HomeMy WebLinkAbout01-6134
,
FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F, KENNEDY BOULEVARD
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD SUITE ISO,
HORSHAM, P A 19044
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CNIL DNISION
TERM
Plaintiff
NO. l}f~ ~/3L/
-
~
v.
DANIEL K. KULIG
JILL ANN KULIG
905 MAPLEWOOD LANE,
ENOLA, PA 17025
CUMBERLAND COUNTY
Defendant( s)
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
"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
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ..
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by 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, P A 17013
(717) 249-3166
Loan #: 493472609
IF TillS IS THE FIRST NOTICE THAT YOU HAVE
RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. IF
DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO
BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
SEND DEFENDANT(S) THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT
FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT
UNTIL THE END OF THE THIRTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH
YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES
THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY
(20) DAYS, YOU MAY OBTAIN AN EXTENSION OF
THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY
(30) DAYS AFTER YOU HAVE RECEIVED THIS
COMPLAINT. HOWEVER, IF YOU REQUEST
PROOF OF THE DEBT OR THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS
UPON YOUR RECEIPT OF THIS COMPLAINT,
THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR
OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY
FOR ADVICE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
1. Plaintiff is:
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD SUITE 150,
HORSHAM, PA 19044
2, The name(s) and last known addressees) of the Defendant(s) are:
DANIEL K, KULIG
JILL ANN KULIG
905 MAPLEWOOD LANE,
ENOLA, P A 17025
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described,
3, On 6/12/98 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. 1461, Page 488.
4, The premises subject to said mortgage is described as attached,
5, The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 3/1101 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 notice is attached as Exhibit "A."
6, The following amounts are due on the mortgage:
Principal Balance
Interest
2/1/01 through 10/1/01
(Per Diem $29,03)
Attorney's Fees
Cumulative Late Charges
6/12/98 to 10/1/01
Cost of Suit and Title Search
Subtotal
$151,392.89
7,054.29
4,000,00
248.64
750,00
$163,445,82
Escrow
Credit
Deficit
Subtotal
TOTAL
0,00
868,65
$ 868.65
$164,314.47
7, The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriff's Sale, If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged,
8, This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000,00,
9, The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S, g1680.403c 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.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$164,314.47, together with interest from 10/1/01 at the rate of $29,03 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,
~L~~a/\A~'
Is! Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
]0/23/01 i1:00 F~l ~008/012
~;,~t Mm'tgage Loan Servicing
3451 Hammond lave
P.Or Box 780
Waterloo, IA 50704-0760
GMRC Mortgage
Date: May 24, 2001
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is a n o~--:~: u~c~ that the ~..,, t~c on your home i~ iu defaul~ and ~e ~nder bunds M Foreclose.
Spe~ hf~ about ~e umre of ~e dehu~ h pro~d h the a~ch~ umfeJ.
The HO~O~ER'S MORTGAGE ~S~T~CE ~R~ ~M~) may be ~bb ~ hc~ ~ szve your
ho~. TMs ~o~e ~,lsh~ how ~e n~ ~.
To s~ ~H~ eau h.~: you mu~ ~ET ~ A CONS~R C~D~ CO~S~G AG~
WIT~ ~ DA~ OF T~ DA~ OF 'l~ NO~CE. T~e ~b No~e ~ you w~=a yo~ ~i ~ ~
~e --m.: ~a.:..~= nd nho~ --tuber of Co~*-m~ C~t Co~s~iue A~~ g~a vent Coun~ are
~:~ at ~c end ofthh No,ce. H~u have any ~ue~=_ you mv ~ ~e F~=~v~.a~ Houshu ~nre
A~encv to~ free at 1~0~2-23~. ~ersons ~ impaled h~ ~n ~a~ I~ ~0.1~9~:
This ,N, ofi~e con_toins impoFtant legal information. If you h~ve any ques~ons, repFescntafive, at the C. on.s. umer
· Credit Counsehg Agency .m~y be able to help exphin it. YOU.XlL~y also wlnt ~o conUc~ an attorney m ~ our
oFea. The local bar assocbfion n~y be able to help you find a mwyer.
LA NOx'~-iCACION EN ADJIYNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SI/DERECHO A
CONTINUAE: VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTLFICACION OBTENGA UNA TRADUCCION IMMEDIATASIENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FE~ANCE AGENCY) SIN CARGOS AL NU'MERO MENCIONADO
ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAI~LADO
-HOMEOWNER°S EMERGENCY MORTGAGE ASSISTANCE PROGRAM*' EL CUAL PUEDE
SALVAR SU CASA DE LA PERDH)A DEL DERECHO A REDIMIR SU IlII'OTECA
HOMEOWNI?~R'S NAME(S):
PRO PERTY ADDP, ESS:
JILL A. KULIG
905 MAPLEWOOD LA~E
ENOLA, PA 17025-2069
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
493472609
N/A
GMAC Mortgaqe Corporation
141 003/012
10/23/01 10:58 FAX
f11"$\ Mortgage loan Servicing
3451 Hammond'Ave
p ,0, Box 780
Waterloo, IA 50i704-0780
'---../
'-' GMAC Mortgage
-
Date: !>la.y 24. 2001
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
,
FORECLOSURE
Thl. I. .B offteial i:tic. tbat dI. mortUlI!. on voar "om. I. In defaalt. ud die I.nder intend. to foreclo...
SDecUk _formation aboat die utare of the def.ult is arovld.d in the attached D.....,
Th. HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (BEMAP) may b. able to keta to ..ve vour
kome. Thi. Notice RDIab.. how tJae Droll!ram works.
To .ee If HEMAP ea. "elD. vou ma.t MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF TmS NOTICE. T.ke this Notiee witJa vn wkea vn meet with the
Co_.eHnll! AlI!.ncv,
~ . aaD _ddress .nd ~_ n. nalUbe of Co.s mer Credit Coa...b encle. se' oar Coaa .re
JI.ted.t the e.d oftJais oti..., Ifvoa i.av. anv aae.tloa.. voa mav uII the Peaasvlvanla Hoa., Flunee
A~ncv toB free .t 1.80D-342.2397. (Penon. with Imaalred hearinll! ClD eaR (717\ 780.1869).
This Notie. eontains imporUntlec.llalormatioa. If foa have ..y qae.tiolll, repr....tativ.. .tth. Consumer
Credit Coan.ebe AC'.I:)' may be able to h.1p esp12m It Yoa may .Iso want to contaet a. attom.y in yoar
area, The loeal bar assoclatioa may b. able to help you flad a 12wyer.
LA NOTIFICAClON EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VI'o'lENDO EN SU CASA, SI NO COMPRENDE EL CONTENlDO DE ESTA
NOTIFICACJ:ON OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA
(pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUJEDES SER ELEGmLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PllOGRAM" EL CUAL PUEDE
SALV AR SU CASA DE LA PERDIDA DEL DERECBO A REDIMlR SU BIPOTECA
BOMEOWNJ~.R'S NAME(S):
PROPERTY ADDRESS:
DANIEL 1(, KULIG
905 MAPLEWOOD LANE
ENOLA, PI'. 17025-2069
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDEIVSERVlCER:
493472609
NIl'.
GMAC Mortqaqe Corporation
_SiT A
,10/23/01 10:59 FAX
141004/012
'-./
'---"
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MA.Y BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE" ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES
YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS,AND
IF YOU MEET OTHER ELIGIBD..ITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitlod to a temporary stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notice. During that time you nmst ammge and attend a
"face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS
MEETING MUST OCCUR WITHIN THE NEXT (30\ DAYS. IF YOU DO NOT APPLY FOR EMERGENCY
RTG GEASSISTANC OUMUSTBRIN YOURMORTG EUPTODATE.11l PARTOF11lIS
NO CECALI "HOWTOCU YO RTG GEDEF ULT" LAlNS WTOB GYO
MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNS1f.l,ING AGENCIES -- If you meet with one of the consumer cn:dit COlmseling
agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date
, ofthis meeting.The names. addresses and tele"hone munbers of desil!Jll,ted conslOner c",dit cOlmselinl! al!encies for
the co in which the is I ted are t orth at e e d of ' otice. It is only necessary to scbolhde one
face-to-face moeting, A vise your lender,inunediatelv of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default forthe ",asons set forth later
in this Notice (see following pages for specific infonnation about the nature of yOlO' defaldl) If yOll have tried and
are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the
Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed
Homeowner's Emergency Assistance Prognun Application with one of the designated consumer credit cOlmseling
agencies listed attbo end of this Notice, Only consumer cn:dit counseling agencies have applications for the
prognun and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency,
Your application MUST be filed or postmarked within thirty (30) days of yOU face-to-face meeting.
YOU MUST lllLE YOUR APPLICATION PROMPlLY, IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW THE OTHER TIME PElUODS SET FORTH IN THIS LETIER,FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSlSTANCI~ WILL BE DENIED,
AGENCY ACTION ,. Available ii.uuis for emergency mortgage assistance are very limited. They will be disbursed
by the Agency 'alder the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has
sixty (60) day. to make a decision after it receives your application. During that time, no forcc1oS\de 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.
f.)(HIBlT A'
10/23/01 10:59 FAX
141 005/012
,--,'
'--'
NOTE: ni YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BAc~UPTCY.
THE FOLLOWING PART OF TIDS NOTICE IS FOR INFORMATION PURl"OSES ONLY AND
SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT,
(If yoa hlIv. med bankruptcy yoa can stDI apply for Emerx.ncy Mortpg. As.i.tanc.,)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brinlt all to date),
NATURE OF THE DEF AUL T .. Th. MORTGAGE debt h.ld by the above l.nder is on your property located at:
905 Maplewood Lane Eno1a"PA 17025.2069 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTIlL Y MORTGAGE PAYMENTS for the following months and the
fo11owinq amounts are now past due: March 1, 2001 throuqh May 1, 2001. See
attached Exhibit for payment breakdown.
Montl,ly Payments 3 , 78 0 . 69
Late ChaIges 124,32
NSF 0,00
Inspections 0 . 00
Other
Suspense 0 , 00
TOTAL AMOUNT PAST DUE:
3,905.01
B, YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot a1llllicable):
HOW TO CURE THE DEFAULT.. You may cure the default within TIlIRTY (30) DAYS of the date of this
,noticeBYPA'IINGTHE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS .
$ 3,905.01 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments nmst be made either bv cash. cashiers check.
certified check or monev order made rovable and sent to:
Payment Processing
GMAC Mortqaqe Corporation
PO Box 780
Waterloo, IA 50704'0780
You can cure.ny other default by taking the following action within THIRTY (30) DAYS of the date of this letter:
(Do not use if not a1llllicable,) N tAl' b1
o pp 10a e
IF YOU DO NOT CURE THE DEFAULT n If you do not cure the default within THIRTY (30) DAYS of the date
of this Notice, th. lead.r Intend. to ....n:is.lts ri..hts to accel.rate the mortl!a... d.bt, This means that the entire
OlltStanding balance of this debt will be considenld due immediately and YOll may lose the chance to pay the
mortgage in monthly installments, Iffull payment of the total amolmt past chIC is not made within THIRTY (30)
DAYS, the lender also intends to mstn.ct its attorneys to start legal action to for.clos. .1I0n voar mortl!a...d
IIrou.rtv ,
IF THE MORTGAGE IS FORECLOSED UPON n The mortgaged property will be sold by the Sheriff to payoff
the mortgage debt If the lender refers your case to its attorneys, but you clIre the delinquency before the lender
begins legal p,,,ceedings against you, you will still be required to pay the reasonable attorney's fees that were
aclllally incurred, up to $50,00. However, if legal proceedings are started against against you, you will have to pay all
reasonable attorney's fees actually inCllIIed by the lender even if they e"ceed $50,00, Any attorney's fees will he
added to the amOlalt you owe the lender, which may also include other reasonable costs,
If voa cur. tine defaalt within th. THIRTY (30) DAYS neriod. voa ...m not b. req.ired to uav attorn..". f....
_aU"
I4J 006/012
10/23/01 11:00 FAX
"
"---,,,
'-.../
OTHER LENDER REMEDIES n The lender may also sue you penonally for the unpaid principal balance and all
other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the defa.dt within
lhe THIRTY (30) DAY period and fOlllclos\ll'O proceedings have begun, vou still have the ri..ht to cure the defa.dt
and ~entthe sale a~ anv time ut> to one hourbefolll the Sherifi's Sale. You l\1llV do so bv t>avilll! the ~otal amo.ml
then vast <h... t>1l1S an. ;ate or other ch'::,"S then ,duo. Illason,able attorneys f,?"s a!1Ji co~~ colDlected with the
foreclosure sale and an_other costs co --"cted with the Sheriff's Sale as SllOcified m writiIll! bv the lender and bv
pelfonnin.. anv other reauirements .mder the mortslaM~ Curinll your default in the IIlaJ\Ber set forth In this
Ilotice wlIl Rotore your mortaalle to the .a.... po. Oil a.lfyou had never defaulted.
EAln ,IF.ST POSSIBLE SHERIFF'S SALE DATE .- It is estimated that the earliest date that such a Sherifi'. Sale
of the mortgaged property could be held wOldd be approDmate1y.1x (6) month. from the date oftbb Notice. A
notice of the actual date of the Sheriff's Sale will be sent to you befolll the snle. Of COUIlle, the amOlmt needed to
Cllre the defa.dt will increase the longer you wait. You may find Ollt at any time exactly what the required payment
or action will 1>0 by contacting the lender,
HOW TO CONTACT THE LENDER:
Name of Lender:
Address:
GMAC Mortgage Corporation
401 Mile of Cars Way
National city, CA 91950
Phone Nl.III1ber:
Fa" Nl.III1ber:
Con.taot Person:
(BOO) B50-4622
(619) 470,5579
Collection Department
EFFECT OF $HERIFF'S SALE -. YOll should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and YO'11" right to occupy it. If you contirme to live in the property after the Sherifi's Sale, a
, lawsuit to remove you and yom fllrnishings and other belongings could be started by the lender at any time.
ASSUMPTlOJ'I OF MORTGAGE _. Youlilay or may Ilot sell or transfer yom home to a buyer or transferee who
will aSSllme th~ mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are
paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL TIlE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSmunON TO PAY OFF TIllS DEBT,
TO HAVE THIS DEF AUL T CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF,
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD
OCCURRED, IF YOU CURE THE DEF AULT, (HOWEVER, YOU DO NOT HAVE THIS RlGHT TO
CURl; YOUR DEF AUL T MORE TIlAN THREE TIMES IN ANY CALENDAR YEAR,)
TO ASSERT THE NONE.XISTENCE OF A DEF AULT IN ANY FORECLOSURE PROCEEDING OR
ANY OTHER LA WSUlT INSTInlTED UNDER THE MORTGAGE DOCUMENTS,
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY TIlE
LENDER,
TO SEEK PROTECTION UND,ER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ENCLOSED
EXHlB\TA
PENNSYLVANIA HOUSING FINAl'ICE AGENCY
HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAYI
CONSUMER CREDIT COUNSELING AGENCIES
(REV. 8/00)
Lycoming-Clinton Counties Commision for
Community Action (STEP)
2138 lincoln Street P.O. Box 1328
Williamsport, PA t 7703
(570) 326.0587 FAX (570) 322-2197
CLINTON COUNTY
CCCS ofNortheastem PA
163 t South Athenon St., Suite 100
State College. PA 16801
(814) 238-3668 FAX (814) 238-3669
CCCS ofNortheastem PA
20 I Basin Street
Williamsport. P A 17703
(570) 323-6627 FAX (570) 323-6626
COLUMBIA COL~'TY
1400 Abington Executive Park
SUite 1
Clacks Summit PA 18411
(570) 587,9163 or (800) 922.9537
FA..X (570) 587.9134-9135
31 W. Market Street
POB 1127
Wilkes.Barre. PA 18702
(570) 821-0837 or (800) 922-9537
FAX (570) 821-1785
Commission on Economics Opportunity of Luzeme Couney
t 63 Amber Lane
Wilkes-Barre. PA 18702
(570) 326-0510 or (800) 822-0359
FAX (570) 329-'665-(Call Before Faxing)
(570) 4554994 Hazeltown
FAX (570) 455-563 '-(Call Before Faxing)
(570) 836-4090 Tunkhannock
CRAWFORD COl':'/TY
Gre:l1cr Eric Community ActIOn Committee
18West9l/1Street
Ene, PA 16501
(814) 4594581 FA-X (814)456-0161
Booker T. Washington Center
1720 Holland Center
Erie. PA 16503
(814) 453-5744 FA-X (814) 5749
John F Kennedv Center. Inc.
20ll East 201ll Street
Efll:.PA 16510
(814) 398-0400
FAX (814) 898,1243
Shenango Valley Urban League, Inc.
601lndiana Avenue
Farrell, PA 16121
(412) 981,5310
CUMBERLAND COl':'/TY
FinanCial Counseling Services of Franklin
3l West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
CCCS of West em Pennsylvania. Inc.
2000 Linglestown Road
HlllTisburg. PA 17102
(717) 541-1757
Urban League of Metropolitan Harrisburg
N.6ll1Street
HlllTisburg. PA 17101
(717) 234-5925 FA-X (717) 234-9459
YWCA of Carlisle
301 "G" Street
Carlisle, PA 17013 .
(717) 243.3818 FA-X (717)-731-9589
Community Action Comm iJfthe Capital Region
1514 Derry Street
HlllTisburg, PA 17104
(717) 232-9757 FAX (717) 234.2227
Adams County Housing Authority
139-143 Carlisle St.
Gettysburg, PA (7325
(717) 334-1518 FAX 334.8326
PENNSYL V Ao'lIA BULLETIN. VOL 29, NO. 23, JUNE 5. 1999
I)lM8T A
ALL THAT CERTAIN lot or iece of ground situate in the Township of East Pennsboro,
Cumberland County, Pennsylv nia bounded and described according to a certain Final Plan for Penn
Valley Phase I, prepared by H rtman & Associates, Inc., Engineers and Surveyors, Camp Hill,
,
Pennsylvania. dated June 23, 1 93 and last revised September 9, 1993 and recorded on Ncvember 5,
1993 in Plan Book 67 page 20, as follows, to wit:
. .' \
I3EGINNING at a point on the orthwest side of Maplewood Lane and a corner of Lot No. 52 on said
Plan; thence extending along d Jot north 09 degrees 45 minutes 15 seconds west 101.61 feet to a
point in line of Lot No. 47 on id plan; thence extending along said lot and continuing north 80
degrees 14 minutes 45 seconds st 80.00 feet to a point. a comer of Lot No. ,49 on said plan; thence
extending along said lot and co~tinuing south 09 degrees 45 minutes IS seconds east 129.98 feet to a
point on the northwest side of Nfaplewood Lane; thence extending along said lane along a curve
having a radius of 200.00 feet, the arc distance of 85.53 feet to the point and place of beginning.
, ~
BEING Lot No. 51 i
CONTAINING 9.005,33 SQU~RE FEET
BEING PART OF THE SAME!PREMISES which James A. Acri, as Executor of the Estate of Edith
Loretto Acri, and as Trustee of ~e Testamentary Trust of Ovidio Acri, and James A. Acri.
individually. by Deed dated Noyembcr 22, 1993 and recorded in the Office for recording of Deeds in
and for Cumberland County in peed Book R30, Page 148, and Deed Book R36. Page 155, granted
and conveyed unto Penn Valley \Corporation. a Pennsylvania corporation. in fee.
PREMISES ON:
,;,.
VERIFICATION
KRISTINE-WILSON hereby states that she is FORECLOSURE SPECIALIST of
GMAC MORTGAGE CORPORATION 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 18 Pa, C,S. See, 4904
relating to unsworn falsification to authorities,
C)?,;.aT~ 0 _ !..Ii P/JITXJ
DATE:
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001..06134 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GMAC MORTGAGE CORPORATION
VS
KULIG DANIEL K ET AL
DAVID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
KULIG JILL ANN the
DEFENDANT , at 1120:00 HOURS, on the 1st day of November, 2001
at BOOKSPAN 1225 SOUTH MARKET ST
MECHANICSBURG, PA 17055
by handing to
JILL ANN KULIG
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof,
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6,00
6,50
.00
10.00
,00
22.50
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R. Thomas Kline
11/05/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before
By:
rfjYl/7/74 ~ '
Deputy Sh ri~
d_1C-
me this T
day of
?Lo.t,,~ .26<1( A. D,
~.-C? 7J.vJ'~,. ~
rothonotary ,
SHERIFF'S RETURN.. REGULAR
CASE NO: 2001-06134 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GMAC MORTGAGE CORPORATION
VS
KULIG DANIEL K ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
KULIG DANIEL K
the
DEFENDANT
at 1846:00 HOURS, on the 2nd day of November, 2001
at 905 MAPLEWOOD LANE
ENOLA, PA 17025
by handing to
DANIEL K KULIG
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
9,75
,00
10,00
.00
37.75
r~~~~
R. Thomas Kline
11/05/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before
9~
day of
BY4~.IA~~~
Deputy Sh ~ff
me this
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~~othonotary ~
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPIDA, PA 19103-1814
(215) 563-7000
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
CIVIL DIVISION
v.
NO. 01-6134 CIVIL
DANIEL K. KULIG
JILL ANN KULIG
Defendant(s).
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor ofthe Plaintiff and against DANIEL K. KULIG and JILL
ANN KULIG, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from
service thereof and for Foreclosure and Sale ofthe mortgaged premises, and assess Plaintiffs damages
as follows:
As set forth in Complaint
Interest from 10/1/01 to 12/6/01
TOTAL
$164,314.47
$1,915,98
$166,230.45
I hereby certify that (1) the addresses of the Plaintiff and Defendant( s) are as shown above, and
(2) that notice has been given in accordance with Rule 237.1, copy attached,
G tl--,
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: I^- Ityl C~ivJ K J: JrVl.o. ~
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(Rule of Civil Procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SffiTE 150
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
CIVIL DIVISION
v.
NO. 01-6134 CIVIL
DANIEL K. KULIG
JILL ANN KULIG
Defendant(s).
Notice is given that a Judgment in the above-captioned matter has been entered against you on
( ;L - 14
2001.
By:
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESQUIRE
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHNF, KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HA VB PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A
LIEN AGAINST PROPERTY,""
FEDERMAN AND PHEL&~, L.L,P,
Frank Federman, Esquire
Identification No, 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563..7000
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
GMAC MORTGAGE CORPORATION
CIVIL DIVISION
Plaintiff
CUMBERLAND COUNTY
vs.
DANIEL K. KULIG
JILL ANN KULIG
NO, 01-6134 CIVIL
FILE COpy
Defendant(s)
TO: DANIEL K. KULIG
905 MAPLEWOOD LANE
ENOLA,PA 17025
DATE OF NOTICE: NOVEMBER 23. 2001
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE, IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN
AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIA nON
2 LIBERTY A VENUE
CARLISLE, PAl 70 13
(717) 249-3166
1i1lHLk ~ f ti~iL41)f(jit ~
Frank Federman, Esquire
Attorney for Plaintiff
": ."
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,
I
FEDERMAN AND PHE~~
Frank Federman, Esquire
Identification No, 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
vs,
CUMBERLAND COUNTY
DANIEL K, KULIG
JILL ANN KULIG
NO.01-6134 CIVIL
Defendant
FILE COpy
TO: JILL ANN KULIG
1225 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
DATE OF NOTICE: NOVEMBER 23. 2001
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN
AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights, You
should take this notice to a lawyer at once, If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PAl 70 13
(717) 249-3166
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rank Federman,Esquire
Attorney for Plaintiff
FEDE~ANandPHELAN
By: FRANK FEDE~AN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BL YD., SUITE 1400
PIDLADELPIllA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
CIVIL DIVISION
v.
NO. 01-6134 CIVIL
DANIEL K. KULIG
JILL ANN KULIG
Defendant(s).
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that on information and belief, he has knowledge ofthe following facts,
to wi!:
(a) that the defendant(s) is/are not in the Military or Naval Service ofthe 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 DANIEL K. KULIG is over 18 years of age and resides at , 905
MAPLEWOOD LANE, ENOLA, P A 17025 .
(c) that defendant JILL ANN KULIG is over 18 years of age, and resides at , 1225
SOUTH MARKET STREET, MECHANICSBURG, PA 17055.
This statement is made subject to the penalties of 18 Pa, C,S, Section 4904 relating to
unsworn falsification to authorities.
Ul~
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FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
GMAC MORTGAGE CORPORATION
Plaintiff,
v.
DANIEL K. KULIG
JILL ANN KULIG
No. 01-6134 CIVIL
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$166,230.45 V'
Interest from 12/6/01 to 3/6/02
(per diem -27.33)
$2,459.70 and Costs
TOTAL
$168,690.15
UiL-
F~FEDE~N,ESQlmRE
One Penn Center at Suburban Station
1617 JohnF. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property.No.
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ALL THAT CERTAIN lot or piece of ground situate in the Township of East Pennsboro, Cumberland
Coumy. Pennsylvania bounded and described according to a certain Final Plan for Penn ValIey Phase
I, prepared by Hartman and Associates. Inc, , Engineers and Surveyors, Camp HilI. Pennsylvania. dated
June 23, 1993 and last revised September 9. 1993 and recorded on November 5. 1993 in Plan Book 67.
Page 20, as folIows, to wie:
BEGINNING at a poim on the Northwest side of Maplewood Lane and a corner of Lot No, 52 on said
Plan; thence extending along said Lot North 9 degrees 45 minutes 15 seconds \Vest 101.61 feet co a
poim in line of Lot No, 47 on said Plan; thence extending along said Lot ami continuing NOrth 80
degrees 14 minutes 45 seconds East 80,00 feet to a poim, a corner of Lot No, 49 on said Plan: thence
extending along said Loe and continuing South 9 degrees 45 minutes 15 seconds East 129,98 feet co a
point on the Northwest side of Maplewood Lane; thence extending along said lane along a curve having
a radius of 200,00 feet, the arc distance of 85,53 ft;et co the point and place of beginning,
BEING Lot No, 51
CONTAINING 9,005,33 square feet
Tax Parcel #13..0999-094
TITLE TO SAID PREMISES rs VESTED IN Daniel K, Kulig and Jill Ann Kulig, his wife by
Deed from Penn ValIey Corporation, a Pa, Corp, <1ate<1 1/1//':)7 and 'recorded 1/29/97 in Record
Book 152, Page 754,
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GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
DANIEL K. KULIG
JILL ANN KULIG
CIVIL DIVISION
NO. 01-6134 CIVIL
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No, I)
GMAC MORTGAGE CORPORATION, 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 .905 MAPLEWOOD LANE. ENOLA.
PA 17025.
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
DANIEL K. KULIG
905 MAPLEWOOD LANE
ENOLA, P A 17025
JILL ANN KULIG
1225 SOUTH MARKET STREET
MECHANICS BURG, PA 17055
2, Name and address ofDefendant(s) in the judgment:
DANIEL K. KULIG
905 MAPLEWOOD LANE
ENOLA, P A 17025
JILL ANN KULIG
1225 SOUTH MARKET STREET
MECHANICSBURG, P A 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None,
4, Name and address oflast recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
TMS MORTGAGE, INC.
1770 TRIBUTE RD., SUITE 109
SACRAMENTO, CA 95815
5, Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
6, Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale,
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
905 MAPLEWOOD LANE
ENOLA, P A 17025
Domestic Relations of Cumberland County
13 North Hanover Street
Carlisle, P A 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, P A 17105
December 7. 2001
DATE
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties ofl8 Pa, C,S, Sec, 4904 relating to unsworn falsification to authorities,
~ t rJ~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
DANIEL K. KULIG
JILL ANN KULIG
CIVIL DIVISION
NO. 01-6134 CIVIL
Defendant(s).
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is;
o an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
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FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
v.
No. 01-6134 CIVIL
DANIEL K. KULIG
JILL ANN KULIG
Defendant(s).
December 7, 2001
TO: DANIEL K. KULIG
905 MAPLEWOOD LANE
ENOLA, PA 17025
JILL ANN KULIG
1225 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
"THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION
OBTAINED WILL BE USED FOR THA T PURPOSE, IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN A TTEMPT TO COLLECT A DEBT. BUT ONL Y ENFORCEMENT OF A LIEN A GAINST PROPERTY, ..
Your house (real estate) at. 905 MAPLEWOOD LANE. ENOLA. PA 17025. is scheduled to
be sold at the Sheriff's Sale on MARCH 6. 2002 at 10:00 a,m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 166.230.45 obtained by
GMAC MORTGAGE CORPORATION (the mortgagee) against you, Ifthe Sheriffs sale is
postponed, the property will be relisted for th~ JUNE 5, 2002 Sheriffs Sale,
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
I. 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.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000,
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To
find out if this has happened, you may call (717) 240-6390,
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe
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 oft1re money which was paid for your house, A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money, The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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ALL TH.". T CERT.".I:-.i lot or piece of ground situate in the Township or' East Pennsboro. Cumberland
Coumy. Pennsylvania bounded and described according to a certain Final Plan for Penn Valley Phase
I. prepared by Hartman and Associates. Inc,. Engineers and Surveyors. Camp Hill. Pennsylvania, dated
June 23. 1993 :.lnd las, revised September 9. 1993 and recorded on :>Jovember 5. 1993 in Plan Book 6-,
Page 20, as follows, to wit:
BEGIN;\IING at :.l poim on the Northwesr side of Ylaplewood Lane :.lnd :.l corner of Lor 'io, 52 on said
Plan; rhence exrending along said Lor North 9 degrees 45 minures lj seconds Wes, 101.61 feer ro a
point in line of Lor No, 47 on said Plan: rhence exrending along said Lor and COntinuing 0iorrh 80
degrees 14 minures 45 seconds Easr 80,00 feer to a point, a comer of Lot 'i 0, 49 on said Plan: thence
exrending along said Lor and cominuing Sourh 9 degrees 45 minures !j seconds Ease 129,98 feet ,0 a
point on the 0iorthwesr side of ylaplewood Lane; thence extending along said lane along a curve having
a radius of 20000 feet, rhe arc distance of 85,53 f~er to the point and place of beginning,
BEING Lor No, 51
CONT,\INING 9,005,33 square feet.
Tax Parcel #13-0999-094
TITLE TO SAID PREMISES IS VESTED IN Daniel K, Kulig and Jill Ann Kulig, his wife bv
Deed from Penn Valley Corporarion, a Pa, Corp, dared 1/ 1 /I'9~ and recorded 1/29/97 in Reco~d
Book 152, Page 754,
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AFFIDAVIT OF SERVICE
CUMBERLAND COUNTY
PLAINTIFF
GMAC MORTGAGE CORPORATION
No. 01-6134 CIVIL
DEFENDANT(S)
DANIEL K. KULIG
JILL ANN KULIG
ACCT. #493472609
SERVE JILL ANN KULIG AT
1225 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
Type of Action
- Notice of Sheriff's Sale
Sale Date: MARCH 6, 2002
Served and made known to
at d.:O~_,o'c1ockem".t
SERVED
~
, Defendant, on the JJt7
day ofJ7VrIUN~'120oi,
, Commonwealth
of Pennsylvania, in the manner described below:
~Defendant personally served,
Adult family member with whom Defendant(s) reside(s), Relationship is
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship,
Manager/Clerk of place oflodging in which Defendant(s) reside(s),
Agent or person in charge ofDefendant(s)'s office or usual place of business, NOT-{': \ h-e ~Ov€...
an officer of said Defendant(s)'s company, ,_,... .l('C~~ 'IS Ji 11.'So plaCe..
Other: ..,.,u.o ~
, I' _ ~ lo,...s'llrleSS.
Agea'il-da-.Height~ Weight ~15 Race~ Sex 1::.- Other 6co't.st:6"\->
(
I. I
a true and correct copy of the
the address indicated above,
, a competent adult, being duly sworn according to law, depose and state that I personally handed
otice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at
Sworn to and subscribed
before me this _ day
of ,200_,
Notary:
By:
PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED.
NOT SERVED
On the day of
,200_, at
o'clock _,m" Defendant NOT FOUND because:
Moved Unknown
No Answer
Vacant
Other:
Nct,:;rii?\ ;':;;e<,,1
Pu:
C'
By:
U~i) M.
(::-,,:\ ',,' ;-.: .-.
or e for PI . tif
Frank Feder n, E uire - 1.0. No. 12248
One Penn C ter at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
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FEDERMAN AND PHELAN
By: FRAJ{KFEDERMAN,ESQtmRE
IDENTIFICATION NO, 12248
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(71~) ~(i,-7000
ATTORNEYFORP~IFF
COURT OF COMMON PLEAS
CIVIL DIVISION
GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
vs.
No.: 01-6134
DANIEL K KULIG
JILL ANN KULIG
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PURSUANT TO P R <: P, 404(7)/401
FRANK FEDERMAN, ESQtmRE, 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,
at 905 MAPLEWOOD LANE, ENOLA, P A 17025, which notice of Sheriff's Sale was received by
Defendant, on 12/17/01 as evidenced by the attached return receipt.
The undersigned understands that this statement is made subject to the penalties of 18 P A
C.S. s 4904 relating to unsworn falsification to authorities,
9--~ 9:;),A-
FRAJ{K FEDERMAN, ESQtmRE
Date: Fehnl"'Y (i, 7007
. .
,..__..___n_du....--.--..........--.....--....n..n-n........nn..U_.._
· ~\I\ft\" 1\1111
7lololl 3'1]], 'VI"" IoS3O "'l'Il
: 3. Service Type CERTIFIED MAIL
: 4. RestriCted Delivery'? (Extra Fee) Yes
, 1. Article Addressed to:
. DANIEL K, KULIG
, 905 MAPLEWOOD LANE
ENOLA, PA 17025
O. Is delivery addreSS different from Item 11
II YES, enter delivery ackIress below:
SALES (493472609) JPG
PS Form 3811, July 2001 Domestic Return Receipt
o Agent
o Addressee
DYes
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SALE DATE: MARCH 6. 2002
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
GMAC MORTGAGE CORPORATION
No,: 01-6134 CIVIL
vs.
DANIEL K. KULIG
JILL ANN KULIG
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:
905 MAPLEWOOD LANE. ENOLA. PA 17025,
As required byPa, 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 Supplemental Affidavit No.2 on the date
indicated, and a copy ofthe notice is attached as an Exhibit. A copy of the Certificate of Mailing
(Form 3817) andlor Certified Mail Return Receipt stamped by the U,S, Postal Service is attached
for each notice,
February 25,2002
1 y~/
FRANK. FEDERMAN, ESQUIRE
Attorney for Plaintiff
GMAC MORTGAGE CORPORATION
Plaintiff,
CUMBERLAND COUNTY
v.
COURT OF COMMON PLEAS
DANIEL K. KULIG
JILL ANN KULIG
CIVIL DIVISION
Defendant(s).
NO. 01-6134 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
GMAC MORTGAGE CORPORATION, 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 .905 MAPLEWOOD LANE. ENOLA.
PA 17025.
I. Name and address ofOwner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
DANIEL K. KULIG
905 MAPLEWOOD LANE
ENOLA, PA 17025
JILL ANN KULIG
1225 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
2. Name and address ofDefendant(s) in the judgment:
DANIEL K, KULIG
905 MAPLEWOOD LANE
ENOLA, PA 17025
JILL ANN KULIG
1225 SOUTH MARKET STREET
MECHANICSBURG, P A 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None,
4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
TMS MORTGAGE, INC,
1770 TRIBUTE RD" SUITE 109
SACRAMENTO, CA 95815
5, Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None,
6, Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None,
7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant'Occupant
905 MAPLEWOOD LANE
ENOLA, P A 17025
Domestic Relations of Cumberland County
13 North Hanover Street
Carlisle, P A 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, PAl 71 05
December 7. 2001
DATE
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 of18 Pa. C.S, Sec, 4904 relating to unsworn falsification to authorities.
1 ~rJ~
FRANK FEDERMAN, ESQUffiE
Attorney for Plaintiff
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DATE:
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S) DANIEL K. KULIG
JILL ANN KULIG
PROPERTY: 905 MAPLEWOOD LANE
ENOLA, P A 17025
Improvements: Residential Property
CUMBERLAND COUNTY
The above-captioned property is scheduled to be sold at the Sheriff's Sale on MARCH 6.
~, at 10:00 a.m. in Cumberland Countv 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
SALE DATE: MARCH 6. 2002
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
GMAC MORTGAGE CORPORATfON
No,: 01-6134 CIVIL
vs,
DANIEL K, KULIG
JILL ANN KULIG
A>> IOHNEV FILE COPY
PLEASE RETURN
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:
905 MAPLEWOOD LANE. ENOLA. PA 17025,
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 Supplemental Affidavit No, 2 on the date
indicated, 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,
}
JJ1
i , I Uliil/t:V FILE copy
J.i I E-.URN
February 25, 20<HLEASE R I
FRANK FEDERMAN, ES UIRE
Attorney for Plaintiff
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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55.
Robert P Ziegler
1,_____________________________________________________.________________________Ilecorderof
Deeds in and for said County and State do 'hereby certify that the Sheriffs Deed in which ----------------
GMAC Mtg Corp
___________________________.________________________________________________________ uthegr.antce
6th
the same having been sold to said gr.antcc on the _______________________________________________ day of
March ' .2002 ..
________________________________________ A. D., : _____, under and by virtue of a wnt______________
Dee
clay of __________________________ A. D.,
Civil
______________________________..._______ __________ __ _______ ________________________ Tenn, :
6134 GMAC Mtg Corp
Number ______________, at the suit of _______________________________________________________________
Daniel K Kulig & Jill Ann
---------------- ------------ -- _ _ _ __ against_ _ _ _ _ _ _ _ __ _ __ _ _ __ _ __ __ _ __ __ _ _ _ _ __ __ __ __ __ __ __ __ __ __ _ is
251 69
duly recorded in Sheriffs Deed Book No. ____________, Page ____________.
Execution . 11 th
________________________________________________lSSucd on the _____________ _______________ __ _______
2001
_____~ out of the Court of Cornman PIcas of said County 'as of
2001
IN TESTIMONY WHEIlEOF, I have hereunto
set my hand and seal of said office this ___L______ day
/1p..., ( 2-dI' Z--
of ______________________________ A. D., ._____
~---~-----------------
Ilccordcr of Deeds
GMAC Mortgage Corporation
VS
Daniel K. Kulig and
Jill Ann Kulig
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-6134 Civil Term
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on January 17, 2002 at 7:33 o'clock pm, EST, he served a true copy of the within
Real Estate Writ, Notice and Description, in the above entitled action, upon the within
named defendant, to wit: Daniel K. Kulig, by making known unto Daniel K. Kulig,
personally, at 905 Maplewood Lane, Enola, Cumberland County, Pennsylvania, its
contents and at the same time handing to him personally the said true and correct copy of
the same.
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that
on December 21,2001 at 4:41 o'clock pm, EST, he served a true copy of the within Real
Estate Writ, Notice and Description, in the above entitled action, upon the within named
defendant, to wit: Jill Ann Kulig, by making known unto Jill Ann Kulig, personally, at
1225 S. Market Street, Mechanicsburg, Cumberland County, Pennsylvania, its contents
and at the same time handing to her personally the said true and correct copy of the same.
Gerald Worthington, Deputy Sheriff, who being duly sworn according to law,
states that on January 08,2002 at 1:40 o'clock P.M., E.S.T., he posted a true copy ofthe
within Real Estate Writ, Notice, Poster and Description, in the above entitled action,
upon the property of Daniel K. Kulig and Jill Ann Kulig located at 905 Maplewood Lane,
Enola, 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 ofthe pendency ofthe action to one ofthe within named
defendants to wit: Daniel K. Kulig, by regular mail to his last known address of905
Maplewood Lane, Enola, P A 17025. This letter was mailed under the date of January 28,
2002 and never returned to the Sheriff s Office.
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: Jill Ann Kulig, by regular mail to her last known address of 1225 S.
Market Street, Mechanicsburg, PA 17055. This letter was mailed under the date of
January 28,2002 and never returned to the Sheriffs 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 Courthouse, Carlisle, Cumberland County,
Pennsylvania on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the
sum of$1.00 to Attorney Frank Federman for GMAC Mortgage Corporation. It being
the highest bid and best price received for the same, GMAC Mortgage Corporation of
500 Enterprise Road, Suite 150, Horsham, PA 19044, being the buyer in this execution
paid SheriffR. Thomas Kline the sum of $761.50, it being costs.
Sheriffs Costs:
Docketing
Poundage
Advertising
Posting Handbills
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Law J oumal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
$30.00
14.93
15.00
15.00
30.00
10.00
.50
1.00
17.25
.82
15.00
30.00
284.00
222.30
24.20
25.00
26.50
$761.50
Sworn and subscribed to before me
This ~ day of () >>-,~'J
I
2002, A.D. ~~ O. ~ I ~
Prot onotary
~~4~
R. Thomas Kline, Sheriff
BY Vt c&.l JML~
Real Estate Deputy
o?~
.Jb. oV
p.-o
CIc 3;(AJ'{ (,
Av. j:l.37)1
GMAC MORTGAGE CORPORATION
CUMBERLAND COUNTY
Plaintiff,
COURT OF COMMON PLEAS
v.
DANIEL K. KULIG
JILL ANN KULIG
CIVIL DIVISION
NO. 01-6134 CML
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No.1)
GMAC MORTGAGE CORPORATION, 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 .905 MAPLEWOOD LANE. ENOLA.
PA 17025.
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
'reasonably ascertained, please indicate)
DANIEL K. KULIG
905 MAPLEWOOD LANE
ENOLA, P A 17025
JILL ANN KULIG
1225 SOUTH MARKET STREET
MECHANICS BURG, PA 17055
2. Name and address ofDefendant(s) in the judgment:
DANIEL K. KULIG
905 MAPLEWOOD LANE
ENOLA, P A 17025
JILL ANN KULIG
1225 SOUTH MARKET STREET
MECHANICSBURG, P A 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
-,
,
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
TMS MORTGAGE, INe.
1770 TRIBUTE RD" SUITE 109
SACRAMENTO, CA 95815
5. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
905 MAPLEWOOD LANE
ENOLA, P A 17025
Domestic Relations of Cumberland County
13 North Hanover Street
Carlisle, PA 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
1 t rL
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
December 7. 2001
DATE
..
GMAC MORTGAGE CORPORA nON
Plaintiff,
CUMBERLAND COUNTY
No. 01-6134 CIVIL
v.
DANIEL K. KULIG
JILL ANN KULIG
Defendant( s).
December 7,2001
TO: DANIEL K. KULIG
905 MAPLEWOOD LANE
ENOLA, PA 17025
JILL ANN KULIG
1225 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
**THlS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
Your house (real estate) at, 905 MAPLEWOOD LANE, ENOLA. PA 17025. is scheduled to
be sold at the Sheriffs Sale on MARCH 6, 2002 at 10:00 a.m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 166,230.45 obtained by
GMAC MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is
postponed, the property will be relisted for th~ JUNE 5, 2002 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:
L 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.)
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 tire money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed,
7 . You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
.
../
ALL TH.\ T CERT;\,I~ 10( or piece of ground situate in the Township of East Pennsboro. Cumberland
Coumy. Pennsylvania bounded and descri.bed according to a certain Final Plan for Penn Valley Phase
1. prepared by Hartman and .\ssociates, Inc" Engineers and Surveyors, Camp Hill, Pennsylvania, dated
June 23, 1993 and last revi.sed September 9. 1993 and recorded on :'>iovember 5, 1993 in Plan Book 67.
Page 20, as follows. to wie:
BEGI~01ING at a poim on the Northwest side of Maplewood Lane and a corner of Lot :--;0, 52 on said
Plan; thence extending along said Lor Norrh 9 degrees 45 minutes 15 seconds \Vest 101.61 feet co a
poim in line of Lot No, 47 on said Plan; thence extending along said LOt and cominuing ;-;orrh 80
degrees 14 minutes 45 seconds East 80,00 feet ro a paine, a corner of Lot :--;0, -1-9 on said Plan: thence
extendim: alon~ said Lot and cominuin~ South 9 degrees 45 minutes 15 seconds East 129,98 reet :0 .1
- - ...'"
point on the Northwest side of Maplewood Lane; thence extending along said lane along a curve having
a radius of 200,00 feet, the arc distance of 85,53 f~et ro the point and place of begi.nning,
BEING Lot No, 51
CONT.\INING 9,005,33 square feet,
Tax Parcel #13-0999-094
TITLE TO SAID PREMISES IS VESTED IN Daniel K. Kuli~ and Jill Ann Kuli~. his wife bv
Deed from Penn Valley Corporation, a Pa. Corp. dated 11 ll/I.)~ and'recorded 1/29/97 in Reco~d
Book 152, Page 754,
WRIT OF EXECUTION. and/or ATTACHMENT
.
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-6134 CIVIL 19
CIVIL ACTION - LAW
CUMBERLAND
ro THE SHERIFF OF ______,_____~__~_____COUNTY
To satisfy the debt, interest and costs due __c;~~~l"!~E!JIage Corporation
PLAINTIFF(S)
PA 17025 and Jill Ann
17055.
from __~anie~_!<. Kulig, 905 Maplewood La~E:l' Enola
Kulig, 1225 S. Market st., Mechanicsburg PA
DEFENDANT(S)
Real estate located
(1) You are directed to levy upon the property of the defendant(s) and to sell
at 905 Maplewood Lane, Enola PA 17025. (See attached legal
descripton. )
(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 Of for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If propertyofthe defendant(s) not levied upon an subject to attachment is found inthe possession of anyone 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,
L,L,
Due Prothy
Other Costs
$.50
$1. 00
Amount Due $166,230.45
Interest 12/6/01 to 3/6/02 $2,459.70
Atty's Comm
Atty Paid
Plaintiff Paid
%
$132.25
Date
December 11, 2001
CURTIS
by ____
Deputy
REQUESTING PARTY:
Name Frank Federman, Esq.
Address: 1617 JFK Blvd., Ste 1400
Philadelphia PA 19103 1814
Attorney for: Plaintiff
Telephone: (215) 563 7000
Supreme Court ID No, 12248
REAL ESTATE SALE No. 55
On December 13,2001, the sherifflevied upon the
defendant's interest in the real property situated in
East PennsboroTownship, Cumberland County, PA,
known and numbered as 905 Maplewood Lane, Enola
and more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: December 13,2001
By: 9 tJ~ ~mi::l:h
Real Estate Deputy
VINV^lASNN3d
II C:!"j 1.1'1:)
10. Wd ZE E ZI :1:10
AlNOO:) C))// hUBr/OO
.:I.:11ll3HS 3111 .;lO 3:l1.:l.:l0
.
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,
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATEOFPENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues ofthe said Cumberland Law
Journal on the following dates,
V1Z:
JANUARY 25, FEBRUARY 1,8,2002
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.
,}
Roger M. Morgenthal, Editor
...
RBAL B8TAft &AUt 110. ISIS
Writ No, 2001-6134 Civil
GMAC Mortgage Corporation
SWORN TO AND SUBSCRIBED before me this
8 day of FEBRUARY. 2002
vs.
Daniel K. Kulig and
Jill Ann Kulig
Arty,; Frank Fedennan
ALL TIiAT CERTAlN lot or piece
of ground situate In the Township
of East Pennsboro, Cumberland
County, Pennsylvania bounded and
described according to a certain Fi-
nal Plan for Penn Valley Phase I.
prepared by Hartman and Associ-
ates. lnc.. Engineers and Survey-
ors, Camp Hill. Pennsylvania. dated
___ _____ ~.._ . __.1..0._
NOTARIAL PubI\C
LOIS E. SNYDE~ CountY
.:= Expires March 5, 2005
...
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
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..IM
Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and
12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said countYlD phin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION ...................... .'. ...... ..
COpy Sworn to and subscribe ary 2002 A.D.
S ALE #55
....... ." . Mo..
.. .::~,', ." ' .. .., -,.' ~.. .'
...,:..,:'........ ....'....
' ...... '.,.... ,. :~ " " "
" "',:.. ,'.~; .,- ',.,.-.<
. ". '~'"i,...;;;il.'..
NolaJtal Seal
T8IlY l. RUIll(ll1, Notary PublIc
Harrtlburg, Dauphin County ARY PU BUG
My ComrDIuIon Explras June 8, 2002 ..' J
commiSSion expires une 6, 2002
Member, Pennsylvania Association 01 Notaries
CUMBERLAND COUNlY SHERIFFS OFFICE
CUMBERLAND COUNlY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
220.80
1.50
222.30
publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
By....................................................................
.;.'~ .'
~.;,~, .'e" .
""'"" 1l-
.,
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)
)
I
r
Corrected Deed
,/
STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55.
Robert P Ziegler
I, _____________________________________________________________ ________________Ileco~ro(
Deals in and. for &aid County and State do 'hereby certify that the Sherifr. in which ________________
Secretary of Veterans Affairs .
___________________________._________________________________________ ______________ u theg<antcc
6th
the same having heat sold to said gntntcc OIl the _____________________00___ ____________n______ day of
March' . 2002 "
__00____________________________________ A. D., ' __on' under and by ,rtue of a wnt______________
llt
Execution .
___________________________n___________________lSSucd... the ____ow_on __________________________
2001
___ow, out or the Court of
December
day or __________________________ A. D"
Picas or said County'as 0(
20r
Civil
------------------------------..----------_______ ________n_____n____ ___________ Tenn, :
" 6134 GMAC Mtg Corp
Number ______00______, at the .uit of ______________________00____________ __________________________
DAniel K Kulig & Ji 1 Ann
___________________________________agaiRst____________________._______ ____________.__________ D
251 3321
duly recorded in Sherifr. Deed Book No, ____woo_own' Page ____________.
IN TESTIMONY WHEIlEOF, I have hereullto
*
set my hand and seal of 'd office thU __j~______ day
of -----~7f--- --ji---1ft D.,
----7((- -- -~---
<1..t!!~_
Deeds
t'r~-==~"~'::;'~