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HomeMy WebLinkAbout04-0548 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id, No, 12248 LAWRENCE T. PHELAN, ESQ., Id, No. 32227 FRANCIS S. HALLINAN, ESQ" Id, No, 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 Ql.2} 563-7000 ATTORNEY FOR PLAINTIFF TIlE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER I, 1997 338 SOUTH W ARMINSTER RD HATBORO,PA 19040 COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff NO, OLl - SZlf CIl>.L '- lW,. v. CUMBERLAND COUNTY EDWARD G. RIDOLFI JANICE M, RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE 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, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 File #: 86996 File #: 86996 IF THIS 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. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. L Plaintiff is THE CHASE MANHATTAN BANK, AS TRUSTEE OF lMC HOME EQUITY LOAN TRUST 1997,8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER], 1997 338 SOUTH WARMINSTER RD HATBORO, PA 19040 2, The name(s) and last known addressees) of the Defendant(s) are: EDWARD G, RIDOLFI JANICE M. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) ofthe property hereinafter described, 3, On 07/31/1997 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to DIVERSIFIED MORTGAGE SERVICES which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No, 1397, Page 143, By Assignment of Mortgage recorded 4/7/00 the mortgage was assigned to INC MORTGAGE COMPANY which Assignment is recorded in Assignment of Mortgage Book No, 641, Page 997, PLAlNTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 1 ] /0 1 /1999 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 al1 interest due thereon are col1ectible forthwith, File #: 86996 6, The following amounts are due on the mortgage: Principal Balance Interest 10101/1999 through 02/06/2004 (Per Diem $20,75) Attorney's Fees Cumulative Late Charges 07/31/1997 to 02/06/2004 Cost of Suit and Title Search Subtotal $57,666.19 32,992.50 1,250,00 1,150,10 $ 550,00 $ 93,608,79 Escrow Credit Deficit Subtotal 0,00 2,87L27 $ 2,87L27 TOTAL $ 96,480,06 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. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency, 9, This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000, 10, This action does not come under Act 91 of 1983 because the mortgage is more than twenty-four (24) months in arrears, WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 96,480.06, together with interest from 02/06/2004 at the rate of $20,75 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, FEDERMAdAND PHELAN, '1LP;/ tl By: IslFra~all~a~ FRANK FEDERMAN, ESQUIRE LAWRENCE T, PHELAN, ESQUIRE FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 86996 /1 JILL 'l'IU\T CER:rAtN p1.ec. c>r"parc.~ of ~ancl s1.Cuace :Ih loower A~~.,n TQWd.ah1.p, Cw:llbe,..~and Councy. PelUlB,.~v_1.a, PlOre part:l.cularly bounded and rlescr1.bed as follows, Co w1.c, BEGINNING at a point on the Boul:herly l:l.ne ,of Scarsdale Dr1.ve, w1Uch pc>:l.nc ~.s ~2S feet: west of the souchwest:erly corne,.. of Scarsdale Dr::f.ve and NepOJ1s1.c Lane exc:ende:d and at: t::he d1.'V1.d1.nS ~ .-I l~ne baeween Lot9 N~er 1 and 2S on th~ bere1.naft:er mentioned plan of lots; thence along che southerly 1~ne of Scarsda1e Drive, North 55 degrees 20 minutes Ease 107.51 feec to .4 po~c:~ thence in an arc havi.ng a rad:Lus of 20 feet 1.n a southeasterly direc~ion, 28.74 feee to a point on che wes~erly l~e of Nepon8~t land aforesa~dJ thence along same souch 42 degrees 20 ~nuces East. 67.51 feet to a po:tnt: at: d:l.v:lding line bet:ween Lot:.. Numb,er 1 and 2, Block "E" on .a:td planl thence along ..ame. South 47 desrees 40 minutes West 137.57 feet to a point at: d1.v:l.d:l.ng l:l.n" between.Lacs Number 1 and 25, Block liE" af'ores.a.i.d; thenc.e alonJ!; same-North 34 degrees 40 ~utes West, 102.59 fuse to a po~e. the place of BEGINNING.' . BE:tNG Lot: Number 1, Block liE" on Plan of Lots lc:11own as CaunCry and ""l"own 1:iomes.. :tnc:orpora't:ed.. wh:l.c.h p1s.n was recorded J.n the CUmber1and COUDt:y Recorder's O:f'f1..ee on"Hay 14.. 1956. i.n Plan 8()ok 7. Page 41. HAVING THEREOn ERECTED preDi1.ses known as nUlllber 32 Scar "dale DJ'1.ve. BEING THE SAMll premises wb:l.ch MAR~T I. lWLLIN and GEOlUiE C. MULLIN. her, husband.. 'by the:!.r, deed dated MAY 1.9. 1978. and recc>Tded 1.n the CUIIlberland County Recorder of Deeds Office :I.n Deed Book "V", Volume 27. Pal:e 139, g,..anted and conveyed unto WXLLtAM B. RDBI~ISON and BETTY LEE ROB:tNSON, h:Ls w1.fe. Grantor"_ BEING KNOWN AS: 32 SCARSDALE DRIVE. . VERIFICATION FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verifIcation from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unsworn falsifIcations to authorities. ~, .,;, g. lJJL. Francis S. Hallinan, tsquire Attorney for Plaintiff DATE 07{{:G I C) ,.- (::) "'<l. ;Q \ lf1 ~ .U1 " W t/1 . ~.. . -- ~ C> ~~~~ ...c:::. ~ ...0 -U -~ w ~ C0 ~ F- ~ -..() ~ ~ ~ '"" C-:;) ,= L- o 'n ,-1 ri fT~ F Q:) I'll C:J I t:) -1", , 8 I ~O -..", Coo) c:> SHERIFF'S RETURN - REGULAR CASE NO: 2004-00548 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN BANK THE VS RIDOLFI EDWARD G ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon RIDOLFI EDWARD G the DEFENDANT , at 0020:55 HOURS, on the 11th day of February, 2004 at 32 SCARSDALE DRIVE CAMP HILL, PA 17011 by handing to JANICE RIDOLFI (WIFE) a true and attested copy of NOTICE together with COMPLAINT IN MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.97 .00 10.00 .00 36.97 So Answers: rP~ I'~~.e R. Thomas Kline 02/12/2004 FEDERMAN & PHELAN Sworn and Subscribed to before By: A....d...I/VW~ --"'"<.r Deputy Sh ff me this .2 30'4\. day of d~. -"-"I 2/JrJ'I A.D. I Q~ ~~~thonotary ,~ SHERIFF'S RETURN - REGULAR CASE NO: 2004-00548 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN BANK THE VS RIDOLFI EDWARD G ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon RIDOLFI JANICE M the DEFENDANT , at 0020:55 HOURS, on the 11th day of February, 2004 at 32 SCARSDALE DRIVE CAMP HILL, PA 17011 by handing to JANICE RIDOLFI a true and attested copy of NOTICE together with COMPLAINT IN MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 r-~A~t:~2 R. Thomas Kline 02/12/2004 FEDERMAN & PHELAN Sworn and Subscribed to before BY:A~Wr~ Deputy S iff me this ..23.....( day of :J41""~/ ;l.PV '( A.D. ( ) Iv Cl !J"...;h." ~ ~othonotary ,/- / FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Ptaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SillTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 338 SOUTH W ARMINSTER ROAD HATBORO, PA 19040 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 04-548 CIVIL TERM Plaintiff, v. EDWARD G. RIDOLFI JANICE M. RIDOLFI Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against EDWARD G. RIDOLFI and JANICE M. RIDOLFI, Defendant(s) for failure to fIle an Answer to Plaintiffs 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 2/7/04-3/18/04 TOTAL $96,480.06 $850.75 $97,330.81 I hereby certify that (I) 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. ~ sili. ~ cLJU'NJ) fL, FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICAT}f' '. ---:J '- ~ DATE: ~lJr"'--_)..J.. ')..~'1 ~I(. c7(~ I PROPROTHY ~ (/'. FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ" Id, No, 12248 LAWRENCE T. PHELAN, ESQ" Id, No. 32227 FRANCIS S. HALLINAN, ESQ" Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (71,) ,61,7000 THE CHASE MANHATIAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997,8 UNDER TIlE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 Plaintiff A TIORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY Vs, : NO, 04-548 CIVIL TERM EDWARD G, RIDOLFI JANICE M. RIDOLFI Defendants FILE COpy TO: EDWARD G. RIDOLFI 32 SCARSDALE DRIVE CAMP ffiLL, PA 17011 DATE OF NOTICE: MARCH 3, 2004 THIS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT. TIllS NOTICE IS SENT TO YOU IN AN ATIEMPT 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 ATIEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITIEN APPEARANCE PERSONALLY OR BY A TIORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ" Id, No, 12248 LAWRENCE T, PHELAN, ESQ., Id. No, 32227 FRANCIS S, HALLINAN, ESQ., Id, No, 62695 ONE PENN CENTER PLAZA, SUITE 1400 ATTORNEY FOR PLAINTIFF PHILADELPHIA, PA 19103 (7.1 '\) '\61-7000 THE CHASE MANHATTAN BANK, AS mUSTEE OF : COURT OF COMMON PLEAS !MC HOME EQUITY LOAN mUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT : CML DMSION DATED AS OF DECEMBER I, 1997 Plaintiff : CUMBERLAND COUNTY Vs, : NO, 04-548 CML TERM EDWARD G, RIDOLFI JANICE M. RIDOLFI Defendants TO: JANICE M. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, PA 17011 DATE OF NOTICE: MARCH 3, 2004 TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT 1HE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSEJF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSmUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNfY CUMBERLAND COUNfY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff SHERI FF 'S RETUR ~GULAR CA3E NO: 2004-00548 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN BANK THE VS RIDOLFI EDWARD G ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon RIDOLFI EDWARD G the DEFENDANT , at 0020:55 HOURS, on the 11th day of February, 2004 at 32 SCARSDALE DRIVE CAMP HILL, PA 17011 by handing to JANICE RIDOLFI (WIFE) a true and attested copy of NOTICE together with COMPLAINT IN MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18,00 8.97 .00 10.00 .00 36.97 So Answers: -:P""""~'l"'~.~ ~-- r ~ ~ tt: ......e ;" - R. Thomas Kline 02/12"/2004 FEDERMAN & PHELAN day of BY:AApZ.! ~ Deputy Sworn and Subscribed to before me this A.D. Prothonotary SHERIFF: S RETUF JULAR CASE NO: 2004-00548 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN BANK THE VS RIDOLFI EDWARD G ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon RIDOLFI JANICE M the DEFENDANT at 0020:55 HOURS, on the 11th day of February, 2004 at 32 SCARSDALE DRIVE CAMP HILL, PA 17011 by handing to JANICE RIDOLFI a true and attested copy of NOTICE together with COMPLAINT IN MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ~ ,#Af' :/{/' , ~ . ~,~'''<'-c' R. Thomas Kline 02/12/2004 FEDERMAN & PHELAN day of By: I f (bd:, A-?<<.d, J AJ ,*' < ~. Deputy S &iff Sworn and Subscribed to before me this A.D. Prothonotary r.::J "'Is. ~~ 1- ..0 C> () ~ - fA; ...c::. ~ F ~h "\) .. --0 ...... , , ..{) D - ... lJ' ~ [, ~ K ~ " : c^.. FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SIDTE 1400 PIllLADELPIDA, PA 19103-1814 (215) 563-7000 THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQIDTY LOAN TRUST 1997-8 CUMBERLAND COUNTY UNDER THE POOLING AND SERVICING COURT OF COMMON PLEAS AGREEMENT DATED AS OF DECEMBER 1, 1997 338 SOUTH W ARMINSTER ROAD CIVIL DIVISION NO. 04-548 CIVIL TERM Plaintiff, v. EDWARD G. RIDOLFI JANICE M. RIDOLFI 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 EDWARD G. RIDOLFI is over 18 years of age and resides at, 32 SCARSDALE DRIVE, CAMP HILL, P A 17011 . (c) that defendant JANICE M. RIDOLFI is over 18 years of age, and resides at, 32 SCARSDALE DRIVE, CAMP HILL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsifIcation to authorities. ~ D N k. ~o-dJ ),.)"'('1. ~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff f-' (j., Request for Military Status Page 1 of 1 Department of Defense Manpower Data Center MAR-I 8-2004 09:49:21 .. Military Status Report .. Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940 <:Last Name First Middle Begin Date I Active Duty Status I Service/Agency RIDOLFI Currently not on Active Military Duty, based on the Social Security Number and last name provided. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the Defendant( s), per the Information provided, as to all branches of the Military. ~( Kenneth C. Scheflen, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlin~on, VA The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the offIcial source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please send an e-mail tosscra.helpdesk@osd.pentagon.mil. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https://www.dmdc.osd.miVudpdri/owalsscra.prc_Select 3/1812004 Request for Military Status Page 1 of 1 Department of Defense Manpower Data Center MAR-l 8-2004 09:49:38 .. Military Status Report .. Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940 <Last Name First Middle Begin Date I Active Duty Status I Service/Agency RIDOLFI Currently not on Active Military Duty, based on the Social Security Number and last name provided, Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the Defendant(s), per the Information provided, as to all branches of the Military. P( Kenneth C. Scheflen, Director Department of Defense - Manpower Data Center . 1600 Wilson Blvd., Suite 400 Arlington, VA The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Emollment and Eligibility Reporting System (DEERS) database which is the offIcial source of data on eligibility for military medical care and other eligibility systems. Uyou have information that makes you feel that the DMDC response is not correct, please send an e-mail tosscra.helpdesk@osd.pentagon.mil. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https://www.dmdc.osd.mil/udpdri/owalsscra.prc_Select 3/18/2004 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 THE CHASE MANHATTAN BANK, AS TRUSTEE OF!MC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 Plaintiff, No. 04-548 CML TERM v. EDWARD G. RIDOLFI JANIC}) M. RIDOLFI Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $97,330.81 Interest from 3/19/04 to SEPTEMBER 8, 2004 (per diem -$16.00) $2,784.00 and Costs TOTAL $100,114.81 ~~~ftne, FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. .... .... .... .... 00 .... .... .... .... << ~~ ~J ...l...l .... .... == ~~ r;..;:$ ~~r;.. Z :;:; 0 << OZ 00 ~o .... uu oo~ <8,,~ ... ~~ o;J 't:i <...l :i~z~ U " r..l;>< ;:;: t: ~oo ~ ....r..l ~s: ~'F ::::: ~~ " ~sg~~ "'S '" zZ ...l...l r.il = r..lr.il " '" OZ 00 r;.. 0 .~ .D ~S'~~~ ~ ~~ ~~ ~~ 0'13 ~ >, ~ ~ ... ~ r..l'" . ;:;: ... ~~ s ... .. .. =z.... ;:~ ..s ~~ o~ !Un ,.; c. '" >, .. .. ~~ ~~ " uz a g. r;..o;J ~:., UU P- 00 .8 0000 01:: < " u ~.... ... ... ~ ;~ r;.. 0 ,., ,., r..lr;..cc<1:l ~~ r..l6 ~ o;J~ ~Or!-" r..l'" ~ '" 8~ .... '" =r..l~~ U {J 1 Ur..l....u ~ -d r..l>oJ r..l.......... ,.!,l ~ =~ .~ ...:; =~oo~ ~ ~ Zo;J ...~~>oJ ....u ......00 Ji C::) ;..:J 1 ~. .~ :--'J ( <:',..: ~ 1 c~: - - w ~ , .'-- , , , _..- - c~::-' ~J '-.<J CI t8~ d) ('...,. , :: :: :: 0- ~ , ~ - - ~ () a 0 'J 0 () Q \) "'> ~ t" t'- () L, ...... 0 0': 0 ~ 0 t.) 0- . ~ ~ t.i t4 . . . ~ bJ..' .... ..J ...,0..')' ::r- -t;;. 1'1) -- J~ Q ~ .._-,,--,._,~"",_._". ALL TItA T CERTAIN piece or parcel of land silUare in Lower Allen ToW1lShip. Cumberland County. PennsylvaoJa, more partlcularly bounded and described as follows, to wit: BEGINNING 1Il a point 011 die Soudlerly line of Scmclale Drive, which point is 12.5 feel West of llIc Southwesterly comer of Scmdale Drive and Nepoll5it Lane extcmded and at the dividing line between LoIs Nwnber 1 and 2.5 on the hc:rcinafter mentioru:d Plan of Lots; ~ alon; the Southerly line of ScarIIdale Drive, North 55 degrees :ro mllllltes East 101,51 feet to a poinl; tbence In an arc having a raaius of 20 fee( in a SoIItbc:asu:rly dirol.1ion. 28.14 feet lU a polnl on the Wcmrly 1lnc ofNcpoll5illand aforesaid; then,;:e along same SOUlIl 42 degteee 20 minutes Eul. 67." feel 10 a point at djYl(!ltlg line belweea Lots N\II1lber I and 2. Block "Eo on said plan, tllenl:e aIoog same. SOOth 47 degrees 40 minutes w...t 131.57 feet to a [XJinl at dividing line blllweeo 1018 Number I and 25, Block 'Ii" aforeseld; !benee alq same North 34 dl!grees 4() minutes West, 102.59 feet 10 a point, llIc p1llce of beginning. BEING Lot Number 1, Block "EO 0lI Piau of lois lalown as COVlIIty and Town Homes, .!llc()l'pQl"aled. which plan was recorded 1n the Cumberland County Recorder's OffICe 011 May 14, 1956, in Plan Book 7, Page 41. HA VING thereon erecled pIllIlIlses known as number 32 Scarsdale Drive, TITLE TO SAID PREMISES IS VESTBD IN Bdward G. Ridolfi and Janice M. Ridol/l, his with by Deed from Wllliam B. Robinson and Beuy Lee Robinson, bls wife dated 111011987 and m;orded 7fJ3/l987 in RetOld Boole u-n, Page 376. Tax Pareel/13-2S-0022-125 WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 04-548 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-81JNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997, Plaintiff (s) From EDWARD G. RIDOLFI AND JANICE M. RIDOLF1 (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or othelWise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $97,330.81 L.L. $.50 Interest FROM 3/19/04 TO 9/8/04 (PER DIEM - $16.00) - $2,784.00 AND COSTS Arty's Comm % Due Prothy $1.00 Atty Paid $134.97 PlaintitTPaid Date: MARCH 22, 2004 Other Costs (Seal) CURTIS R. LONG Prothonotary n 7n. By: ~ n..,. L- t' . , "L(Y}./J,<YJ"""' Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court JD No, 12248 FEDE~ANandPHELAN,LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF THE CHASE MANHATTAN BANK, AS TRUSTEE OF!MC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1,1997 CUMBERLAND COUNTY COURT OF COMMON PLEAS CML DMSION Plaintiff, v. NO. 04-548 CML TERM EDWARD G. RIDOLFI JANICE M. RIDOLFI 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: () 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. . ~J'l~.J~. dill N'L~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04-548 CIVIL TERM EDWARD G. RIDOLFI JANICE M. RIDOLFI Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) THE CHASE MANHATTAN BANK. AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1,1997, 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, 32 SCARSDALE DRIVE. CAMP HILL. P A 17011. 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) EDWARD G. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 JANICE M. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 2. Name and address ofDefendant(s) in the judgment: Same as above 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) SECCO IN. 1111 PRIMROSE AVENUE CAMP HILL, P A 17011 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) None 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) LOWER ALLEN TOWNSHIP AUTHORITY 120 LIMEILN ROAD NEW CUMBERLAND, P A 17070 LOWER ALLEN TOWNSHIP 1993 HUMMEL AVENUE CAMP HILL, P A 17011 7. Nam6 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 32 SCARSDALE DRIVE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 1 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. March 18. 2004 DATE '" ..rf..--- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff .......... c_ THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 Plaintiff, CUMBERLAND COUNTY No. 04-548 CIVIL TERM v. EDWARD G. RIDOLFI JANICE M. RIDOLFI Defendant(s). March 18, 2004 TO: EDWARD G. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 JANICE M. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION 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, 32 SCARSDALE DRIVE. CAMP HILL. PA 17011. is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 8. 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of$97.330.81 obtained by THE CHASE MANHATTAN BANK., AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1.1997 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 ifthe bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390. 4. rfthe 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 ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 ALL mAT CERTAIN piece or parcel of land situate In Lower Allen ToWll!bip. Cumberlaml County. Pennsylvlltlia, more partlcularly boondoo ami described as follows, co wi!: BEGINNING at a polllt on lIle SOUlberly line of scmdaIe Drive. which pGiJU is 12.5 feel West of lbe Southweat<<ly """",r of Scarodale Drive ami Neponsit Lane extended and at the dividing line b,tw""n LoIs Number 1 and 2.5 on tile 1u:reinaI't<< mclllloocd Plan of Lw; tbence alolli the SOutherly line of Scarsdale Drive, Nortb " degrees W minutes East 107.'1 feet co a point; dtenee In an arc having a millS of ZO feet In a SOutbeasterly direction. 28.74 fed co a point on the WCSlc:rly Ii.ae ofNepcIII5illand aforesaid; thence along $iII11C SO\Illl 42 degrees 20 mlnulCS Easl, 67..:11 feet 10 a point at divklll\i line between LoIs Nwnber I and 2, Bloct "E' on said plan: theoce along same. South 47 degrees 40 minutes West 137.57 feet co a point at dividing line betweco lolli Nwnber I and 25. Block "E" aforesaid; dleoce along _ Nom 34 degrees 40 millUles West. 102.'9 feel to a POilU. lbe place of beginning. BEING L<< Number 1. Block "E" on PIaII of loIS known as COWllI'y ami Town Homes. 1tIcocporllled. which plan Will< mcordcd in the Cumberland County Reconler'. OffICe on May 14, 1956, in Plan Book 7, PaS' 41. HAVING thereon erecfed prennses knoWIl as number 32 Scarsdale Drive, TITLE TO SAID PREMISES IS VESTED IN Edward G. Ridolfi llDd Janice M. Ridoll1, his wife by Deed from William B. Robinson and Beny Lee Robinson, his wife dated 7/1011987 and reo;:orded 7/13/1987 in Re.:ord Book" U-32. Page 376, TlL' Parcel #13-25-0022-125 .~ (,.- 1..-'. AFFIDAVIT OF SERVICE , THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 EDWARD G. RIDOLFI JANICE M. RIDOLFI CUMBERLAND COUNTY PIT PLAlNTJI;.1f No. 04-548 CIVIL TERM ;,CCT.#3013357698 .' DEFENDANT(S) Type of Action - Notice of Sheriff's Sale SERVE EDWARD G. RIDOLFI AT 32 SCARSDALE DRIVE CAMP ffiLL, PA 17011 Sale Date: SEPTEMBER 8, 2004 SERVED Served and made known to Edward G. Ridolfi ,Defendanl,onth" 27th dayof March ,200_~ at8:23 . a 32 Scarsdale Drive, Camp Hill, PA 17011 , o'clock _,m., at , Commonwealth of Pennsylvania, In the manner described below: x Defendant personally served, Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Glerk ofptace oflodging in which Defendant(s) reside(s), Agent or person in charge ofDefendant(s)'s office or usual place of business, an officer of said Defendant(s)'s company, Other: Description: Age45-50 , h 6' 3" Helgt_ Weight 21 0 Race ~ S"x M Other I, Daniel P. Ryan . a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated aboveO"..---_, l: Notarial Seal \ . Wendy M. Livingston, Notary Public Sworn to and su}scrj:ged Susquehanna Twp., Dauphin County before this ii.!zI!j day My Commission Expires Oct. 24, 2005 of ,200t. ,->rnl:->'if,FennsylvaniaAsSOciati 01Not?"ip~,; Notary: By: ~~!l,; TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of .200_, at Moved Unknown No Answer 15t Attempt: 1 1 Time: 3rd Attempt: 1 1 Time: o'clock _.m, Delendant NOT FOUND because: Vacant 2nd Attempt: 1 1 Time: Sworn to and subscribed before me this _ day of ,200_, Notary: By: Attornev for Plaintiff Frank Federman, Esquire - 1.0. No. 12248 AFFIDAVIT OF SERVICE , CUMBERLAND COUNTY THE CHASE MANHAlTAN BANK, AS PIT TRUSTEE OF IMC HOME EQUITY LOAN No. 04-548 CIVIL TERM TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED ACCT. #3013357698 AS OF DECEMBER 1, 1997 . PLAINTIFF DEFENDANT(S) EDWARD G. RIDOLFI JANICE M. RIDOLFI Type of Action 0, Notice of Sheriff's Sale SERVE JANICE M. RIDOLFI AT 32 SCARSDALE DRIVE CAMP HILL, PA 17011 Sale Date: SEPTEMBER 8, 2004 SERVED Served and made known to Janice M. Ridolfi ,Defendant,onthe 27th dayof March ,200~at 8:23 ,o'clock~,m,at 32 Scarsdale Drive, Camp Hill, PA 17011 , Commonwealth oft'ennsylvania, in the manner described below: Defendant personally served, X Adult family member with whom Defendant(s) reside(s). Relationship is spouse Adult in charge ofDefendant(s)'s residence who refused to give name or rel"tionship, Manager/Clerk of place oflodging in which Defendant(s) reside(s), Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company, Other: Description: Age 45 - 5 0 Height 6 I 3" Weight 21 0 Race ~ S"x MOther I, Daniel P. Ryan . a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date a s m ca e a ove. . olana S~ J Sworn to and S;f~bed Wendy M. Livingston. Notary_ Public hefo me this day Susquehanna 1\vp., Dauphin County ~ of 200~. y Commission Expires Oct. '24, 2005 Notary: ennsylval'io/.'ssoc Ie ( ERVICE AT LEAST 3 T S. ~ DATE.I & TIMES OF SERVICE AITEMPTED. NOT SERVED On the day of .200-, at o'clock _.m, Defendant NOT FOUND because: Moved Unknown No Answer V.cant '. 1 st Attempt: 1 1 Time: 2nd Attempt: 1 1 Time: 3rd Attempt: 1 1 Time: Sworn to and subscribed before me this _ day of .200_. Notary: By: Attornev for Plaintiff Frank Federman, Esquire - 1.0. No. 12248 .. (') ..., c = 0 = <:' .t:" -n ~?, ~'~~' L.. :i! ;:-;: c:: z rn~ C;I -om ::::~ CT\ :::00 _:- 86 , ~... ~:~~~ '"'0 ::c -r" ::x o~ 2" '- N om -",... ~ .. s~! U1 CD :- -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA THE CHASE MANHATTAN BANK, AS ) CIVIL ACTION TRUSTEE OF IMC HOME EQUITY ) LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1,1997 vs. EDWARD G. RIDOLFI JANICE M. RIDOLFI ) CIVIL DIVISION ) NO. 04-548 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for THE CHASE MANHATTAN BANK. AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1.1997 hereby verify that on MARCH 23. 2004 true and correct copies of the Notice of Sheriffs sale were served by certifIcate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: August 13.2004 ~&PN~~S~~ Attorney for Plaintiff t"' "'o-j tv - 5 ~'E - w - ::; '0 00 -.l 0, V. ... VI " " z v. ... tv - :;~ )>- [Ii to" ;:l. ~g, (;. W co " ~ ~ Z " 3 e- m ., t"' t"' CIl >-l () t:I z . "'0' ~ ~ 0 trj ~ 0 0 a ~E: ~ R I ~ . g, ~'z g 0 ,. ~~ CIl ~ ~ ~ :::j ~ .,,~ ~ ~ ~ 2 ~g, 0 () ~ . 0." P ~ t"' () ~ f'g ~~. trj - ~ ~ ~ Z - ~ ~ . " - . j >-l - 5:J r' 0 0 ." ~ ~ . t"' ~ i ~ il. :!1 ." . CIl ! CIl VI ." ij .ij tv ~ 0 0 CIl CIl ." ill trj () ~ . )> - ~ CIl ,. "'." ~ '0 )> ~ .. iI ~ .. '0 j ! og VI i t:I j h .~ ~ ~ ." ~ 1 ~ ~ t:I N ~ 0 0 )> () ~ .~ .~ '" t"' ~ . 8 ! () g ~ ~ ., ." ~ )> ~ ~ - w .~ - -.l ~ Z ~~UgJ := .t"' 0 ~~l~~ ~ - ." ; I'" )> 5:J ~ 8"~~ , ~ - ~~ PJ.g ~ -.l ~ &j.[a.; 0 ." Ul 0" g g. ~ )> - ~ ..., 0 :::l 0 - ~....,o - S'8:gg<, -.l ." tii ... <II .5 III 0 0 ~g b~ 8' - I'" Ei~' 801;;' .~ - to 0 CIl g.] ~ ~d ~ 1 ~';igH o ~ n CIl tv ~.~ ." 0, 8 <;l" ~ g t"' -.l .>-l v. ~ Ie ~ :::l !!. ~ . ~ .u,~u; ~ ~ ~ . g. 5 ~ - 8'p" -.l @ . tl'l g. 0 - . . -.l CIl CIl ~.~] 8- 0 to J;; It 3 ~ S. .~ [[:;::ft ." g~H )> - :-~'g ~ ~ -.l ~." ~ - := ". . !.''''<i{~ ~ iLti 5-ng8 .gga&. II .",~"" "f i (' ~ 2\ilV ~ g. =. a~ I ~I', "../ ", '< . /:2 ((/ {Y""'_ ~ " 0 5 :<:". t 'Z"\'~-~'''7" " ~ Ii .1 I I';:l . """, n ~ " ''''I@';~ : gEl" . 02 iA . . ~ n ~ '''~"':l, ~ 7 . [. .' ~~jl~~DU ~'R~ ' " ~ o ~ ~ j;'.g; ~.liig~. ~H$ LW1 ~~~~ ~1;;'"8.~ [ ~~ 0>:': ....Q... CIlQ.8 '" ., '" = ~ j:,) Q.~= ~ Q. '"O-0'T1 """':3'tT1 =':-('\'10' 0>"'"OtT1 o..~(b~ " 0 '" oS S::> ~;r1\l~ ~~~~ -So> 'O"'~ -o..Cfj~ 8'< g.:Ii 'toE;tT1 ~g (j'"~~ :O:i'Dg <: "'!!l "'- "","lOr< ;t" 0-. l" ., 0 '"0 '"''''::> . " >-l -, ;l " .g ... " 0 ., 0 ~ ~ ~~~~~ ~~~ ~ ~IlN~'~ 80WICs $ 01.800 il.,lAR 23 2004 M ZIP CODE 1 ~ 03 - '" ",,"_'71 c:.~::' c:::> "'- 0'\ -G ~.."., -." (1? r....) r.....,) The Chase Manhattan Bank, as Trustee OfIMC Home Equity Loan Trust et al VS Edward G. Ridolfi and Janice M. RidolfI In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-548 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Frank Federman. Sheriff's Costs: Docketing Poundage Posting Handbills Advertising Law Library Prothonotary Levy Mileage Surcharge Law Journal Patriot News Share of Bills 30.00 15.66 15.00 15.00 .50 1.00 15.00 20.02 30,00 316.55 309.43 30.49 $798.65 Sworn and subscribed to before me This,jM.. day of J~L- 2004, A.D. ~h () Ind.b'J,~' Prothonotary So Answers: r~~..t:~-u R. Thomas Kline, Sheriff BY \loriv.sm.iJ:.h R;al~ Es~e Deputy ~:)O ), C:./1-y,vJo' Ru... / >'cr'bl?c .' THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04-548 CIVIL TERM EDWARD G. RIDOLFI JANICE M. RIDOLFI Defendant(s). AFFIDA VlT PURSUANT TO RULE 3129 (Affidavit No.1) THE CHASE MANHATTAN BANK. AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1.1997. 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. 32 SCARSDALE DRIVE. CAMP HILL. P A 17011. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) EDWARD G. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 JANICE M. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL. P A 17011 2. Name and address ofDefendant(s) in the judgment: Same as above 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) SECCO IN. 1111 PRIMROSE AVENUE CAMP HILL, P A 17011 4. Name and address oflast recorded ljolder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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) LOWER ALLEN TOWNSHIP AUTHORITY 120 LIMEILN ROAD NEW CUMBERLAND, P A 17070 LOWER ALLEN TOWNSHIP 1993 HUMMEL AVENUE CAMP HILL, PA 17011 7. Nam~ 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 32 SCARSDALE DRIVE CAMP HILL, P A 17011 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 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. March 18, 2004 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 Plaintiff, CUMBERLAND COUNTY No. 04-548 CIVIL TERM v. EDWARD G. RIDOLFI JANICE M. RIDOLFI Defendant(s). , March 18,2004 TO: EDWARD G. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 JANICE M. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 "THIS FIRM IS A DEBT COLLECTOR A1TEMPTING TO COLLECT A DEBT AND ANY INFORMATION 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 A1TEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at, 32 SCARSDALE DRIVE, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 8. 2004 at 10:00 a,m, in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $97,330.81 obtained by THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 ari 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. L 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, P A 17013 (717) 249-3166 (800) 990-9108 ALL 11IATCERTAIN' piece or parcel Oflaodsilua!& In Lower Allen ToWllSbip, Cumberlaod County. I'J:nnaylyallJa. DlOre pardcWarly lloUndE.dlmd descrlbed as folloW$. to Wil: B.WINNI.NO . a polm 0II1Ile SoulIlerly lllle of Seandale Drive, which point .IS 12$ feel WeSt of \be Southwesterly ....-. of Scmda1e Dri"" aod NlIJlOosit Lane exllllHhldand al tlIIl dividing line between Lots N\lJllbea' f and 2$ on lbelilln:inldlllc mcmtioned Plan of Ldtll; 1DeIlce alone the Soothed)' liDe of SIlanIdllle Drive. North .5, ~grees~mllmtes Il8&t 107..51 f~1O a point; 1bebce.1lIanllIC having a ndius of20feet in a~IY.dircl;tioll.,Z8.74 tectto a JlOiIII 011 tbti W_rly IiDCOfNqlClasilland aforesaid; tllcneo alOIIIIllII'IlC .SOIlIt\4ZileiR* 2() mlllUTCS EUl.67;'1 feel to apOlm: at dtvIdJl'IIlilJe belween Locs Num~ I and.' 2. S1~t<"E. all said plan: thence along SIIII1e. SOUtll 47 depees. 40 mmuteo WlISt 137.57 feet 10 a 1J!lil!t. at dividiDlIioe. b~LoI8 NlIDIllel- 1 and 25. 8fuck. ~E' afor~d; tWocu.lOng _ NCltth 34 (Je8rees 40 mllllllt8 West, 102.'9 feef to . point, !be.. pblCe of begillniDg. BBlNG Lo( l'lvIlIbet 1. Block "E" OlIPIaD of l.()ts!alo'lYll as Covnlry andTOWI1 Homes. b1corporaled, wbich plan WlI8 recorded in the CunibedlUlll County RllCOl"der'. Off""""" MlI)' 14, 1956, in Plan Book " Page 41. HAVING thereon etecIed. premises known as IIIUl1ber 32 Scarsdale Drive. TITLE to SAID PJlRdlSES IS VESTED IN Ildward G. Ridolfi ud Juice M. Rldolll, hb wife by Deal from \ViIllilm B. RObins(jn and )Jelly Lee RobInsoo, his wife dated 1110{1987 and tecorded 7{1(311987 in ReCord Boolt u.n,!'. 3%. Tax Parcel #13-25-0022-125 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-548 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997, Plaintiff (s) From EDWARD G. RIDOLFI AND JANICE M. RIDOLFI (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirnlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $97,330.81 LL $.50 Interest FROM 3/19/04 TO 9/8/04 (PER DIEM - $16.00) - $2,784.00 AND COSTS Atty's Cormn % Due Prothy $1.00 Atty Paid $134.97 Other Costs Plaintiff Paid Date: MARCH 22, 2004 CURTIS R. LONG (Seal) Prothono", n ~ '-- Bv: .IC4 ~ I . ~' , C/l..I1/J ~ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Real Estate Sale #17 On May 17, 2004 the sheriffIevied upon the defendant's interest in the real property situated in Lower AIlen Township, Cumberland County, P A Known and numbered as 32 Scarsdale Drive, Camp HiIl, more fuIly described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 17, 2004 By: JbcU)j~ Real Estle Deputy ~.. ~ ~ ~ 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. Lisa Marie Coyne, Esquire, Editor ofthe Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2,1952, and designated by the local courts as the offIcial legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JULY 16,23,30,2004 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. 17 Writ No, 2004,548 elvll The Chase Manhattan Bank. as Trustee of IMC Home Equity Loan Trust 1997-8 Under the Pooling and Servicing Agreement Dated as of December 1, 1997 vs, Edward G. Ridolfi and Janice M, Ridolfi Atty.: Frank Federman ALL THAT CERTAIN piece or par- cel of land situate in Lower Allen Township, Cumberland County. Pennsylvania, more particularly bounded and described as follows. to wit: BEGINNING at a point on the Southerly line of Scarsdale Drive. which point is 125 feet West of the Southwesterly comer of Scarsdale Drive and Neponsit Lane extended and at the dividing line between Lots N1ITI'\hPr 1 Ann ?fi nn thp hf'rptn~f~,,>., ~~Coq,-;;;, SWORN TO AND SUBSCRIBED before me this 3'0 day of JULY 2004 ~-{~) i hdh?j NOfu\~ YsEAL if LOIS E, SNYDER, Notary Public CaMisle Bora, CumbeMand County My Commission Expires March 5, 2005 eel of land situate in Lower i\Jte'lI Township, Cumberland County, Pennsylvania. more particularly bounded and described as follows. to wit: BEGINNING at a point on the Southerly line of Scarsdale Drive, which point is 125 feet West of the Southwesterly corner of Scarsdale Drive and Neponsit Lane extended and at the dividing Hne between Lots Number 1 and 25 on the hereinaf- ter mentioned Plan of Lots: thence along the Southerly line of Scarsdale Drive, North 55 degrees 20 minutes East 107,51 feet to a point; thence in an arc having a radius of 20 feet in a Southeasterly direction. 28.74 feet to a point on the Westerly l1ne of NeponsU land aforesaid: thence along same South 42 degrees 20 minutes East. 67,51 feet to a point at dividing line between Lots Num~ ber 1 and 2. Block "E" on said plan; thence along same. South 47 de- grees 40 minutes West 137,57 feet to a point at dividing line between Lots Number 1 and 25. Block "En aforesaid; thence along same North 34 degrees 40 minutes West. 102.59 feet to a point. the place of beginning: BEING Lot Number I, Block "E" on Plan of Lots known as Country and Town Homes, Incorporated, which plan was recorded in the Cumberland County Recorder's Of- fice on May 14. 1956, in Plan Book 7, Page 41. HAVING thereon erected prem- ises known as number 32 Scarsdale DrIve. TITLE TO SAID PREMISES, IS VESTED IN Edward G, Ridolfi and JanIce M. Ridolfi, hIs wIfe by Deed from William B. Robinson and Betty Lee Robinson. his wIfe dated 7(101 1987 and recorded 7(13/1987 in Record Book U,32, Page 376, Tax Parcel # 13-25-0022,125, fi Carlisle, I My Commi! ........- - THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No, 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Danphin} ss Joseph A. Dennison, 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/ Metro editions which appeared on the 27th day(s) of July and the 3rd and lOth day(s) of August 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317, PUBLICATION COPY SALE#17 Sworn to and SCribedbeforeZ) , rddaYOf~Ug~O ,D. \ NOTARIAL SEAl ~/. ~ Terry L Russell, Notary b Oly of Harrisburg, Oouphln U"~ My Commission Expires June 6. 2QQ@> PUBLIC Member,Penn.ylv.nlaA.socI4\ll1'tllil'llti:l88ion expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO, For publishing the notice or publication attached hereto on the above stated dates 309.43 Publisher's Receipt for Advertising Cost The Patriot News Co" publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid, By""""."""".""",,,,,,,,,,,.,,,,,,,,,,,,,,,,,,,,,,,,,,,,,.,, ,\1 'iP. . AFFIDAVIT OF SERVICE PLAINTIFF THE CHASE MANHA'IT AN BANK, AS TRUSTEE ET. AL, CUMBERLAND COUNTY PJT No, 04-548 CIVIL TERM --- DEFENDANT(S) EDWARD G. RIDOLFI JANICE M. RIDOLFI AC:CT, #3013357698 SERVE EDWARD G, RIDOLFI AT 32 SCARSDALE DRIVE CAMP lULL, PA 17011 Type of Action - Notice of Sheriff's Sale Salle Date: MARCH 2, 2005 SfRVED Served and made known to ftw ~v cf.. Q. f(~ ~ \~, Defendant, on the _ J ~ ~ day of at 7,'ptO' ,o'clock~.m.,at 3.;2.., CSC(yV"5 ~l~ 'Ov.) Q;;~V'o<\ 17\" ~\ of Pennsylvania, in the manner described below: ~}~, ,200_'-1- . Conunonwealth Defendant personally" served. . Y- Adult family member with whom Defendant(s) reside(s). Name and Relationship is W I <f.l( d I Adult in charge of Defendant(s)'s residence who refused to give name or relationship. ~ y...$, '- ~ A. f..\ 0 \& ~ Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: ~,........,' II( C Description: Age ~ . Height "5 (; Weight ~ Race W'^ Sex -L-- Other I, ~c:......~"-- L... Q'(t.t-y, ~mpetent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed befuethiS~daY ~ of '.J.t..vwtbM..'l-00.!j.~ NOtary~ By: PLEASE ATTEMPT SERVIC T LEAST 3 TIMES. INDICATE DATE NOTARIAL SEAL LUCILlE H, CARrY, Notary PubIc Townstl , FranIdin ColI1ty My ~ Ex! 10,2007 S OF SERVICE ATTEMPTED. NOT SERVED On the day of , 200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1st Attempt: / / Time: 20d Attempt: / / Time: 3rd Attempt: / I Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire -I.D. No. 62205 (") ~ ~ c c;::::l ~ ~ .-\ CJ -ow f'11 ~:!J rnn-' ("'") 11r- z: '1"', -om tIS: N ::!:)O ~ ~~ C1J oS? ~c' 9' ?Zc -0 a:D 3 -",(") .~.-C) N Ofn J;> c- -'-l Z ?O :t J,:"" 0) :-< AFFIDAVIT OF SERVICE ~ PLAINTIFF CUMBERLAND COUNTY THE CHASE MANHATTAN BANK, AS TRUSTEE ET. AL, PITT Nt), 04-548 CIVIL TERM DEFENDANT(S) EDWARD G. RIDOLFI JANICE M. RIDOLFI ACCT. #3013357698 SERVE JANICE M, RIDOLFI AT 32 SCARSDALE DRIVE CAMP IllLL, PA 17011 T:~pe of Action - Notice of Sheriff's Sale Sule Date: MARCH 2, 2005 SERVED Served and made known to :Ja:tJ( C'~ M, 1C ~ ~l:l \~;. Defendant, on the , 2004' at 7.';).0 ,o'clock-t-.m.,at ~a... 5c..V"~ ~l:r\.~ 0",.) , Commonwealth of Pennsylvania, in the manner described below: ~ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and 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 of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. ~~ J e;... day of 't:> ~ c. . Co;. ~(' ~--\ ~ l \.. Other: Description: Age .:3;- Height ; A G f( Weight (e CRace tJ ~ Sex L Other I,c:\'CJU' ~ f-'~~ L, ('''a-vJ.!t;~ ~ompetent adult, being duly sworn according 10 law, depose and state that I personally handed a true and corr t copy of the Notice ofShenff's Sal m the manner as set forth here issued m the captioned case on the date and at the address indicated above. NOTIRlALSEAL LUCIU.E H, C~, NaIIry PubIc Tow , FrankIn County My ~. Nov. 10, D1I Sworn to and subscribed be~methis~daY ~ of ~~200.!:i..~ Il Notary: ~ By: f/ . _ PLEASE ATTEMPT SERVIC AT LEAST 3 TIMES. INDICATE DA ATTEMPTED. NOT SERVED On the day of ,200_, at o'clock _.m., Ddendant NOT FOUND because: Moved Unknown No Answer Vacant 1 st Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire - 1.0. No. 62205 g s: '"'T1 tJ,;',l tT\G'.' Z'')} 21.;. (/) ;: ;~ ':'<'~C'~' ':2- )"> C~ ::':0 :PC Z :.2 .. ..." = = J::" o rrI ("") N (Xl ~ ~1:D -oM; -::a 0 'OT '0 ~::H 6- >"'Q :"". r" S -r;JJI' ~l -0 ~ ~ .r::- CP IN THE COURT OF COMMON PLEAS OF CUMBERLAN][) COUNTY, PENNSYLVANIA THE CHASE MANHATTAN BANK, AS ) CIVIL ACTION TRUSTEE OF !MC HOME EQUITY ) LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 vs, EDWARD G. RIDOLFI JANICEM, RIDOLFI ) CIVIL DIVISION ) NO. 04-548 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for THE CHASE MANHATTAN BANK. AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 hereby verify that on 12/3/04 & 1/21/05 true and COD:ect copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto, DATE: January 25.2005 1)?K\OQQ~1 D NIEL G. SCHMIEG, ESQU Attorney for Plaintiff THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 CmtlBERLANDCOUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO" 04-548 CIVIL TERM EDWARD G. RIDOLFI JANICE M. RIDOLFI Defendant(s). AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, 1) THE CHASE MANHATTAN BANK. AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1. 1997, Plaintiff in the above action, by its attomey, DANIEL G. SCHMIEG, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information conceming the real property located at,32 SCARSDALE DRIVE, CAMP HILL, PA 17011. L Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably asceliained, please indicate) EDWARD G. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 JANICE M. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL., P A 17011 2, Name and address of Defendant(s) in the judgment: Same as above 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 aSI~ertained, please indicate) IMC MORTGAGE COMPANY 5901 EAST lrOWLER AVENUE TAMPA FL 33617 SECCO INC. 1111 PRIMROSE AVENUE CAMP HILl., P A 17011 4, Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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) LOWER ALLEN TOWNSHIP AUTHORITY 120 LIMEIL:~ ROAD NEW CUMBERLAND, PA 17070 LOWER ALLEN TOWNSHIP 1993 HUMMEL AVENUE CAMP HILL,. PA 17011 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 asc,~rtained, please indicate) Tenant/Occupant 32 SCARSDALE DRIVE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 1'7013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 171 05 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, January 21. 2005 DATE ~I\\OoJ p,~~l\\ o~ IEL G. SCHMIEG, ESQ Attorney for Plaintiff ",,,, n ;;. "; -c:. ;:; -;::; '0 ~s "'~ ~9., 'fI ~ ~ ~~ ~ p ~ U~ %9.- ~~ P ~m ~ ~ ,... ~~ i\ '" ~ 'Z ~ g % ~. ~~~xi! ? ~?; \ 0: ~~ $ - l!d ~ ~ r inl~ Vla.-..,. \:;T. ;e% g.,o g _ tt\'......o !n.~ i _.~ "" Ii a.~.6~ .... >s<<"o....'" ,;.-a ~ t:'<t .~ ~ ..'%. s.~~ii ~::.~ \ g s 1;;.' ~~ og-sll\~ g~ [l:l'et. Hll %.B~~ a ~~~ ....g c." 0 ,..O!'~ ~"'~~ ~1O~(l .~;l.'" i}"~~ ,gg,,,, t"'H ihit \U~ ,~.... ~~\H 'iI :;.,; % ...... po. nil ~~ 8~ ~~l~ '€ <i,,-d.~ <=. ~ '0' e.. <'... '" QO --l '" OJ' ". '" '" ,... r ~' ~ g,~~ w~~ So ~ ~ l!\ Coo ~ '[ .. z " 3 a .. ~ >'d.-"O>'rl 9"~"1Z'. S5'-1~v ~~~rr1t -trg-9 ~>'rl(i J' . g ~i~~ '\Oo~o 8~ t. ~ ~tg",1Z'. 00 " 0' ' ~~~~ ~e', </1" ~ ?- ~. F- ~ Q~ ...</1'" ~~. .. '" .. .-" .%~ ~g r r ..-\ () c:l 'Z oo\Qoo~ ~~~t~\ ~~g~~j ~~~r.~~ ~~~~ll <p<p",,,,,<P~ ~~~~Q,~ ~~~~%\ ~\~~\ ~';~%8 ~ \'~ \ ~ ~.() '!l.... ~~~Q,~ ~~~~~ ~~~'e;:: ;,: '"" ~ ~ ~ 8 ~ . 0 ~ ~ '8 ~ ~... ~ Vi r ';< ..-\ ~ \t m Cl '-l ..-\ .~ H o r/l r!- \!? t" A"''i5 FOSr",,~ 0' ~6- . ~ 14. ~'jF-~~ . z ~~ .? !A./ _,,,,,,,,~i$'-"-'!f{' c-: ,_ $ 01.500 _,'~43Y'Y1L~~~r:. 20C4 ;,i;\\EDf~~:~' -'0 ,\ .~) . g ~ ~ z o t~ ~Q.'i ~ ~ ~ ~~;:: ~ Qo l o~ ~"''; :=;. (!) r- ~~'J>o ~~"2.. "''''~ S".(l _ ~~~ ~...~ )o-~2 ,....~> ~w.'2. e.g.ge ~fP .,~ :' ~ ~.~ <,Cl ... .. .:0 .:0 ~;:; .";.-;:> c.,n :j () -n <-- ~: N -J -.'~ r:-? - c;,"; - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which IMC Home Equity Loan Trust 1997-8 Tr is the grantee the same having been sold to said grantee on the 2nd day of March AD., 2005, under and by virtue of a writ Execution issued on the 1 st day of Dec, AD., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2004 Number 548, at the suit oflmc Home Equity Loan Trust 1997-8 Tr against Edward G Ridolfi & Janice M is duly recorded in Sheriffs Deed Book No, 269, Page 3887. IN TESTIMONY WHEREOF, I have hereunto set my hand 7-11:- day of , AD. dtJfJo- rder of Deeds 01 CauriIy, -. "" """"1hI firIllolondlr oI.....1IlDI My The Chase Manhattan Bank, as Trustee OfIMC Home Equity Loan Trust et al VS Edward G. RidolfI and Janice M. RidolfI The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-548 Civil Term Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 07,2004 at 7:20 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Edward G. Ridolfi and Janice M. Ridolfi, by making known unto Janice RidolfI, personally and adult in charge for Edward G. Ridolfi, at 32 Scarsdale Drive, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2005 at 11 :10 o'clock A.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Edward G. Ridolfi and Janice M. RidolfI, located at 32 Scarsdale Drive, Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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 the within named defendants, to wit: Edward G. RidolfI and Janice M. Ridolfi, by regular mail to their last known address of32 Scarsdale Drive, Camp Hill, PA 17011. These letters were mailed under the date of December 29,2004 and never returned to the Sheriffs OffIce, R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 2, 2005 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg for The Chase Manhattan Bank, as Trustee of lMC Home Equity Loan Trust 1997-8 under the Pooling and Servicing Agreement Dated as of December 1, 1997. It being the highest bid and best price received for the same, The Chase Manhattan Bank, as Trustee ofIMC Home Equity Loan Trust 1997-8 under the Pooling and Servicing Agreement Dated as of December 1, 19970f338 South Warminster Road, Hatboro, P A 19040, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of$9l0.25, Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library $30.00 17.85 15,00 15.00 30,00 10.00 Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $ 1.00 20.72 6.63 15.00 30.00 316.55 307.27 30.73 25.00 39.50 910.25 Sworn and subscribed to before me This f <:: day of ef.7 2005, A.D. ~ C:h/1.tiJPI".~ ro onotary So Answers: ~~ :~<:~ R. Thomas Kline, Sheriff BY \Jor1L1JlI1/Ul~ Real Estate mputy a-Ju ~ JO. o~ ~ loV . die- 5fJ3cJ'/ Ilu. lut,/IJ THE CHASE MANHA TT AN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRNST "997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CML DIVISION v. NO. 04-548 CML TERM EDWARD G. RIDOLFI JANICE M. RIDOLFI Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) THE CHASE MANHATTAN BANK. AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1. 1997. Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, 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.32 SCARSDALE DRIVE. CAMP HILL. PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) EDWARD G. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, PA 17011 JANICE M. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 2. Name and address of Defendant(s) in the judgment: Same as above 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 'holdtrr- of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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) LOWER ALLEN TOWNSHIP AUTHORITY 120 LlMEILN ROAD NEW CUMBERLAND, PA 17070 LOWER ALLEN TOWNSHIP 1993 HUMMEL AVENUE CAMP HILL, PA 17011 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 32 SCARSDALE DRIVE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. 1 understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. November 30, 2004 DATE 1\NIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff . THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQIDTY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER 1, 1997 Plaintiff, CUMBERLAND COUNTY No. 04-548 CIVIL TERM v. EDWARD G. RIDOLFI JANICE M. RIDOLFI Defendant(s). November 30, 2004 TO: EDWARD G. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 JANICE M. RIDOLFI 32 SCARSDALE DRIVE CAMP HILL, P A 17011 "THIS FIRM IS A DEBT COLLECTOR AlTEMPTlNG TO COLLECT A DEBT AND ANY INFORMATION 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 ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY," Yourhous,e (real estate) at, 32 SCARSDALE DRIVE. CAMP HILL. PA 17011. is scheduled to be sold at the Sheriff's Sale on MARCH 2. 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $97,330.81 obtained by THE CHASE MANHATTAN BANK. AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER I. 1997 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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: 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. r 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. lfthe 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 ifthe 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. Ifthe 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 maybe 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 ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the olaintiff at the Sheriffs Sale. The sale must be postponed or s~yed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL mAT CERTAIN piece oqmceJ,.Jfland slluale In Lower Allen ToW1lSbip, Cumberland County. Pennsylvllllla, more particularly bounded and described as follows, 10 wil: DOOINNING lU a poInt on die SoulIIeriy line of Stmdale Drive, which polnl is 125 feet West of !be Southwesterly corner of Scarsdale Drive and NepollOil Lane extended and lit the dividing line betwt:en Lols NuIllber 1 and 2S on the hcteinafIcr mentloncd Plan of 1..00;; 1heI:1ao along the Southerly line ()f Scarsdale Drive, North" degrees 20 mtmltes Sasl101.,t feet 10 a point; !benee 111 an arc having a millS l)f zq feet in a ~Iy direction, 28.74 fl:d to a polot on the Westerly IiDt of NcpoIIJiIlaJld aforcsaid;lbcncc along same SO\IIIl 42 degrees 20 minuteS East, 67.S I ~ 10 a point at dividing line bdweetl lois Number I and 2. Slock "E" on said plan; lhence along same. South 41 degrees 40 minullos West 137.57 feot to a point at dividing line between LaIB Nwnixlr 1 and 25, Block 'E' aforesaid; thence along same North 34 degrees 40 millUles West, 102.'9 feet to a point, !he place of begillJling. BEING 1.01 NUlIIber I, Block "E" on PIalI of LOIS lClIown as COIIllltY and Town Homes, IocotpOtaled, which plan w,," recorded in the Cwn'berlaod County Rccnrder's OffICe on May 14, 1956, in PIon Book 7, Page 4L HAVING !hereon ereeled premises known as number 32 SCIIlsdaJe Drive, nTLE Tq SAID PREMISES IS VESTED IN Fdward G. Ridolfi and Janice M. Ridolfi, his wife by DeW hom William B. Robinson and Belly Lee Robinson, his wife dated 1110/1987 and rec;orded 7113/1987- in RecOOl Boole U-32, Page 316. TlVt Parcel #13'25-0022-125 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1997-8 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF DECEMBER I, 1997, Plaintiff (s) From EDWARD G. RIDOLFI AND JANICE M. RIDOLFI NO 04-548 Civil CIVIL ACTION - LAW (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant( s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $97,330.81 L.L. Interest FROM 3/23/04 - 3/2/05 (PER DIEM - $16.00) - $5,520.00 AND COSTS Atty's Comm % Due Prothy $1.00 Ally Paid $946.12 Other Costs Plaintiff Paid Date: DECEMBER 1, 2004 CURTIS R. LONG (Seal) prothoa ~ ~y: 17",- '" P 7l17",,~_r- Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No, 62205 Real Estate Sale #36 On December 02, 2004 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 32 Scarsdale Drive, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 02, 2004 I I :[ d I - 330 Il/lOl lid 'AlllnOJ QNV'I~3aWnJ .:I.:I11l3HS 3Hl .:/0 3JfJJO By:Jbdtj Jndi. Real Estate Deputy ~ c:::~ ~ '1;~. . ' . 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 James L. Clark, being duly sworn according to law, deposes and says: That he is the Accounts Receivable Manager 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! Metro editions which appeared on the 18th and 25th day(s) of January and the 1st day(s) of February 2005, 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 arc true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317, PUBLICATION ...................,...........................g.....4.................................... NOTARIAL SEAL Terry L Russell, Not Oty of Harrisburg, Dauphin CaulJllo My Commission expires ' n expires June 6, 2006 Momber,PennsyivanlaAnoclal onolNotar.. COpy S ALE #36 Sworn to and subscribed before me CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA, 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO, For publishing the notice or publication attached hereto on the above stated dates 307.27 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot,News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid, By""""..""""""",..."""""",.."",..""""..,,,,,,,, MAL E81IIl'I'I ULaNo.. "'No..l'. CIvIl..... 11Ie a-e..... -lll"t....... ~ GlIIIC _EcpJIIy t..n - _,18117'- III*rthe POOIii\8 _ SolrYIllIng ~IIDMoa As,ofn.u,ubIi11,1187 -' v. ~G.""'" and JanIca.. RldDIlI AIly:DInIeI ScIvnalg DESCRIPTION AU. 11IAT CEKrAIN piece or porceI IlfIaDd slID ill Lower AIIlIII T......... Cwobi:daod iliDy,l'aaIsylYlllia,.... porti<oIady_ aoddeaaibed.-'1O wit: BEGINNING ala point OIlllle SoulhaIy line of_Dri~_pointia12SfeotWeal of lIIe _eslolly comer of S<andaIe Drive aod I/epoDait We_ aod II ... tIMdiDg linebelwcmLola~ll111ll2501l"'_ iDalto:rlllllllionedPlanofLols:tbeDceakmgllle Soudledy line of S<andaIe Dri.... Nonh 55 ~ 20 .......1lul11l7.51!l'l1O. ~ tbeDceill..""1IlniDI',.JiUaof20feotill. ~,. I il~21.74!eo1IO'pointOll lbew-tyIille'6fl/epoDaitlaDdafotoaaid; tbeDceakmg__42~20miootes 1lul,67.51!eolIO~aldividiu&linebctweeo AoIt**"I-.it:li .......... M~&41i~f __ '.... _ _ l4 .......411 mioob:aWeat,la2.S9feotlO.poinl....placeof . lI1:GINNINO, '~~.;::i~~ l4. . .PIlo~7.Papl. 41. ... -prem-""-. _ JZIoan,daIo , 1IIIE TO SJ\{D ~. is vemd in BdndO,'_"_M.RidoIfi.hia ... lor Doed from William B, _ lIIIll Idly \.Ie Robinsoo. hia wife. doll:d 7/100987 .. _ 7/1311987 ill Jl.raxod Book U-32. ..m; ....'..'01113-25-0022.125, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), p, 1.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: January 14, 21, 28, 2005 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. t' SWO TO AND SUBSCRIBED before me this 28 day of January, 2005 ~~~)'~wyk~Q~ REAL ESTATE SALE NO. 36 Writ No, 2004,548 Civil The Chase Manhattan Bank. as Trustee of IMe Horne Equity Loan Trust 1997-8 Under the Pooling and Servicing Agreement dated as of December 1, 1997 vs, Edward G, RIdolfi and Janice M. Ridolfi Atty,: DanJel Schmieg ALL THAT CERTAIN piece or par- cel of land situate in Lower Allen Township, Cumberland County, Pennsylvania. more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Scarsdale Drive, which point is 125 feet West of the Southwesterly corner of Scarsdale Drive and Neponsit Lane extended and at the dividlng line between Lots Number 1 and 25 on the hereinaf. ter mentioned Plan of Lots; thence along the Southerly line of Scarsdale Drive. North 55 degrees 20 minutes East 107.51 feet to a pOint: thence in an arc having a radius of 20 feet in a Southeasterly direction, 28.74 feet to a point on the Westerly line of Neponsit land aforesaid; thence along same South 42 degrees 20 minutes East, 67.51 feet to a point at dividing line between Lots Num. ber 1 and 2, Block "E" on said plan; thence along same, South 47 de- grees 40 minutes West 137.57 feet to a point at dividing line between Lots Number 1 and 25, Block "'E" aforesaid; thence along same North 34 degrees 40 minutes \Vest, 102.59 feet to a point, the place of beginning. BEING Lot Number 1. Block "E" on Plan of Lots known as Country and Town Homes, Incorporated. which plan was recorded in the Cumberland County Recorder's Of- fice on May 14, 1956, in Plan Book 7, Page 41. HAVING thereon erected prem- ises known as number 32 Scarsdale Drive. TITLE TO SAID PREMISES IS VESTED IN Edward G, RIdolfi and Janice M, RIdolfi, his wife by Deed from Will1am B. Robinson and Betty Lee Robinson, his wife dated 7/10/ 1987 and recorded 7/13/1987 in Record Book U-32, Page 376. Tax Parcel #13-25-0022-125.