HomeMy WebLinkAbout02-1730IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A.,
Plaintiff,
vs.
CIVIL DIVISION
NO.: Off. - /720
D. ANDREW RALPH and DONNA
MARIE RALPH AWA DONNA M.
RALPH,
TYPE OF PLEADING
CIVIL ACTION-COMPLAINT
IN MORTGAGE FORECLOSURE
Defendants.
TO DEFENDANT
FILED ON BEHALF OF PLAINTIFF:
Washington Mutual Bank, F.A.
You are hereby notified to plead
to the ENCLOSED COMPLAINT WITHIN
TWENTY (20) DAYS FROM SERVICE HEREOF
ATTORNE-Y FOR PLAIN IFF
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
75 Fairway Drive
Vernon Hills, IL 60061
AND THE DEFENDANT IS:
17 B Glenwood Drive
Camp Hill, PA 17011
AT EY FOR LAINTIFF
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
17 B Glenwood Drive
Townshio of East Pennsboro
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Faust, Esquire
Pa. I.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
9 West
Pittsburgh, PA 15222
(412) 281-7650
(CITY, BORO, TOWNSHIP) (WARD)
.c. _ Gloms,
A NEY F R PLA IFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A., CIVIL DIVISION
Plaintiff, ((?j
vs. NO.: 62-1736
D. ANDREW RALPH and DONNA
MARIE RALPH A/K/A DONNA M.
RALPH,
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim 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 SHOULD
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A.,
VS.
Plaintiff,
D. ANDREW RALPH and DONNA
MARIE RALPH A/K/A DONNA M.
RALPH,
Defendants.
CIVIL DIVISION
NO.: Oa- 1730 &.)?L ?-7s2_i?1
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
Washington Mutual Bank, F.A., by its attorneys, Grenen & Birsic, P.C., files this
Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Washington Mutual Bank, F.A., which has its principal place
of business at 75 Fairway Drive, Vernon Hills, IL 60061 and is authorized to do business in the
Commonwealth of Pennsylvania.
2. The Defendants, D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M.
Ralph, are individuals residing within the Commonwealth of Pennsylvania, whose last known
address is 17 B Glenwood Drive, Camp Hill, PA 17011.
3. On or about May 9, 1994, Defendants executed a Note in favor of Fleet Real
Estate Funding in the original principal amount of $68,916.00.
4. On or about May 9, 1994, as security for payment of the aforesaid Note,
Defendants made, executed and delivered to Fleet Real Estate Funding a Mortgage in the original
principal amount of $68,916.00 on the premises hereinafter described, said Mortgage being
recorded in the Office of the Recorder of Deeds of Cumberland County on May 11, 1994 in
Mortgage Book Volume 1211 Page 1197. A true and correct copy of said Mortgage containing a
description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and
made a part hereof.
5. Fleet Real Estate Funding assigned the aforesaid Mortgage and Note to Bank
United pursuant to the terms of a certain Assignment of Mortgage.
6. Bank United assigned the aforesaid Mortgage and Note to Plaintiff pursuant to the
terms of a certain Assignment of Mortgage.
7. Defendants are the record and real owners of the aforesaid mortgaged premises.
8. Defendants are in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due. Defendants
are due for the October 1, 2001 payment.
9. Plaintiff was not required to send Defendants written notice pursuant to 35 P.S.
§1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 - Act 91 of 1983) prior
to the commencement of this action for the reason that the aforesaid Mortgage is insured by the
Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.
§§1707-1715z-18).
10. Plaintiff was not required to send Defendants written notice of Plaintiff s
intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the
commencement of this action for the reasons that said Mortgage is not a "residential mortgage"
as defined in 41 P. S. §101 and the Defendant is not a "residential mortgage debtor" as defined in
41 P.S. §101.
11. The amount due and owing Plaintiff by Defendants is as follows:
Principal $61,262.01
Interest through 4/1/02 $ 2,614.90
Late Charges through 4/1/02 $ 0.00
Escrow Deficiency through 4/1/02 $ 88.07
Attorney's fees $ 1,250.00
Title Search, Foreclosure and
Execution Costs $ 1,500.00
TOTAL $669714.98
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount
due of $66,714.98 with interest thereon at the rate of $14.04 per diem from April 1, 2002, and
additional late charges, additional reasonable and actually incurred attorney's fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged
premises.
GR`ENEN & BIRSIC, P.C.
BY: ? C? / t C
Kristine M. Fa st, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
EXHIBIT A
ID-7433390 P05/07
03-2E?-02 13:119 PREMIER TRACT
L?
? l4S3?
.lcC J114 LI\ Jr : ?r,f5 .
C',:LI:ITY-PA
'911 f907 I'M 3 09
ST /03 -7
IAlwse AWre a lie V Y,a Ygai
ClanmunwwYh or l'eausylvanh
441-4862207 MORTGAGE 11Inn..la'
441-a 2107
THIS MORTGAGE ("Socurhy InvmWelal`) is given an
May 9 , 1994
711L• Iillmlg:Iga la D ANDREW RALPH AND DONNA M RALPH, IIUSBANO AND WIPE
whose address is 174 GLENWOOD DRIVE, CAMP HILL, PA 17011 :y
Fleet Real Eutate Funding Corp. ("BiMOWer"), luia Security ina"ncnt Is given a
which is agmilmd and existing uuJcr ere luwv or the State of South Carolina M where
address is 1333 Hein Street, CO1-irbla, Be 29201 , O
SIXTY f"Landoe). Boaowor owp Leader the principal sum of
MIGHT THOUSAND NINE HVNDREO SIX7'SEN AND NO/100,-----"_-__--__--_
Inanus (U.S. S 68,916,00
---
Inswme des rim ") This Jobt is avdanced by barowifa 11010 datad the arse doe se this Socurily
u ("Neu"), which provides cs !a Inanody M17ynlwuy with 1110 full Jcla, if no paid earlier, due and rlaymbla on
June 1, 2024 . This Security lauulcnt socums in Load= (a) ilia npaytncnl of the data avidcnmd
by the Num, with huaast. mid all ra wwals. OateMions and lmxlificolianc (b) the paymeat of all other soma, widl illlofti.
advanced and" paragmiJl 6 to pnmccl Ilia imewily of ilia Saucily 1110ruiRm is and (c) the performanco of 9orrowcr's commas
wW %mccinwas under lids Socially Iwuunu:nt and the Not. Fur this pullAna, Borruwa does hereby mortgage, arrant and
convey to Lander ilia following dawribad Pmreny located in CUMBERLAND
County. Pennslyvenue
SEE ATTACHED LIZAL DESCRIPTION .?
which lulu ilia oddma of 178 GLEN wooD DRIVE, CAMP HILL "
Panlulyrxnia 17811 I2IPGd h (Tropary Addiam"): IAMSt. Cigl.
TOGETHER WITH all the ionprovamones now or Iwmfnr creme! 00 Um Pm(erly, and all casements. rights, app rnasncrs,
Mau, royalties, miraral, oil and gas dghM and profits, wader night4 and stuck mW all (Gourds now a hxea()nr a parr of (he
PlU auy, All teldaoamonM and additions diall on) be ct sin by this Security IulnuOam. All IJ in faagoing Is referred
to in this Security hatru nont in the "Pmperny."
BORROWER COV ENANTS [list Borrower is lawfully sclod of ilia awls hereby conveyed and her the right to mongagd,
gnat ud convey Ilia Pmpony and del ilia Pmpcny is unencumbered. asccpt fur encumbrmhcea of reacna Borrower wwroax
and will defend gtmcrally Ilia title to the Properly against all clahns and dclmad&. nbjocl to any acum6raiem of recad.
1. Payment of Principal, Inlorasl mad tale Charge. borrower shall pay when due ilia principal of, and interest go, the
duN evidenced by rim Nos mid Iwo charges due under the tvoa.
2. Monthly 1'uYmenls W "1'wa, 4lruranca u11r1 0dw, Clursm. Ilamwa shall bmlullo in each moodily paymen/. mamhar
with the primipal unit inMAin an set forth in the Nuic mid any lam ahmram. an Iaaullmanl of any (1) nvcs and splsial amosanonls
Iavied ar to ne JeW.J aghhat Ilia Pmlariy. (0) ncnschn4l laymern or gruwd miss on Inc Properly. nod le) prorduons fa
Isom xi: squired by paragraph a,
Loan a: 37119349S
11p1 W4
Rini oei.Ayaae, oaf. m1? YwYe Maw*cm
J•su
BtuK:L ?.ti I'Af: J rara-m?taw
We got this FAX on ServerA at: 03/26/2002 01:20PM Page: 5
IDa7dV433390 P04/07
03-26-02 13:P9 PREMIER TRACT
such mriddy installment for )terns (a). (b), and (C) shall Mount onPtwolhh of the mmunl amounts. as reatmebly aalitnaed
by tender, plus an amount suffrc;ero to maintain an additional balance of not me a Chan alo•si ilh of the Cxlimaed nnahunls.
3bc full annual amount for each item shall be eaumuhlal by tender within a peril owing one motion before an item weld
became delimrycln. Unoler stall hold der amounts collated in men to pay hems (a), (Ith and (C) bufwe III07 become delinquent.
If at hay now the teal of tic pay hams had by Lv nkr fur hoes (a). (b). And (c), together with Coke future monthly paymon s
for such items payahlo to Lender prior to Ilia Ow dnld3 of such items exceeds by more dam mc•sixih due cleated amounl
of pyments noprircd it, pa such hems wla:n due, and if paynn uum an the Note are Carrara. then Lefler shall either refund
xcess o nur erne-sixth of slue emanated aymenta or Cmdll the excess owr alto-Sixth of The cmimmed payments to subsequent
ti
c e
paynwnts by Borrower. as it= rnI(pdon of ?nrmwcr. If taw town or she ptyments model by Borrower tin item (o), (b), or (c)
tw deficienc
nt necessar
to make u
h
ll
L
d
y
y
pay to
er any amou
a
ea
p
is msufficienl in ply the item wlwn due, than Borrower s
Ito or berm Ile dale Iha ilan banm" dec.
i K
As used In this Security Instrument. *S mc:ay' annex it= Secrelnry of Ihnsin@ and Urbon Development or his or her
rance
cash monthly payment alkali
e ins
remium la tin Secretory
mM
a
u
L
I
i
hi
h
d
,
cr must pay a
g
g
u
p
l
te
m
n w
c
docigmuu,
n my year
also include either: (i) an heowboem or taw annul mortgage insurance premium m be paid by Lender to link Secretary,
or (it) a monthly chase inxnamd of it mongngo insurance premium if this Security Imarumee I. held by nlw Secrcary.
Lxdr Manwiy Inswlhmem of me montage, hanmmo proration, akll be in an amount surnecto to accurnulae the hill
meal mmgng, Cnsuranco premium with Lcnda one month prior to do dale the full annual montage insentnce premium is
the in the Scaretary, w if this Security Instrument is held by the Seem". each mondlly chargo shat be in an amaml
alum to one-twenrn, of me-haif gnrecol of taw oulswnding principal kdaacc due eh Ilia Note,
If Bonoww tenders to Lender the full payment of all sums secured by this Security Instrument. Borrolver's account shall
ix: Credited with the balance remaining far gal installments for items (d, (b), and (c) eel any InorlIl Insurance prianknon '
instnllowni "at bade tuns Coal became obligati) to pay to Iho Secretary, and Under shall promptly refund any excess runds
to Borrower. Immwdialcly prior It, a foreclosure ale of Ilia Prolwny or let acquighim by Lend". Bomrwer's iccounl shall -
he credited will, any kd;nee remaining fm all installments for Items (a), (b), and (c).
t. Apprirnton or Paymmis- All payments elder paragraph 1 aa12 shall kr nppltaJ by Lendw u ft4lowx
rafts ,n the mortgage insurance premium to be paid by Lender to ,w Secretary of to the mombly cluugc by the Seemlay,
iInstead of the mombly morlgago inxwxn rp litm;
SOCOUL w any laic, spacial asuummu, lamehokl payments or ground rents, net tare, flood and other hoard Insurance
prem;wns. as reguircd;
Third to interest tine near lw Noe;
L•uuWl, to anoniratinn of do; principal of [be Note: '
Ffth, to law charges due under the Nule.
4. Fire, Flood eel Other Naxaard Inauronce. gorro"r shall insure all improvements on the Property. whether now In
existence or sutmilucMiy cocked, againsl May hazards, comalties, and aapinfoncies. including fire, far which tend" rrydree
Insurance. TI.h; insurance shall be malaldned in the Common and for tlic"Isrild that Lender rcquirra. Borrower shall Cols,
insure all improvements an Ile Prop rty, whether now In oximence w whsapcIlly erected, against less by floods to dc extent
acquired by Ilia Se;rcary. An llinmacc xkdl be caritd Willi companies apprm vc! by Lender. The insumnco policies and any
renewals shall be held by lender and shill include loss,pnyablo clnusa a favor uf, cud in a fen necghwaha in, Lender.
In the cw:nl of lax, Borrower atoll g;w Leader immediate notice by mail. Lcmdw may make pnmf or Ica if IN redo
promptly by Bolyower. Bach Insurance company cmccrpW is Iherehy authorized and dinoc a l to make (aytmnt ter such loss
directly to LrnJw
Inx,nJ of an Borrower and to Lend" )nllul
All or an
art at d
insurance
d
b
l
.
y.
y p
er
"Co
s may
e apppd
ad
by Leader. at its opkm, either (a) to Ilia reduction of Cho wdukedn ess %motor low Noe mad Inds 9eeurllY hearemonl
Brsl to I
.
.any dahimtrwre amounts applied in law order in Porugmpb 3, and the„ to prymymmna of principal, or (b) M taw reslomdon
or repair of the da moted property, Any appl(ca)on o me prcceds to the principal snap not a1110a1 or postpone the dux dale
of the monthly payments which are m1cmd to in paragraph 2, or change tc amount of such payments. Any oscm insurance
procads over any Mamas required to pay all onlaanding indebtedness unda:r the Now and this Sc urlly Insuhlmcnl shall he
paid to Be entity kegmliy eplhlal nitrate.
In Ilia event or'erecmure or his Saarity incontinent or other trailer of title to the Pnlpprly thin axtinguisIm low
indebtedness, all rlgh4 title and Interval M Borrower in and to insurance policies in have Bond[ pun to the purelasw,
S. UrCUPimcy, Preservaliom, Maihlsnwncs and i•ratacdlm or the 1'ropertyl alorrower's Lnxn Application; Lenscholds.
Borrower thill occupy, eslablixh, and use the Pro(wmy as Bonowcr'u priaipsl fi idem:c within sixty days after Iln execmim
of this Security inarumenl and shall Combine to occupy slow Propeny as Bwrower'n principal midenet for at )cut ww year
ahcr tic dale of awnpracy, mleu the SCacmry cklermincs this requiromaq with Calm undo, hardship for Borrower, as unless
ocuamaing ipbCUmaanca exist which arc beyond Bmm)wcr's cmowl. Borrower shall noliry Landers or any extenuating
cirrumslances. BOmhwCr skin nol commit waste or destiny. Chump or Suh tiandilly change the Properly or allow the pfopwly Ill
dccriwatc. M:tio ab% eta and tau exceplud. Lcmier ooy inspect site Pnhpwly it Ile property Is Victim tit ahnndunod ar Inn
horn is in defauln..Lendw may lake reasonable action to procCl and pmwa,C awl raCMI or alrud,MJ PmpCut . Bono""
shall also he in dernult if &rrowar, during the loan application process, gave materially fulac or Inaaauw Information
nr swlemumx to Lender (or faked to provide lender with any material infnnnalim) in conncCtim Willi tic loon oviddncCd by
Ilia Nolc. including. bra not himhed in, mpreaernation containing Bomhwcr's occupancy or the properly as a Iriaipal MSidanco.
If Ibis Security Inxlnnnml is on a kenscwkL IlwroWw shall comply Willi the pnrvGions of the lease. If 110I11DWe1 404uire,
fa title w tic Property, the leasehold and fee rite shat; Coe be merged unless Lender agteq In tow merger in writing.
6. Charges to Burrower and 1'rntactbn or Lender's Rights in Ilia Properly. BwOwcrsholl Poyallgovemrnmtd,rmunicipg
O'BrgCS, rhm Sul impxitims that are nnl included in Paragraph 2. narrower shall pay Ihcse obligates an Onto directly in
tom cony which is owed the payment, it Fallen to Puy would alvoraclY dtacl Lender s ;oorom in me Moparly, wpm L,"dw,s
msgncst Bmmw" $14,11 promptly furnish to Leader reeeipx evidencing Iheye payments
If Burrower fail,,, make (host payments or the payments required by Purnorapl 2, or fails to Worm sly Color amounts
and rggreemc ll Contained In this Sanity Instrument, w "writ is a legal procecling that may significantly affect LordrYS to"
in me Ropey (such M a prraccJing in Iankrhplcy, fa cmdemntnim or to cn(msc hews or rcgulatims). Cho Londe may
I
to and pay wlumcvcr to na tica ry to potect the value of the Kpirerly and tender 's righs in one Prouty. including paymwm
r
h
h
n
euu,
award
uumnsc and mbw koW14 Incnlim d in famoomph 2 „ }y y
Any mmuna disklrwil by leader under this Pauympa shall Iwanrw on nt Chard slob, of borrower onto he "cural ' "-
by Ihix Security Inamrncin. Throe: amounts shall Ica, mount fen Ilia ditto if disbursement, no Cho Norc mac, and 0 the
option of Lander, shall her tmm alinc y due and payable.
Loan an 7?1193695
7. Condemoxl;ion. The pmeeeds of any award or claim for Jsrmget. direct or col mopnmld, in morncdon with any
condemn h or llcr taking of nay pm of Clw property, at for cmveyancr In pact of condemnation, a, hemby assigned
-
- -
IarbN"t P« 7al4 '? PALE... Itnxrl•ras Mnnxxae-Nn
o
-
-
i .
We got this FAX on ServerA at: 03/26/2002 01:20PM Page: 4
ID°7433390 P05/07
03-28-02 13:299 PREMIER TRACT
and
S6Wt!tyilatlrolAC114 iLnder Shall entry suchl Proceeds to rcdwdea of am nda mi,s, under the NmetYmd lahrs Seeulityay
nswmenl, Brsl to my delinquent anwunis 014ju l'n the Order provided m Parents 3. and then to I+wlIKaymc+t of Pwiinc11- 1
'Any afplatwton or the xOce? w the gMhcirml dsll um ea ctul yyor PWIPmma IMM.. due time of the Mont IIY rmY+oaMood L% W 'a 1 alro
SxuritYrlKawinGw shill be Paid to the costly legally teniil to.
iss PueY all on 1'.cling iindcdbtulless aundar Irw Nuiu and dd of aid' ma
outstan
a, Peas. Lend" lacy udluet fees and alarga mlimived by the Sociology.
9. Uruunds for ACCal"atiati of debt.
(a) Denials. Leader ma t as limited by m4?{ulations issued by this SaroMy In din case of Payment dcfmrls. requim
inonedium Poymealinfail oral axon? mmssccurcdby,lisSMurilyinstruimnl IC Security Lavwnom riot to
(i) Burtaw" dofaulu by failing w Pay in full my monthly Payment requited by this Y P
of on the due date of the next monthly Pay,%]=. Of
`--' ((u) Burrower &-faults by failing, fin a Pt+rind of thirty days, to Pefwm Say oNG obligations conlaincd in this
Sccurily Instrument.
(b) Shia W irbaut Credit Approval. Lo dot Said" if paemitled byy ar+pli table law and with the Prior approval or she
Secretary. require reinoculate Payment in fell of all the sums saumd by t Sccurily instrument if.,
(I) All or pall of to PmicnY, or a beneficial imGrst in a treat owning all Of Pan of the Prorwny, it mkd
or olu,swiao umsrereed (other than by dating; or dmCOM) by the BOn'Ow*t, and
(it) TIN Properly is nil occuptod by one rU,,h Cr or SMUW as hit OF Ief principal laudation, or dm Pltchas"
or granite doe m m:eupY (he Propiny hot his or her Credit has Sol been approved in accontWKC Willi the
reluirenwns of the Socimary,
e) No Walter. if cifeumwoens occur slid would Parents LendcF a m4uim Ilmnedime payment in full, but Lander
dims look require such ply+onns. Lander dues rot wuivm its rights with respect to subsa prism ovenla.
(d) Regulations or mu Secretary. In many eircutnslmea regulations issued by the Secretary will limit Leaders rights
in the use of Payment dafmlls in require immediate payment in full and foreclose if not paid Ths Security Insironnca
d+ws non awhoriae escciero tien Or Lxeelosuro If not pmmihad by ragWGlons of roe Secrelary.
(a) Mortgage Nut Insured. BWTU"f agrees dust Should this Security Instrument and the note accmcd ILednr not be
eligible for hatmas m under the National Housing Act within sixty ISO) Hoye from gin data l; (, Lend"
rely. at its option sal nolwlNalmdlolg anything in Paragraph 9, require immediate payment to fend of dl ins Secured
by this Security Iagrunwnt. A Written aiaternent of any aulSUizel ague of din Secretary dmod misaqu i m
Sixty (60) Day* from the dale I",r. dalining to inmrc tiffs Security lsvmnent and ilia note accurad
Lullaby shall be dared conclusive proof of such ioaligibility. Notwithstanding din ro ilimng, this option may
not be oscn:iard by Lender when the unavailability of trumraao is Solely due to Lenders failulil to remit a marylage
insumo s; Prcntiam to the mcmuny.
10. Reinstatement. BrxrOwar bus a d I to be misgWed if Lender hall required Lnlrmdime tsymmn in full became of
Borrower's failure to lay not anou i duo under the Note or this Security Instrumw- This right aprBss even afar LoeeWtwe
pmcecdinYYS xis iiKlitulW. To rcinsslc low SauriiY InsWmenL BOrtowOr Nall and" in a lunp sum dl am0unls required
to bring Bonowci a rsx:uoni cum:ni including. m No eahW that era obilgylima of Bartow" under Uis Sccurhy Indrunsnt.
foracbSUro teats and rusauphla and Wmolwry alauuoya' fen and carxnaes (uglerly aseoeialad wish lira foreclaure pmamiling.
Upon rotnamieneit by Burrower, Nis Bacuriry Insutanenl std to oh igatiom list n seCUta dhtii remain in effccl ns if Lender
Itad rot feyutred imnwdiate paYn+ml is full. However, l,enakr it iron rcqu'Imd to Pa:rmil rcinsateinent IL (() Lmdrr has accepted
rcinsnaemenl after lbe commeneemanl of f"cchauie proceedings within two Pasts ImmedstelY Muscling the canmancommit
elf a Wmsno fmxltmlre Mccceding. ((u) rcinslalcmuu well preclude fmaebsun on dlfferenl g to'1' is to fmure, or (iii)
... nunstatemmt will adversely alrai Its priOrlly of din lien eluted ry nits Satiny Irmimmenl.
lt. Burrower Non Raleased; Porbearmce by Lender NOr u Walter. Bxwnakn of lire tbne OC payment " moBorro er
o! mmutimdbn of tlw sums severed by Nis Security hsvumam 66nnmJ by Lauder m my mconmr in tnierast I. required
shall ram upcatc w rdasase uha lialglily of the nfginal Barrow" nr Burmw"'s suceesror in kl"tal. Lendw shall nut be requirod
to comiiwaa:e proc"diny aydnst m1' sucabawr is anwreat " rafuec io exwud Dine fa puytnenl w ollerwim modify ariwniadmn
of rte sutras sucuiod by t h is Security Inatruin by rcaaon d gay damsel Iy b7 tic urigmal Borrow m Bu s exercise ise of
of
In Imernt. Any fmirwaaC by Isomer in c sewrng any right or randy a nsB ram ha a wdv" of o tar ptaluda uda the IhC exercise
any right Or mtnedy.
11. Succesarva mad Assigns Boundi Joint and Several Usually; Co-Signers, The covenants and agreemerols of this Security
Indrualmt shall hind anti bawfil the sueccssms and assign of Leader and BOTRIwor, subject to (he provslons of paragraph
9.6. Borrusees covenets and agrecrnens slihlr be joint and mv"al. Any Borrower who io•slgas t is security Inatrumcgid
W does Fall execute the Note: (a) 16 ca•alpping this SMU6LY Immument only to men g!?r 1 will convey tell Borrower's
imarat in Ihm Plurally under the terns of ths Security Irturvmant: (b) is not P"aonWy obligated to pay. oho aunK woured
by this SWurafty inatwmenl; and (c) ugroas that Under and any mho game wm mat alpx to at", toothy, forbear ac make
any wconlin lions with regard to the series of this Security lasumnonl m ion oa without thin Borrower's cmment.
13. Nalims. Any nuke to Borrow" provided fa in this Severity lorlrumanl shalt be rvan by daliverine i( or by mailing
it by Gm ehtss hail unless rfflrcrhk law requires tau of another mmlad, The notice shill Ot directed w the RopGty Address
or my tier actress Bmruwor datgnates by rwdon in Leculer. Any a mice to under ahail be given by land class tnml to lend" s
addrces stated homes or my P"d Lender designates by notice to Borrower. Any rwlic; provided fen in this Security Insumnani
shall be deemed to have been given to Borrower of Landta when given w provided in this Paragraph.
14, Conversing Law; Severaoility. This Security Instrument shall be govenncd by Federal law amt the law of the urtalrelion
in which ilia ProP"ty is Imaged. In the event teat any prevision or clause of this Security Irshwmem m the NA fAnllicli
Willi appllcablu law, such eonBied mug not oflect other Provisions or this Security Inewumem or ate Now which can be given
CITecl whited use Wltatcdrng ouiviahulr. To alis aid its, IWvisios of this Security ItalrOalont and Ilia Nola we dwdmed to
be smv"ublc. '
IS. llnnower's Copy. BOnwrm dnallWgivcn una onnfmmcd copy Of tlas Secudtylasuumcni. ,
16. Assignment or Rms. BOrrower unaondlllondly asdge, mad oanden to Land" all tie revs and revenue of ilia property;
Hurmwer authmiaes lender or Lender's agents to callow the rents and rcvmuus will hereby Willis each 1ons01 of Ihm Prulwray
to pay the rents w Lender or Lender's agents. However. prim to Untlm's ninth to Borrow" of Bronower s branch of my
entmant or ugrouncnl in the Swurity Instrument, Borrower shill collect and receive all rains and revenus or tiro Propcny,
as vustw for the benefit of Lender and Borrower. Tias assignment of rcna cunnhues an absolute assignment and Fiat an
-
usstgenml rise Sddhimull security only.
If Lender gives IwiiCe or Itrmah to Borrower: (a) all rents raeivet by Borrower shall be held by Bortowor n trustee for
bamfit of Lander only, to be opfdied 10 use signs secured by the SeWrity Inswuacn6 (b) larded shall be entitled to to11e:1
and Mesita ail or soon taut of Ilin property; and (c) owls Icnml of taw Property shall pay all rends due and unpud to lender
or Leach's agent on Lender's written demand w tin wn tan.
Burrower line nil nauseant any later astignnaln or (be rents and has not and will not Perform my act that would prevent
Lend" limn eaansing Its fights under this Psuayruph 16.
Laodcr dull net Ins required to after upon, lake more] of or insimafn (lw. ProParly before Or sorrel giving notice of breach
to BOrrOWer. however, Leader or a judicially appointed mociwr may do so at any tuns there it a beach. Any aapppikation
of rtes shall elm cure tor waiter mg, default or invalidate any mice right Or sommly of Linde. This assignment of mass of
Ida ProlarY assets crinkles; wiwo llm hi Famed by the Security [K iron Is low in fug, Loan 0, 771191405
,'1044 IF644AA Inmatq 14,394 a - •• MIA I4aa41vrota Mwipagr. us]
? ,, R
We got this FAX on ServerA at: 03/26/2002 01:20PM Page: 6
B3-26-02 13:BB PREMIER TRACT ID=7433399 P03Z07
NON- UNIFORM COVENANTS. Burrower and Lender further covemnt andagrce as follows:
11. 11oreclosun Procedure. If t,snder naulra immediate payment Imfull under parngraph 9, Leader muy Invoke Ilia power of
sale and any other remedies permirted by applicable law. Lander skull be entitled to collect all expenses incurred to pursuing
The remedies provided in this paragraph 17, including, but not limited In. reasonable atlorneyr' fees and caaU of title evidence.
Is. Release. Upon puyanam of all sums scoured by this Security instrument. this Security Instrument and the estate conveyed
shag terminate and become void. After such aecuraanee, Linder shall discharge and satisfy this Security instrument without charge to
Hrunwor, Burrower shall pay any recordation coati.
19. Wulvers. Bnmwer. In the extent permitted by applicable law, waives and rcletaes any emu nr defects in 5 ;;•
praccalings Io anfome this Security Instrument, and hereby waives the boncEt of any proem[ or future haws providing for stay of
execution, extension of time, exemption from munchmed, levy and rah:, and homestead exemption.
20. Rtlnsbdemant Forced. Bconasar's Time to in nrmte provided in pmagroph TO Shall extend to one hour Orion 10
the commenaement of bidding at a shtariff s sale or other sale pursuant to this Security Instrument.
21. Purchase Money Mortgage. If any of the debt socurod by this Security Instrumcnl is lent to Borrower to arquirc
title to Ili : Property. This Security Inswurocat shall be a purchase money mortgage.
22. Interest Rate After Judgment Borrower agmal that dro inicrcal mic payable after a judgment in entered an OiC
Nate or In an action of rnangage foreclWUrc shall be the rule payable fmtn time to time under the Note.
Riders to flits Security Instrument. It one w mare riders am executed by Renewer and recorded together with Oils
Security Instrument, the covenants of can such. rider shall be Incorporated into and shell amend and supplement the mvonsrlu
antl agreements of Ihu Security instrument as if the ride(s) wan in a pan of this Security Instrument. {Chock applicable box(e)) -
Condominium Rider ??yl GnduaoU Paymonl Rit%r ? Crowing Equity Rider
Planned Unit Development Rider U d Other Ispeeifyi ADIUSTABLB RATE
BY SIONINO BELOW. 110110mr acmpu:md agrees 40 the leas mainland In this Sorority Indictment and in any riders)
executed by Borrower and recorded with 4.
/??/'y/
Wianexvr. ,!///
^
T
IsU
(?)
/?1? 0 AND
RALPH
-likinoweir
/ISeYNMM.I
///•
t
ch
DONNA M RALPH -BOINWer
(Seal)
-Borrower
(SOW)
C1TRTIPICBTE OF RESIDENCE -BmrDWer
I, do hatpby Certify that the correct address of the within-named lender is 1333 main
Street, C61%vabilt, SC 29201, witness my hand this 9th day of Me 19
A r
Avant of ffeinder
liars d es Fl1AP meNv I M I ...Iflt
COMMONWEALTH OF Peerry{Mn+SYLVANIA
COUNTY OF Curti bel aaa as,
On this 9th dale of may, 1994 before ma, a Notary Public In and for said County
and Stater personally appeared, D ANDREW RALPH AND DONNA M RALPH, HUSBAND AND WIFE,
the individual(s) who executed the foregoing instrument and acknowledged t . sit'
examination and reading ec the same --d aid siloo LLv rarrvevinq inatewerenC
acknowledged that the same is said individual(s) tree act and dead.
IN WITNESS WHEREOF, I have hereunto set my hand and Official seal. N<'
n:iN a I:. w
w Lo
mY Commission expires: NNaaN Seal .i ?-?ItIQfJ lr ifl
aria c. Vrepriw. Nolryy . _ w.r..?._.n.?aw n "'"WAi:
This instrument was prepared W FLEET MORTDAOB, of 5035 RITTER ROAD, 11MCHANCISBtIRO. PA
17055.
hDud.211 ?Acc 1.201) Loan N= 371193495
We got this FAX on ServerA at: 03/26/2002 01:20PM Page: 3
03-26-02 13:21 PREMIER *TRACT ID-74W433390 P07/67
i
SCHEDULE C - Land Description
CanmlOnanlNumber; 2180
?t
ALL THAT CERTAIN traot or parpel of land situate in zest Pennaborc
Township, Cumberland County, Pennsylvania, more particularly bounded
and described in accordance with a survey of D.P. Raffenspesger,
Registered Surveyor, Camp Bill, Pennsylvania, dated December 1, 1967,
as follows, to wits
BEGINNING at a point on the westerly line of Glenwood Driv (West),
which point is 295.06 fast north of the northwesterly corner of Glenwoo
Drive (Went) and Erford Road (West), and at dividing line between
Lots 3X and 4, Block "B" on the hereinafter mentioned Plan of Lots;
thence along said dividing line, North 63 degrees 30 minutes West,
115 feet to a point; thence along the easterly line of Lots 23X and
23, Mneth 26 degreaa 30 minute Eaot, 37.5 foot to • Point at the
dividing line between Lots 4 and 4X, Block "B" on said plan; thence
along said dividing line, South 63 degrees 30 minutes East and
through the center of a partition wall and beyond, 115 feet to a
point on the westerly line of Glenwood Drive (West), aforeeaidr
thence along same, South 26 degrees 30 minutes West, 37.5 feet to a
point; thence place of BEGINNING.
BEING known as 17-B Glenwood Drive (Went).
BEING Lot No. 4, Block "B", Plan No. 10, Ridley Park, recorded in
Cumberland County Plan Book 18, Page 47.
BEING THE SAME PREMISES which Kirk D. Sell and Brands K. Se114 by
their deed dated 03/20/92 and recorded on 03/26/92.in the Office of
the Recorder of Deeds in and for Cumberland County in Book 0-35, Page
788, granted and conveyed unto Kirk Sell.
UNDER AND SUBJECT to conditions, restrictions and rights of
record.Surveyor,
U ,K 1' 1.1 17,41 12(4
STEWART TITLE
GUARANTY COMPANY
We got this FAX on ServerA at: 03/26/2002 01:20PM Page: 7
03-28-02 13:f7 PREMIER TRACT ID-7&433390 1?02i07
ADJUSTABLE RATE RIDER
441-4862107 sort day of
THIS ADJUSTABLE RATE RIDER is mode 11115
may '1994 and is Incorporated inlo and shall he deemed to amend and supplement
Ina Mortgage, Dead of Treat, or Security Deed ("Security Imtmmeot") Of the same dale given by the undersigned
("Borrower") Insecure Borrower's Nola ("Note")to riser Real Estate Funding Corp.
(the "Ladder") of the same date and covering Ole properly described in Iha Security Instrument and located at:
1711 GLEN WOOD DRIVE, CAMP IIILL. PA 17011
II'atmny Aadmal
THE NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN THE INTEREST RATE
AND THE MONTHLY PAYMENT, THE NOTE LIMITS THE AMOUNT TITS BORROWER'S
INTEREST RATIt CAN CHANCE AT ANY ONE. TIME AND THE MAXIMUM RATS. THE.
BORROWRR MUST PAY.
ADDITIONALCOVENAPffS. in addition to the covenants and agreements made in theSaurity Instrument. Bomwcr
and Lander furiler cuvananl and agree us rolluws:
1. INTEREST RATE AND MONTHLY PAYMIiNT CHANGES
(A) Change (late
The interest rate may change on the first day of October. .19 95, mul on that day ofeac h
succeeding year. "Change Date" means each date an which the intemia rate could change. .
(B) Tine Index
Beginning with Ile first Change Dale, the interest role will be based an an Index. "Index" means the weakly
average yield on United Slates Treasury Securities adjusted to a conalwu maturity of one year, as made available by the
Federal Reserve Board. "Current Index" means lie most recent index figure availably 90 days before the Change Date.
if the Index (as refined above) Is no longer available. Lander will use tis a now Index any Index prescribed by Ile Secretary
(as defined in Paragraph 7(B) of the Note)_ Lander will give Bomlwcrnticc or The new Index.
(Lt. Calculation of Interest Rate Cblttlgea
Berme each CTwnge Date, Lender will calculate a new interest rate by adding a margin of 7Mo
percentage points ( 2.000%) m ilia Current Index and munding Ihtl`suhl to Ole Dearest rare-eighth of one percentage
point (0-125%). Subject on the limits stated to Paragraph 5(D) of Ole NOW, this mended amount will be the new
Interest rate will ilia next Change Dale.
(D) Limits un interest Rate Changes
The (merest rate will never incrcuso or dcemaac by mono man one percentage point (1.0%) on arty single
Change Data The Interval rate will never be more than five percentage Paints (5.0%) higher or lower then the
initial Interest rate stated in Paragraph 2 nr Ilc Now.
(B) Calculation of Payment Change
If me interest rate changes on a Chetge Dale. Lender will calculate the mantel of mondily payment or principal
ant Interest which would be necessary ID repay Oe unpaid principal balance in full of tie maturity data at Ile new Interest
ram through svbstantlilly equal payments. In making such calculation, Len)erwill use the unpaid principal balance; which
would be owed on the Change Dale If them had boon no daraull in payment on the Note, reduced by the amount of any
prepayments no principal„TTe result or this culculation will be the amount of the new moubfy payment of principal and
Interest.
(F) Notice of Changes
Lender will give mica to Borrowerof any change in the interest rate mid monthly payment amount. The notice
must be given at lea05 days before the new monthly payment amount is due. and must ae rush (D the date of fix mice,
(i1) the Change Dare, (Of) lie old Interest rate, IN) the new interest rate, (v) tie new monthly Payment amount. NO the
Current Index and the date It was published, (vie) Ilia method of C21CUladmg the change in monthly paymem amount, and
(viii) any other information which may be required by law from time to time.
(G) Efroctive Dale at Changes
A 'low Interest rare calculated in accordance with Parsgrephs 5(C) and 5(0) of one Note will become effective
no ilia Change D?otP. Botrowershadl make a payment in me new monthly amount beginning On the first payment date which
occurs at (cast 25days aner Lender has given Burrower the m olict, or changes required by Paragraph S(F)of the Nola.
Borrower shall have no obligation to pay any increase in Ilia monthly payment amount calculated in accordance will,
Paragraph 5(E) or the Note for any payment date occurring less Own 25 days slier Lander hex given the required notice. If
the monthly payment ambanl calculated in accordance aim Paragraph S(E) of the Nule doercased. but Lander failed to give
timely notice of rite decrease sold Borrower mare any monthly payment amomlu5 CxeeCJhlg the payment amount which
should have been stated in a timely notice, man Borrower has Ike option 10 either (1) demand Ilia return to Bormweror any
cxccav payment. with interest Olcrean el the Note mile (a ram equal to the interest rate which should have been stated In a
timely nmicc), rot (ii) mquest that any excess payment, with interest themon at Ore Note rate, be applied m payment or
principal. Laner's obligation to velum any excess payment wile interest nn demand is not assignable even If the Note is
othcrwixe meoigned before one demand for rclunl is made.
Rider. BY SIGNING BELOW Borrower accepts and agrees to ilia Icons and covenants eomainod In this Ad)uslablc Rate
?(/n.,(I( 1I I?(n(j?rA ? ? ?®
llX?' 1_ d?ll?lhl 6(igCt_ (SEAL)
?',(/?') VVV oov rn ? D AN RAI PII anmm.•er
ISfiAL)
4W -
OO N B RAL PR
Il.nsn.r
FOR Perm Neme.r
1.141.4.1
YP[efl
In,w4 rata. arya.; hn..
a.hx R.I. RM. - Nn
4h-x.o. r< hamfixFf?37
We got this FAX on ServerA at: 03/26/2002 01:20PM
•?^ 11
Yk.
Page: 2
A'ERIFIC -MON
The undersigned, and duly authorized representative of Plaintiff, deposes and says subject
to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities that the
facts set forth in the foregoing Complaint are true and correct to his information and belief.
cm:
d
ca o m
4r- A
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-01730 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK F A
VS
RALPH D ANDREW ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
RALPH D ANDREW
DEFENDANT
the
at 1641:00 HOURS, on the 12th day of April , 2002
at 17 B GLENWOOD DRIVE
CAMP HILL, PA 17011
D ANDREW RALPH
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 10.35
Affidavit .00
Surcharge 10.00
.00
38.35
Sworn and Subscribed to before
me this /7 E-- day of
u0j,2J A. D.
000 ,., ? Ty ./tom A.Qa?r
othonotary T'
So Answers:
R. Thomas Kline
04/15/2002
GRENEN & BIRSIC
By:
Deputy Sheriff
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-01730 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK F A
VS
RALPH D ANDREW ET AL
RONALD HOOVER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
RALPH DONNA MARIE AKA DONNA M RALPH
the
DEFENDANT , at 1641:00 HOURS, on the 12th day of April 2002
at 17 B GLENWOOD DRIVE
CAMP HILL, PA 17011
by handing to
D ANDREW RALPH
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this /7 (W day of
?u?? o2GD.2J A.D.
I &4K
P othonotary
So Answers:
R. Thomas Kline
04/15/2002
GRENEN & BIRSIC
By :
Deputy Sheriff
% 1.v
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption: ( ) Confessed Judgment
Washington Mutual Bank, F.A. ( ) Other
File No. 02-1730
VS.
D. AhdtdTd Ralph and Donna Marie Ralph a/k/a
Donna M. Ralph
Amount Due $ 67,398.12
Interest $ 1,848.04
Atty's Comm
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County,
for debt, interest and costs, upon the following described property of the defendant(s)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
Andrew M. Ralph and Donna Marie Ralph, a/k/a Donna M. Ralph
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
cZ
Date ? °2 ?? dv Signature:
Print Name: Kristine M. Faust
Address:
Attorney for:
Telephone:
Supreme Court ID No.:
One Gateway Center, 9 West
Plaintiff
(412) 281-7650
77991
(over)
Notes: If real property, supply six copies of description including improvements and an original and copy of
affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
r
r
?[ N m
CT
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-1730 CIVIL 19 _
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due $67, 398.12
PLAINTIFF(S)
from
D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell
17 B 1,--- ood Drive
Camp Hill,.PA 17011
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyoneother
than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $67,398.12 L.L.
Interest 1,848.04 Due Prothy
Atty's Comm
Atty Paid
Plaintiff Paid
Date:
Other Costs
Prothonotary, Civil Division
REQUESTING PARTY:
Name Kristine M. Faust
AddresSOne Gateway Center, 9 West
Pittsburgh. PA 15222
Attomeyfor: Plaintiff, Washington Mutual Bank, F.A.
Telephone: (412) 281-7650
by:
Deputy
Supreme Court ID No. 77991
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A., CIVIL DIVISION
Plaintiff,
NO.: 02-1730
vs.
D. ANDREW RALPH and
DONNA MARIE RALPH a/k/a
DONNA M. RALPH,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in
the Township of East Pennsboro in the County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows:
BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is
295.06 feet north of the northwesterly corner of Glenwood Drive (West) and Erford Road
(West), and at dividing line between Lots 3X and 4, Block "H" on the hereinafter mentioned Plan
of Lots; thence along said dividing line, North 63 degrees 30 minutes West, 115 feet to a point;
thence along the easterly line of Lots 23X and 23, North 26 degrees 30 minutes East, 37.5 feet to
a point at the dividing line between Lots 4 and 4X, Block "H" on said plan; thence along said
dividing line, South 63 degrees 30 minutes East and through the center of a partition wall and
beyond, 115 feet to a point on the westerly line of Glenwood Drive (West), aforesaid; thence
along same, South 26 degrees 30 minutes West, 37.5 feet to a point, thence place of
BEGINNING
BEING KNOWN as 17-B Glenwood Drive (West), Camp Hill, Pennsylvania 17011.
BEING Lot No. 4, Block "H", Plan No. 10, Ridley Park, recorded in Cumberland
County Plan Book 18, Page 47.
o O
'v S
ITI
C)
y rn
J
«
BEING THE SAME PREMISES which Kirk Sell and Alexis E. Sell, husband and wife,
by Deed dated May 9, 1994 and recorded May 11, 1994 in the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book 105, Page 257, granted and conveyed unto D.
Andrew Ralph and Donna Marie Ralph, husband and wife.
GRENEN & BIRSIC, P.C.
By teL? '41?
Kri tyre M. Faust, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED INTHE TOWNSHIP
OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF
PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND
NUMBERED AS 17-B GLENWOOD DRIVE, CAMP HILL, PENNSYLVANIA 17011. DEED
BOOK VOLUME 105, PAGE 257, BLOCK AND PARCEL NUMBER 09-16-1050-285.
? J
1
V
7Z
w cF
G rv
T -G
' r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A., CIVIL DIVISION
Plaintiff,
NO.: 02-1730
vs.
D. ANDREW RALPH and
DONNA MARIE RALPH a/k/a
DONNA M. RALPH,
Defendants.
AFFIDAVIT OF LAST KNOWN ADDRESS
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF CUMBERLAND )
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Faust, attorney for the Plaintiff, who being duly
sworn according to law deposes and says that the owner of the property located at 17 B Glenwood
Drive, Camp Hill, Pennsylvania 17011 are, Defendants, D. Andrew Ralph and Donna Marie Ralph
a/k/a Donna M. Ralph, who reside at 17 B Glenwood Drive, Camp Hill, Pennsylvania 17011, to the
best of her information, knowledge and belief.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS 6&4AY OF MC-i 2002.
Qc?o1C1 ? (? A ? ?? o ? c?c>r?C1`1
Notary Public
Notarial Seal
Patricia A. Townsend, Notary Public
City of Pittsburgh, Allegheny County
My Commission Expires June 2, 2003
Member, PennsylvaniaAssociation of Notaries
v ru .
z>
C
CT -?;
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A., CIVIL DIVISION
Plaintiff,
NO.: 02-1730
vs.
D. ANDREW RALPH and
DONNA MARIE RALPH a/k/a
DONNA M. RALPH,
Defendants.
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974, 41 P.S.101, ET SEQ.
AND ACT 91 OF 1983
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF CUMBERLAND )
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Faust, attorney for the Plaintiff, who being duly
sworn according to law deposes and says that Plaintiff was not required to send Defendants written
notices pursuant to 35 P.S. § I680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983
- Act 91 of 1983) prior to the commencement of this action for the reason that the aforesaid
Mortgage is insured by the Federal Housing Administration under Title II of the National Housing
Act (12U.S.C. §§1701-1715z-18) [35 P.S. §1680.401C(a)(3)]
Additionally, Plaintiff was not required to send Defendants written notices of Plaintiffs
intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the
commencement of this action for the reasons that said Mortgage is not a "residential mortgage" as
defined in 41 P.S. §101 and the Defendants are not a "residential mortgage debtor" as defined in 41
P.S. §101.
v
SWORN TO AND SUBSCRIBED BEFORE
ME THIS DAY OF , 2002.
Notary Public
al seat
send, Notary Public
, Allegheny County
xpires June 2. 2(103iaASSOdation of Notaries
ga
c rv -,
mr
c
t'j
.J
cr,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A., CIVIL DIVISION
Plaintiff,
NO.: 02-1730
VS.
D. ANDREW RALPH and
DONNA MARIE RALPH a/k/a
DONNA M. RALPH,
Defendants.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF CUMBERLAND )
Washington Mutual Bank, F.A., Plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information concerning the real
property of D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph located at 17 B
Glenwood Drive, Camp Hill, Pennsylvania 17011 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS 17-B GLENWOOD DRIVE, CAMP HILL,
PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257, BLOCK AND PARCEL
NUMBER 09-16-1050-285.
1. The name and address of the owner(s) or reputed owner(s):
D. Andrew Ralph and
Donna Marie Ralph a/k/a
Donna M. Ralph
17-B Glenwood Drive
Camp Hill, PA 17011
2. The name and address of the defendants in the judgment:
D. Andrew Ralph and
Donna Marie Ralph a/k/a
Donna M. Ralph
17-B Glenwood Drive
Camp Hill, PA 17011
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Washington Mutual Bank, F.A. PLAINTIFF
4. The name and address of the last record holder of every mortgage of record:
Washington Mutual Bank F.A.
CitiFinancial, Inc.
PLAINTIFF
3401 Hartzdale Dr. #126
Camp Hill, PA 17011
5. The name and address of every other person who has any record lien on the property:
Domestic Relations Office
P.O. Box 320
Carlisle, PA 17013
PA Dept of Revenue
Commonwealth of Pennsylvania
Inheritance Tax Division
Bureau of Individual Taxes Dept. 280601
Harrisburg, PA 17128-0601
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
None
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
None
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities.
Kristine . Faus , Esquire
Attorney for Plaintiff
SWORN to and subscribed before
me this q$day of Cb tt , 2002.
Notary Public
Notarial Seal
Patricia A. Townsend, Notary Public
City of Pittsburgh. Allegheny County
My Commission Expires June 2. 2003
Member, Pennsylvania Association of Notaries
C---
C-
-
TI
c-5
L
a n
tT
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A., CIVIL DIVISION
Plaintiff,
NO.: 02-1730
vs.
D. ANDREW RALPH and
DONNA MARIE RALPH a/k/a
DONNA M. RALPH,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129.2(c)
TO: Domestic Relations Office
P.O. Box 320
Carlisle, PA 17013
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
on September 4, 2002, at 10:00 A.M., the following described real estate which D. Andrew
Ralph and Donna Marie Ralph a/k/a Donna M. Ralph, are the owners or reputed owners and on
which you may hold a lien or have an interest which could be affected by the sale:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS 17-B GLENWOOD DRIVE, CAMP HILL,
PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257, BLOCK AND PARCEL
NUMBER 09-16-1050-285.
The said Writ of execution has been issued on a judgment in the action o£
Washington Mutual Bank, F.A.,
Plaintiff,
VS.
D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph,
Defendants,
at Execution Number 02-1730 in the amount of $69,246.16.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs sale or this Notice,
you should contact your attorney as soon as possible.
GRENEN & BIRSIC, P.C.
Dated: 16 /14/6 z
Kristine M. Faus , squire
Attorneys for Plaintiff
21-
ON .y
40
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A., CIVIL DIVISION
Plaintiff,
vs.
ISSUE NUMBER:
D. ANDREW RALPH and DONNA NO.: 02-1730
MARIE RALPH A/K/A DONNA M.
RALPH,
Defendants.
TYPE OF PLEADING:
Pa. R.C.P. RULE 3129.2(c)(2)
PURSUANT TO RULE 3129.1
LIENHOLDER AFFIDAVIT OF
SERVICE
CODE-
FILED ON BEHALF OF PLAINTIFF:
Washington Mutual Bank, F.A.
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Faust, Esquire
Pa. I.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
9 West
Pittsburgh, PA 15222
(412) 281-7650
SALE DATE: September 4, 2002
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A., CIVIL DIVISION
Plaintiff,
NO.: 02-1730
vs.
D. ANDREW RALPH and DONNA
MARIE RALPH A/K/A DONNA M.
RALPH,
Defendants.
Pa. R.C.P. RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Faust, Attorney for Plaintiff, Washington Mutual Bank, F.A., being duly
sworn according to law, deposes and makes the following Affidavit regarding service of the
notice of the sale of real property on all persons named in Paragraphs 3 through 7 of Plaintiff s
Affidavit Pursuant to Rule 3129.1 as follows:
1. By letters dated May 22, 2002, undersigned counsel served all persons (other than
the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1
with a notice of the sale of real property by ordinary mail at the respective addresses set forth in
the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pursuant to Rule
3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked Exhibit
"A", attached hereto, and made a part hereof.
I verify that the facts contained in this Affidavit are true and correct based upon my
personal knowledge, information and belief.
GRENEN & BIRSIC, P.C.
BY:
Kristine M. Fa st, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Sworn to and subscribed before
me this 'L'KY of 2002.
Notary Public
Notarial Seal Public
Wreghn,l Nota n iry County5
Joanne M. l
00 19,
Cltyommissio U Exp es June 2
My C
Member, Pennsylvania Association °t Notaries
EXHIBIT A
6 0
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK, F.A., CIVIL DIVISION
Plaintiff,
NO.: 02-1730
vs.
D. ANDREW RALPH and
DONNA MARIE RALPH a/k/a
DONNA M. RALPH,
Defendants.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF CUMBERLAND )
Washington Mutual Bank, F.A., Plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information concerning the real
property of D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph located at 17 B
Glenwood Drive, Camp Hill, Pennsylvania 17011 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS 17-B GLENWOOD DRIVE, CAMP HILL,
PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257, BLOCK AND PARCEL
NUMBER 09-16-1050-285.
1. The name and address of the owner(s) or reputed owner(s):
D. Andrew Ralph and
Donna Marie Ralph a/k/a
Donna M. Ralph
17-B Glenwood Drive
Camp Hill, PA 17011
2. The name and address of the defendants in the judgment:
D. Andrew Ralph and
Donna Marie Ralph a/k/a
Donna M. Ralph
17-B Glenwood Drive
Camp Hill, PA 17011
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Washington Mutual Bank, F.A. PLAINTIFF
4. The name and address of the last record holder of every mortgage of record:
Washington Mutual Bank F.A. PLAINTIFF
CitiFinancial, Inc. 3401 Hartzdale Dr. #126
Camp Hill, PA 17011
5. The name and address of every other person who has any record lien on the property:
Domestic Relations Office
P.O. Box 320
Carlisle, PA 17013
PA Dept of Revenue
Commonwealth of Pennsylvania
Inheritance Tax Division
Bureau of Individual Taxes Dept. 280601
Harrisburg, PA 17128-0601
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
None
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
0
None
•
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities.
Kristine M/ Fadsr, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
me this C?Q C&-day of a 12002.
Notary Public
Notarial Seal
Patricia A. Townsend, Notary Public
City of Pittsburgh, Allegheny County
My Commission Expires June 2. 2003
Member, Pennsylvania Association of Notaries
0-4
d
d
'
c?
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL
DOES NOT
,
,
PROVIDE FOR INSURANCE-POSTMASTER
Received From: ?f
MEN RlRSIr a
ONE GATEWAY CENTER, NINE WEST
A. 52
I
One place of ordinary
mail addressed to-
r
NY
;
S ask,
POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From GRENEN & BIRSIC < - y
ONE GATEWAY CENTER, NINEIWES
One piece of ordinary mail aouWad to: - J G
?x aU Lill
P,% Form 3817, January
-7?-agIb
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
GREN N R RIRSIf
ONE GATEWAY CENTER
t
NINE
,
V. t„
MISHUHUH, PA. 15222 U, a
P piece of o ry mail addressed to,
`:'?' •yr
:
Q
; _ Sn
r ?. v
1 CPA
.
rn
in starF
or a
post mLwk. In u of
ostmasterfo ero
fee. w
c
ttt IILI
V
?Q
C i
4
U= ='; f
??
I
A
i
L
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-1730 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, F.A. PLANTIFF(S)
From D. ANDREW RALPH AND DONNA MARIE RALPH a/k/a DONNA M. RALPH, 17b
GLENWOOD DR., CAMP HILL PA 1701 L.
(1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE
LOCATED AT 17B GLENWOOD DR., CAMP HILL PA 17011. (SEE ATTACHED 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/are enjoined
from paying any debt to or for the account of the defendant (s) and from delivering any property of the
defendant (s) or otherwise disposing thereof;
(3) 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 $67,398.12
Interest $1,848.04
Atty's Comm %
Atty Paid $126.35
Plaintiff Paid
L.L. $.50
Due Prothy $1.00
Other Costs
Date: MAY 29, 2002
REQUESTING PARTY:
Name KRISTINE M. FAUST, ESQ.
Address: ONE GATEWAY CENTER, 9 WEST
PITTSBURGH PA 15222
Attorney for: PLAINTIFF
Telephone: (412) 281-7650
Supreme Court ID No. 77991
CURTIS R. LONG
Prot
By:
Washington Mutual Bank, F.A.
VS
D. Andrew Ralph and Donna Marie Ralph
a/k/a Donna M. Ralph
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-1730 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Kristin Faust.
Sheriff's Costs:
Docketing 30.00
Surcharge 30.00
Law Library .50
Prothonotary 1.00
Mileage 20.70
Levy 15.00
Advertising 15.00
Posting Handbills 15.00
Share of Bills 25.20
Poundage 14.99
Law Journal 321.20
Patriot News 251.35
Postpone Sale 20.00
Certified Mail 4.78
$ 764.72 paid by attorney
11/25/02
Sworn and subscribed to before me S er ??a?
This q G' day of
R. Thomas Kline, Sheriff
2002, A.D.?
BYE. LI" )
Prothonotary
Real Estate Deputy
SZ)
;?? i3z 3v7
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
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. 44
Writ No. 2002-1730 Civil
Washington Mutual Bank, F.A.
vs.
D. Andrew Ralph and
Donna Marie Ralph, a/k/a
Donna M. Ralph
Atty.: Kristine Faust
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract or par-
cel of land and premises, situate,
lying and being in the Township of
East Pennsboro in the County of
Cumberland and Commonwealth of
Pennsylvania, more particularly de-
scribed as follows:
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
9 day of AUGUST, 2002
LOIS E. SNYDEER,,NNotary Public
BEGINNING at a point on the My C=*61M westerly line of Glenwood Drive M&-Ch 5, W
(West), which point is 295.06 feet
north of the northwesterly corner
of Glenwood Drive (West) and Erford
Road (West), and at dividing line
between Lots 3X and 4, Block "H"
on the hereinafter mentioned Plan
of Lots; thence along said dividing
line, North 63 degrees 30 minutes
West, 115 feet to a point; thence
along the easterly line of Lots 23X
and 23, North 26 degrees 30 min-
utes East, 37.5 feet to a point at
the dividing line between Lots 4 and
4X, Block "H" on said plan; thence
along said dividing line, South 63
degrees 30 minutes East and through
the center of a partition wall and
beyond, 115 feet to a point on the
westerly line of Glenwood Drive
(West), aforesaid; thence along same.
South 26 degrees 30 minutes West,
37.5 feet to a point, thence place of
BEGINNING.
BEING KNOWN as 1.7-B Glenwood
Drive (West), Camp Hill, Pennsylva-
nia 17011.
BEING Lot No. 4, Block "H", Plan
No. 10, Ridley Park, recorded in
Cumberland County Plan Book 18,
Page 47.
BEING THE SAME PREMISES
which Kirk Sell and Alexis E. Sell,
husband and wife, by Deed dated
May 9, 1994 and recorded May 11,
1994 in the Recorder of Deeds in
and for Cumberland County, Penn-
sylvania, in Deed Book 105, Page
257, granted and conveyed unto D.
Andrew Ralph and Donna Marie
Ralph, husband and wife.
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 resclution 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 Miscellaneot,is Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
SALE#44
REAL ESTATE SALE No. 44
Writ No. 2002-1730
Civil Term
Washington Mutual
Bank, F.A.
vs
D Andrew Ralph and
Donna Marie Ralph
a/k/a Donna M. Ralph
DESCRIPAttN. Kristine Faust
ALL THAT CERTAIN tract or parcel of land and
premises, situate, lying and being in the
Township of East Pennsboro in the County of
Cumberland and Commonwealth of
Pennsylvania, more particularly described as
follows:
BEGINNING at a point on the westerly line of
Glenwood Drive (West), which point is 295.06
feet northwesterly comer of Glenwood Drive
(West) and Erford Road (West), and at dividing
line between Lots 3X and 4, Block "H" on the
hereinafter mentioned Plan of Lots; dmce along
Sworn to and subscribed before me
Notarial Seal /
Terry L. Russell, Notary Public
City Of Harrisburg, Dauphin County
My Commission Expires June 6, 2006
Member, Pennsylvania Association (X Notaries
14th day
A. D.
NOTARY PUBLIC
commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFF=S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates
Probating same Notary Fee(s)
Total
$ 249.60
$ 1.75
$ 251.35
said mviaing line. North 63 degrees 30 minutes 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. Wesl,;_ tl5 feet to a point; thence alb the
easterly line of Lots 23X and 23, North 26
degrees 30 minutes East, 37.5 feet to a point at
the dividing line between Lots 4 and 4X, Block
"H" on said plan; thence along said dividing line,
By ....................................................................
South 63 degrees 30 minutes East and through
the center of a partition wall and beyond, I 15 BEING THE SAME PREMISES which Kirk Sell
feet to a point on the westerly line of Glenwood and Alexis E. Sell, husband and wife, by Deed
Drive (west), aforesaid; thence along same, South dated May 9,1994 and recorded May IL 1994 in
26 degrees 30 minutes West, 37.5 feet to a point, the Recorder of Deeds in and for Cumberland
thence place of BEGINNING. County, Pennsylvania, in Deed Book 105, Page
BEING KNOWN as 17-B Glenwood Drive
(west), Camp Hill, Pennsylvania 17011. 257, granted and conveyed unto D. Andrew
Ralph and Donna Marie Ralph, husband and
BEING Lot NoA Block "H", Plan No. 10, wife.
Ridley Park, recorded in Cumberland County
Plan Book 18, Page 47.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Washington Mutual Bank, F.A.
vs.
D. Andrew Ralph and
Donna Maire Ralph a/k/a
Donna M. Ralph
( ) Confessed Judgment
? ) Other Writ of Execution
File No. 02-1730 Civil Term
Amount Due$67,398.12
Interest 92640.90
Atty's Comm
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Cumberland
- Issue writ of execution in the above matter to the Sheriff of ?+? - _ ---- County,
for debt interest and costs, upon the following described property of the defendant(s)
1?-B, Glenwood Drive, Camp Hill, PA 17011
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the. Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit. Date 01/15/04 Signature: CC 26
?'?7CC cx f.G?z/
Kristine M. Anthou
Print Name:
Address:
Attorney for:
Telephone:
Supreme Court ID No.:
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
Plaintiff
412 281-7650
77991
(over)
Notes: If real property, supply six copies of description including improvements and an original and copy of
affidavit of ownership (PaR.C.P. No. 3129).
7??1v
R?
y
f
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
fa
? w
'{9,n
C f
(-??
1 ?
r \
wl \ h
1
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-1730 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, F.A., Plaintiff (s)
From D. ANDREW RALPH AND DONNA MARIE RALPH A/K/A DONNA M. RALPH
(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 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 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 $67,398.12
Interest $9,640.90
Atty's Comm %
Atty Paid $903.57
Plaintiff Paid
Date: JANUARY 21, 2004
(Seal)
L.L.
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Prothonottat
By: -Kir /L1 P , P.
Deputy
REQUESTING PARTY:
Name KRISTINE M. ANTHOU, ESQUIRE
Address: ONE GATEWAY CENTER, NINTH FLOOR
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
5?" 4. J'--
Supreme Court ID No. 77991
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
Donald Andy & Donna Marie Ralph,
Debtors.
Washington Mutual Home Loans, Inc.,
VS.
Movant,
Donald Andy & Donna Mane Ralph,
Debtors, and Charles J. DeHart, III, Trustee,
Respondents,
"AwwOwy, PA
SM TYAII r_1.?4 P.M.
2 7 2003
64K, U.a. aw
h?rr
ORDER OF COURT
hh ?
AND NOW, this d 7 day of ?r? 2003, upon consideration of
the foregoing Certificate of Default, filed on behalf of Washington Mutual Home Loans, Inc., it is
hereby ORDERED, ADJUDGED, and DECREED that the Default is granted and the automatic stay
is terminated as it affects the interests of Movant in the real property and improvements thereon
commonly known as 17B Glenwood Drive, Camp Hill, Pennsylvania, 17011.
BY THE COURT:
4 MAH)(Q. FRANCE
Mary D. France
U.S. Bankruptcy Judge
Loan No. 6162674482
BANKRUPTCY CASE NO.: 1-02-0473 1 -MDF
CHAPTER 13
Ls
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL CIVIL DIVISION
BANK, F.A.,
Plaintiff,
NO.: 02-1730 CIVIL TERM
Vs.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
Washington Mutual Bank, F.A., Plaintiff in the above action, sets
forth as of the date the Praecipe for the Writ of Execution was filed
the following information concerning the real property of D. Andrew
Ralph and Donna Marie Ralph a/k/a Donna M. Ralph, located at 17-B,
Glenwood Drive, Camp Hill, PA 17011, and is more fully described as
follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CITY OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AS 17-B, GLENWOOD DRIVE, CAMP
HILL, PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257. TAX PARCEL
NUMBER 09-16-1050-285.
1
2
The name and address of the owners or reputed owners:
D. Andrew Ralph 17-B, Glenwood Drive
Donna Marie Ralph a/k/a Camp Hill, PA 17011
Donna M. Ralph
The name and address of the defendants in the judgment:
D. Andrew Ralph 17-B, Glenwood Drive
Donna Marie Ralph a/k/a Camp Hill, PA 17011
Donna M. Ralph
3. The name and last known address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Bank, F.A. Plaintiff
Commonwealth of PA Department of Welfare
P. O. Box 2675
Harrisburg, PA 17105
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Bank, F.A
Citifinancial Inc.
Plaintiff
3401 Hartzdale Drive 126
Camp Hill, PA 17011
5. The name and address of every other person who has any record lien
on the property:
PA Department of Revenue
Domestic Relations
Office
Tax Assessment Office
Bureau of Individual Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
P. O. Box 320
Carlisle, PA 17013
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
6. The name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
None
7. The name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be affected
by the sale:
Tenant (s) or
Current Occupant (s)
17-B, Glenwood Drive
Camp Hill, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification tc
authorities.
BY:? 4C ?l CSC'?2?'l??« 6?/
Kri e M. thou, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
me this a _ day of L--FU) ILL"
NA pu
Notary Pubblic
,2004.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Gerald L. Potter, Jr., Notary Public i
City Of Pittsburgh. ABegheny County
MY Commission E)ires Dec. 10, 2007
Member, Pennsylvania Association Of Notaries
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL CIVIL DIVISION
BANK, F.A.,
Plaintiff,
NO.: 02-1730 CIVIL TERM
VS.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: D. ANDREW RALPH
17-B, Glenwood Drive
Camp Hill, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out
of the Court of Common Pleas of Cumberland County, Pennsylvania, and to
the Sheriff of Cumberland County, directed, there will be exposed to
Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COMMISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17103
on June 09, 2004, at 10:00 A.M., the following described real estate,
of which D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph
are the owners or reputed owners:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CITY OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AS 17-B, GLENWOOD DRIVE, CAMP
HILL, PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257. TAX PARCEL
NUMBER 09-16-1050-285.
The said Writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL
BANK, F.A.,
Plaintiff,
vs.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
at Execution Number 02-1730 CIVIL TERM in the amount of $77,039.02.
Claims against the property must be filed with the Sheriff before
the above sale date.
Claims to proceeds must be made with the office of the Sheriff
before distribution.
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must
be filed with the Office of the Sheriff no later than ten (10) days from
the date when Schedule of Distribution is filed in the office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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
ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717)249-3166
(800)990-9108
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after service of the Complaint for Mortqaqe Foreclosure and Notice to
Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE
ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
GRENEN & BIRSIC, P.C.
Kr tine M. Pj thou, Esquire
Attorney for Plaintiff
SHERIFF'S SALE DATE: JUNE 09, 2004
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL
BANK, F.A.,
Plaintiff,
VS.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
CIVIL DIVISION
NO.: 02-1730 CIVIL TERM
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF ALLEGHENY )
Washington Mutual Bank, F.A., Plaintiff: in the above-captioned
action files the instant Supplemental Affidavit: Pursuant to Rule 3129.1.
The information identified below is in addition to the information
previously identified in the Affidavit Pursuant to Rule 3129.1.
As of the date that the Praecipe for Writ of Execution was filed,
the information set forth below was of record concerning the real
property of D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph,
and is more fully described as follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF
EAST PENNSBORO, CITY OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AS 17-B, GLENWOOD DRIVE, CAMP
HILL, PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257. TAX PARCEL
NUMBER 09-16-1050-285.
1. The name and last known address of every judgment
creditor whose judgment is a record lien on the property to be sold:
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025
I verify that the statements made in the Supplemental Affidavit are
true and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification
to authorities.
Kristine, M. Anthou, Esquire
Attorney's for Plaintiff
SWORN TO and SUBSCRIBED BEFORE ME
THIS 07W DAY OF A10" , 2004.
Notary Public
COMWEALTH OF PENNSYLVANIA
MOO L. Potter, JrSNoltary Pu61ic
MY M OfMONPlttsfwe Allegheny County
Commission Expires Dec_ 10, 2007
Member. Pennsylvania gssociation of Notaries
-c- -r7
-i
r-
r\) p - m
C!D
d
- j L1J
C l?J
- ? Ul
SHERIFF'S SALE DATE: JUNE 09, 2004
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL
BANK, F.A.,
CIVIL DIVISION
Plaintiff,
NO.: 02-1730 CIVIL TERM
ISSUE NUMBER:
Vs.
D.ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
TYPE OF PLEADING:
Pa. R.C.P. RULE 3129.2(c)
AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
CODE -
FILED ON BEHALF
OF PLAINTIFF: Washington
Mutual Bank, F.A.
COUNSEL OF RECORD
FOR THIS PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL CIVIL DIVISION
BANK, F.A.,
Plaintiff, NO.: 02-1730 CIVIL TERM
VS.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
I, Kristine M. Anthou, Esquire, Attorney for Plaintiff, Washington
Mutual Bank, F.A., being duly sworn according to law deposes and makes
the following Affidavit regarding service of Plaintiff's notice of the
sale of real property in this matter on May 18, 2004 as follows:
1. D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph
are the owners of the real property and have not entered an appearance
of record.
2. The undersigned counsel served Defendant, D. Andrew Ralph,
with a true and correct copy of Plaintiff's notice of the sale of real
property by certified mail, return receipt requested, restricted
delivery. A true and correct copy of said Notice is marked Exhibit "A",
attached hereto and made a part hereof.
3. On or about February 2, 2004, Defendant, D. Andrew Ralph,
received the notice of the sale of real property in this matter as
evidenced by the signed U.S. Postal Service form 3811, certified mail,
return receipt requested, restricted delivery. A true and correct copy
of the signed U.S. Postal Service form 3811, evidencing service by
certified mail, return receipt requested, restricted delivery on the
identified Defendant, is marked Exhibit "B", attached hereto and made a
part hereof.
4. The undersigned counsel served Defendant, Donna Marie Ralph
a/k/a Donna M. Ralph, with a true and correct copy of Plaintiff's notice
of the sale of real property by certified mail, return receipt requested,
restricted delivery. A true and correct copy of said Notice is marked
Exhibit "C", attached hereto and made a part hereof.
5. On or about February 2, 2004, Defendant, Donna Marie Ralph
a/k/a Donna M. Ralph, received the notice of the sale of real property
in this matter as evidenced by the signed U.S. Postal Service form 3811,
certified mail, return receipt requested, restricted delivery. A true
and correct copy of the signed U.S. Postal Service form 3811, evidencing
service by certified mail, return receipt requested, restricted delivery
on the identified Defendant, is marked Exhibit "D", attached hereto and
made a part hereof.
I verify that the facts contained in this Affidavit are true and
correct based upon my personal knowledge, information, and belief.
GRENEN & BIRSIC,, P. C.
BY: 'k- ?- c. i K C c C /- 4Q
Kr ine M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-765()
SWORN TO AND SUBSCRIBED BEFORE ME
THIS ( `:ITU DAY OF Hat, 2004.
Notary Public
COMMONWEACfH OF PENNSYLVANIA
Notarial Seal
Gerald L. Potter, Jc, Notary Public
City Of Pittsburgh, Allegheny County
My Commission Expires Dec. 10, 2007
Member, Pennsylvania Association Of Notaries
EXHIBIT "A"
•
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL CIVIL DIVISION
BANK, F.A.,
Plaintiff,
NO.: 02-1730 CIVIL TERM
V8.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: D. ANDREW RALPH
17-B, Glenwood Drive
Camp Hill, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued
out of the Court of Common Pleas of Cumberland County, Pennsylvania,
and to the Sheriff of Cumberland County, directed, there will be
exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COb;MISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17103
on June 09, 2004, at 10:00 A.M., the following described real estate,
of which D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph
are the owners or reputed owners:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CITY OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AS 17-B, GLENWOOD DRIVE, CAMP
HILL, PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257. TAX PARCEL
NUMBER 09-16-1050-285.
# •
The said writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL
BANK, F.A.,
Plaintiff,
VS.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
at Execution Number 02-1730 CIVIL TERM in the amount of $77,039.02.
Claims against the property must be filed with the sheriff before
the above sale date.
Claims to proceeds must be made with the Office of the Sheriff
before distribution.
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thirty (30) days from sale: date.
Exceptions to Distribution or a Petition to Set Aside the Sale must
be filed with the Office of the Sheriff no later than ten (10) days from
the date when Schedule of Distribution is filed in the Office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you. wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF ]EXECUTION 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
ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717) 249-3166
(800)990-9108
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after service of the Complaint for Mortgage Foreclosure and Notice to
Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made -a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO,HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE: PRICE OR, IF THERE
ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
GRENEN & BIRSIC, P.C.
-`u G.C O-i.-
By:
Kris ne PQ. Anthou, Esquire
Attorney for Plaintiff
EXHIBIT "B"
i ¦ Complete items 4, 2, and 3. Also complete' A. s nab" 0,
? Agent
item 4 if Restricted Delivery is desired. f
¦ Print your name and address on the reverse Addressee
so that we can return the card to you. B Rte,
?y ivery
j ¦ Attach this card to the (rack of the mailpiece. /
rmits
rt if
h
f It"
.
space pe
or on t
e
ror
ass n it?m t?
li
e
adc#
I
d
v
Q
s
e
ry
i . Article Addressed to: If YES. alter detiveryX be ?
?11N a
tku ZP\ 1 o & 'Service Type
r MaU. ? Express Matt
? Registered g Eietum Receipt for Merchandise
krsured Mal! ? aoD
4. Restricted Deliver? (Extra F&O btes
2. Article Number 7003 2260 0006 0422 25101
I P$ Fhrrrr 3I,`At'21 t ` ` ` Dbrnestlctcat? Receipt 102505-024A-1540
EXHIBIT "C"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL CIVIL DIVISION
BANK, F.A.,
Plaintiff,
VS.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
NO.: 02-1730 CIVIL TERM
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: DONNA MARIE RALPH A/K/A
DONNA M. RALPH
17-B, Glenwood Drive
Camp Hill, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out
of the court of Common Pleas of Cumberland County, Pennsylvania, and to
the Sheriff of Cumberland County, directed, there will be exposed to
Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COMMISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17:103
on June 09, 2004, at 10:00 A.M., the following described real estate,
of which D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph
are the owners or reputed owners:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CITY OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AS 17-13, GLENWOOD DRIVE, CAMP
HILL, PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257. TAX PARCEL
NUMBER 09-16-1050-285.
0
?J
The said Writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL
BANK, F.A.,
Plaintiff,
vs
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
at Execution Number 02-1730 CIVIL TERM in the amount of $77,039.02.
Claims against the property must be filed with the Sheriff before
the above sale date.
Claims to proceeds must be made with the Office of the Sheriff
before distribution.
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must
be filed with the Office of the Sheriff no later than ten (10) days from
the date when Schedule of Distribution is filed in the Office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you. wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF :EXECUTION 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
ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717)249-3166
(800)990-9108
0
0
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those: rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after service of the Complaint for Mortgage Foreclosure and Notice to
Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging aa,valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE
ARE 'DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
GRENEN & B:CRSIC, P.C.
By:
Kri ine M. Aithou, Esquire
Attorney for Plaintiff
EXHIBIT "D"
¦ Complete items V2, and 3. Also complete ,
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpieoe,
?N?.??? ?(? (?. ?.] ?Q?? ?j ? enter livery address beipiw ,` L7 No
r,
Aw/
{ 3. Type
+ l L A ?16 L L? "fled Ma(I ?, /Express Malt
U Registered ?,p.,(? Refum Receipt for Merchandise
? lnsw ed Mail LJ C.O.D.
J4. Restricted Delivery? (Exba Fee) Yes
2. Article Number - -
(ransferfrom service bW 7003 1010 0004 8783 2392
PS Form 3811, August 2001 Domestic Return Receipt
102505-024A-1540
j j:
1l7
CD
l I
.. ?? C. rn
SHERIFF'S SALE DATE: JUNE 09, 2004
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL
BANK, F.A.,
Plaintiff,
Vs.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
CIVIL DIVISION
NO.: 02-1730 CIVIL TERM
ISSUE NUMBER:
TYPE OF PLEADING:
Pa. R.C.P. RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT
OF SERVICE
CODE -
FILED ON BEHALF
OF PLAINTIFF: Washington
Mutual Bank, F.A.
COUNSEL OF RECORD
FOR THIS PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. # 77991
GRENEN & BIRSIC, P.C.
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL CIVIL DIVISION
BANK, F.A.,
Plaintiff, NO.: 02-1730 CIVIL TERM
VS.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
Pa. R.C.P. RULE 3129.2(c);2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Anthou, Attorney for Plaintiff, Washington Mutual
Bank, F.A., being duly sworn according to law, deposes and makes the
following Affidavit regarding service of the notice of the sale of real
property on all persons named in Paragraphs 3 through 7 of Plaintiff's
Affidavit Pursuant to Rule 3129.1 as follows:
1. By letters dated January 28, 2004 and February 3, 2004,
undersigned counsel served all persons (other than the Plaintiff) named
in Paragraphs 3 through 7 of Plaintiff's Affidavit Pursuant to Rule
3129.1 and Supplemental Affidavit Pursuant to Rule 3129.1 with a notice
of the sale of real property by ordinary mail at the respective addresses
set forth in the Affidavit Pursuant to Rule 3129.1. True and correct
copies of said Affidavit Pursuant to Rule 3129.1, Supplemental Affidavit
Pursuant to Rule 3129.1, U.S. Service Postal Forms 3817 and 3877, and any
letters, if returned as of this date, are marked Exhibit "A", attached
hereto, and made a part hereof.
I verify that the facts contained in this Affidavit are true and
correct based upon my personal knowledge, information and belief.
GRENEN & BIRSIC, P.C.
BY: C..it.-./C CsL
Kx?i e K. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Sworn to and subscribed before
me this ? day of ?ClA 2004.
otary Publi
COMMONWEALTH OF P
Sea ENIJSYLVANIA
Notarial l
Gerald L. Potter, Jr., Notary Public
Gty Of Pittsburgh, Allegheny County
!MV Commission Expires Dec. 10, 2007
MemUer. Pennsylvania Association of Notaries
EXHIBIT "A"
E
•
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL
BANK, F.A.,
Plaintiff,
Vs.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
CIVIL DIVISION
NO.: 02-1730 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
Washington Mutual Bank, F.A., Plaintiff in the above action, sets
forth as of the date the Praecipe for the Writ of Execution was filed
the following information concerning the real property of D. Andrew
Ralph and Donna Marie Ralph a/k/a Donna M. Ralph, located at 17-B,
Glenwood Drive, Camp Hill, PA 17011, and is more fully described as
follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CITY OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AS 17-B, GLENWOOD DRIVE, CAMP
HILL, PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257. TAX PARCEL
NUMBER 09-16-1050-285.
• 0
1
2
The name and address of the owners or reputed owners:
D. Andrew Ralph 17-B, Glenwood Drive
Donna Marie Ralph a/k/a Camp Hill, PA 17011
Donna M. Ralph ,
The name and address of the defendants in the judgment:
D. Andrew Ralph 17-B, Glenwood Drive
Donna Marie Ralph a/k/a Camp Hill, PA 17011
Donna M. Ralph
3. The name and last known address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Bank, F.A. Plaintiff
Commonwealth of PA Department of Welfare
P. 0. Box 2675
Harrisburg, PA 17105
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Bank, F.A
Citifinancial Inc.
Plaintiff
3401 Hartzdale Drive 126
Camp Hill, PA 17011
5. The name and address of every other person who has any record lien
on the property:
PA Department of Revenue
Domestic Relations
Office
Tax Assessment Office
Bureau of Individual Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
P. O. Box 320
Carlisle, PA 17013
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
6. The name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
None
•
•
7. The name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be affected
by the sale:
Tenant (s) or
Current Occupant (s)
17-B, Glenwood Drive
Camp Hill, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to
authorities.
BY: a'
Kri a Mi. thou, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
me this jRt day of , 3ZU DA?&4_, 2004.
d.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Gerald L Potber, Jr., Ndary
Pubic
City OFRtlsburo, AllepFreny County
My Cormwssion Ejires Dec. 10, 2007
Member, Pennsylvania Association Of Notaries
SHERIFF'S SALE DATE: JUNE 09, 2004
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL
BANK, F.A.,
Plaintiff,
VS.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
CIVIL DIVISION
NO.: 02-1730 CIVIL TERM
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF ALLEGHENY )
Washington Mutual Bank, F.A., Plaintiff in the above-captioned
action files the instant Supplemental Affidavit :Pursuant to Rule 3129.1.
The information identified below is in addition to the information
previously identified in the Affidavit Pursuant to Rule 3129.1.
As of the date that the Praecipe for Writ of Execution was filed,
the information set forth below was of record concerning the real
property of D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph,
and is more fully described as follows:
ALL THE RIGHT, TITLE INTEREST
DONNA MARIE RALPH A/K/A DONNA M.
DESCRIBED PROPERTY:
AND CLAIM OF' D. ANDREW RALPH AND
RALPH OF, IN AND TO THE FOLLOWING
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF
EAST PENNSBORO, CITY OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AS 17-8, GLENWOOD DRIVE, CAMP
HILL, PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257. TAX PARCEL
NUMBER 09-16-1050-285.
1. The name and last known address of every judgment
creditor whose judgment is a record lien on the property to be sold:
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025
I verify that the statements made in the Supplemental Affidavit are
true and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification
to authorities.
Kristine M. thou, Esquire
Attorneys for Plaintiff
SWORN TO and SUBSCRIBED BEFORE ME
THIS J5M DAY OF _, 2004.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial ;.,Membersylvania Asoation Of Notaries
7 Z
W N Z m
PD 7-4
c7 W '"d Y T N
>rt
o z - n p?? Hi X rGt a •o rtrtD 'a
(D ?4
IT ri C < Zw
-4 4 r K rr (D n £ O
J v p^ N ?D = m M1
F- z A MR
? P• rr c
n N
•Z G rOj rr K N•O v9N
i'
0 Q M N Z
o g?g M C' 7
b H N T
N Z r' FM'h co
v H. O 9 r3 S
m m n ,..? N fD y
v `? N M 8 C ...?
(D
O
? _ d H
J `' C wT 00130
C m x N
v '
'i Q
N
c- ! Z> Cj ro y ? x $
a* I -I I o w N F 8 00130
?•
? gm g
o
W
9 (!' GJ W J V V a?
o v v
y WW d
g v
a 2
a>
A St
? $C
2 g?
PITS
e
y? f 1??L
?
O
fffffk
PS Form 3817, January 2001
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 Sheriff's Deed in which Washing Mutual Bank F A is the grantee the same having been sold to said
grantee on the 9th day of June A.D., 2004, under and by virtue of a writ Execution issued on the 21st
day of Jan, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2002
Number 1730, at the suit of Washington Mutual Bank F A against D Andrew Ralph &Dona M is duly
recorded in Sheriff's Deed Book No. 263, Page 3542.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this Ay- day of
l'? Q , A.D2004
??
Rec rder of Deeds
neowder of oeK%, CumbeftMd CwMy, Conk, M
My CwwftW LV ne do RW Magq Of AIL 2M
Washington Mutual Bank, F.A.
VS
D. Andrew Ralph and Donna Marie
Ralph a/k/a Donna M. Ralph
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-1730 Civil Term
Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that
on February 17, 2004 at 6:17 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
defendants, to wit: D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph, by
making known unto Donna Ralph, personally and wife of D. Andrew Ralph, at 17-B
Glenwood 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 April 07, 2004 at 7:25 o'clock P.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 D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph located at
17-B Glenwood 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: D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph, by
regular mail to their last known address of 17-B Glenwood Drive, Camp Hill, PA 17011.
These letters were mailed under the date of April 06, 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 June 9, 2004 at 10:00 o'clock A.M. He sold the same for the
sum of $1.00 to Attorney Kristine Anthou for Washington Mutual Bank, F.A. It being
the highest bid and best price received for the same, Washington Mutual Bank, F.A. of
11200 West Parkland Ave., Milwaukee, WI 53224, being the buyers in this execution,
paid to Sheriff R. Thomas Kline the sum of $918.40.
Sheriffs Costs
Docketing $30.00
Poundage 18.01
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library
Prothonotary 1.00
Mileage 20.70
Levy 15.00
Surcharge 30.00
Law Journal 330.50
Patriot News 309.43
Share of Bills 29.26
Distribution of Proceeds 25.00
Sheriffs Deed 39.50
S 918.40
Sworn and subscribed to before me So Answers:
This day of 9L I R. Thomas Kline, Sheriff
2004, A.D. Q, )21,?/uy'
f t othonotary BY \jp ?Lvvu?-
Real EstatciDeputy
3°- CFO 1+?'
(, vU
AL-]S-°'1 Ck't(. zti9
Q 6 N 0 A 0 lt, h U +j-d-? pu? l S-2 S -C ?,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL CIVIL DIVISION
BANK, F.A.,
Plaintiff,
NO.: 02-1730 CIVIL TERM
VS.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
Washington Mutual Bank, F.A., Plaintiff in the above action, sets
forth as of the date the Praecipe for the Writ of Execution was filed
the following information concerning the real property of D. Andrew
Ralph and Donna Marie Ralph a/k/a Donna M. Ralph, located at 17-B,
Glenwood Drive, Camp Hill, PA 17011, and is more fully described as
follows:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CITY OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AS 17-B, GLENWOOD DRIVE, CAMP
HILL, PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257. TAX PARCEL
NUMBER 09-16-1050-285.
I
2
The name and address of the owners or reputed owners:
D. Andrew Ralph 17-B, Glenwood Drive
Donna Marie Ralph a/k/a Camp Hill, PA 17011
Donna M. Ralph
The name and address of the defendants in the judgment:
D. Andrew Ralph 17-B, Glenwood Drive
Donna Marie Ralph a/k/a Camp Hill, PA 17011
Donna M. Ralph
3. The name and last known address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
Washington Mutual Bank, F.A. Plaintiff
Commonwealth of PA Department of Welfare
P. O. Box 2675
Harrisburg, PA 17105
4. The name and address of the last record holder of every mortgage
of record:
Washington Mutual Bank, F.A
Citifinancial Inc.
Plaintiff
3401 Hartzdale Drive 126
Camp Hill, PA 17011
5. The name and address of every other person who has any record lien
on the property:
PA Department of Revenue
Domestic Relations
Office
Tax Assessment Office
Bureau of Individual Taxes
Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
P. 0. Box 320
Carlisle, PA 17013
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
6. The name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
None
7. The name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be affected
by the sale:
Tenant (s) or 17-B, Glenwood Drive
Current Occupant (s) Camp Hill, PA 17011
I verify that the statements made in the Affidavit are true and
correct to the best of my personal knowledge, information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to
authorities.
BY; ac c - L/E
Kri e M. 2 thou, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
me this ba-121 day of ,1(((( 2004.
=4 _
-'d, , k? NtR Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seai I
GeraM LPollen,al N Z=n
?y Of Mftburgh, AYegheny County
My Commstsion EVhes Dec. 10, 2007
Member, Pennsylvania Association Of Notaries
k
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL CIVIL DIVISION
BANK, F.A.,
Plaintiff,
NO.: 02-1730 CIVIL TERM
VS.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: D. ANDREW RALPH
17-B, Glenwood Drive
Camp Hill, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out
of the Court of Common Pleas of Cumberland County, Pennsylvania, and to
the Sheriff of Cumberland County, directed, there will be exposed to
Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COMMISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17103
on June 09, 2004, at 10:00 A.M., the following described real estate,
of which D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph
are the owners or reputed owners:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CITY OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AS 17-B, GLENWOOD DRIVE, CAMP
HILL, PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257. TAX PARCEL
NUMBER 09-16-1050-285.
The said Writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL
BANK, F.A.,
Plaintiff,
VS.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
at Execution Number 02-1730 CIVIL TERM in the amount of $77,039.02.
Claims against the property must be filed with the Sheriff before
the above sale date.
Claims to proceeds must be made with the Office of the Sheriff
before distribution.
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must
be filed with the Office of the Sheriff no later than ten (10) days from
the date when Schedule of Distribution is filed in the office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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
ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717)249-3166
(800)990-9108
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after service of the Complaint for Mortgage Foreclosure and Notice to
Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE
ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
GRENEN & BIRSIC, P.C.
By:
I
Kri3t ine M. Ai(thou, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL CIVIL DIVISION
BANK, F.A.,
Plaintiff,
NO.: 02-1730 CIVIL TERM
Vs.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: DONNA MARIE RALPH A/K/A
DONNA M. RALPH
17-B, Glenwood Drive
Camp Hill, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out
of the Court of Common Pleas of Cumberland County, Pennsylvania, and to
the Sheriff of Cumberland County, directed, there will be exposed to
Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
COMMISSIONERS' HEARING ROOM, SECOND FLOOR
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17103
on June 09, 2004, at 10:00 A.M., the following described real estate,
of which D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M. Ralph
are the owners or reputed owners:
ALL THE RIGHT, TITLE INTEREST AND CLAIM OF D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A DONNA M. RALPH OF, IN AND TO THE FOLLOWING
DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP
OF EAST PENNSBORO, CITY OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AS 17-8, GLENWOOD DRIVE, CAMP
HILL, PENNSYLVANIA 17011. DEED BOOK VOLUME 105, PAGE 257. TAX PARCEL
NUMBER 09-16-1050-285.
The said Writ of Execution has been issued on a judgment in the
mortgage foreclosure action of
WASHINGTON MUTUAL
BANK, F.A.,
Plaintiff,
vs.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
at Execution Number 02-1730 CIVIL TERM in the amount of $77,039.02.
Claims against the property must be filed with the Sheriff before
the above sale date.
Claims to proceeds must be made with the Office of the Sheriff
before distribution.
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must
be filed with the Office of the Sheriff no later than ten (10) days from
the date when Schedule of Distribution is filed in the Office of the
Sheriff.
This paper is a notice of the time and place of sale. It has been
issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise
you more specifically of these rights. If you wish to exercise your
rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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
ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PENNSYLVANIA 17013
(717)249-3166
(800)990-9108
You may have legal rights to prevent the Sheriff's Sale and the
loss of your property. In order to exercise those rights, prompt
action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by
filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection, you might have within twenty (20) days
after service of the Complaint for Mortgage Foreclosure and Notice to
Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid
claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right
you would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect in
the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE
ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD
FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF
HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE
DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10)
DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE
OFFICE OF THE SHERIFF.
GRENEN & BIRSIC, P.C.
By,?C LtiOv
Kris ne M. Anthou, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL CIVIL DIVISION
BANK, F.A.,
Plaintiff, NO.: 02-1730 CIVIL TERM
Vs.
D. ANDREW RALPH AND
DONNA MARIE RALPH A/K/A
DONNA M. RALPH,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being
in the Township of East Pennsboro in the County of Cumberland and Commonwealth
of Pennsylvania, more particularly described as follows:
BEGINNING at a point on the westerly line of Glenwood Drive (West), which point
is 295.06 feet north of the northwesterly corner of Glenwood Drive (West) and
Erford Road (West), and at a dividing line between Lots 3X and 4, Block "H" on
the hereinafter mentioned Plan of Lots; thence along said dividing line, North
63 degrees 30 minutes West, 115 feet tp a point; thence along the easterly line
of Lots 23X and 23, North 26 degrees 30 minutes East, 37.5 feet to a point at the
dividing line between Lots 4 and 4X, Block "H" on said plan; thence along said
dividing line, South 63 degrees 30 minutes East and through the center of a
partition wall and beyond, 115 feet to a point on the westerly line of Glenwood
Drive (West), aforesaid; thence along the same, South 26 degrees 30 minutes West,
37.5 feet to a point, thence place of BEGINNING.
BEING KNOWN as 17-13 Glenwood Drive, Camp Hill, Pennsylvania 17011.
BEING Lot No. 4, Block "H", Plan No. 10, Ridley Park, recorded in Cumberland
County Plan Book 18, Page 47.
TAX PARCEL NUMBER: 09-16-1050-285.
UNDER AND SUBJECT to conditions, restrictions and rights of record.
BEING the same premises which Kirk Sell and Alexis E. Sell, husband and wife,
by deed dated May 9, 1994 and recorded on May 11, 1994 in the Office of the
Recorder of Deeds for Cumberland County in Deed Book Volume 105, Page 257,
granted and conveyed unto D. Andrew Ralph and Donna Marie Ralph a/k/a Donna M.
Ralph, husband and wife.
DBV 105
Page 257
Tax Parcel Number 09-16-1050-285
nGRENN & BIRSIC, P.C.
By:
a M. ;thou, Esquire
Attorneys for Plaintiff
One Gateway Center,. Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-1730 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, F.A., Plaintiff (s)
From D. ANDREW RALPH AND DONNA MARIE RALPH A/K/A DONNA M. RALPH
(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 $67,398.12
Interest $9,640.90
Any's Comm %
Arty Paid $903.57
Plaintiff Paid
Date: JANUARY 21, 2004
(Seal)
REQUESTING PARTY:
Name KRISTINE M. ANTHOU, ESQUIRE
Address: ONE GATEWAY CENTER, NINTH FLOOR
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991
L.L.
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Prothonot ^
y
Deputy
% &12,1 r.
Real Estate Sale # 09
On February 13, 2004 the sheriff levied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA
Known and numbered as 17-B Glenwood Drive,
Camp Hill, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: February 13, 2004 By: 1
Real Estate"Deputy
a..
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Michael Morrow, being duly sworn according to law, deposes and says:
That he is the 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 April and the 4th and 11th
day(s) of May 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 Sworn to and subscribed efore mgAhif 28th day f Ma 4 A.D.
SALE #9 // /_ >
REAL ESTATE SALE No. 9 /"?
Writ No. 2002-1730 Terry L. Russell, Notary Public
Civil Term Gty of Harrisburg, Dauphin County NO' ARY PUBLIC
Washington Mutual Bank, FA L-, y Commission irene 62006
vs br,P,nnaylvanlaMaociationolNotaries My commission expires June 6, 2006
D. Andrew Ralph and
Donna Marie Ralph
a/k/a Donna M. Ralph CUMBERLAND COUNTY SHERIFF=S OFFICE
Atty: Kristine Anthou CUMBERLAND COUNTY COURTHOUSE
DESCRIPTION CARLISLE, PA. 17013
ALL THAT CERTAIN tract or parcel of land
and premises, situate, lying and being in the Statement of Advertising Costs
g
Township of East Pennsboro in the County of TO THE PATRIOT-NEWS CO.
Dr.
Cumberland and Commonwealth of
Pennsylvania, more particularly described as ,
For the notice or
publishing publication attached
follows: hereto on the above stated dates
BEGINNING at L point on the westerly line Total
of Glenwood Drive (West), which point is 295.06 $ 309.43
feet north of the norLSwesterly comer of
Glenwood Drive (West) and Erford Road (West), Publisher's
and at a_dividing line between en Lots 3X and 4, 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. Block lHi on the hereinafter mentioned Plan of
Lots; thence along said dividing fine, North 63
degrees 30 minutes West, 115 feet to a point;
thence along ?he easterly line of Lots 23X and 23,
By"""'
North 26 degrees 30 minutes East, 37.5 feet to a
point at the dividing fine between Lots 4 and 4X,
Block lHi on said plan; thence along said dividin
fine, South 63 degrees 30 minutes East and g AND SUBJECT
,
through the center of a partition wall and beyond,
115 feet to a point on the westerly line of restrxbow and rights of record.
BEING the Berne ses
which
Kuk Sell
?
Glenwood Drive (West), aforesaid; thence along
the same, South 26 degrees 30 minutes West, 37.5 and Alexis E. Sell, l
and
wife,
dated May 9, 1994 and recorded on Ma by deed
y 11,1994
feet to a point, thence place of BEGINNING. in the Office of the Recorder of Deeds for
Cumberland County in Deed Book V
lu
105
BEING KNOWN as 17-B Glenwood Drive,
Camp Hill; Pennsylvania 17011. o
me
,
Page 257, granted and conveyed unto D. Andrew
BEING Lot No. 4, Block 1111, Plan No. 10, Ralph an? Donna Marie Ralph a/k/a Donna M.
Ralph
husband and wife
Ridley Park, recorded in Cumberland County Plan
Book 18, Page 47. ,
.
DBV: 105; Page 257; Tax Parcel No. 09-16-
TAX PARCEL No.: 09-16-1050-285. 1050-285.
• 1, - . ..
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 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:
APRIL 16, 23, 30, 2004
Affiant further deposes that he is authorized to verify this statement by the Cumberland
r
Lisa Marie Co)1e, Editor
SWORN TO AND SUBSCRIBED before me this
30 day of APRIL 2004
NOTXR K SEAL V
LOIS E. SNYDER, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires March 5, 2005
Writ No. 2002-1730 Civil
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. 9
Washington Mutual Bank, FA
VS.
D. Andrew Ralph and
Donna Marie Ralph,
a/k/a Donna M. Ralph
Atty.: Kristine Anthou
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract or par-
cel of land and premises, situate, ly-
ing and being in the Township of East
Pennsboro in the County of Cum-
berland and Commonwealth of Penn-
sylvania, more particularly described
as follows:
BEGINNING at a point on the
westerly line of Glenwood Drive
(West), which point is 295.06 feet
north of the northwesterly corner
of Glenwood Drive (West) and Erford
Road (West), and at a dividing line
between Lots 3X and 4, Block "H"
on the hereinafter mentioned Plan
of Lots; thence along said dividing
line, North 63 degrees 30 minutes
West, 115 feet tp a point; thence
along the easterly line of Lots 23X
and 23, North 26 degrees 30 min-
utes East, 37.5 feet to a point at
the dividing line between Lots 4 and
4X, Block "H" on said plan; thence
along said dividing line, South 63
degrees 30 minutes East and through
the center of a partition wall and
beyond, 115 feet to a point on the
westerly line of Glenwood Drive
(West), aforesaid; thence along the
same, South 26 degrees 30 minutes
West, 37.5 feet to a point, thence
place of BEGINNING.
BEING KNOWN as 17-B Glen-
wood Drive, Camp Hill, Pennsylva-
nia 17011.
BEING Lot No. 4, Block "H", Plan
No. 10, Ridley Park, recorded in
Cumberland County Plan Book 18,
Page 47.
TAX PARCEL NUMBER: 09-16-
1050-285.
UNDER AND SUBJECT to con-
ditions, restrictions and rights of
record.
BEING the same premises which
Kirk Sell and Alexis E. Sell, hus-
band and wife, by deed dated May
9, 1994 and recorded on May 11,
1994 in the office of the Recorder
of Deeds for Cumberland County in
Deed Book Volume 105, Page 257,
granted and conveyed unto D. An-
drew Ralph and Donna Marie Ralph
a/k/a Donna M. Ralph, husband
and wife.
DBV 105, Page 257.
Tax Parcel Number 09-16-1050-
285.
U
Zt
(`i i ?1
v r
-n IT7
;
"? r.r7 ,