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HomeMy WebLinkAbout02-1008 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 (215) 563-7000 CENDANT MORTGAGE CORPORATION 6000 ATRIUM WAY MT LAUREL, NJ 08054 Plaintiff V. AMY L. RAUDABAUGH 449 NORTH COLLEGE STREET CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. Oa -/04 nn l . l U? f l C`? CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. We nefeuy cernty the CUMBERLAND COUNTY within to be a true and CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE uvrrect copy of the CARLISLE, PA 17013 original filed of rewrer (717) 249-3166 FEMEWAN AND PHELAN' Loan n: 00077061 12 WYFROM INTRW C2N This is ar?o?i N?. 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. 1. Plaintiff is CENDANT MORTGAGE CORPORATION 6000 ATRIUM WAY MT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: AMY L. RAUDABAUGH 449 NORTH COLLEGE STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 10/26/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MEMBERS FIRST FEDERAL CREDIT UNION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1289, Page 81. PLAINTIFF is now the legal holder of the mortgage and is in the process of formalizing as assignment of same. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. r' 6. The following amounts are due on the mortgage: Principal Balance $59,589.28 Interest 1,488.00 10/1/01 through 2/1/02 (Per Diem $12.00) Attomey's Fees 1,000.00 Cumulative Late Charges 43.66 10/26/95 to 2/1/02 Cost of Suit and Title Search 550.00 Subtotal $62,670.94 Escrow Credit 740.88 Deficit 0.00 Subtotal ($740.88) TOTAL $61,930.06 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attomey's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c. 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $61,930.66, together with interest from 2/1/02 at the rate of $12.00 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. FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALL THAT CERTAIN lot of ground with the improvements thereon erected situate in the Borough of Carlisle, Cumberland County, Pennsylvania and being more particularly described as follow, to wit: BEGINNING on the North land formerly of Miss E. M. Groome, now or formerly of William Cornman; on the East by a 16 foot wide alley; on the South by land formerly of Alfred Baker, no or formerly of Thomas Adams; and on the West by North College Street. Containing 50 feet in the front on said North College Street and extending at an even width 210 feet, in depth, to the aforesaid alley. Having thereon erected a two and one-half story frame dwelling hose known as 449 North College Street. V/ VERfFICATION MARC J. HINKLE hereby states that he is V.P. of CENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. DATE: SHERIFF'S RETURN - REGULAR CASE NO: 2002-01008 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORPORATION VS RAUDABAUGH AMY L DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RAUDABAUGH AMY L DEFENDANT the at 1717:00 HOURS, on the 12th day of March , 2002 at 449 NORTH COLLEGE STREET CARLISLE, PA 17013 by handing to AMY RAUDABAUGH a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this 9 day of ?UtJ ,2 A.D. r thonotary ' So Answers- ? ;,*-10 R. Thomas Kline 03/13/2002 FEDERMAN & PHELAN By: 1 "- Deputy'Shdrif f FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION 6000 ATRIUM WAY MT LAUREL, NJ 08054 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, V. AMY L. RAUDABAUGH Defendant(s). CIVIL DIVISION NO. 02-1008 CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against AMY L. RAUDABAUGH, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint interest from 2/2/02 to 4/15/02 TOTAL $61,930.06 $876.00 $62,806.06 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237. 1, copy attached. F NK FEDE AN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ?( / apo? PRO PROTHY FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215)561-7000 CENDANT MORTGAGE CORPORATION Plaintiff Vs. AMY L. RAUDABAUGH Defendant(s) TO: ANY L. RAUDABAUGH 449 NORTH COLLEGE STREET CARISLE PA 17013 DATE OF NOTICE: APRIL 2. 2002 Attorney for Plaintiff COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-1008 CIVIL ' 4e, Gp)0` THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 2z"2/?- Frank Federman, Esquire Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2002-01008 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORPORATION VS RAUDABAUGH AMY L DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RAUDABAUGH AMY L the DEFENDANT , at 1717:00 HOURS, on the 12th day of March , 2002 at 449 NORTH COLLEGE STREET CARLISLE, PA 17013 by handing to AMY RAUDABAUGH a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this--- - -- day of A. D. So Answe R. Thomas Kline 03/13/2002 FEDERMAN & PHELAN By: L Deputy Sh riff Prothonotary ° -I 0 ?rn ? R; ;,o -!7, ? }A .jj G E5 P4 FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION 6000 ATRIUM WAY ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. AMY L. RAUDABAUGH Defendant(s). CIVIL DIVISION NO. 02-1008 CIVIL VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant AMY L. RAUDABAUGH is over 18 years of age and resides at, 449 NORTH COLLEGE STREET, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. RANK FE RMAN, ESQUIRE Attorney for Plaintiff n N :n rn rn x _,?.ci C 4M cs+ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CENDANT MORTGAGE CORPORATION Plaintiff, V. AMY L. RAUDABAUGH Defendant(s). No. 02-1008 CIVIL TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $62,806.06 Interest from 4/16/02 to 9/4/02 $1,465.44 and Costs (per diem -$10.32) TOTAL $64,271.50 1nPJ? ? - Z)2tNK RMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. b v CD ?G 0 N "2 CD a 071 ao v°ia A K A O C A A bd ? C11 ? ? O[ 07y t" ? A y p0 41 w d ? ?O O ? O ? x o ?O ?b O O ?O z z ? ,? DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in the Borough of Carlisle, Cumberland County, Pennsylvania and being more particularly described as follows, to wit: BEGINNING on the North by land formerly of Miss E. M. Groome, now or formerly of William Cornman; on the East by a 16 foot wide alley; on the South by land formerly of Alfred Baker, now or formerly of Thomas Adams; and on the West by North College Street. CONTAINING 50 feet in front on said North College Street and extending at an even width 210 feet, in depth, to the aforesaid alley. HAVING thereon erected a two and one-half story frame dwelling house known as and numbered 449 North College Street. Tax Parcel #20-1798-159 PREMISES BEING KNOWN AS 449 NORTH COLLEGE STREET, CARLISLE, PA 17013 TITLE TO SAID PREMISES IS VESTED IN Amy L.-Raudabaugh, Single Person by Deed from John E. Snow, Jr. and Ann R. Snow, Husband ant e ate /1989 and recorded 5/30/1989 in Deed Book Y, Volume 33, Page 1083. f? V 1 O W ( 4? gi$ 'LJ l17 Z r) 0 N D? '+J fJ" 0 r?tom -Fr s)Cn Urn I WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1008 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENDANT MORTGAGE CORPORATION, Plaintiff (s) From AMY L. RAUDABAUGH, 449 NORTH COLLEGE STREET, CARLISLE, PA 17013 (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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $62,806.06 L.L. $.50 Interest FROM 4/16/02 TO 9/4/02 (PER DIEM - $10.32) $1,465.44 AND COSTS Atty's Comm % Any Paid $103.45 Plaintiff Paid Date: APRIL 17, 2002 REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division By l?f?o o ?? ??F-4-? Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADLEPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. AMY L. RAUDABAUGH Defendant(s). CIVIL DIVISION NO. 02-1008 CIVIL CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. RANK FE IIiRMAN, ESQUIRE Attorney for Plaintiff G N 'S ,a -V co, -0 Z al ? rn M ? E 5 Ln d CENDANT MORTGAGE CORPORATION Plaintiff, V. AMY L. RAUDABAUGH Defendant(s). COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-1008 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CENDANT MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at,449 NORTH COLLEGE STREET, CARLISLE, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name AMY L. RAUDABAUGH Last Known Address (if address cannot be reasonably ascertained, please indicate) 449 NORTH COLLEGE STREET CARLISLE, PA 17013 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) CUMBERLAND COUNTY SEARS ROEBUCK AND CO. 6 NESHAMINY INTERPLEX TREVOSE, PA 19053 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) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 449 NORTH COLLEGE STREET CARLISLE, PA 17013 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. April 15. 2002 DATE RANK FE RMAN, ESQUIRE Attorney for Plaintiff ? O N r+C7 A in CS ? O `n v CENDANT MORTGAGE CORPORATION Plaintiff, V. AMY L. RAUDABAUGH Defendant(s). CUMBERLAND COUNTY No. 02-1008 CIVIL April 15, 2002 TO: AMY L. RAUDABAUGH 449 NORTH COLLEGE STREET CARLISLE, PA 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF ALIEN AGAINST PROPERTY. * * Your house (real estate) at 449 NORTH COLLEGE STREET, CARLISLE, PA 17013, is scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $62,806.06 obtained by CENDANT MORTGAGE CORPORATION (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: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected; situate in the Borough of Carlisle, Cumberland County, Pennsylvania and being more particularly described as follows, to wit: BEGINNING on the North by land formerly of Miss E. M. Groome, now or formerly of William Cornman; on the East by a 16 foot wide alley; on the South by land formerly of Alfred Baker, now or formerly of Thomas Adams; and on the West by North College Street. CONTAINING 50 feet in front on said North College Street and extending at an even width 210 feet, in depth, to the aforesaid alley. HAVING thereon erected a two and one-half story frame dwelling house known as and numbered 449 North College Street. Tax Parcel #20-1798-159 PREUSES BEING KNOWN AS 449 NORTH COLLEGE STREET, CARLISLE, PA 17013 TITLE TO SAID PREMISES IS VESTED IN Amy L. ?Raudabaugh, Single Person by Deed from John E. Snow, Jr. and Ann R. Snow, Husband an r e re /1989 and recorded 5/30/1989 in Deed Book Y, Volume 33, Page 1083. C) ? C? Ctt a I ?i $r r'Y.r 50 rn C: L7 U <.J'1 PLAINTIFF CENDANT MORTGAGE CORPORATION DEFENDANT(S) AMY L. RAUDABAUGH SERVE AMY L. RAUDABAUGH AT 449 NORTH COLLEGE STREET CARLISLE, PA 17013 CUMBERLAND COUNTY KMD No. 02-1008 CIVIL ACCT. #0007706112 Type of Action - Notice of Sheriffs Sale Sale Date: 9/4/02 SERVED as day of 200-;k Served and made known to ? ?"' •/ L •A'?av ?IZ 6J!5 ?,, Defendant, on the N at : 6-0, o'clock r.m., at G) ` a `? 5 `aK \ i 3I? Commonwealth of Pennsylvania, in the manner described below: F-1-AN Defendant personally served. Co p Adult family member with whom Defendant(s) reside(s). Relationship is - ?a6 t alt `LKjS _t?ovu oS Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: i5_* ai tZ Description: Age ? Height G'0it Weight ?? Race W? Sex ? Other 9Ibwve_>' i S e R! 1, 624teNCe-L , `svt.ty T5 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 Sal anner n the captioned case on the date and at the address indicated above. ELMBETN M. JOfu OMW Nobry Na Sworn to and subscril? l :4sy 01pBI1S7NIp., F18111d G 1 * befo me (his day Y=.; Wrn -- walk of k 200'1 of Nota? ynu By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE T &'TIMES OF SERVICE ATTEMPTED. NOTSERVED On the day of 200, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1s` Attempt: Time: 2nd Attempt: Time: 3rd Attempt: Time: Sworn to and subscribed before me this day of 200 Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 " ll t ??` ? I I ??' ?! ??, ?-' ;Y ?C: ? ; Z? ? =-'C? ??? y ? w ? L .._ ? ? "? Cendant Mortgage Corporation VS Amy L. Raudabaugh In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-1008 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on May 16, 2002 at 1:55 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Amy L. Raudabaugh, by making known unto Amy Raudabaugh personally, at 449 North College Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on July 5, 2002 at 2:55 o'clock PM, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Amy L. Raudabaugh located at 449 North College Street, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Amy L. Raudabaugh, by regular mail to her last known address of 449 north College Street, Carlisle, PA 17013. This letter was mailed under the date of July 8, 2002 and never returned to the Sheriff's 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 Court House, Carlisle, Cumberland County, Pennsylvania, on September 4, 2002 at 10:00 AM. He sold the same for the sum of $ 1.00 to Attorney Frank Federman for Cendant Mortgage Corporation. It being the highest bid and best price received for the same, Attorney Frank Federman, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of $793.36, it being costs. Per Attorney Federman's request, record should be marked "terms of sale not complied". Buyer does not want deed to property. Sheriffs Costs Docketing $ 30.00 Poundage 209.65 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 6.90 Certified Mail 1.16 Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds 15.00 20.00 228.20 193.75 25.20 25.00 $ 796.36 paid by attorney 10/29/02 Sworn and subscribed to before me This 14?- day of So sw R. Thomas Kline, hS eriff??? 2002, A.D. BY, 0d<. _ 11,c: Pr thonotary Real Estate_ eputy 5739 CENDANTMORTGAGE CORPORATION Plaintiff, v. AMY L. RAUDABAUGH Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 02-1008 CIVIL 7 sue. ? ? AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CENDANT MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,449 NORTH COLLEGE STREET CARLISLE, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name AMY L. RAUDABAUGH Last Known Address (if address cannot be reasonably ascertained, please indicate) 449 NORTH COLLEGE STREET CARLISLE, PA 17013 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) SEARS ROEBUCK AND CO. 6 NESHAMINY INTERPLEX TREVOSE, PA 19053 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) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 449 NORTH COLLEGE STREET CARLISLE, PA 17013 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. April 15. 2002 DATE RANK FEI RMAN, ESQUIRE Attorney for Plaintiff CENDANT MORTGAGE CORPORATION Plaintiff, V. AMY L. RAUDABAUGH Defendant(s). CUMBERLAND COUNTY No. 02-1008 CIVIL April 15, 2002 TO: AMY L. RAUDABAUGH 449 NORTH COLLEGE STREET CARLISLE, PA 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKR UPTCYAND 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, 449 NORTH COLLEGE STREET, CARLISLE, PA 17013, is scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $62,806.06 obtained by CENDANT MORTGAGE CORPORATION (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: 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 if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in the Borough of Carlisle, Cumberland County, Pennsylvania and being more particularly described as follows, to wit: BEGINNING on the North by land formerly of Miss E. M. Groome, now or formerly of William Cornman; on the East by a 16 foot wide alley; on the South by land formerly of Alfred Baker, now or formerly of Thomas Adams; and on the West by North College Street. CONTAINING 50 feet in front on said North College Street and extending at an even width 210 feet, in depth, to the aforesaid alley. HAVING thereon erected a two and one-half story frame dwelling house known as and numbered 449 Notch College Street. Tax Parcel #20-1798-159 PRE[USES BEING KNOWN AS 449 NORTH COLLEGE STREET, CARLISLE, PA 17013 TITLE TO SAID PREMISES IS VESTED IN Amy L. -Raudabaugh, Single Person by Deed from John E. Snow, Jr. and Ann R. Snow, Husband an i e to /1989 and recorded 5/30/1989 in Deed Book Y, Volume 33, Page 1083. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1008 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENDANT MORTGAGE CORPORATION, Plaintiff (s) From AMY L. RAUDABAUGH, 449 NORTH COLLEGE STREET, CARLISLE, PA 17013 (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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $62,806.06 L.L. $.50 Interest FROM 4/16/02 TO 9/4/02 (PER DIEM - $10.32) $1,465.44 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $103.45 Other Costs Plaintiff Paid Date: APRIL 17, 2002 CURTIS R. LONG Prothonotary, Civ l Divi ion REQUESTING PARTY: i s ( t Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURB AN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADLEPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Real Estate Sale # 23 On May 10, 2002 the sheriff levied upon the defendant's interest in the real property situated in the Borough of Carlisle, Cumberland County, PA known and numbered as 449 North College Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 10, 2002 CV:D Q4? By: 0JCLCL +r Q . -4 :11 r i 8dtl Q F i 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 Frank J. Epler being duly sworn according to law, deposes and says: That he is the 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 23rd and 30th day(s) of July and the 6th day(s) of August 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY L Sworn to and subscribed before me 14th day of ugust A.D. S A L E #23 Notarial Seal REAL ESTATE SALE No. 23 Terry L. Russell, Notary Public Writ No. 2002-1008 Civil Term City Of Harrisburg, Dauphin County My Commission Expires June 6, 2006 NOTA Y PUBLIC Cendant Mortgage Corp. Member. Pennsylvania Association Of Notaries My commission expires June 6, 2006 AnW L"4110110 Qh , Aft F CUMBERLAND COUNTY SHERIFFS OFFICE DFSCRWTM ALL THAT CHAIN lot of ground with the CUMBERLAND COUNTY COURTHOUSE improwments thereon erected, situate in the CARLISLE, PA. 17013 Borough of Carlisle, Cumberland County, Pennsylvania and being more particularly described as follows, to wit: Statement of Advertising Costs BEGINNING on the North by land formerly of Miss E. M. Groome, now or formerly of William TO THE PATRIOT-NEWS CO., Dr. Comman; on the East by a 16-foot wide alley; on For publishing the notice or publication attached the South by land formerly of Alfred Baker, now or formerly of Thomas Adams; and on the West hereto on the above stated dates $ 192.00 by North College Street. CONTAINING 50 feet in front on said North Probating same Notary Fee(s) $ 1.75 College Street and extending at an even width Total $ 193.75 210 feet, in depth, to the aforesaid alley. HAVING thereon erected a two and one-half 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 .................................................................... story frame dwelling house known as and numbered 449 North College Street. TAX PARCEL #10.1798-159. PREMISES: Being known as 449 North College Street Carlisle, PA 17013. TITLE TO SAID Premises is vested in Amy L RaudabaughI single Person, by Deed from John E. So . ow, Jr. and Ann R. Snow, husband and wife, dated 5/2611989 and recorded 513011989 in Deed Book Y, Volume 33, Page 1083. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 26, AUGUST 2, 9, 2002 Afflant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 23 Writ No. 2002-1008 Civil Cendant Mortgage Corporation VS. Amy L. Raudabaugh Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erect- ed, situate in the Borough of Carlisle, Cumberland County. Pennsylvania and being more particularly de- scribed as follows. to wit: BEGINNING on the North by land formerly of Miss E. M. Groome, now or formerly of William Cornman; on the East by a 16 foot wide alley: on the South by land formerly of Alfred Baker, now or formerly of Thomas Adams; and on the West by North College Street. CONTAINING 50 feet in front on said North College Street and ex- ----------? R ger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST. 2002 LOIS E. SNYDER, Notary Public Cerhle Boro. C{i Tharkm county My Corns on Elves Meech 5, tending at an even width 210 feet, in depth, to the aforesaid alley. HAVING thereon erected a two and one-half story frame dwelling house known as and numbered 449 North College Street. Tax Parcel #20-1798-159. PREMISES BEING KNOWN AS 449 NORTH COLLEGE STREET, CARLISLE, PA 17013. TITLE TO SAID PREMISES IS VESTED IN Amy L. Raudabaugh, Single Person by Deed from John E. Snow, Jr. and Ann R. Snow, Hus- band and Wife dated 5/26/1989 and recorded 5/30/1989 in Deed Book Y, Volume 33, Page 1083. 10/28/02 HON 10:26 FAX 2155638658 Federman & Phelan '" f?001 The Law Offices FEDERMAN & PHELAN, LLP One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Fax (215) 563-5656 Cheryl McGrath Paralegal Bidding & Sales Dept Eat# 1207 October 28, 2002 Fax (717) 240-6397 Office of the Sheriff Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 RE: Cendant Mortgage Corporation v. Amy L. Raudabaugh Cumberland County # 02-100SCivil Property Address: 449 North College Street Carlisle, PA 17013 Sheriffs Sale: September 4, 2002 Dear Sir/Madame: Please return the writ of Execution on the above captioned property and mark the record "terms of sale not complied". My Client, Cendant Mortgage Corporation will not be settling. They have accepted reinstatement funds on the property. The funds received in consideration of this stay were $10,482.44. If I can be of any further assistance, please feel free to contact the undersigned. Thank you. Sincerely, Cheryl McGrath Paralegal Federman & Phelan Cc: File