HomeMy WebLinkAbout04-3247KIM C. RARAIGH and
CATHLEEN D. RARAIGH,
Plaintiffs
LEE A. WOODALL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- O q- ~ &'4 "/ CIVIL TERM
ACTION OF MORTGAGE FORECLOSURE
CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
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 loose 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 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 Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
KIM C. RARAIGH and
CATHLEEN D. RARAIGH,
Plaintiffs
LEE A. WOODALL,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- 3,2 ¥ '1 CIVIL TERM
ACTION OF MORTGAGE FORECLOSURE
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiffs, KIM C. RARAIGH and CATHLEEN D. RARAIGH, are adult individuals
residing at 7 Gordon Drive, Carlisle, Pennsylvania 17013.
Defendant, LEE A. WOODALL, is an adult individual, whose last known address is
21 WEST MULBERRY HILL ROAD, CARLISLE, PENNSLVANIA 17013.
The said Defendant executed and delivered a Mortgage Note in the sum of
$80,000.00, a copy of said Mortgage Note being attached hereto and incorporated
hereby reference as Exhibit "A."
Contemporaneously with and at the time of the execution of the aforesaid Mortgage
Note, in order to secure payment of the same, Defendant made, executed, and
delivered to original Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds Office of the within County and Commonwealth conveying to
original Mortgagee the subject premises, a copy of said Mortgage being attached
hereto and incorporated herein by reference as Exhibit "B."
The land subject to the Mortgage is: 21 WEST MULBERRY HILL ROAD,
CARLISLE, PENNSYLVANIA 17013.
The said Defendant is the real owner of the property.
I0.
11.
The Mortgage is in default due to the fact that Mortgagor has failed to pay the
installment due on April 7, 2004 and all subsequent installments thereon, and the
following amounts are due on the Mortgage:
UNPAID PRINCIPAL BALANCE
Interest at $12.96 per day
From 3/7/04 to 7/1/04
(based on contract rate of 6.00%)
Late Charges $33.75/month
For 1/22/04 and from 4/7/04 to 6/7/04
Attorney's Fee at 5% of Principal Balance
TOTAL
$ 77,760.42
1,503.36
135.04
3,888.02
$ 83,286.84
** Together with interest at the per diem rate noted above after July 1, 2004 and
other charges and costs to date of Sheriff's Sale.
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
completed Sheriff's Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that am actually incurred by
Plaintiff.
No judgment has been entered upon said Mortgage in any jurisdiction.
Notice of Intention to Foreclose and accelerate the loan balance pursuant to
Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance
exceeds $50,000.00. However, Notice was given in an effort to avoid this
foreclosure action.
Defendant is not a member of the Armed Forces of the United States of America, nor
engaged in any way which would bring them within the Soldiers and Sailors Relief
Act of 1940, as amended.
Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983
(Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant
has either failed to meet the time limitations as set forth therein or has been
determined by the Housing Finance Agency not to qualify for assistance.
WHEREFORE, Plaintiffs demand judgment in mortgage foreclosure "IN REM" for the
abovementioned total amount due together with interest at the rate of 6.00% ($12.96 per diem),
together with other charges and costs including escrow advances incidental thereto to the date of
Sheriff's Sale and for foreclosure and sale of the property within described.
B~Esquire
GRIFFIE & ASSOCIATES
Attorney for Plaintiffs
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsifications to authorities.
DATE:
DATE:
KIM C. RARAIGH
CATHLEEN D. RARAIGH
MORTGAGENOTE
July 7, 2003
21 West Mulberry Hill Road
Carlisle, PA 17013
1. BORROWERS PROMISE TO PAY
In return for a loan that I have received, I promise to pay EIGHTY THOUSAND
AND XX/100 ($80,000.00) (this mount is called "Principal"), plus interest, to the order
of the Lender. The Lender is KIM C. RARAIGH and CATHLEEN D. RARAIGH.
I will make all payments under th~s Note in the form of cash, check or money
order.
I understand that the Lender may transfer this Note. The Lender or anyone who
takes this Note by transfer and who is entitled to receive payments under this Note is
called the "Note Holder".
2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has
been paid. I will pay interest at a yearly rate of six (6%) percent, amortized as though
being paid over a period of fifteen (15) years.
The interest rate required by this Section 2 is the rate I will pay both before and
after any default described in Section 6(B) of th/s Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by making a payment every month.
I will make my monthly payment on the 7th day of each month beginning on
August 7, 2003. I will make these payments every month until I have paid all of
the principal and interest and any other charges described below that I may owe
under this Note. Each monthly payment will be applied as of its scheduled due
date and will be applied to interest before Principal. If, on July 7, 2005, I still
owe amounts under this Note, I will pay those amounts in full on that date, which
is called the "Maturity Date".
I will make my monthly payments at 7 Gordon Drive, Carlisle, PA, 17013, or
at a different place if required by the Note Holder.
(B) Amount of Monthly Payments
My monthJy payment will be in the amount of SIX HUNDRED SEVENTY-
FIVE AND 09/100 ($675.09) DOLLARS.
EXHIBIT
! "A')
4. BORROWER'S RIGHT TO PREPAY
I have the fight to make payments of Principal at any time before they are due. A
payment of Principal only is known as a "Prepayment". When I make a Prepayment, I
will tell the Note Holder in writing that I am doing so. I may not designate a payment as
a Prepayment if I have not made all the monthly payments due under the Note.
I may make a full Prepayment or partial Prepayments without paying a
Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of
Principal that I owe under this Note. However, the Note Holder may apply my
Prepayment to the accrued and unpaid interest on the Prepayment amount, before
applying my Prepayment to reduce the Principal amount of the Note. If I make a partial
Prepayment, them will be no changes in the due date or in the amount of my monthly
payment unless the Note Holder agrees in writing to those changes.
5. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loan charges, is
finally interpreted so that the interest or other loan charges collected or to be collected in
connection with this loan exceed the permitted limits, then: (a) any such loan charge
shall be reduced by the amount necessary to reduce the charge to the permitted limit; and
(b) any sums already collected from me which exceeded permitted limits will be refunded
to me. The Note Holder may choose to make this refund by reducing the Principal I woe
under this Note or by making a direct payment to me. If a refund reduces Principal, the
reduction will be treated as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED .
Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment
by the end of fifteen (15) calendar days after the date it is due, I will pay a
late charge to the Note Holder. The amount of the charge will be five (5%)
percent of my overdue payment of principal and interest. I will pay this late
charge promptly but only once on each late payment.
(B)
Default
If I do not pay the full amount of each monthly payment on the date it is due,
I will be in default.
(c)
Notice of Defauk
If I am in default, the Note Holder may send me a written notice telling me
that if I do not pay the overdue mount by a certain date, the Note Holder
may require me to pay iumaediately the full amount of Principal which has
not been paid and all the interest that I owe on that amount. That date must
be at least thirty (30) days after the date on which the notice is mailed to me
or delivered by other means.
(D)
No Waiver By Note Holder
Even if, at a time when I am in default, the Note Holder does not require me
to pay immediately in full as described above, the Note Holder will still have
the right to do so if I am in default at a later time.
(E)
Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described
above, the Note Holder will have the right to be paid back by me for all of its
costs and expenses in enfoming this Note to the extent not prohibited by
applicable law. Those expenses include, for example, reasonable attorneys'
fees.
7. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given
to me under this Note will be given by delivering it or by mailing it by first class mail to
me at the Property Address above or at a different address if I give the Note Holder a
notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by
delivering it or by mailing it by first class mail to the Note Holder at the address stated in
Section 3(A) above or at a different address if I am given a notice of that different
address.
8. OBLIGATIONS OF PERSONS tINDER THIS NOTE
If more than one person signs this Note, each person is fully and personally
obligated to keep ail of the promises made in this Note, including the promise to pay the
full amount owed. Any person who is a guarantor, surety or endorser of this Note is also
obligated to do these things. Any person who takes over these obligations, including the
obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of
the promises made in this Note. The Note Holder may enforce its rights under this Note
against each person individually or against all of us together. This means that any one of
us may be required to pay all of the amounts owed under this Note.
I and any other person who has obligations under this Note waive the rights of
Presentment and Notice of Dishonor. "Presentment" means the right to require the Note
Holder to demand payment of amounts due. "Notice of Dishonor" means the right to
require the Note Holder to give notice to other persons that amounts due have not been
paid.
10. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions.
In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed
of Trust, or Security Deed (the "Security Instrument"), dated the same date as this Note,
protects the Note Holder from possible losses which might result if I do not keep the
promises which I make in this Note. That Security Instrument describes how and under
what conditions I may be required to make immediate payment in full of all mounts I
owe under this Note. Some of those conditions are described as follows:
If all or any part of the Property or any Interest in the Property is sold and
transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is
sold or transferred) without Lender's prior written consent, Lender may require
immediate payment in full of all sums secured by this Security Instrument. However, this
option shall not be exercised by Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration.
The notice shall provide a period of not less than thirty (30) days from the date the notice
is given in accordance with Section 15 within which Borrower must pay all sums secured
by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of
this period, Lender may invoke any remedies permitted by this Security/It?stmment
without further notice or demand on Borrower .... /; ~, i
WI~F~Sg--T-klE HAND(S).AND SEAL(S) O~.,TI~E U2J~ED. ;?//
:zz::T.f ........ , Borrower t /
Tills I3,rDEI~2~U'RE, MADE THE day of
of our Lord two thousand three.
~J J ~ ~ in the year
BETWEEN LEE A. WOODALL, married man, party of the first part, and KlM C.
RARAIGH and CATHLEEN D. RARAIGH, husband and wife, parties of the
second part:
WHEREAS, the said LEE A. WOODALL, in and by his certain obligation, or writing
obligatory, under his hand and seal, duly executed and bearing even date
herewith, stand bound unto the said parties of the second part in the sum of
EIGHTY THOUSAND AND XT~/I O0 ($80,000.00) DOLl,iR& conditioned for th~
payment of the just and full sum of EIGHTY THOUSAND AND XX/IO0
($80, 000.00) DOLLARS, together with interest at the rate of SiX (6%) PERCENT
per annum, amortized as though payments are being made for FIFTEEN (15)
YEARS, by making monthly payments in the amount of SiX HUNDRED SEVENTY-
FIVE AND 09/1 O0 ($675.09) DOLLARS, beginning on the 7th day of August, 2003,
and continuing on the 7th day of each successive month thereafter for TWO (2)
years or TWENTY-FOUR (24)payments, when the entire principal and interest
then due shall be paid in full, with all such payments first being applied to
interest and then to principal, such that payment of all principal and interest due
shall be made in full in or before July 7, 2005. All such payments to be made
together wffh the premiums of insurance, taxes, ground rents, water rents,
municipal assessments and charges from time to t~me a~sessed against or upon
the hereinafter described mortgaged premises, without any fraud or further
delay, as in and by the said recited obligation and the condition thereof relation to
the same being had, may more fully and at large appear, and in case of default
in payment, as aforesaid, shall also pay ail costs, fees and expenses of collecting
the same including an attorney's commission of five per cent.
NOW THIS INDENTURE WITNESSETH, that the said parties of the first
part, as well for and in consideration of the aforesaid debt or sum of EIGHTY
THOUSAND AND XX/ IO0 ($80,000.00) Dollars, and for the better securing the
payment thereof unto the said parties of the second part, their
executor, administrators and assigns, in discharge of the said obligation above
recited, as for and in consideration of the further sum of one dollar in specie, well
and truly paid to the said party of the first part, by the said parties of the second
part, at and before the ensealing and delivery hereof, the receipt of which one
dollar is hereby acknowledged, they have granted, bargained, sold, released and
confirmed, and by these presents do grant, bargain, sell, release and confirm
unto the said parties of the second part, their heirs and assigns.
EXHIBIT
ALL that certain tract of land situate in Middlesex Township,
Cumberland County, Pennsylvania, being Lot No. 59, as shown on
the Plan entitled Meadowbrook Farms Final Subdivision Plan Phase
17 dated February 12, 1999, last revised June 3, 1999, and
recorded August 1 7, 1999, in Cumberland County Plan Book 79,
Page 85, more particularly bounded and described as follows:
BEGINNING at an iron pin, lying in a westerly right-of-way line of
Country Side Drive (50-foot right-of-way), and being a northerly
comer of Lot No. 77; thence along said Lot, South 62 degrees 01
minutes 02 seconds West, I89,06 feet to an iron pin, being a
westerly comer of said Lot and lying in an easterly line of Lot No.
60; thence along said Lot, North 27 degrees 58 seconds West,
120. O0 feet to an iron pin, being a northerly comer of said Lot and
lying in a southerly right-of-way line of Mulberry Hill Road (50-foot
right-of-way); thence along said right-of-way, North 62 degrees 0I
minutes 02 seconds East, I87. 73 feet to a point, lying along said
right-of-way; thence continuing along said right-of-way, along a
curve to the right, having a chord bearing of South 69 degrees 38
minutes 16 seconds East, a chord distance of 37.36feet, a radius
of 25.0O feet, and an arc distance of 42.19 feet to a point, lying in a
westerly line of Country Side Drive (50-foot right-of-way); thence
along said right-of-way, South 21 degrees 1 7 minutes 34 seconds
East, 19. 94 feet to a point; thence continuing along said right-of-
way, along a curve to the right, having a chord bearing of South 11
degrees 39 minutes 25 seconds East, a chord distance of 75.32
feet, a radius of 225.0O feet, and an arc distance of 75.68feet to
an iron pin, being the place of BEGiNNiNG.
CONTAINiNG O. 564 acre.
BEiNG the same real estate that Mark Sheely Builder, Inc., a
Pennsylt~ania Corporation, by its deed dated the 24th day of May,
2002, recorded in the Cumberland County Recorder of Deeds
Office, in Mortgage Book 251, Page 4436, conveyed unto Lee A.
Woodall, married man, party of the first part herein.
TOGETHER with ail and singular the buildings, improvements, woods,
ways, rights, liberties, privileges, hereditaments and appurtenances to the same
belonging, or in anywise appertaining, and the reversion and reversions,
remainder and remainders, rents, issues and profits thereofi To Have and to
Hold the said hereditaments and premises above granted, or intended so to be,
with the appurtenances, unto the said parties of the second part, their heirs and
assigns forever.
AND it is further understood and agreed that the said party of the first
part, his heirs and assigns, will pay ail taxes, municipal assessments and
charges from time to time assessed against or upon said mortgaged premises
forthwith when the same become due and payable, and will keep the buildings
erected upon the said premises insured in some good and reliable fire insurance
company or companies licensed to transact business in the Commonwealth of
Pennsylvania, in the amount of at least EIGHTY THOUSAND AND XX/100
($80,000.00] Dollars, and shall take no insurance upon said buildings not
marked for the benefit of the Mortgagee, and the policy or policies, with a proper
mortgagee or loss payable clause attached, shall be delivered to and held by the
said parties of the second part, their executors, administrators or assigns, as
collateral security for the payment of moneys secured hereby, and in case said
party of the first part, his heirs or assigns, shall neglect to procure such
insurance, or shall neglect to pay said taxes, municipal assessments and charges
forthwith when the same become due and payable, the said parties of the second
part, their executors, administrators or assigns, may take out such policy or
policies in their own names, and may pay such taxes, municipal assessments
and charges, and the premium or premiums paid therefor, and the sum or sums
paid for such taxes, municipal assessments and charges as aforesaid, shall bear
interest from time of payment, and be added to and collected as part of the said
principal sum and in the same manner.
And it is further agreed and understood, that in case default be made at
any time in the payment of the principal debt or any installment of principal debt
or interest, or any part thereof, or of any taxes, municipal assessments, charges
or premiums of insurance aforesaid, for FIFTEEN (25) days after the same falls
due as aforesaid, the whole of the said debt and interest and additions thereto as
aforesaid shall, at the option of the said parties of the second part, their
executors, administrators or assigns, become due and payable forthwith; and
thereupon an action of mortgage foreclosure as now provided by Pennsylvania
Procedural Rules 114l to 1148, both inclusive, or other appropriate proceedings,
now or hereafter prescribed by law, may forthwith be commenced and prosecuted
to judgment, execution and sale, for the collection of the whole amount of the said
debt and interest remaining unpaid, together with all premiums of insurance, and
all taxes, municipal assessments and charges, and all fees, costs and expenses
of such proceedings, including reasonable attorney's fees. And all errors in said
proceedings, together with all stay of or exemption from execution, or extension of
time of payment which may be given by any Act or Acts of Assembly now in force,
or which may be enacted hereafter, are hereby forever waived and released.
PROV1DED ALWAYS, NEVERTHELESS that if the said parties of the first
part, his heirs, executors, administrators or assigns, do and shall well and truly
pay, or cause to be paid unto the said parties of the second part, their executors,
administrators and assigns, the aforesaid debt or sum of EIGHTY THOUSAND
AND XX/200 ($80,000.00) DOLLARS on the day and time hereinbefore
mentioned and appointed for the payment thereof, together with lawful interest
for the same, and the premiums of insurance aforesaid, taxes, municipal
assessments and charges, in like money, in the way and manner hereinbefore
specified therefore, without any fraud or further delay and without any
deduction, defalcation or abatement to be made, for or in respect of any taxes,
charges or assessments whatsoever, that then, and from thenceforth, as well this
present Indenture, and the estate hereby granted, as the said obligation above
recited, shall cease, determine and become absolutely null and void to all intents
and purposes, anything hereinbefore contained to the contrary thereof in anywise
not~vithstanding.
IN WITNESS WHEREOF, the said party of the first part hereunto sets his
hand and seal, the day and year first above written.
Signed,. SeaIedpresenceand DeIiveredof /~~j
I do hereby certify that the precise residence and complete post
address of the within named Mortgagee is
Attorney f~
COMMO~TH OF PENNSYLVANIA )
) SS
cOV T '
undersigned officer, personally app~ared~JLee
office
, 2003, before me, the
A. Woodall, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within
instrument, and acknowledge that he executed the same for the purpose therein
contained.
Notary Public (/
NOTARIAL SEAL
ROBIN J. GOSNORN, NOTARY PUBLIC
C~RLISLE BORO. CUMI~F. RLAND COUNTY
MY COMMISSION EXP RES APRIL 17, 2007
COMMONWEALTH OF PENNSYLVANIA )
) SS.
COUNTY OF CUMBERLA2VD I
RECORDED on this day of
A.D. 20 , in the Recorder's office of said County, in Mortgage Book
, Volume , Page
Given under my hand and the seal of the said office, the date above
written.
, Recorder.
!!':is ~o be recorded
........ ¢ :~: County PA
Recorder of Deeds
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-03247 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
RAP~AIGH KIM C ET AL
VS
WOODALL LEE A
GERALD WORTHINGTON ,
Cumberland County, Pennsylvania,
says, the within COMPLAINT - MORT FORE
WOODALL LEE A
DEFENDAiqT , at 1955:00 HOURS, on the
at 21 WEST MULBERRY HILL ROAD
pARLISLE, PA 17013
LEE A WOODALL
a true and attested copy of COMPLAINT -
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
8th day of July , 2004
by handing to
MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.70
Affidavit
Surcharge 10.00
.00
31.70
Sworn and Subscribed to before
me this /J~ day of
Q,_~j~ ~ A.D.
~Prbthonot ary ' --
So Answers:
R. Thomas Kline
07/o /20o4
GRIFFIE & ASSOC
By:
KIM C. RARAIGH and
CATHERINE D. RARAIGH,
Plaintiffs
VS.
LEE WOODALL,
Defendant
TO: LEE WOODALL
IN THE COUg',T OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-3247 CIVIL TERM
ACTION OF MORTGAGE FORECLOSURE
CIVIL ACTION - LAW
DATE OF NOTICE: August 12, 2004
NOTICE OF DEFAULT JUDGMENI'
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS 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 INFOMRATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
KlM C. RARAIGH and
CATHERINE D. RARAIGH,
Plaintiffs
VS.
LEE WOODALL,
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 04-3247 CIVIL TERM
:
: ACTION OF MORTGAGE FORECLOSURE
: CIVIL ACTION - LAW
.CERTIFICATE OF SERVICE
I, Bradley L. Griffie, Esquire, hereby certify that I did, the 1~'/2/day of August, 2004,
cause a copy of Plaintiffs' Notice of Default Judgment to be served upon Defendant by first class
mail, postage prepaid at the following addresses:
Lee Woodall
21 West Mulberry Hill Road
Carlisle, PA 17013
1941 Monterey Drive
Mechanicsburg, PA 17055
DATE:
?flffie, Esquire
~ _~ttorne~or Plaintiffs
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717)243-5551
(800)347-5552