to authorities. May 18.2000 1 ° A DATE Fl NK FE E AN, ESQUIRE?? A omey for Plaintiff 1 FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Resource Bancshares Mortgage Croup, Inc. Plaintiff, V. Michael J. Manual Linda H. Manual Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-5429 Civil CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRA K FE RM N, ESQUIRE Att ney for Plai iff i.; i v'. Ci- -- ?, i? C ?. ?.,? ?_ i, ._ L' ?_. Resource Bancshares Mortgage Group, inc. Plaintiff, V. Michael J. Manual Linda H. Manna! Defendant(s), TO: Michael J. Mannai Linda H. Mannai 7514 A Mill Run Road Fort Wayne, IN 46819 CUMBERLAND COUNTY No. 99-5429 Civil May 18, 2000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 333 Allen Street, Carlisle. PA 17013, is scheduled to be sold at the Sheriffs Sale on September 6. 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by Resource Bancshares Mortaaee Group, Inc. (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the December 6, 2000 Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE, THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of South Middleton, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pipe on the Northern line of Allen Street, (50 feet wide) which point is located 469.80 feet treasured Westwardly from the Western line of Valley Street is shown on the Plan of Carlisle Manor Extension recorded in Plan Book 3, Page 99; thence from said beginning point by lands now or formerly of L. Don Patterson, North 12 degrees 45 minutes East, a distance of 150 feet to an iron pipe; thence by land now or formerly of John R. Mellinger and lands now or formerly of John W. Heikes, South 77 degrees 15 minutes East, a distance of 75 feet to a point; thence through the center of Lot No. 34, South 12 degrees 45 minutes West, a distance of 150 feet to a point on the Northern line of Allen Street; thence North 77 degrees 15 minutes West, a distance of 75 feet to an iron pipe, the Place of the BEGINNING. CONTAINING 75 feet in front along the Northern line of 50 feet wide Allen Street extending Northwardly therefrom at an even width, a distance of 150 feet and being all of Lot No. 35 and the Western 1/2 of Lot No. 34 of Block "D" of Carlisle Manor Extension as recorded in the hereinafter mentioned Recorder's Office in Plan Book 3, Page 99, on which there is erected a brick and aluminum siding covered 1 story ranch type dwelling house with attached garage numbered 333 Allen Street, Carlisle. TITLE TO SAID PREMISES IS VESTED IN Michael I. Manrai and Linda H. Mannai, His Wife by Deed from Michael J. Manual, dated 06/02/95, recorded 06/09/95 in Deed Book 123, Page 363 ,. (;' '.(1 O: 1. __ (- 1 ?? _ ? ? L?J ( ., L_ F- _ 11 _ Li ? ? ? ? 1 FEDERMAN AND PHELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF SUITE 900 - TWO PENN CENTER PLAZA PHILADELPHIA, PA 19102 (215) 563-7000 CUMBERLAND COUNTY RESOURCE BANCSHARES MORTGAGE COURT OF COMMON PLEAS GROUP,INC vs. CIVIL DIVISION NO. 99-5429CIVIL MICHAEL J. MANNAI LINDA H. MANNAI VERIFICATION I hereby certify that a true and correct copy of the Notice of Sheriff's Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to the following person (s) MICHAEL J. MANNAI on MAY 22, 2000 at7514 A MILL RUN ROAD ,FORT WAYNE,IN 46819 and 333 ALLEN STREET CARLISLE, PA 17013 in accordance with the Order of Court dated,NOVEMBER, 23 1999. The undersigned understands that this statement is made subject to the penalties of 18 PA. C.S. s4904 relating to unsworn falsificaton to authorities. DATE: JUNE 23, 2000 REIIJRN PDSP4E Po E° RECEIPT PE9DCTED CEIhERY . [7 SERVICE CERREDFEE •TSTLMPRECEVT . TOT&VOtifpE Yq FEES LQ SENT O qo ,E 1-1 Ir r KICKALi. J. "Amw c 333 AI-TJM STIM CL CARLISLE. PA 17013 qmK r T i 12 PS FORM 3800 US Postal Service Receipt for ' Certified Mail S ..o E3 .03 0 Ir o- s r r a .9 REMRN CQ4TAOE - RR GATE V _ Q? .•. ` PE4TPICTED DEUVEPV ? ? -` t RE EPT O a GEltllF[O FEE.PENPoIPECEVT E /,. ? 9 SERVICE ' 1 TDT&PD§TIGEMOFEES ZO ?y' 1-= 2W . SENT TO: ParFDR Ta.DONUm W C: ? , .. C S ,_ KICBAJIL J. NAMW I 7314 A KILL UN ROAD .' 1ORT YA21i8. Is 46819 WW W°+ owl K a+ PS FORM 3800 US Postal Service Receipt for Certified Mail S i -l , BY: Lisa D. Blankenburg, Esq. Atty. I.D. 478020 Sty. 9JG/'Iwo Tenn Center Plaza Philadelohia, PA 19102 .L2 15) 567_7000 RESOURCE BANCSHARES MORTGAGE GROUP, INC. COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY MICHAEL J. MANNAI No. 99-5429-CIVIL LINDA H. MA,Wi AI I ORDER AND NOW, this QT-9 day cf ? ovc? 1y99, upon consideration of DI a4 Z:4ff 3 Mot,:) _-d - the t_dar_t ?f Gocc :with Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), MICHAEL J.i'L\1NAI, by mailing a true and correct copy i of the Complaint by certified ma-1 and ecular mail to the defendant's last known address, 7514 A MILL RUN ROAD I FORT NAME IN 46819, and to the mortgaged ? premises at 333 ALLEN STREET, CARLISLE, PA 17013 ? yl? b, p L??G I q,z c C I } 2.17 C 7LCl`i a r7Cwsa?D *-.3x trr ?C^ C Service of the floemen2io edt a lincs?is effective u on7the date of mailing and is to be done by Plaintiffs attorney, who will file with the prothonotary 's Office ar.. Affidavit as to the mailing. BY THE COURT: u? O r W -o r -• ? ?' ?`- ? - l - ?C N ._ . ?; ..1= u. li:? ?_? G. ::J ,? L:... ?..:- 1_ -_? i ?.. : 1 lU :Y ??) O :. 1 f.^ -? ,? c.? CJ AFFIDAVIT OF SERVICE PLAINTIFF Resource Bancsha;cs Mortgage Croup, Inc. Cumberland County DEFENDANT(S) Linda H. Manna) No.99-5429 Civil SERVE AT 7514 A MITI Run Road Type of Action Fort Wayne, IN 46819 - Notice of Sheriffs Sale Sale Date: September 6, 2000 / SERVED Served and made known to iZiaNvlA4 ? lS?r° Defendant, on the day of Z u n e'_ , nog atg'°s o'clock O.m.,at ?5i`Ir)rN;// Run r?,Q 2=+ LJ4 C. ? TaJ ?f68 /q , 1xrrtnomvealtb o P°"=?;A, in the manner described below: 2 Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: AgeY9-I(S Height f_e7 Weight l _qO Race -{y_ Sex Other I' ryc'`?? OCI a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of_ ghe_ riffs Salo in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscri d befor me this/day or Notary: ?/A,•,.o ? On the day of By' NOTSERVED 200_, at o'clock _.m., Defendant NOT FOUND because: - Moved _ Unknown _ No Answer Other: Sworn to and subscribed before me this _ day of ,200 Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 Vacant tr, C r) i I Ll :(L co - V U PROOF OF PUBLICATION 1?9- sw? ?C%•ut:L ~? State of Pennsylvania, County of Cumberland. Sherry Clifford, Classified Ad Manager Mf 7=7? of THE SENTINEL, the County and State aforesaid, being duly sworn, deposes and says that THE ENTINEL, a newspaper of general circulation In the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly Issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published In the regular editions and issues of THE SENTINEL on the following dates, viz June 15, 2000 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. June 21, Sworn to and subscribed before me this 21 day of June 2000 Notary Public My commission expires: MOTARIAL SEAT.. SHIRLEY U. DURNiN, Abtar/ r^uNx [Carlisle Ooro., Ccmbarland County Commission Ex•nras Au . 9, 2003 I Copy of Notice of Publication ,A NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Actlon-Law No. 99.5429 Civil Resource Bancshares Mortgage Group, Inc., Plaintiff VS. Michael J. Manual and Linda H. Mannal, Defendants NOTICE OF SHERIFFS SALE OF REAL PROPERTY TO: MICHAEL. J. MANNAI TAKE NOTICE that the real estate located at 333 Allen Street. Carlisle, PA 17013, Is scheduled to be sold at Sheriffs Sale on Wednesday. Seplenn- her 6, 2000 at 10:00 A.M., In the Cmn. berland County Courthouse, South Hanover Strcel. Carlisle, PA 17013, to enforce the court judgment of $106.859.47, obtained by Resource Bancshares Mortgage Group, Inc. (the mortgagee). Prop. sit. In the TWp, of South Middletown beg. Al an iron pipe on the N line of Allen St. 469.80 ft. from the W line of Valley St. Front: 75 ft. Depth: 150 R. Being Premises: 333 Allen Street, Carlisle, PA 17013. Improvements consist of resldeu- Hill property. Sold as the property of Michael J. Mannat and Linda H. Manual, TERMS OF SALE: The purchaser at sale must pay 10% of the amount of Ins/her bld on the day of sale, the remaining balance Is to be paid it, later than the Friday following the Sherlfl's Sale. If compiled with, a deed will be tendered by the Sheriff al the next available Court of Common Pleas far Cumberland County con- veying to the purchaser all the right, title. Interest and clalm which the said defendant has In and to the said property at the time of levying the same. If the above conditions are not complied with on the behalf of the purchaser. the property will again be offered for sale by the Sheriff within thirty days of the original sale. The said purchaser will be held liable for the deficiencies and additional cost of said sale. TAKE. NOTICE that a Schedule of Distribution will be filed by the Sher- Iff on 10/6/00, distribution will be made in accordance with the sched- ule unless exceptions are filed. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 June 23 Cumberland Notices PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, 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, JUNE 23. 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 of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 23 day of JUNE. 2000 VDIS E. 54YDE1, NotaryP,W (arhd r loro, Curnbadand County, ?A My Commiuion ExpprM Momh 3, 2001 c_; lJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FLEET MORTGAGE CORPORATION Plaintiff CIVIL DIVISION vs. No. 99-5429 CIVIL MICHAEL J. MANNAI LINDA H. MANNA[ Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for FLEET MORTGAGE CORP, hereby verify that on MAY 22. 2000, true and correct copies of the Notice of Sheriffs 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 MAY 22. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. FE ERMAN, ESQUIR 4 F Attorney f r Plaintiff Date: August 10. 2000 0 a` z? a r ? W O 2a? d z a? 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HA,CII « " 7514 A DMZ 8= )m01D 4b Se v ce Type ^ ?•? ?{ . { FORT MUE, la 46819 CER T IF IE l W r w e .' ; ' . 7. Date of Delivery)t?" " 5 Received By. (Airtf Name! 8.. Addressee's' mn ' PS FORIVI 3811, ember 1994 ?'*`?"^ +k r'? DOI?BS?IC 8 RI ?'`?m Ilii i'•iia nilr;k'?s'af+fFa,x?il - r - 1 SENDER: ?:e• « : :. r+ xr'+K' 1 . Cteck;ex M right e>ul?n Re 'er'Etl ettkled sz ?? • M r Iann en' addmu on f{\a - , ! ?Ydt.°i M1, J,t ,j IN ao mat wa ran nbrrl tnfi eery „}, \ . Attain this I.m ro Ire hard of ttw Mwblec'Er a(t the'bark M aosgdoea oerme..'if?^ Ni•9pF.? . • TIN Rem. Receipt x511 slaw le whom the ab win 1 aq nb deb dWAyad ` ...' . Coasutt PustRlssfet'.lor"fee?ta 3. Ankle Addressed to' , Arocie Number ( x? - P 97 IT?9Zp 6[}7 LSM1A tt•'tlA`iDW 4b- Seance Type 4^ •:. 7514 A HILL. nX RDAp r > t MT ilAtK, IN 46319 ^"' X CERTIFIED .i r.,.: 7. Dale of Delivery sus 5. Received By: (Riot Name' U. Addressees Address 6. Signat e' (Adtlress r Ps F 38 10, 94 Domestic Return Receipt L_I RE TU,: r, POSTMARK OR DATE r cc C3 ....I .: ? SENT TO_ NUI FOR INTE N NgrION.L MILL r r OWN t , PS FORM 3800 US Postal Service Receipt for Certified Mail I I Cc ra r s r Q. RETURN P.DSTMARK AA RATE A RECEIPT fF.00fLIVERV E SERVICE c STbE ANO FEES LQ 1 ?L q SENT TO: NO1..T FOOx,x agNgnON4 , 4 C -._... n € ,achAz. J. us'gA1 1514 A I RLSA itt AD n "rCRT iATiJr:, TN 40319 LL L F D?K v J r umvi jouu uo roscai service Receipt for 'z Certified Mail n 7 - , - - I "'" POSTMARK OR RATE RETURN ¦ € M1 ¦ nT.LmrTEOCrr:Em ? RECEIPT ' -13 I frri:.C J!(IL:Ei.vT, vE: r'VT SERVICE C r•vL ? ;ra u,o F-E; L C, AO 11A u IxC v q0 yL - _.! SENT TO: xor FOn lxrERH?n IL ALga pjr. `? LL aH LL C IT' C ?IMK s PS FORM 3800 US Postal Service Receipt for Certified Mail } (V cl, _ T J _ J _y w?z Cl- (- ri Resource Bancshares Mortgage Group In The Court of Common Pleas of Cumberland County, Pennsylvania -vs- No. 1999-5429 Civil Micael J. Mannai and Linda Mannai R. Thomas Kline, Sheriff, who being duly swom according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 14.27 Advertising 15.00 Posting Bills 15.00 Law Library .50 County 1.00 Mileage 3.10 Certified Mail 1.38 Levy 15.00 Postpone Sale 20.00 Surcharge 30.00 Share of Bills 23.53 Law Journal 344.45 Patriot News 198.68 $ 711.91 Pd by Arty 09/07/00 Sworn and subscribed to before me This //!? day of cZo 2000, A.D. ro onotary Soa eJll"r,??' R. Thomas Kline, Sheriff BYl&) Real Estate Deputy I.? ek. 3oo / 9 J .,,. /02.25(, J Resource Bancshares Mortgage Group, Inc Plaintiff, V. Michael J. Mannai Linda H. Mannai CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-5429 Civil Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Resource Bancshares Mortgage Group Inc., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 333 Allen Street. 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.) Michael J. Mannai 7514 A Mill Run Road Fort Wayne, IN 46819 Present Whereabouts Unknown Linda H. Mannai 7514 A Mill Run Road Fort Wayne, IN 46819 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 everyjudgment 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.) PA Housing Finance 2101 North Front Street Agency Harrisburg, PA Household Realty 25 Gateway Drive, Suite 107 Corporation Mechanicsburg, PA 17055 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 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 333 Allen Street Carlisle, PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County 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 unswom falsification to authorities. May 18.2000 DATE F NK FE E AN, ESQUIRE At omey for Plaintiff Resource Bancshares Mortgage Group, Inc. Plaintiff, V. Michael J. Manual Linda H. Manual Defendant(s). TO: Michael J. Mannai Linda H. Mannai 7514 A Mill Run Road Fort Wayne, IN 46819 CUMBERLAND COUNTY No. 99-5429 Civil May 18, 2000 "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 M BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at 333 Allen Street, Carlisle PA 17013, is scheduled to be sold at the Sheriffs Sale on September 6, 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by Resource Bancshares Morteaee Group, Inc. (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the December 6, 2000 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if thejudgment 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 attomey 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWY.-?R 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 (300) 990-9108 ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of South Middleton, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pipe on the Northern line of Allen Street, (50 feet wide) which point is located 469.80 feet measured Westwardly from the Western line of Valley Street is shown on the Plan of Carlisle Manor Extension recorded in Plan Book 3, Page 99; thence from said beginning point by lands now or formerly of L. Don Patterson, North 12 degrees 45 minutes East, a distance of 150 feet to an iron pipe; thence by land now or formerly of John R. Mellinger and lands now or formerly of John W. Heikes, South 77 degrees 15 minutes East, a distance of 75 feet to a point; thence through the center of Lot No. 34, South 12 degrees 45 minutes West, a distance of 150 feet to a point on the Northern line of Allen Street; thence North 77 degrees 15 minutes West, a distance of 75 feet to an iron pipe, the Place of the BEGINNING. CONTAINING 75 feet in front along the Northern line of 50 feet wide Allen Street extending Northwardly therefrom at an. even width, a distance of 150 feet and being all of Lot No. 35 and the Western 112 of Lot No. 34 of Block "D" of Carlisle Manor Extension as recorded in the hereinafter mentioned Recorder's Office in Plan Book 3, Page 99, on which there is erected a brick and aluminum siding covered 1 story ranch type dwelling house with attached garage numbered 333 Allen Street, Carlisle. TITLE TO SAID PREMISES IS VESTED IN Michael J. Matmai and Linda H. Mannai, His Wife by Deed from Michael J. Mannai, dated 06/02/95, recorded 06/09/95 in Deed Book 123, Page 363 it WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-5429 CIVIL W TERM COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Resource Bancshares Mortgage Group Inc from Michael J. Mannai and Linda H. Mannai, 7514 A Mill Run Road, Fort Wayne, IN 46819 (1) DEFENDANT(S) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/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 istoundinthepossession ofanyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $t 06,8`;9 47 L.L. Interest from 3/1/00 9/6/00 (per diem $177,57) $'A, '418-30. Due Prothy Atty's Comm Arty Paid $125.10 Plaintiff Paid $1.00 Other Costs Date: May 23, 2000 REQUESTING PARTY: Name Frank Federman, Esq. Address: Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 Attorney for: Plaintiff Telephone: 215-563-7000 Curtis R. Long Prothonotary, Civil Division Deputy Supreme Court ID No. 12248 REAC ESTATE SALE No, a? the sheriff levied upon the defendants interest in the real property situated in.. }- Curnberiand County, Pa., known and numbered as: zg? d0 & ,f G and more t,,, ,,scribed on Exhibit "q" filed with v this writ and by this reference incorporated herein. ?9te: 2?rv By- PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 Fleet Mortgage Corp Plaintiff, Cumberland County V. Michael J. Mannai Linda H. Manual Defendant(s). No. 99-5429 Civil TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $106,859.47 Interest from 3/1/00 - 3/7/01 $6,536.0 4 and Costs (per diem - $$17.57) J113,395.51 TOTAL FRANK FEDERMAN, ESQUIRE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property.No. Q C) O N w"? oz Wa J ?+ z z z a OF Uz 00 F ]z Oa W W F? U o ? 'R ?p O p R ?a W z 0 F U w -. k? w ? Gc o 0 F L a? 00 w `o CWn U W 9 N 'w R? o? xe Ra'z Rai apw° b oco •`°CKe C ?z 5 ? C RQ3 in N 4 Q v Z N r c. s 3 DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, simate, lying and being in the Township of South Middleton, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pipe on the Northern line of Allen Street, (50 feet wide) which point is located 469.80 feet treasured Westwardly from the Western line of Valley Street is shown on the Plan of Carlisle Manor Extension recorded in Plan Book 3, Page 99; thence from said beginning point by lands now or formerly of L. Don Patterson, North 12 degrees 45 minutes East, a distance of 150 feet to an iron pipe; thence by land now or formerly of John R. Mellinger and lands now or formerly of John W. Heikes, South 77 degrees 15 minutes East, a distance of 75 feet to a point; thence through the center of Lot No. 34, South 12 degrees 45 minutes West, a distance of 150 feet to a point on the Northern line of Allen Street; thence North 77 degrees 15 minutes West, a distance of 75 feet to an iron pipe, the Place of the BEGINNING. CONTAINING 73 feet in front along the Northern line of 50 feet wide Allen Street extending Northwardly therefrom at all even width, a distance of 150 feet and being all of Lot No. 35 and the Western 1/2 of Lot No. 34 of Block "D" of Carlisle Manor Extension as recorded in the hereinafter mentioned Recorder's Office in Plan Book 3, Page 99, on which there is erected a brick and aluminum siding covered 1 story ranch type dwelling house with attached garage numbered 333 Allen Street, Carlisle. TITTLE TO SAID PREMISES IS VESTED IN Michael J. Mannai and Linda H. Mannai, His 'W'ife by Deed from Michael J. Mannai, dated 06/02/95, recorded 06109195 in Deed Book 123, Page 363 r Ham. ? r ? y ? ? LI 10 ? 1 1 1 C... C_ Li j.Ll 1 O V O / Q 1 N Q J `_ ¢ a j J ? V V ^ V bJ6 4 ?Y Fleet Mortgage Corp CUMBERLAND COUNTY Plaintiff, V. COURT OF COMMON PLEAS Michael J. Mannai CIVIL DIVISION Linda If. Mannai NO. 99-5429 Civil Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Fleet Mortgage Corp, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praccipe for the Writ of Execution was filed the following information concerning the real property located at 333 Allen Street. Carlisle PA 17013 Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Michael J. Mannai 7514 A Mill Run Road Fort Wayne, IN 46819 Linda H. Manual 7514 A Mill Run Road Fort Wayne, IN 46819 2. 3. Name and address of Defendant(s) in the j udgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above Name and address of everyjudgment creditor whosejudgment 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.) PA Housing Finance 2101 North Front Street Agency Harrisburg, PA Household Realty 25 Gateway Drive, Suite 107 Corporation Mechanicsburg, PA 17055 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 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 333 Allen Street Carlisle, PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County 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 unswom falsification to authorities. December 6, 2000 ya?? /?n/? e?\ DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,. ,. ,-, ?. ' ? - F- • ' .. ?- = s . ; ..- : _ _. :_? L -? ' _ i c ,? i G' . ? :L ?: , s} ?_) tj FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 Fleet Mortgage Corp Plaintiff, V. Michael J. Manual Linda H. Mannai Defendant(s). , ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-5429 Civil CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ? ? -- r'-' ?` - =; ?_?=: - -- , <, ,, _, " ' ,;? ;` `? c: ;Sri r7 t, _j U Fleet Mortgage Corp CUMBERLAND COUNTY Plaintiff, v. Michael J. Mannai Linda H. hlannai No. 99-5429 Civil Defendant(s). December 6, 2000 TO: Michael J. Mannai Linda H. Mannai 7514 A Mill Run Road Fort Wayne, IN 46819 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 333 Allen Street. Carlisle. PA 17013, is scheduled to be sold at the Sheriffs Sale on March 7, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by Fleet Mortgage Corp (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the June 6. 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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.) RIGHTS EVEN IFTHE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DZ tlyr N ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of South Middleton, in the Counry of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pipe on the Northern line of ,Alen Street, (50 feet wide) which point is located 469.80 feet measured Westwardly from the Western line of Valley Street is shown on the Plan of Carlisle Manor Extension recorded in Plan Book 3, Page 99; thence from said beginning point by lands now or formerly of L. Don Patterson, North 12 degrees 45 minutes East, a distance of 150 feet to an iron pipe; thence by land now or formerly, of john R. `Iellinger and lands now or formerly of John W. Heikes, South 77 degrees 15 minutes East, a distance of 75 feet to a point; thence through the center of Lot No. 34, South 12 degrees 45 minutes West, a distance of 150 feet w a point on the Northern line of Allen Street; thence North 77 degrees 15 minutes West, a distance of 75 feet to an iron pipe, the Place of the BEGINNING. CONTAINING 75 feet is front along the Vorthern line of 50 feet wide Allen Street extending Northwardly therefrom at an even width, a distance of 150 feet and being all of Lot No. 35 and the Western 1/2 of Lot No. 34 of Block "D" of Carlisle Manor Extension as recorded in the hereinafter mentioned Recorder's Office in Plan Book 3, Page 99, on which there is erected a brick and aluminum siding covered 1 story ranch type dwelling house with attached garage numbered 333 Allen Street, Carlisle. TITLE TO 5 1D PREMISES IS VESTED IN Michael J. Mannai and Linda H. Mannai, His Wife by Deed from Michael J. Manual, dared 06/02/95, recorded 06109195 in Deed Book 123, Page 363 ri F- .J .'f 1 J LZ. G J - u CJ SALE DATE: MARCH 7.2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FLEET MORTGAGE VS. No.: 99-5429 CIVIL MICHAEL J. MANNAI LINDA H. MANNAf AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 333 ALLEN STREET. CARLISLE PA 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed), and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff February 2, 2001 -> ,:_; Lti `a ? ) SALE DATE: MARCH 7. 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW FLEET MORTGAGE vs. MICHAEL J. MANNAI LINDA H. MANNAI No.: 99-5429 CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 333 ALLEN STREET. CARLISLE PA 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed), and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. FRANK FEDERMAN, ESQUIRE February 2, 2001 Attorney for Plaintiff Fleet Mortgage Corp CUMBERLAND COUNTY Plaintiff, V. COURT OF COMMON PLEAS Michael J. Mannai CIVIL DIVISION Linda H. Mannai NO. 99-5429 Civil Defendant(s). _ AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Fleet Mortgage Coro, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 333 Allen Street. Carlisle PA 17013, Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Michael J. Manual 7514 A Mill Run Road Fort Wayne, IN 46819 Linda H. Mannai 7514 A Mill Run Road Fort Wayne, IN 46819 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 Name and address of everyjudgment creditor whosejudgment 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.) PA Housing Finance 2101 North Front Street Agency Harrisburg, PA Household Realty 25 Gateway Drive, Suite 107 Corporation Mechanicsburg, PA 17055 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 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 333 Allen Street Carlisle, PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County 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 unswom falsification to authorities. December 6. 2000 4112x'-t DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DATE: December 6, 2000 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) Michael J. Mannai Linda H. Manual PROPERTY: 333 Allen Street Carlisle, PA 17013 Improvements: Residential Property Cumberland County The above-captioned property is scheduled to be sold at the Sheriffs Sale on March 7. 2001, at 10:00 a.m. in Cumberland County Courthouse. South Hanover Street Carlisle PA. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH -? .- - ;?. i ? _ ; ?. r ?_-. , ?_ . ,. , _ . ' ? `? Law Offices FEDERMAN AND PHELAN One Perri Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 Fax: (215) 563-5534 Leo Magee Foreclosure Department April 10, 2001 Office of the Prothonotary Cumberland County Courthouse South Hanover Street Carlisle, PA 17013 Re: FLEET MORTGAGE CORP. v. MICHAEL J. MANNA] and LINDA H. MANNA] No. 99-5429 CIVIL Premises: 333 ALLEN STREET, CARLISLE, PA 17013 Dear Sir/Madam: Representing Lenders in Pennsylvania and New Jersey Enclosed for filing and transmittal to the assigned Civil Signing Judge for execution please find Plaintiffs Petition for Service of the Notice of sale Pursuant to Special Order of Court and proposed Order. Kindly return a time-stamped copy in the enclosed self-addressed stamped envelope. Also, find attached a copy of the Order granting alternative service which should be signed by the Judge. Please return this signed Order in the attached stamped self-addressed envelope. Very truly yours, Leo Magee Leo for Federman and Phelan /leo enclosures cc: FLEET MORTGAGE CORP. Attention: Foreclosure Department File #74080591 FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FLEET MORTGAGE CORP. VS. MICHAEL J. MANNAI LINDA H. MANNAI ATTORNEY FOR PLAINTIFF APR 12 2001tp COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 99-5429 CIVIL ORDER ff Zoo1 AND NOW, this tG lI day of Af ( 11 , ZW, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s), and LINDA H. MANNAI, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last known address and the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service. BY THE COURT: ?n FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION FLEET MORTGAGE CORP. CUMBERLAND COUNTY VS. No.: 99-5429 CIVIL MICHAEL J. MANNAI LINDA H. MANNAI MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Frank Federman, Esquire, moves this Honorable Court for an Order directing service of the Notice of Sale upon the above captioned Defendant(s) by certified mail and regular mail to Defendant's last known address. 1. Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated by the Affidavit of Service attached hereto as Exhibit "A." 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "B." WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. F NK FEDERMA , ESQUIRE ATTORNEY FOR PLAINTIFF 04106/2001 05:00 3175491147 04/06/01 FRI 13:40 FAX 010711110307 AFFORDABLE PROCESS S MARY SCROCCA AFFIDAVIT OF SERVICE PLAINTIFF Fleet Mortgage Corp DEFENDANT(S) Michadl J.1Vlannal Linda H. Maenat SERVE AT 7314 A Mill Bun Road Fort Wayuv? IN 44819 i Served and made known to at O'clock _.m. at of Pennsylvania, in the:-ar descdbe4 below: Defendantpennuffyserved. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in oharge of Dettndan*Ys residence who refused to give name or relationship. Manager/Clerk of place of lodg((rrg? in which Defendant(s) reside(s). Agent or parson in charge of Ddf'endant(sys otllee or usual place of business. Other: an o.Scer of said Defendant(s)'s company. , ''Description: Age_ Height-- Weight- Race Sax Other Comtronweal0 I a Oorppetent adult, being duly swum awording to law, depose and state that I personally hand a true and correct copy of the Notice of_ ,dt,?1fFs gale in the mazer as set forth herein, issued in the captioned case on the date mad a the address indicated above, Sworn to and subscribed before me this _,,,_ day Of 200_. .Notary: By: ?!/' NOT SERVED the // ?Y of " 200 L at ? o'clock?m., Defendant NOT FOUND because; '.? Moved Unknown No Answer Vacant Other: NW &A '2r0 S Qv44 IWAY**l i/vto ?Pv we .¢iP?.Pt,?S'?/??sPR(3 •?p Sworn to and s?ubsh dev0 G 'nIDwV /fOD,P??S, /jJtei/,}tt /19iprttvit/ ?'D A? auS 1l?Cf. before finis -10L- day. of 200 No Attorn r PWf Wff_ Frank Federman, Esquire - Y.D. No.1 -One can Center Suburban Station, I Philadelphia, PA 19103 (215) 563-7000 „?wpD1 By %0,1_77,V?6? 21AO EXHIBIT A SERVED Cumberland County N0.99-5429 Civil Type of Action - Notice of Sheriff's Sale Sale Dater March 7, 2001 PAGE 01 Q Defendant, on the day of- 200_ 04/06/2001 05:00 3175491147 04/06/01 FRI 13:41 FAY 8107180307 PLAIN'TIF'F Fleet Mortme Corp DEFENDANT (S) Mlcha I J. Mj?mal AFFORDABLE PROCESS S PAGE 02 NARY SCROCCA AFFIDAVIT OF SERVICE Cumberland County No.99-5429 Civil IJ"da H Mapmd Type of Action .-UMVR AT Notlea of Sherifro Sale Dy) copy, Solerflorm 5928 W Ja Blvd. Sale Date: March 7, 2001 Fort Wayne, 46804 SERVED . Served and made (mown to Defendant, on the day of 4t O'clock _.n2.. at of Pennsylvania, in the mmnner described below: - a persownyseved. -Adult femily Mamba with whmn Defendant(s) reaide(s). Relationship is Adult in ehstge of Defe"daat(s)'a reaidenoe who refined to give name or relationship. Manager/Qerk of place ofl is which Defendant(s) reside(s). Agent or person is charge of Dd s)•s office or usual plus of business. „ .; an oMm of said Dofendam(s)'s company. Other: 200 Conanc"woald Thmcoption: AgeHeW_ Weight- Race -Sax - Other . s' oatnpetenradult. being duly sworn according to law, depose and sate that I personally ha"d roue and correct copy of the i I"tlr? of Shioi@'e S.t. in the manner as eat forth herein, issued in the captioned case on the deb and a the address indicated above. 3WOM to And subscribed hefore me this ,_ day • of_ .200_ Notary: By: NOTSERVED On the / / day of ^ J 200L, at o'clock G•m., Defendant NOT FOUND because: Moved _ Unlmown -iNo Answer Vacant Other: VMW, 7V . &fte'T (Nat 17lAN,t4Y/ r 600 Sour/on(S wow /S ' Swom and bcd • v ?t7fi'?? 41-WAX' /, *1,0oGg, . before me this _(o day Of 200 L. Notary., By: n'll? 6? Prank Federman, Esquire - I.D. No. 12218 'One Pea" Center 9ubnrhaa Btatfoa, Su1p 1400 Madelphia, PA 19103 ' (315) 563-7800 700. < a?° JNVJ __ ?t Nor-01-00, 06:02rm From-PLAYERS ASSOCIATION 6362300556 - T-163 P.02/03 F-583 PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number 99-6429-CIVIL Attorney Firm TRACK STARS Case Number Suoiect. MICHAEL J & LINDA H MANNAI AAA. LINDA MARTIN Property Address: 333 ALLEN STREET CARLISLE, PA 17013 Lest Known Address: 7514 MILL ROAD A FORT WAYNE, IN 46818 Last Known Number: ( ) - Michael K Gross. being duly swoon according to law, deposes and says, 1. 1 am employed in the capacity of President for Players National Locator. 2. On 10107/1999, 1 conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows. CREDIT INFORMATION A SOCIAL SECURITY NUMBER 028.54.8258 006.58.1341 B. EMPLOYMENT SEARCH' Contacted Linda At work, 219-436-2679, Copy Solutions, 5928 W Jefferson Blvd., Fort Wayne, IN. 46804. She stated she is working at this address. She also stated she and Michael are both living at 7514 Mill Run Road #A, Fort Wayne, IN. 46819. C. INQUIRY OF CREDITORS The creditors indicated that Michael and Linda are both living at 7514 Mill Run Road 4A, Fort Wayne, IN. 46819 with no valid home phone number. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: The directory assistance has no listing for Michael and Linda Mannai. INQUIRY OF NEIGHBORS - N/A INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of October 5, 1999 the National Change of Address (NCOA) has no change for Michael and Linda from 7514 Mill Run Road #A, Fort Wayne, IN. 46819. MOTOR VEHICLE REGISTRATION - A MOTOR VEHICLE & DMV OFFICE. The Indiana Department of Drivers Licensing has Michael and Linda listed at 7514 Mill Run Road AA, Fort Wayne, IN. 46819. OTHER INQUIRIES - A. DEATH RECORDS' As of October 5, 1999 the Social Security Administration has no death records on file for Michael EXHIBIT 6811 mar-0I-00 09:022m From-PLAYERS ASSOCIATION 6362300688 T-183 P 03/03 F-883 J and Linda H Mannai and or a.k.a.'s under their social security numbers. B PUBLIC LICENSES (PILOT, REAL ESTATE, ETC I. None Found C. COUNTY VOTER REGISTRATION NIA ADDITIONAL INFORMATION ON SUBJECT - A DATE OF BIRTH: Michael 06160 Linda 18168 AFFIANT Michael K Gross Subscnbed and sworn to before me on 03101/2000 UBLI NOTARY SEAL " IGibtin? M t3aort, My Comm aunty S? ary?12002r W10n?E of Players National Locator 16201 Westwoods Business Park Drive St. Louis, MO 63021 Phone' (636) 230.9922 Fox (636) 230-0558 Ex`.. eff (L 5 u FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FLEET MORTGAGE CORP. vs. MICHAEL J. MANNAI LINDA H. MANNAI ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 99-5429 CIVIL MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant and the reasons why service cannot be made. Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Affidavit of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit-B.- WHEREFORE, Plaintiff respectfully requests service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. Respectfully submitted: F NK FEDERMAN, QUIRE TTORNEY FOR PLAINTIFF VERIFICATION FRANK FEDERMAN, ESQUIRE, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE NOTICE, OF SALE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. /?/ / - SQUIRE 40ARNEY K FEDERMA 1, E FOR PLAINTIFF F FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FLEET MORTGAGE CORP. VS. MICHAEL J. MANNAI LINDA H. MANNAI ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 99-5429 CIVIL CERTIFICATION OF SERVICE I, FRANK FEDERMAN, ESQUIRE, hereby certify that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individuals indicated below on April 10, 2001. MICHAEL J. MANNAI LINDA H. MANNAI 7514 A MILL RUN ROAD FORT WAYNE, IN 46819 F NK FEDERMAN, SQUIRE Attorney for Plaintiff Date: April 10, 2001 FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103.1 S 14 COURT OF COMMON PLEAS (215) 563-7000 CIVIL DIVISION FLEET MORTGAGE CORP. CUMBERLAND COUNTY VS. No.: 99-5429 CIVIL MICHAEL J. MANNAI LINDA H. MANNAI AFFIDAVIT I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to LINDA H. MANNAI on 04/24/01 at 7514 MILL RUN ROAD #A, FORT WAYNE, IN 46819, in accordance with the Order of Court dated 04116/01. The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. s 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN, ESQUIRE Date: A „n 'I 25, 2001 oQ T d z? Q {? N s? ry C u n ?ya`a n m 3 Z ?+.F4 n I I w ? 9 L ? d A 9 v zao 7106 4575 1294 1904 3947 TO: LINDA H. MANNAI 7514 MILL RUN ROAD#A FORT WAYNE, IN 46819 SENDER: LEO REFERENCE: SALES RETURN RECEIPT SERVICE Total Postace 6 Faes US Postal Service 4 POSTMARK OR.9ATE ) ( 5 Receipt for y? Certified Mail :;.., Ol AY2? No lmwance Coverage Provided Do Not Use for International MMI c`c, ai C?j i? ? U STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND ss. Robert P Ziegler h ---------------------------------------------- ------------- Recorder of Deeds in and for said County and State do'hereby certify that the Sheriff's Deed in which ________________ Wahington Mutual HOme Loans Inc sbm Fleet Mtg Corp - -- ----- ------- - --------------------------- is the grantee the same having been sold to said grantee on the __6th --- ----------------------------------------- day of June 01 ---------------------------------------- A. D.,? ---- under and by virtue ofa writ-------------- Execution ----------- 13th ---- ---------------------------------issued on the -------------- ----------------- dsy -__--_----Dec------------ A. D. ?? out of the Court of Comman Pleas of said County as of ----Civil 1999 -------------------° ------ --- Term, ----------------------------- 5429 Fleet Mtg Corp Number --------------, at the suit oL_____-----____ --------------------------- ______________ ---------------------against____ Michael J Marnai & Linda H ___ duly recorded in Sheriffs Deed Book No ------ 247 ---, Page ------------ 391 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this _____2% ?-_ day of --------------` -- -----------A.D., r - Reeorda of De horider of Deeds, Cumberland County, Cvf*, PA Yy Commission Expires the First Monday of Joe. 2062 Fleet Mortgage Corp. In the Court of Common Fleas of -vs- Cumberland County, Pennsylvania Michael J. Mannai and Linda H. Mannai No. 1999.5429 Civil 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 above entitled action upon one of the within named defendants, to wit: Michael J. Mannai by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver To Addressee Only to his last known address 7514 A Mill Run Road, Fort Wayne, IN. This letter was mailed under the date of January 4, 2001 and returned to the Sheriffs Office on January 16, 2001 with reason checked "Attempted Unknown:" 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: "1'he Sheriff mailed a notice of the pendency of the action to one of the within named defendant to wit: Linda H. Mannai by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver To Addressee Only to her last known address 7514 A Mill Run Road, Fort Wayne, IN. This letter was mailed under the date of January 4, 2001 and received by Linda Mannai on January 8, 2001 the return receipt card signed by signature unreadable. Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law, says on January 8, 2001 at 10:40 o'clock A.M., EST, he posted a copy of Real Estate Writ, Notice, Poster and Description on the property of Michael Mannai and Linda H. Mannai, located at 333 Allen Street, Carlisle, Cumberland County, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit; Michael Mannai by regular mail to his last known address 7415 A Mill Run Road, Fort Wayne, IN. This letter was mailed under the date of January 16, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to low, says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: lice Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Linda Mannai by regular mail to her last known address, 7514 A Mill Run Road, For Wayne, IN. This letter was mailed under the date of January 16, 2001 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 outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 6, 2001 at 10:00 o'clock A.M., EDST, and sold the same for the sum of $ 1.00 to Attorney Dale Shughart for Washington Mutual Home Loans, Inc., s/b/m To Fleet Mortgage Corp.. It being highest bid and best price received for the same Washington Mutual Home Loans, Inc., s/b/m to Fleet Mortgage Corp., of 11200 West Parkland Avenue, Milwaukee, WI 53224, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum ofS'875.11, it being costs. Sheriffs Costs Docketing 30.00 Posting Bills 15.00 Poundage 17.16 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 County 1.00 Mileage 3.10 Certified Mail 13.69 Levy 15.00 Surcharge 30.00 Postpone Sale 20.00 Law Journal 325.85 Patriot News 272.28 Share of Bills Distribution of Proceeds Sheriff's Deed 25.53 25.00 26.50 $875.11 paid by Attorney 6-20-01 Sworn and Subscribed to Before Me ThisA-!t Day o? 2001, A.D. Pr h otary 4rs?.eC ?"as R. Thomas Kline, Sheriff B - De uty Sheriff U ck 33069 &i 11YE90 , h Fleet Mortgage Corp CUMBERLAND COUNTY Plaintiff, v COURT OF COiNINION PLEAS Michael J. Mannai CIVIL DIVISION Linda H. Mannai NO. 99-5429 Civil Defendant(s). , AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Fleet Mortaaae Corp. Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 333 Allen Street, 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.) Michael J. Nlannai 7514 A Mill Run Road Fort Wayne, IN 46819 Linda H. Mannai 7514 A Mill Run Road Fort Wayne, IN 46819 2. Name and address of Defendant(s) in thejudgment: NAME LAST KNOWNADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of everyjudgment 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.) PA Housing Finance 2101 North Front Street Agency Harrisburg, PA Household Realty 25 Gateway Drive, Suite 107 Corporation Mechanicsburg, PA 17055 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 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 333 Allen Street Carlisle, PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County 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 unswom falsification to authorities. December 6, 2000 i8 n? 4-C?? ? DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 Fleet Mortgage Corp Plaintiff. V. Michael J. Manna! Linda H. Vlannai Defendant(s). , ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-5429 Civil CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied O vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Fleet Mortgage Corp CUMBERLAND COUNTY Plaintiff, , V. No. 99-5429 Civil Michael J. Mannai Linda H. Mannai , Defendant(s). December 6, 2000 TO: Michael J. Mannai Linda H. Mannai 7514 A Mill Run Road Fort Wayne, RJ 46819 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 333 Allen Street, Carlisle, PA 17013, is scheduled to be sold at the Sheriffs Sale on March 7. 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by Fleet Mortgage Corp (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the June 6, 2001 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, i f 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCILT?T'ION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of South Middleton, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pipe on the Northern line of Allen Street, (50 feet wide) which point is located 469.80 feet measured Westwardly from the Western line of Valley Street is shown on the Plan of Carlisle ?Manor Extension recorded in Plan Book 3, Page 99; thence from said beginning point by lands now or formerly of L. Don Patterson, North 12 degrees 45 minutes East, a distance of 150 feet to an iron pipe; thence by land now or formerly of John R. Mellinger and lands now or formerly of John W. Heikes, South 77 degrees 15 minces East, a distance of 75 feet to a point; thence through the center of Lot No. 34. South 12 degrees 45 minutes West, a distance of 150 feet to a point on the Northern line of Allen Street; thence North 77 degrees 15 minutes West, a distance of 75 feet to an iron pipe, the Place of the BEGINNING. CONTAIMNG 75 feet in from along the Northern line of 50 feet wide Allen Street extending Northwardly therefrom at an. even width, a distance of 150 feet and being all of Lot No. 35 and the Western 1/2 of Lac No. 34 of Block "D" of Carlisle Manor Extension as recorded in the hereinafter mentioned Recorder's Office in Plan Book 3, Page 99, on which there is erected a brick and aluminum siding covered 1 story ranch type dwelling house with attached garage numbered 333 Allen Street, Carlisle. TITLE TO SAID PREMISES IS VESTED IN Michael 1. Manual and Linda H. Mannai, His Wife by Deed from Michael J. Mannai, dated 06/02/95, recorded 06/09/95 in Deed Book 123, Page 363 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-5429 CIVIL TERM COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Fleet Mortgage Corp. from Michael J. Mannai and Linda H. Mannai, 7514 A Mill Run Road, Fort Wayne, IN 46819 DEFENDANT(S) (t) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/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 propertyof thedefendant(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 hinvher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $105,859.47 L.L. 3/1/00-3/7/01 - $6,536.04 and Costs Interest 57 Due Prothy_ $1 .00 Atty's Comm % Other Costs Atty Paid $805.51 Plaintiff Paid Date: December 13, 2000 Curtis R. Long Prothonotary, jCivil Division Deputy REQUESTING PARTY: Name Frank Federman, Esq. Address: One Penn Center at Suburban Station, Suite 1400 Philadelphia, PA 19103 Attorney for: Plaintiff Telephone: _ 215-563-7000 Supreme Court ID No. _ 12248 REAL ESTATE SALE No.yr 4 •. ig? the , ,erifr levied upon the detenda . interest in the real prnopov c fi itari in- ?? `711 Cumberland County, Pa ?oKt?.r?s and more n umberedas:-33.3 ,to on Exhibit "A" filed with this writ and by this reference ,c;orporated herein. Bt; 6a; (ED CUO p WO o? `L? y yww. . y G PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 19, 26, FEBRUARY 2, 2001 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 of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. PEA ESTATE SALE NO. 41 Writ No. 1999-5429 Civil Fleet Mortgage Corp. VS. Michael J. Manna) and Linda H. Manual Ally.: Frank Federman DESCRIPTION ALL THAT CERTAIN tract or par- cel of land and premises, situate, lying and being in the Township of South Middleton. In the County of Cumberland and Commonwealth of Pennsylvania, more particularly de- scribed as follows: Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 2 day of FEBRUARY. 2001 NOTARIAL SEAL LOTS E. SNYDER, Noeary Public Ce,We Som, CwnbMlond County. PA My Commirion Exptes March S. 2001 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ad No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-New c newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 181h, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 30th day(s) of January and the 6th and 13th day(s) of February 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin ' Miscellaneous Book "M", Volume 14, Page 317. I 1 fl , PUBLICATION COPY S A L E # 41 .................................. ..IN: ....................... 27th 2001 A.D. ?IYrMNatfpidlll eldTam FNNrrirrIMCNl LivisH.illsomill FIN CM L Tent' L. Pu9a911, p"Not 'n not Hamsbure, Dauphin My Commrsslon Expires JurM" Member,Pennsylvania ASSOCiationotNOtarles TARY PUBLIC My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE land and CARLISLE, PA. 17013 w?tt u and/ Common Combeilosd Statement of Advertising Costs d ? Pcdar? h npyk* r , f '? ` -SEEPMMGati horogpeontheNorth ffneof r To THE PATRIOT-NEWS CO., Dr. For ublishin p the notice bli ti A9eeSbeN(50feetwl )whichpointistucated : g or pu on attached ca ,469.SIlifeetmeamred Weatwaedly form the hereto on the above stated dates $ 270 78 Wakmgmof `,MetBshownontheFlan 'of Cirihk gland! E#erolon worded In flan . Probatin same 9 Notary Fee(s) $ 1.50 Book 4 h 0 (hence frfa m of Don om?uyld h¢inning LL ? Total $ 272.28 r h now 12 degrees 55' malm FZ4 a a YNM disiOf150feel 10antmnvivr:fw"eeby Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... FEDERMAN AND PHELAN By: FRANK FEDERMAN IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE PHILADELPHIA, PA 19103 a15 =IMO FLEET MORTGAGE CORP. Vs. MICHAEL MINNAI LINDA MINNAI 1400 ATTORNEY FOR PLAINTIFF Plaintiff Defendant(s) TO THE PROTHONOTARY: Cumberland County Court of Common Pleas : CIVIL DIVISION NO. 99-5429 Kindly satisfy the Judgment which was entered on 9/10/02 against MICHAEL MINNAI AND LINDA MINNAI, Defendant(s), in the amount of $106,859.47 relative to the instant matter and mark this case discontinued and ended, without prejudice, upon payment of your costs only. FRANK FEDERMAN; SQUIRE Attorney for Plaintiff Dated: June 24, 2004 :n :u `, ,, ,. ?. ? _ ... ,:?i?; -- _ u.- ?? '.? C Fi