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FEDERMAN AND PHELAN
By: FRANK FEDERMAN. ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA. SUITE 900
PHILADELPHIA. PA 19102
(215) 50-7000
AT'I'ORNE-Y FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
PNC MORTGAGE CORPORATION OF AMERICA
539 SOU'I'1-I FOURTH STREET
LOUISVILLE. KY 40202 T ERh9
Plaintiff' NO. 99- 7l`/ CLu l;,--
v.
KIRAN K. DANDAPAT.
A/K/A KIRAN KUMAR DANDAPAT
852 ERFORD ROAD
EAST PENNSBORO. PA 17011
Defendant(s)
CUMBERLANDCOUNTY
CIVI1. ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
1'LF.\51•:Ill?,\U\'I51;1) '1'u,cf7•Dtg Flit\IIS.\III?m'I'COL1.1•:CI'(lm,c?rl•;All rING'r000L1,I;CrADl:ll'r. ANY
I'RI•;\'IUUSL\' Itl?CI?I\'I•:Il.\
INh'OIt\I,\'I'ION Itlfclil\'IiU W11-1, 11 1: 11511r Fllit'ruixI' milmos1C. IF YOU HAVE
UISCII,\RGV. I Il,\R61tlIPT(:V .\ND'I'I its ulgl r \V,\s NOT Itl{.\I'FIIt\IIiU, ""I's coltlu?51'ONUIsN(ai IS NOT AND
SIIOli1,U NO'i' Itl? CON?1'ItU15U'1'll ISI? •\ LII!N A('\ItNS0 COLLECA, Imu,I' ill: l' 0NIN ENPOucl?\II:N'1' OF'.\
You have been sued in Court, if you \vish to detend against the claims set forth in the fallowing
pages. you must take action within t\ccnty (20) days after this Complaint and Notice are served.
by entering a written appearance personally or by attorney and tiling in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
you and a judgment nu>' be entered against you by the court
do so the case may proceed without
' other claim or relief
without further notice for any money claimed in the Complaint or for it.
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU S140OLD TAKE THIS PAPER 1'0 YOUR LAWYER AT ONCE. IF YOU DO NOT YER OR
CANNOT
TO OR SE
HAVE A T FORTH,BELOW TO FIND OUT WH RE YOUOCAN GLT LEGAL ?IGLP HE OFFICE
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE. PA 17013
(717) 249-3166
Loam 00'118.11x87
PIaintiff is
PNC MORTGAGE CORPORATION OF AMERICA
539 SOUTH FOURTH STREET
LOUISVILLE. KY 10202
2. The name(s) and last known address(es) of the Defendant(s) are:
KIRAN K. DANDAPAT.
A/K/A KIRAN KUMAR DANDAPAT
Rig ERFORD ROAD
EAST PENNSBORO. PA 17011
who is/arc the mortgagor(s) and real owner(s) of the property hereinafter described.
On 3/29/96 mortgagor(s) made. executed and delivered a mortgage upon the premises
hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the
Recorder of CUMBERLAND County. in Mortgage Book No. 1310. Page 1068.
d. 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 Clue 7/1/99 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 balmtce and all interest due thereon
are collectible forthwith. A copy of such notice is attached as Exhibit "A."
6. The following amounts are due on the mortgage:
Principal Balance $56,068.91
Interest 1,733.49
6/1/99 through 11/1/99
(Per Diem $11.33)
Attorney's Pecs 2,803.00
Cumulative Late Charges 80.04
3/29/96 to 1l/l/99
Cost of Suit and Title Search 550.00
Subtotal 61,235.44
Escrow
Credit 457.90
Deficit 0.00
Subtotal 45790
'TOTAL 560,777.54
7. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with 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.
I l. Pursuant to the Pair 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
$60,777.54, together with interest from 1 f/1799 at the rate of 511.33 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/ prank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
ZZ119
BS203-Gist
September 20, 1999
Kiran K Dandapat RE: LOAN NUMBER: 0091841887
852 Erford Road PROPERTY ADDRESS: 852 Erford Road
East Pennsboro PA 17011 0000 East Pennsboro PA 17011
Current Servicer: PNC Mortage
539 S 4th Avenue
Loui, KY 4002
AGENCY ACTION -- Available funds for emergency mor
tgagelassistance2are
very limited. They will be disbursed by the Agency under the eligibility
criteria established by the Act. The Pennsylvania Housing Finance Agency
has sixty (60) days to make a decision after it receives your
application. During that 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 Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE
DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage
Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it u to date).
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on
your property located at: 852 Erford Road
East Pennsboro PA 17011
IS SERIOUSLY IN DEFAULT because:
As of 09-16-99 YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the
following months and the following amounts are past due:
Payments from 07-01-99 through 09-16-99
* PAYMENT AMOUNT 566.98
* PAYMENTS NOW DUE 3
* LATE CHARGES 60.03
* RETURN CHECK CHARGE 15.00
* OTHER FEES .00
' LESS UNAPPLIED FUNDS .00
TOTAL AMOUNT PAST DUE: 1,775.97
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30)
DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO
THE LENDER, WHICH IS $ 1,775.97, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cash cashier s check, certified rhA U
money order .a ?..,,
EXH(BITA
APPENDIX LA
ACT 91 NOTICE
TAkE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
our home. This Notice ea lains how the pro ram works.
the Counseling Agency. entati
ves at This Notice contains important legal may be able to help explain it. You may alsowant to contact an
Consumer Credit Counseling Agency ncy may
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA SI NO COMPRENDE EL CONTENIDO DE ESTA ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY)ASINNCARGO? NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
STANCE
EMERGENCY
LLAMADO HOME
PROG PU DE SALVAR SUC ASA DE LA PERD DAA DE MORTGAGEDERECHO A RED M R U H POTTE1CA.L CUAL
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
FROM rutcr?? wa ... .. ----
ASSISTANCE
MEOWNER'S EMERGENCY IF YOU COMPLY WITH THE PRO Y BIE BLIG ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
ACT OF 1983 (THE "ACT"), YOU
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL.
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
IF YOU MEET OTHER
PENNSYLVANIA HOUSING FINANCE AGY REQUIREMENTS ESTABLISHED BY THE
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ALL THAT Pennsylvania,Rmore partitract bol d the unded and describe Township follow , jo wloro, Cumberland County,
BEGINNING at a point on Erford Road at the dividing line between
Lots Nos. 16 and 16(x) on the hereinafter mentioned Plan of Lots;
East
along thence a point at the Rand
line dividing B Lots Nos. 16(xjt and 17
37.5 feet to
thence along said dividing fine South 0 degrees 10 minutes West
150 feet to a point; thence North 69 degrees 50 minutes West 37.5
feet to the line dividing Lot* Nos. 16(s) and 18; thence along
said dividing line North O degrees 10 minutes East 150 feat to
the point of BEGINNING.
BEING Lot No. 16(x) on Plan No. 19 or Ridley Park as recorded In the Cumberland County Recorder's Office
In Plan Book 22, Page 64.
HAVING thereon erected a dwelling house known and numbered as 852 Erford Road.
UNDER AND SUBJECT to the Easement of a sanitary sewer line as shown on the aforesaid plan.
and for by CuDeed dated March mberland County?3, 1986,
PREMISES BEING THE SAME 6, 1961), In which the Offla of the Recordeof Deeds In Truo,
and recorded March 16,
Pennsylvania, In Dead Book "V", volume 33, Page 7a0, granted and conveyed unto Pin Hui Kuo and Kuel
Ying Kuo, his wife.-
VERIFICATION
TERE•SA SWITZER hereby states that she is SECOND VICE-PRESIDENT of PNC
MORTGAGE CORP. OF AMERICA mortgage servicing agent for Plaintiff in this matter, that
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 her knowledge, information
and belief. The undersigned understands that this statement is made subject to the penalties of 13
Pa. C.S. Sec. 4904 relating to unswom falsification to authorities.
4, /vW
I C? TERESA SWITZER
DATE: I l Z? CI 1 2nd VICE PRESIDENT
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC MORTGAGE CORPORATION OF AMERICA
Plaintiff CIVIL DIVISION
vs. No. 99-7145 CIVIL
KIRAN K. DANDAPAT,
A/K/A KIRAN KUMAR DANDAPAT
Defendants
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
SS:
CUMBERLAND COUNTY
I, FRANK FEDERMAN, ESQ., attorney for PNC MORTGAGE
CORPORATION OF AMERICA, hereby verify that on FEBRUARY 18, 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 FEBRUARY 18.2000 by first class
mail and certified mail return receipt requested, see Exhibit "B" attached hereto. FRANK FEDERMAN, ESQUIRE'
Attorney for Plaintiff
Date: April 28, 2000
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
PNC Mortgage Corpration of America Cumberland County
Plaintiff,
V.
No. 99-7145 Civil Ternn
Kiran K. Dandapat, a/k/a Kiran Ktunar Dandapat
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest from 1/4/00 - 6/7/00
(per diem - $10.11)
$61.513.99
$1.567.05 and Costs
$63.081.04 TOTAL
F K FEDER IAN, ESQUIRE
TWO PENN CENTER PLAZA
SUITE 900
PHILADELPHIA, PA 19102
Attorney for Plaintiff
Note: Please attach description of property.No.
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DESCRIPTION
ALL THAT CERTAIN tract of land Situate in the Township of East Pennsboro, Cumberland
County, Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point on Erford Road at the dividing line between Lots Nos. 16 and 16(x) on the
hereinafter mentioned Plan of Lots; thence along said Erford Road South 89 degrees 50 minutes
East 37.5 feet to a point at the line dividing Lots Nos. 16(x) and 17; thence along said dividing line
South 0 degrees 10 minutes West 150 feet to a point; thence North 89 degrees 50 minutes West 37.5
feet to the line dividing Lots Nos. 16(s) and 16; thence along said dividing line North 0 degrees 10
minutes East 150 feet to the point of beginning.
BEING Lot No. 16(x) on Plan No. 19 of Ridley Park as recorded in the Cumberland County
Recorder's Office in Plan Book 22, page 64.
HAVING thereon erected a dwelling house known and numbered as 852 Erford Road.
Parcel # 09-17-1044-060
TITLE TO SAID PREMISES IS VESTED IN Kiran Kumar Dandapat by Deed from Pin Hui Juo
and Kuei Ying Kuo (a/k/a Kuei Hui Kuo), his wife dated 3/29/96, recorded 4/1/96 in Record Book
136965.
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
ATTORNEY FOR PLAINTIFF
PNC Mortgage Corpration of America
CUMBERLAND COUNTY
Plaintiff, COURT OF COMMON PLEAS
V.
CIVIL DIVISION
Kiran K. Dandapat, a/Wa Kiran Kumar Dandapat
NO. 99-7145 Civil Term
Defendant(s).
FRANK FEDERMAN, ESQUIRE, hereby verifies that lie 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 unsworn
falsification to authorities.
FRANC FEDERMAV ESQUIRE
Attor ey for Plaidtiff
•i•ii
^ -i
PNC Mortgage Corpration of America
Plaintiff,
V.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Kiran K. Dandapat, a/k/a Kiran Kumar Dandapat CIVIL DIVISION
Defendant(s).
NO. 99-7145 Civil Tenn
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
PNC Morteaee Cornration of America, 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 852 Erford Road East Pennsboro PA
17011.
Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Kiran K. Dandapat, a/k/a 852 Erford Road
Kiran Kumar Dandapat Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Travelers Bank 11436 Cronhill Drive
Suite H, J & K
Owings Mills, MD 21117
s
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.)
Dauphin Deposit Bank P.O. Box 4800
and Trust Company Harrisburg, PA 17111
5. Name and address of every other person who has any record lien on the property:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant 852 Erford Road
East Pennsboro, PA 17011
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 unsworn falsification to authorities.
Februarv 16. 2000
DATE F K FEDERMA ,ESQUIRE
Attorney for Plaintiff
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PNC Mortgage Corpration of America CUMBERLAND COUNTY
Plaintiff,
V. No. 99-7145 Civil Term
Kiran K. Dandapat, a/k/a Kiran Kunar Dandapat
Defendant(s).
February 16, 2000
TO: Kiran K. Dandapat, a/k/a Kiran Kumar Dandapat
852 Erford Road
Camp Hill, PA 17011
"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 852 Erford Road, East Pennsboro, PA 17011, is scheduled to be
sold at the Sheriffs Sale on.June 7, 2000 at 10:00 a.m. in the Cumberland County Courhtouse , South
Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by PNC Mortgage
Corpration of America (the mortgagee) against you. If the Sheriffs sale is postponed, the property
will be relisted for the 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:
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.
917
i
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
i
DESCRIPTION
ALL THAT CERTAIN tract of land Situate in the Township of East Pennsboro, Cumberland
County, Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point on Erford Road at the dividing line between Lots Nos. 16 and 16(x) on the
hereinafter mentioned Plan of Lots; thence along said Erford Road South 89 degrees 50 minutes
East 37.5 feet to a point at the line dividing Lots Nos. 16(x) and 17; thence along said dividing line
South 0 degrees 10 minutes West 150 feet to a point; thence North 89 degrees 50 minutes West 37.5
feet to the line dividing Lots Nos. 16(s) and 16; thence along said dividing line North 0 degrees 10
minutes East 150 feet to the point of beginning.
BEING Lot No. 16(x) on Plan No. 19 of Ridley Park as recorded in the Cumberland County
Recorder's Office in Plan Book 22, page 64.
HAVING thereon erected a dwelling house known and numbered as 852 Erford Road.
Parcel # 09-17-1014-060
TITLE TO SAID PREMISES IS VESTED IN Kiran Kumar Dandapat by Deed from Pin Hui Jun
and Kuei Ying Kuo (a/k/a Kuei Hui Kuo), his wife dated 3/29/96, recorded 4/1/96 in Record Book
136965.
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000
PNC MORTGAGE CORPORATION OF AMERICA
V.
KIRAN K. DANDAPAT A/K/A
KIRASI KUMAR DANDAPAT
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-7145CIVIL TERM
CUMBERLAND COUNTY
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PURSUANT TO P.R.C.P., 404(2)/403
FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby
certifies that service of the Notice of Sheriff's Sale was made by
sending a true and correct copy by certified mail to Defendant,
KIRAN K. DANDAPAT A/K/A KIRAN KUMAR DANDAPAT at 852 ERFORD ROAD
CAMPHILL, PA 17011 which notice of Sheriff's Sale was received by
Defendant,KIRA.N K. DANDAPAT A/K/A KIRAN KUM R DANDAPAT 852 ERFORD
ROAD CAMPHILL, PA 17011 on FEBRUARY 29, 2000 as evidenced by the
attached return receipt.
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 FEDERNLal'V, ESQUIRE
Date: MARCH 10, 2000
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-07145 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC MORTGAGE CORP OF AMERICA
VS.
DANDAPAT KIRAN K
RICHARD SMITH , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon DANDAPAT KIRAN K A/K/A KIRAN KUMAR DANDAPAT the
defendant, at 11:19 HOURS, on the 2nd day of December
1999 at 852 ERFORD ROAD
CAMP HILL, PA 17011 CUMBERLAND
County, Pennsylvania, by handing to MITI DANDAPAT (WIFE)
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 9.30
Affidavit .00 ?
Surcharge 8.00 it. Kline, eri
3 S?II-FEDERNJAN
12/06/199
by
Sworn and subscribed to before me
this rft k day of L
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
PNC Mortgage Corporation of America
539 South Fourth Street
Louisville, KY 40202
Plaintiff
VS.
Attorney for Plaintiff
: Cumberland COUNTY
:COURT OF COMMON PLEAS
: CIVIL DIVISION
Kiran K Dandapat a/Wa :NO. 99-7145 Civil Term
Kiran Kumar Dandapat
852 Erford Road
East Pennsboro, PA 17011
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against Kiran IL Dandapat a/Wa
Kiran Kumar Dandapat, 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 $60,777.54
Interest 11/1/99 to 1/04/00 $763.45
TOTAL $61,513.99
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.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE:
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`•TIIIS FIRM IS A I)EI1T COLLECTOR ATTENIPTINC TO COI.LECr A DEIIT AM) ANY INFORMATION OIIT.UNEI) WILL BE
USED FOR TIIAT PURPOSE. IF YOU HAVE PREVIOUSI,Y RECEIVED A DISCHARGE IN RANKRUMV AND THIS DEBT WAS
NOT REAFFIRMED, THIS CORRESI'ONBF.NCE IS NOT AND SHOULD NOT RE CONSTRUED TO BE AN ATTF'%IPT TO COLLECT
A DEBT. Iurr ONLY ENFORC ENIF.NT OF A 1.1 EN AGAINST PROPERTI'. --
FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
PNC• MORTGAGE CORPORATION OF
AMERICA
Plaintiff
VS.
KIRAN K. DANDAPAT,
A/K/A KIRAN KUMAR DANDAPAT
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
. CUMBERLAND COUNTY
NO. 99-7145-CIVIL TERM
Defendant(s)
TO: KIRAN K. DANDAPAT,
A/K/A KIRAN KUMAR DANDAPAT
852 ERFORD ROAD
EAST PENNSBORO, PA 17011
DATE OF NOTICE: DECEMBER 23. 1999
FILE COPY
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) 2{9.3166
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
PNC Mortgage Corporation of America
Plaintiff
VS.
Attorney for Plaintiff
Cumberland COUNTY
: Court of Common Pleas
: CIVIL DIVISION
Kiran IC Dandapat a/k/a Kiran Kumar : NO. 99-7145 Civil Term
Dandapat
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge 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 Kiran K Dandapat a/k/a Kiran Kumar Dandapat is over 18
years of age and resides at 852 Erford Road, East Pennsboro, PA 17011.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unswom falsification to authorities.
2,J, Z,,-
FKANK FEDERMAN
Attorney for Plaintiff
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SG
PNC Mortgage Corporation of America
-vs-
Kiran K. Dandapat, a/k/a Kiran Kumar
Dandapat
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 1999-7145 Civil
R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ
is returned STAYED.
Sheriff's Costs:
Docketing 30.00
Poundage 13.49
Advertising 15.00
Posting Bills 15.00
Law Library .50
County 1.00
Mileage 18.60
Certified Mail .86
Levy 15.00
Postpone Sale 20.00
Surcharge 20.00
Law Journal 270.05
Patriot News 243.49
Share of Bills 24.80
$687.79 pd by Atty
6/12//00
Sworn and subscribed to before me
This ? day of a?
2000, A.D. t - "
Pot onotary
R. Thomas Kline, Sheriff
BY ?-
Real Estate Deputy
gRA
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7
PNC Mortgage Corpration of America
Plaintirf, CUMBERLAND COUNTY
V. COURT OF COMMON PLEAS
Kiran K. Dandapat, a/Wa Kiran Kumar Dandapat CIVIL DIVISION
Defendant(s).
NO. 99-7145 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
PNC Mortgage Corpration of America, 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 852 Erford Road East Pennsboro, PA
17011.
Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Kiran K. Dandapat, aWa 852 Erford Road
Kiran Kumar Dandapat Camp Hill, PA 17011
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 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.)
Travelers Bank 11436 Cronhill Drive
Suite H, J & K
Owings Mills, MD 21117
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.)
Dauphin Deposit Bank P.O. Box 4800
and Trust Company Harrisburg, PA 17111
5.
6.
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
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 852 Erford Road
East Pennsboro, PA 17011
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.
IDt?-
Februarv 16. 2000
DATE FRANK FEDERMAP, ESQUIRE
Att mey for Plaintiff
PNC Mortgage Corpration of America CUMBERLAND COUNTY
Plaintiff,
V. No. 99-7145 Civil Term
Kiran K. Dandapat, a/k/a Kiran Kumar Dandapat
Defendant(s).
February 16, 2000
TO: Kiran K. Dandapat, a/k/a Kiran Kumar Dandapat
852 Erford Road
Camp Hill, PA 17011
"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 852 Erford Road, East Pennsboro, PA 17011, is scheduled to be
sold at the Sheriffs Sale on June 7, 2000 at 10:00 a.m. in the Cumberland County Courhtouse , South
Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by PNC Mortgage
Corpration of America (the mortgagee) against you. If the Sheriffs sale is postponed, the property
will be relisted for the Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU 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: (2151563-7000.
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.)
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 of land Situate in the Township of East Pennsboro, Cumberland
County, Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point on Erford Road at the dividing line between Lots Nos. 16 and 16(x) on the
hereinafter mentioned Plan of Lots; thence along said Erford Road South 89 degrees 50 minutes
East 37.5 feet to a point at the line dividing Lots Nos. 16(x) and 17; thence along said dividing line
South 0 degrees 10 minutes West 150 feet to a point; thence North 89 degrees 50 minutes West 37.5
feet to the line dividing Lots Nos. 16(s) and 16; thence along said dividing line North 0 degrees 10
minutes East 150 feet to the point of beginning.
BEING Lot No. 16(x) on Plan No. 19 of Ridley Park as recorded in the Cumberland County
Recorder's Office in Plan Book 22, page 64.
HAVING thereon erected a dwelling house known and numbered as 852 Erford Road.
Parcel ff 09-17-1044-060
TITLE TO SAID PREMISES IS VESTED IN Kiran Kumar Dandapat by Deed from Pin Hui Juo
and Kuei Ying Kuo (a/k/a Kuei Hui Kuo), his wife dated 3/29/96, recorded 4/1/96 in Record Book
136965.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 99-7145 CIVIL * Term
CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due PNC Mortgage Corporation of America
PLAINTIFF(S)
from Riran K. Dandapat, a/k/a Kiran Kumar Dandapat, 852 Erford Road, Carap Hill, PA 17011
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell Gee Legal DescriRtion
(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) Ifpropertyofthedefendant(s)notlevieduponansubjecttoattachment isfoundinthepossessionofanyoneother
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 $61,513.99 L.L. $.50
from 1/4/00 - 6/7/00
Interest _$1,567 05 and Cast Due Prothy $1 no
Atty's Comm % Other Costs
Atty Paid $107.50
Plaintiff Paid
Date: February 22, 2000 Curtis R. Long
Prothonotary, Civil Division
tg ? o ??? tr e?
Deputy
REQUESTING PARTY:
Name Frank Federman, Esq.
Address: Two Penn Center Plaza Suite 900
Philadelphia, PA 19102
Attorney for: Plaintiff
Telephone: 215-563-70
Supreme Court ID No. 12248
REAL. ESTATE SALE No.>?3
Un the sheriff levied upon the defendants
interest in the real property situated in
Cumberland County, Pa., known and numbered as:
and more fully described on E hibit "A" filed, with
this writ and by this reference incorporatsd herein.
Date: a 9• ?s?o 6y:?
00? I;G eE 11 P7 e3j
i.lJ
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Underact No. 587, aobroued 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 Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and
THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street,
in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established
March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto Is exactly as printed and published in
their regular daily and/or Sunday and Metro editions/issues which appeared on the 2nd, 9th and 16th day(s) of May
2000. 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 QQQI the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County o?auphin I1 l in Miscellaneous Book "M",
Volume 14, Page 317. II '' _ -
PUBLICATION
COPY
S A L E #23
REAL ESTATE SAL? No. 23'
Writ No, 01111
.,L^ %CIvilTeen
-,_s: PNCMongageCOrporedon.:,:'
. ofAmedu ,..;
been duly paid.
Sworn to and
2nd day
Notarial Seal -4y T I /ivl?iG
Terry L. Russell. Notary Public-
Harrisburg. Depth County NARY PUBLIC
My Com•:?:sion Expires June 6, 200 ommission expires June 6, 2002
Member, Pennsponia Association or Notaries
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
iate Statement of Advertising Costs
Ir% To THE PATRIOT-NEWS CO., Dr.
w
°as For publishing the notice or publication attached
hereto on the above stated dates $ 241.99
fat Probating same Notary Fee(s) $ 1.50
and
of Total $ 243.49
89
tat
17>1isherIs Receipt for Advertising Cost
Jblisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
Ige receipt of the aforesaid notice and publication costs and certifies that the same have
THE PATRIOT-NEWS CO.
By ..............................................
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 La%v Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
La-.v 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,
APRIL 28, MAY 5, 12, 2000
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE SALE NO. 23
Writ No. 99-7145 Civil
PNC Mortgage Corporation
of America
VS.
Klran K. Dandapat,
a/k/a Klmn Kutnar Dandapat
Atty.: Frank Federman
DESCRIPnON
ALL 1I1AT CERTAIN tract of land
Situate in dto Townshlp of East Pemts-
born. Cumberland County, Pennsyl-
var la. more particularly bounded and
descnbcd as follows, to wit:
BEGINNING at a point on Erford
Road at the dividing line between
Lots Nos. 16 and 16(.e) on the hercln-
arter mentioned Plan of Lots; thence
along said Erford Road Soutli 89 de.
grees 50 minutes East 37.5 feet to a
point at the line dividing Lots Nos.
I a1..1 nnrl 17- then,,-alnno said dlvld-
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
12 day of MAY. ?000_
LOTS E. SNYOEft, Notary PlbU,
Cnrtisia born, Cumbor;ond County, PA
MY Co minion 1120ras !larch 2001