UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

COMMUNITY FEDERAL SAVINGS :

BANK, : CIVIL ACTION
:
Plaintiff, : NO. _________
:
v. :
:
C&C ENTITY, L.P., CARDILE :
MUSHROOMS C&M, LCC, :
CARDILE MUSHROOMS, INC., :
D AND C ENTITY, LP, CHARLES :
CARDILE AND DIANE CARDILE, :
:
Defendants. :

PLAINTIFF’S MOTION TO APPOINT A RECEIVER

Plaintiff, Community Federal Savings Bank ("Lender"), acting by and

through undersigned counsel, respectfully moves the court for the appointment of a

receiver in this commercial mortgage foreclosure action ”Motion”), pursuant to Rule

66 of the Federal Rules of Civil Procedure. In support of its motion, Lender submits

its reasons in the accompanying Memorandum in Support of its Motion, proposed

Order and Affidavit.

Dated: September , 2020

__________________________________
Gary F. Seitz, (PA ID No. 52865)
GELLERT SCALI BUSENKELL & BROWN
LLC
1628 JFK Blvd, Ste 1901
Philadelphia, PA 19103
(215) 238-0010
gseitz@gsbblaw.com
Counsel for Plaintiff
Community Federal Savings
Bank